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

Therefore, the Project would not conflict with relevant policies in the City’s Mobility Element.

A Transportation Impact Study (TIS) was prepared to evaluate the Project’s effects on the LOS on transportation facilities in the Project area, including seven intersections and four roadway segments. LOS has been addressed herein for informational purposes only and can no longer be used to determine significant transportation impacts under CEQA as directed by SB 743. The detailed results of the LOS Analysis are provided in Appendix L of this EIR.

Additionally, the applicant has prepared a detailed memorandum (Appendix L of the TIS 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

4.12 – TRANSPORTATION
15138

4.12-16

INTETNIONALLY LEFT BLANK

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025
1 2 3 4 5 6 7 Sep 18, 2023 - 1:20pm mpopovic P:\300.Environmental\15138_Santee Warehouse Project\02 Dudek Work Products\01 Documents\03 Technical Reports\Transportation\Graphics\AutoCAD Files\SanteeWarehouse.dwg Layout: Fig4-ProjAsgnCrs Palisade Santee Commerce Center Project
Project Trip Assignment (Cars) n NOT TO SCALE
SOURCE: SanGIS, Open Street Maps
Legend
Project X Study Intersection
(X) X
Weekday AM Peak Hour Traffic Volumes
Weekday PM Peak Hour Traffic Volumes
Magnolia Avenue 1 SR-52 EB Ramps
(15) 4 1
(3)
(1) 3
Magnolia Avenue 2 SR-52 WB Ramps - SR-67 SB Ramps 5
(18)
(1) 3
(4) 14
Magnolia Avenue - Mission Gorge Road 3 Woodside Avenue
(15) 4
(18) 5
(4) 17
(4) 14
(4) 14
(15) 4
N. Woodside Avenue 4 S. Woodside Avenue - SR-67 SB Ramps (48) 13
(11) 46
Hartley Road 5 Woodside Avenue
(48) 13 (11) 46
Wheatlands Avenue 6 Woodside Avenue
(48) 13 (11) 46
Project Access Roadway 7 Woodside Avenue
(48) 13 (12) 3
(11) 46 (3) 12
FIGURE 4.12-4

4.12 – TRANSPORTATION
15138

4.12-18

INTENTIONALLY LEFT BLANK

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025
1 2 3 4 5 6 7 Oct 08, 2024 - 8:28am ameroux P:\300.Environmental\15138_Santee Warehouse Project\02 Dudek Work Products\01 Documents\03 Technical Reports\Transportation\Graphics\AutoCAD Files\SanteeWarehouse_v2.dwg Layout: Fig5-ProjAsgnTks Palisade Santee Commerce Center Project
Project Trip Assignment (Trucks – PCE) n NOT TO SCALE
SOURCE: SanGIS, Open Street Maps
Legend
Project X Study Intersection
(X) X
Weekday AM Peak Hour Traffic Volumes
Weekday PM Peak Hour Traffic Volumes
Magnolia Avenue 1 SR-52 EB Ramps
(55) 13
Magnolia Avenue 2 SR-52 WB Ramps - SR-67 SB Ramps
13 (55)
(11) 52
Magnolia Avenue - Mission Gorge Road 3 Woodside Avenue
(55) 13
(11) 52
N. Woodside Avenue 4 S. Woodside Avenue - SR-67 SB Ramps (55) 13
(11) 52
Hartley Road 5 Woodside Avenue
(55) 13 (11) 52
Wheatlands Avenue 6 Woodside Avenue
(55) 13 (11) 52
Project Access Roadway 7 Woodside Avenue
(55) 13 (6) 1
(11) 52 (1) 6
FIGURE 4.12-5

4.12 – TRANSPORTATION
15138

4.12-20

INTENTIONALLY LEFT BLANK

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025
1 2 3 4 5 6 7 Oct 08, 2024 - 8:28am ameroux P:\300.Environmental\15138_Santee Warehouse Project\02 Dudek Work Products\01 Documents\03 Technical Reports\Transportation\Graphics\AutoCAD Files\SanteeWarehouse_v2.dwg Layout: Fig6-ProjAsgnTot Palisade Santee Commerce Center Project
Total Project Trip Assignment (Cars and Trucks – PCE) n NOT TO SCALE SOURCE: SanGIS, Open Street Maps
Legend
Project X Study Intersection
(X) X
Weekday AM Peak Hour Traffic Volumes
Weekday PM Peak Hour Traffic Volumes
Magnolia Avenue 1 SR-52 EB Ramps
(70) 17 1
(3)
(1) 3
Magnolia Avenue 2 SR-52 WB Ramps - SR-67 SB Ramps
18 (73)
(1) 3
(15) 66
Magnolia Avenue - Mission Gorge Road 3 Woodside Avenue
(15) 4
(73) 18
(15) 69
(4) 14
(4) 14
(15) 4
N. Woodside Avenue 4 S. Woodside Avenue - SR-67 SB Ramps (103) 26
(22) 98
Hartley Road 5 Woodside Avenue
(103) 26 (22) 98
Wheatlands Avenue 6 Woodside Avenue
(103) 26 (22) 98
Project Access Roadway 7 Woodside Avenue
(103) 26 (18) 4
(22) 98 (4) 18
FIGURE 4.12-6

4.12 – TRANSPORTATION
15138

4.12-22

INTENTIONALLY LEFT BLANK

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-23
Transit, Bicycle, and Pedestrian Facilities
The Project site is served by passenger rail and bus services, as shown in Figure 4.12-1. The San Diego Metropolitan Transit System (MTS) provides public transportation to the Project area. 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. Routes 832 and 833 serve this bus stop. The City of Santee is served by the Green Line Trolley (Route 530), with the sole station 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 Santee Transit Center is located approximately

1.4 miles northeast of the Project site. The Project would not relocate any existing bus stops and would not require any changes to existing or future routes. The Project would not require an increase in service frequency or additional routes to serve the Project area. Therefore, development of the Project would not conflict with the existing bus routes or bus stops. Impacts to transit would be less-than-significant.

As discussed in Section 4.12.1 and shown in Figure 4.12-2, 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 City’s General Plan Mobility Element 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. While the Project does not involve any plans to construct these planned and contemplated facilities, the Project’s design would ensure that these facilities can be readily developed when the City commences implementation of those projects. Moreover, the Project would provide street and frontage improvements and access to the site would be facilitated for both pedestrian and bicycle users in the overall area. The frontage improvements associated with Project development would not conflict with any existing or planned facilities.

The Project would be responsible for constructing frontage improvements including sidewalks along the northern side of N. Woodside Avenue and connect to the existing sidewalk along N. Woodside Avenue that lies to the west of the Project’s driveway. Due to these improvements, the Project would not conflict with any existing or planned facilities.

The proposed project would result in a traffic effect at the N. Woodside Avenue/Woodside Avenue - SR-67 SB OffRamp intersection, under Existing plus Project, Near Term plus Project and Horizon Year plus Project conditions.

The Project will pay its traffic impact fees and construct sidewalk along N. Woodside Avenue on the east, through the street’s intersection with the SR-67 southbound off-ramp and then connect to the existing sidewalk on Woodside Avenue on the west and near the Project driveway, for a total of 990 linear feet or approximately 0.2 miles. In addition, the Project applicant will fund its fair share in the amount of $476,000 payable to the City to rehabilitate the pavement of N. Woodside Avenue starting from, on the west, where it meets the Caltrans right-of-way at the intersection of the SR-67 to, on the east, the easternmost edge of the Project driveway’s intersection with N. Woodside Avenue, to the satisfaction of the City Engineer. In addition, the Project applicant will construct a southbound right turn at the N. Woodside Avenue/S. Woodside Avenue - SR-67 SB Off-Ramp intersection subject to approval by the City and Caltrans. Additionally, the Project applicant will construct a pedestrian crosswalk with pedestrian refuge along the west leg of the intersection and reconstruct the paved sidewalk and bike lane along with other improvements, such as reconstructing storm drain outlet and pipe and protecting the existing soundwall. Based on the queuing analysis, it is also recommended that “KEEP CLEAR’” pavement markings be installed west of this intersection to maintain vehicular ingress and egress to/from the Mission Del Magnolia community to eastbound Woodside Avenue. The above-mentioned improvements would be implemented as PDF-TRA-1 Multi-modal Intersection Improvements at N. Woodside Avenue/Woodside Avenue - SR-67 SB Off-Ramp intersection. These

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-24
improvements will also ensure the Project’s consistency with Policy 2.1 and is explained in detail in the TIS (Appendix L of this EIR).

Based on analysis provided above, the Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities, and its impact to transportation plans and programs would be less than significant.

B. Would the Project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)? Significant and Unavoidable Impact. The Project would generate VMT in excess of the significance threshold even with the implementation of mitigation, as discussed below.

VMT Screening
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 described below. A project that meets at least one of the screening criteria per City’s VMT guidelines below would be presumed to have a less than significant VMT impact due to project characteristics and/or location.

Projects Located in a Transit-Accessible Area
Projects located within a half-mile radius of an existing major transit stop or an existing stop along a high-quality transit corridor2 may be presumed to have a less-than-significant impact absent substantial evidence to the contrary. A map of existing major transit stops and existing stops along high-quality transit corridors is provided in Appendix D of the City’s VMT guidelines. The proposed Project is not located within a half-mile radius of an existing transit priority area or an existing stop along a high-quality transit route, therefore it cannot be screened out using this criteria.

Small Projects
Projects generating 500 or fewer net new daily vehicle trips may be presumed to have a less-than significant impact absent substantial evidence to the contrary. Trips are based on the number of vehicle trips calculated using SANDAG’s (Not So) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region (SANDAG 2002) or ITE trip generation rates with any alternative modes/location-based adjustments applied. As shown in Section

4.12.3, the Project would generate 1,440 PCE daily trips, therefore would not be considered a small project and cannot be screened out using this criteria.

Local Serving Retail Projects
Local serving retail generally improves the convenience of shopping close to home and has the effect of reducing vehicle travel. Local serving retail projects less than 50,000 square feet that are expected to draw approximately 75% of customers from the local area (roughly 3-miles) are presumed to have a less than significant impact absent substantial evidence to the contrary. Retail projects that are between 50,000 square feet and 125,000 square feet 2 Major transit stop: a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods. High quality transit corridor: a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute periods.

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-25
with similar customer attraction (approximately 75% from local area) may also be presumed locally serving. The Project does not propose retail uses; therefore, it cannot be screened out using this criteria.

Local Serving Public Facilities
Public facilities that serve the surrounding community or public facilities that are passive use may be presumed to have a less-than-significant impact absent substantial evidence to the contrary. Transit centers, public schools, libraries, post offices, park-and-ride-lots, police and fire facilities, parks and trailheads, government offices, passive public uses and other public uses are considered local serving public facilities. The Project does not propose local serving public facilities; therefore, it cannot be screened out using this criteria.

Redevelopment Projects with Lower Total VMT
A redevelopment project may be presumed to have a less-than-significant impact absent substantial evidence to the contrary if the proposed project’s total project VMT is less than the existing land use’s total VMT and the CEQA action includes closing the existing land use. Although the Project would redevelop an existing site, this criterion was not applied to the Project.

Infill Affordable Housing
City of Santee presumes deed-restricted affordable housing projects that meet the following conditions meet the City’s screening criteria and would not require a VMT analysis. ▪ Is an infill project (note that most of the City of Santee is presumed to be an infill location); ▪ Consists of a minimum of 52% affordable housing;
▪ Is within ½ mile radius of a transit stop or station; and ▪ Project-provided parking does not exceed parking required by the City’s Municipal Code The Project does not propose infill affordable housing; therefore, it cannot be screened out using this criteria.

Projects in a VMT-Efficient Area
A VMT-efficient area is any area within the City with an average VMT/capita or VMT/employee below the thresholds as compared to the baseline City/Regional VMT per capita for the TAZ that the project is located within. VMT efficient areas are accessed through SANDAG’s SB743 VMT maps3.

The Project site is within Census Tract 166.07 under the current SANDAG Travel Demand model. Based on the San Diego Region SB743 VMT Maps and using the City’s criteria for evaluation of Industrial projects, the Project is within a high-VMT generating area for VMT per employee (i.e., greater than or equal to the regional mean). Compared to the regional mean of 18.9 VMT per employee, the VMT per employee of the Project’s census tract is 22.2 VMT.

Therefore, it can be inferred that the proposed Project is not located in a VMT-efficient area and would therefore result in a significant VMT impact.
3 San Diego Region SB 743 VMT Map accessed at San Diego Region SB743 VMT Maps (arcgis.com)

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-26
VMT Threshold of Significance
The significant thresholds and specific VMT metrics used to measure VMT are described by land use type below:

Industrial Employment projects located within a VMT-efficient area may be presumed to have a less than-significant impact absent substantial evidence to the contrary. A VMT-efficient area for industrial employment projects is any area with an average VMT/employee at or below the baseline regional average for the TAZ that the project is located within.

Project VMT Analysis
Since the Project’s daily trip generation estimate would be below 2,400 average daily trips, and the Project’s census tract includes other employee-based uses, a project-specific model run by SANDAG would not be required. The results of the SANDAG SB 743 VMT maps have been used in the Project’s VMT analysis. Compared to the regional mean of 18.9 VMT per employee, the VMT per employee of the Project’s census tract is 22.2 VMT. Because the Project’s VMT is higher than the regional average of the census tract it is located within, the Project would result in a significant VMT impact. Table 4.12-2 provides Project’s VMT summary. Figure 4.12-7 illustrates the SANDAG SB 743 VMT Map for the Project site.

Table 4.12-2. Project VMT Summary
Criteria VMT/per Employee
Baseline Regional VMT/employee 18.9
VMT Threshold (at or below Baseline) 18.9
Project TAZ VMT/Employee 22.2
% Reduction Required 15%
Source: Appendix L of this EIR.

Note: VMT = vehicle miles traveled

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025
Path:Z:\Projects\j1513801\MAPDOC\DOCUMENT\Transportation FIGURE 4.12-7
SANDAG SB 743 Map
Palisade Santee Commerce Center Project

4.12 – TRANSPORTATION
15138

4.12-28

INTENTIONALLY LEFT BLANK

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-29
To mitigate a project’s VMT impacts, the project applicant must reduce VMT, which can be done by either reducing the number of automobile trips generated by the project or by reducing the distance that people drive. The following strategies are available to achieve this:

Modify the project’s built environment characteristics to reduce VMT generated by the project.

Implement TDM measures to reduce VMT generated by the project Strategies that reduce single-occupant automobile trips or reduce travel distances are called Transportation Demand Management (TDM) strategies. The City VMT guidelines recommend using strategies from the California Air Pollution Control Officers Association (CAPCOA) Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (2021) (GHG Reduction Handbook) and the SANDAG Mobility Management Guidebook/VMT Reduction Calculator Tool.

The following table includes TDM strategies from CAPCOA 2021 and their applicability to the Project.

Table 4.12-3. Transportation Demand Management Measures Trip
Reduction
Program Description
Maximum
Reduction
Possible Project Reduction Possible
T-5 Implement Commute Trip Reduction
Program (CTR) (Voluntary): CTR programs
discourage single-occupancy vehicle
trips and encourage alternative modes of
transportation such as carpooling, taking
transit, walking, and biking, thereby
reducing VMT and GHG emissions.
4% Assuming 100% employees are
eligible for program, a 4% reduction
can be achieved.

T-6 Implement Commute Trip Reduction
Program (Mandatory Implementation
and Monitoring) (Must include T-6 - T-10)
26% Selected measures from T-6 to T-10
are included in this measure.

T-7 Implement Commute Trip Reduction
Marketing: This measure will implement
a marketing strategy to promote the
project site employer’s CTR program.

Information sharing and marketing
promote and educate employees about
their travel choices to the employment
location beyond driving such as
carpooling, taking transit, walking, and
biking, thereby reducing VMT and GHG
emissions.
4% Assuming 100% employees are
eligible for program, a 4% reduction
can be achieved by the Project. See
Appendix B of Appendix L to this
Draft EIR for details on Project VMT
reduction.

T-8 Provide Ridesharing Program: This
measure will implement a ridesharing
program and establish a permanent
transportation management association
with funding requirements for employers.

Ridesharing encourages carpooled
vehicle trips in place of single-occupied
vehicle trips, thereby reducing the
number of trips, VMT, and GHG
emissions.
8% Assuming sub-urban location of the
Project, 100% employees are eligible
for program, a 4% reduction can be
achieved by the Project. See
Appendix B of Appendix L to this
Draft EIR for details on Project VMT
reduction.

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-30
Table 4.12-3. Transportation Demand Management Measures Trip
Reduction
Program Description
Maximum
Reduction
Possible Project Reduction Possible
T-9 Implement Subsidized or Discounted
Transit Program: This measure will
provide subsidized or discounted, or free
transit passes for employees and/or
residents. Reducing the out-of-pocket
cost for choosing transit improves the
competitiveness of transit against
driving, increasing the total number of
transit trips and decreasing vehicle trips.

This decrease in vehicle trips results in
reduced VMT and thus a reduction in
GHG emissions.

5.5% Assuming average transit fare of
$2.50 would be subsidized and
100% of the employees would be
eligible to participate in this
program. Because 72.5% of the
Project trips are from employees,
approximately 72.5% of Projectgenerated VMT can be as assumed to be from employees. Based on the
above inputs, a 0.74% VMT
reduction can be achieved by the
Project. See Appendix B of Appendix
L to this Draft EIR for details on
Project VMT reduction.

T-10 Provide End of Trip Bicycle Facilities: This
measure will install and maintain end-oftrip facilities for employee use. End-oftrip facilities include bike parking, bike lockers, showers, and personal lockers.

The provision and maintenance of
secure bike parking and related facilities
encourages commuting by bicycle,
thereby reducing VMT and GHG
emissions.

4.4% For San Diego-Carlsbad area, a

0.57% reduction can be achieved.

See Appendix B of Appendix L to this
Draft EIR for details on Project VMT
reduction.

T-11 Provide Employer-Sponsored Van pool:

This measure will implement an
employer-sponsored vanpool service.

Vanpooling is a flexible form of public
transportation that provides groups of 5
to 15 people with a cost-effective and
convenient rideshare option for
commuting. The mode shift from longdistance, single-occupied vehicles to shared vehicles reduces overall
commute VMT, thereby reducing GHG
emissions.

20.4% It is likely that individual tenants may
have employees that sign up with the
SANDAG Sustainable Transportation
Services program, formerly known as
iCommute through ride-sharing
program. Therefore, only T-8 has
been included as reduction measure.

T-12 Price Workplace Parking: This measure
will price on-site parking at workplaces.

Because free employee parking is a
common benefit, charging employees to
park on site increases the cost of
choosing to drive to work. This is
expected to reduce single-occupancy
vehicle commute trips, resulting in
decreased VMT, thereby reducing
associated GHG emissions.
20% Not a suitable measure due to suburban project setting that provides few alternate transportation options
for employees.

T-13 Implement Employee Parking Cash-Out:

This measure will require project
12% Not a suitable measure due to suburban project setting that provides

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-31
Table 4.12-3. Transportation Demand Management Measures Trip
Reduction
Program Description
Maximum
Reduction
Possible Project Reduction Possible
employers to offer employee parking
cash-out. Cash-out is when employers
provide employees with a choice of
forgoing their current subsidized/free
parking for a cash payment equivalent to
or greater than the cost of the parking
space. This encourages employees to
use other modes of travel instead of
single occupancy vehicles. This mode
shift results in people driving less and
thereby reduces VMT and GHG
emissions.
few alternate transportation options
for employees.

T-18 Provide Pedestrian Network
Improvement:

6.4% The Project would add 0.2-mile of
sidewalk along its access road from
Woodside Avenue and at the
Woodside Avenue/S. Woodside
Avenue - SR-67 SB Off-Ramp
intersection. This would result in
approximately 0.6 mile of sidewalk
from existing 0.4 mile of sidewalk
between Project driveway and the
Woodside Avenue/S. Woodside
Avenue - SR-67 SB Off-Ramp
intersection. Based on the above
inputs, a 2.51% VMT reduction can
be achieved by the Project.

Source: CAPCOA 2021 and Appendix L of this Draft EIR
Note: VMT = vehicle miles traveled
Based on the review of applicable trip reduction measures to the Project, following measures as part of T-5 Commute Trip Reduction Program have been selected to calculate possible reduction:

T-5 Implement Commute Trip Reduction (CTR) Program to include the following measure and estimated Project VMT reduction (in %):

T-7 Implement Commute Trip Reduction Marketing (4%)
T-8 Provide Ridesharing Program (4%)
T-9 Implement Subsidized or Discounted Transit Program (0.74%) T-10 Provide End of Trip Bicycle Facilities (0.57%)
T-18 Provide Pedestrian Network Improvements (2.51%)
See Appendix B of Appendix L of this EIR for calculation of project VMT reduction % corresponding to measures T7, T-8, T-9, T-10, and T-18.

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-32
To calculate VMT reduction under each component, the following formula is used:

VMT Reduction% = 1 – [(1 – 4%) ∗ (1 – 4%) ∗ (1 – 0.74%) * (1 – 0.57%)*(1 – 2.51%)] = 11.3% A VMT reduction of 11.3% would be achieved through the implementation of CTR measures. A reduction of 15% is required to reduce the VMT per employee to at or below regional level. As shown in Section 4.12.5, MM-TRA-1 Trip Reduction Program would be implemented by the Project’s tenants to reduce the Project’s VMT and MM-TRA-2 Construction of Sidewalk would improve pedestrian network connectivity in the area. Because the Project’s VMT would not be reduced to below significance threshold even with the implementation of MM-TRA-1 and MM-TRA-2, the Project’s VMT impact would remain significant and unavoidable.

C. Would the Project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? Less than Significant. The following discussion describes the potential for increased hazards as a result of geometric design features of the Project, and/or as a result of the addition of Project traffic to adjacent roadways and intersections.

The access to the proposed Project would be from N. Woodside Avenue via an unsignalized intersection with the Project access driveway. Per City’s request, an evaluation for eastbound left turn lane at this access driveway was conducted. The left-turn lane evaluation was conducted using the methodology from the American Association of State Highway Transportation Officials’ (AASHTO 2018) – Geometric Design of Highways and Streets (“Green Book”). As shown in the evaluation provided in Appendix L of this EIR, because the left-turning volumes at the intersection exceed the AASHTO suggested left-tun lane guidance of 50 or more vehicle/hour and due to high truck volume, a dedicated eastbound left turn lane shall be constructed at the Project access driveway/N.

Woodside Avenue intersection. The Project would be responsible for constructing frontage improvements including sidewalks along the northern side of N. Woodside Avenue and connect to the existing sidewalk along N. Woodside Avenue that lies to the west of the Project’s driveway. The Project would also install a crosswalk to improve pedestrian circulation at the Project access driveway/N. Woodside Avenue.

On-site circulation and access to the Project will be provided by a circuitous roadway (see Figure 3-7, Project Description) that would also serve as fire lane. The width of the internal roadway will be between 30 feet to 40 feet.

The on-site circulation will be designed per City’s Standard Drawings and requirements of the Fire Code to provide turn radii for fire truck and apparatus to access all parts of the site. A truck turn analysis showing the availability of appropriate turn radii on the Project site and access driveway from N. Woodside Avenue for a semitrailer, trash truck and fire engine have been provided to the City as part of the Project’s design review submittal.

The proposed Project would result in a traffic effect at the N. Woodside Avenue/ Woodside Avenue - SR-67 SB OffRamp intersection, under Existing plus Project, Near Term plus Project and Buildout plus Project conditions. An intersection lane queuing analysis, using SimTraffic 11 software, was conducted to determine the 95th percentile (design) queue of the existing storage lanes at the N. Woodside Avenue/ Woodside Avenue – SR-67 SB Off-Ramp intersection for informational purposes. The intersection’s queues were calculated for the Existing and Existing plus Project conditions. Under Existing conditions, there are no movements where the 95th percentile queues would exceed their storage lengths during the weekday AM or weekday PM peak hours. Under Existing plus Project conditions, all movements would experience an increase in vehicular queues however, most queues would be accommodated in the storage length available, except for the eastbound left turn lane (during AM peak hour). It should be noted that there is no specific criteria for assessing queuing impacts, however, it is recommended that

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-33
“KEEP CLEAR’” pavement markings be installed west of this intersection to maintain vehicular ingress and egress to/from the Mission Del Magnolia community to eastbound Woodside Avenue.

Additionally, it should be noted that under Existing and Existing plus Project conditions analyzed, the westbound turn movements at the SR-67 off-ramp do not exceed the storage length available. The analysis indicates there are currently no queuing issues that may potentially spill back onto the SR-67 mainline. See Appendix L for details on queuing analysis at the N. Woodside Avenue/ Woodside Avenue - SR-67 SB Off-Ramp intersection.

The Project will pay its traffic impact fees and construct a missing segment of sidewalk along N. Woodside Avenue near the N. Woodside Avenue/Woodside Avenue - SR-67 SB Off-Ramp intersection and near the Project driveway, for a total of 990 linear feet or approximately 0.2 miles. The Project would also be responsible for pavement rehabilitation and restriping of N. Woodside Avenue to the satisfaction of the City Engineer from Caltrans right-ofway at the intersection of the SR-67 to the easternmost edge of the Project driveway’s intersection with N. Woodside Avenue. In addition, the Project would install approximately 1,240 SF of new roadway to fill in an unpaved area between the edge of the existing roadway and the new proposed sidewalk.

Therefore, with proposed improvements at the Project access and implementation of PDF-TRA-1 Multi-modal Intersection Improvements at and west of the N. Woodside Avenue/ Woodside Avenue - SR-67 SB Off-Ramp intersection, the Project would not increase hazards because of a roadway design feature or incompatible uses and impact would be less than significant.

D. Would the Project result in inadequate emergency access? Less-than-Significant Impact. As mentioned above, on-site circulation and access to the Project will be provided by a circuitous roadway that would also serve as fire lane. All street improvements will be designed with adequate width, turning radius, and grade to facilitate access by City’s firefighting apparatus, and to provide alternative emergency ingress and egress. The site plan would be subject to plan review by the City’s Fire Department to ensure proper access for fire and emergency response is provided and required fire suppression features are included. Therefore, the Project’s impact due to inadequate emergency access would be less than significant.

4.12.5 Project Design Features, Mitigation Measures, and Level of Significance After Mitigation
The proposed Project would result in a traffic effect at the N. Woodside Avenue/S. Woodside Avenue - SR-67 SB offRamp intersection, under Existing plus Project, Near Term plus Project and buildout plus Project conditions, .PDFTRA-1 Multi-modal Intersection Improvements will be implemented consistent with the City’s Mobility Element goals and policies in lieu of improving delay at the intersection.:

PDF-TRA-1 Multi-modal Intersection Improvements: Prior to the issuance of a building permit, the Project applicant will pay its traffic impact fees to the satisfaction of the City Engineer. Prior to obtaining the Certificate of Occupancy, the Project will construct a new on-site sidewalk to connect the main entrance of the building with the existing sidewalk on N. Woodside Avenue. Prior to the issuance of a building permit, Tthe Project applicant will also fund its fair share in the amount of $476,000 payable to the City to rehabilitate the pavement with a full width and adequate structural section of N.

Woodside Avenue starting from, on the west, where it meets the Caltrans right-of-way at the intersection of the SR-67 to the eastern most edge of the Project driveway’s intersection with N.

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-34
Woodside Avenue, to the satisfaction of the City Engineer. The Project applicant will install also approximately 1,240 SF of new roadway to fill in an unpaved area between the edge of the existing roadway and the new proposed sidewalk near N. Woodside Avenue’s intersection with the SR-67. The Project will install “KEEP CLEAR’” pavement markings west of this intersection to maintain vehicular ingress and egress to/from the Mission Del Magnolia community to eastbound Woodside Avenue.

A. Would the Project conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?
Impacts would be less than significant. No mitigation is required.

B. Would the Project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)? As described in response to Threshold 4.12b, based on the VMT reduction results, implementation of the TDM Program and sidewalk improvements are anticipated to reduce the VMT per-capita generated per employee by

11.3%. Thus, with implementation of the TDM Program, the Project is anticipated to reduce VMT per employee by

11.3%. Because the mitigation measures would not fully reduce the VMT per employee to less than significant levels (i.e. 15% or more), the impact is only partially mitigated, and the Project is considered to have a significant and partially mitigated impact. Therefore, even with implementation of MM-TRA-1 and MM-TRA-2, impacts related to VMT would be significant and unavoidable.

MM-TRA-1 Trip Reduction Program: Prior to the issuance of first Certificate of Occupancy, the Project tenant will prepare a Trip Reduction program. The program shall include the following components:

Implement Commute Trip Reduction Marketing:
a. Set-up a Transportation Kiosk, either physically on-site or online, with transportation information that employees could access at work or on their smart phones or personal computers. If an online kiosk, information can be available on the company’s website (or intranet, or internal website). The Project developer or property manager will have responsibility for setting up and maintaining the information center. The Transportation Kiosk will have site-specific information about all the measures, services, and facilities discussed in this Program. In addition, the information center will include:
b. A summary of local bus routes and local bicycle facilities to provide further information about their routes and schedules and the incentive programs available to transit users. c. Information about ride matching services (SANDAG - Bike Services) and on-site ride matching) and the incentive programs available to carpools. d. Information about services such as Uber, Lyft, and other on-demand transportation services.
e. A local bikeways map and bicycling resources
f. Availability of bicycle parking such as lockers and amenities including bike pumps, repair stations, full coverage lighting and security cameras.
g. Information about bicycle education classes taught by certified league instructors from the San Diego County Bicycle Coalition.

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-35
Provide Ridesharing Program: The Project tenant will promote ride-sharing programs through a multi-faceted approach, such as designating a certain percentage of parking spaces for ridesharing vehicles, designating adequate passenger loading and unloading and waiting areas for ride-sharing vehicles, and/or providing a website or message board for coordinating rides. A designated employee may partner with SANDAG to use programs such as SANDAG Vanpool, Employer Commuter Program and Guaranteed Ride Home.

Implement Subsidized or Discounted Transit Program: The Project tenant would provide or reimburse the cost of monthly transit passes (such as Pronto card or mobile app) to the employees who use bus or rail transit to work to create incentive programs that reward employees for utilizing non-single occupancy vehicles to commute.

Provide End of Trip Bicycle Facilities: The Project will provide at least 15 bicycle parking spaces per City’s parking code requirement4. Where possible, appropriate designed electrical outlets will be included near the bicycle racks for charging electric bicycles (E-bikes).

MM-TRA 2 Construction of Sidewalk: The Project will construct a new sidewalk along a portion of N. Woodside Avenue to create a continuous sidewalk along N. Woodside Avenue where it intersects the SR-67.

Together, with the sidewalk constructed per PDF-TRA-1, this will be a total of 990 linear feet of new sidewalk. If the applicant, despite commercially reasonable efforts, is unable to obtain the necessary permits to construct the portion of sidewalk located outside of the City of Santee’s right-of-way, the applicant will have an additional six months following the issuance of the Certificate of Occupancy to complete that portion. If, at the end of that six-month period, the applicant is still unable to construct the sidewalk due to the continued inability to obtain the required permits, the project will pay an in-lieu fee in the amount of $50,000 to the City to complete this work.

C. Would the Project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? Impacts would be less than significant. No mitigation is required. Improvements to facilitate Project access along N. Woodside Avenue and sidewalk and pavement rehabilitation at the N. Woodside Avenue/Woodside Avenue – SR-67 southbound off-ramp intersection and along N. Woodside Avenue will be constructed by the applicant as PDF-TRA-1 Multi-modal Intersection Improvements.

D. Would the Project result in inadequate emergency access? Impacts would be less than significant. No mitigation is required. 4 Per City’s code 5% of motorized parking should be bicycle parking, therefore 5% of 301 car parking spaces = 15 bicycle parking spaces.

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.12 – TRANSPORTATION
15138

4.12-36

INTENTIONALLY LEFT BLANK

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025

4.13 – UTILITIES AND SERVICE SYSTEMS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.13-1

4.13 Utilities and Service Systems
This section describes the existing utility conditions of the Palisade Santee Commerce Center 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 Environmental Impact Report [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)
▪ Water Study for Development at 10990 North Woodside Drive, prepared by HDR in April 2023 (Appendix M)

4.13.1 Existing Conditions
Water
Water Supply
Domestic water service is provided to the Project area by the Padre Dam Municipal Water District (PDMWD). PDMWD’s service area is approximately 72 square miles and is divided into two major geographic service areas – the Western Service Area and the Eastern Service Area. The Western Service Area encompasses the City of Santee (City), a small portion of El Cajon, and a small portion of the unincorporated County community of Lakeside (PDMWD 2021).

The primary potable water supply source within the PDMWD’s service area is imported water from the San Diego County Water Authority (SDCWA) through three connections. The potable water supply is imported from the California State Water Project (bSWP) and the Colorado River by Metropolitan Water District of Southern California (Metropolitan). In addition, SDCWA purchases up to 50,000 acre-feet per year (AFY) from the Carlsbad Desalination Plant. The PDMWD’s water supplies also include recycled water and a very small amount of groundwater used to supplement the recycled system (PDMWD 2021).

Pursuant to the Urban Water Management Planning Act, PDMWD prepares an Urban Water Management Plan (UWMP) on a five-year basis to evaluate current and projected water supplies and demands amongst other water planning issues. PDMWD’s UWMP includes plans for the provision of water (including drought scenarios) for its service area. The plan uses regional population, land use plans, and projections of future growth as the basis of planning for future water supply and demonstrating compliance with state water conservation goals and policies.

PDMWD comprehensively updates its UWMP on a 5-year basis to refine population projections and include all new land use patterns and development. In June 2021, PDMWD certified its 2020 UWMP which covers the 2020-2045 planning period, which was used in the analysis below.

The 2020 UWMP determined that PDMWD has sufficient water supply to meet current and projected water demands through the applicable planning horizon (i.e., through 2040 according to the 2015 UWMP and through 2045 according to the 2020 UWMP) during normal-, historic single-dry-, and historic multiple-dry-year periods, as shown in Table 4.13-1. This tables presents the supplies and demands for the various “drought scenarios for the projected planning periods in five‐year increments. Demands for dry years are shown with the effects of assumed urban demand reduction (conservation) measures that would be implemented during drought conditions.

4.13 – UTILITIES AND SERVICE SYSTEMS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.13-2
Table 4.13-1. Supply and Demand Comparison (Acre-Feet per Year) Supply and Demand 2025 2030 2035 2040 2045
Normal Year
Supply totals 13,674 14,818 15,855 16,705 17,176
Demand totals 13,674 14,818 15,855 16,705 17,176
Difference 0 0 0 0 0
Single-Dry Year
Supply totals 14,586 15,751 16,819 17,685 18,148
Demand totals 14,586 15,751 16,819 17,685 18,148
Difference 0 0 0 0 0
Multiple Dry Years Supply and Demand Comparison
First Year Supply totals 14,586 15,751 16,819 17,685 18,148 Demand totals 14,586 15,751 16,819 17,685 18,148
Difference 0 0 0 0 0
Second
Year
Supply totals 14,732 15,909 16,987 17,862 18,329
Demand totals 14,732 15,909 16,987 17,862 18,329
Difference 0 0 0 0 0
Third Year Supply totals 14,879 16,068 17,157 18,040 18,513 Demand totals 14,879 16,068 17,157 18,040 18,513
Difference 0 0 0 0 0
Fourth
Year
Supply totals 15,028 16,228 17,329 18,221 18,698
Demand totals 15,028 16,228 17,329 18,221 18,698
Difference 0 0 0 0 0
Fifth Year Supply totals 15,178 16,391 17,502 18,403 18,885 Demand totals 15,178 16,391 17,502 18,403 18,885
Difference 0 0 0 0 0
Source: PDMWD 2021.

Water Infrastructure
PDMWD’s existing water distribution system includes approximately 300 miles of underground water mains. The distribution system includes groundwater wells, reservoirs, transmission and distribution pipelines, pump stations, pressure reducing stations, and a hydrogenation station (PDMWD 2022).

PDMWD monitors the conditions of its water infrastructure and plans for replacements, upgrades and new infrastructure in its Master Plan. PDMWD’s most recent master plan was prepared in 2022 and contains plans for a 25-year planning horizon. The Master Plan update includes both the district’s 2015 Comprehensive Facilities Master Plan and the 2020 Urban Water Management Plan (PDMWD 2022). The 2022 Master Plan includes plans for a Capital Improvement Plan for water, wastewater, and recycled water projects for the next 20 years, as a large portion of the Plan is to revise demand and flow forecast projections, as well as to identify system deficiencies and improvements in the water, wastewater, and recycled water systems.

4.13 – UTILITIES AND SERVICE SYSTEMS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.13-3
Wastewater
The PDMWD collects the wastewater for the City, where the water is transported to the City’s Water Recycling Facility or to the Point Loma facility which is managed by the City of San Diego Metropolitan Wastewater System (PDMWD 2023). The PDMWD manages the wastewater collection system within its 164-mile service area to collect, treat, and dispose of wastewater delivered by the City. PDMWD facilities serve the City, the City of El Cajon, the City of San Diego and the County of San Diego (County). A wastewater collection system and interceptor sewers convey sewage to regional wastewater treatment plants, which are operated by the PDMWD and the County’s Lakeside Interceptor (PDMWD 2019).

According to the Operation and Maintenance Program, the wastewater collection systems drain from the east to the west (PDMWD 2019). There are four diversion structures between the PDMWD wastewater collection system and the County’s Lakeside Interceptor. Sewage from the City is treated at two locations— the City’s Ray Stoyer Water Recycling Facility (WRF) and the Point Loma Facility (PLF). The PLF has a design flow capacity of 240 million gallons per day (mgd) and treats approximately 175 mgd, and the WRF has a design flow capacity of 2 mgd and treats on average 2 mgd (City of San Diego 2023; PDMWD 2023).

Sewer Infrastructure
Sanitary sewer service would be provided by the PDMWD. The Project would connect to the existing sanitary sewer line within the Project Driveway.

Existing Stormwater 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 over natural terrain, with no on-site storm drains. 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).

Solid Waste
Solid waste from the Project site is expected to be disposed at the Sycamore Landfill (City of Santee 2003). The Sycamore Landfill, located in Santee (at 8514 Mast Blvd), is permitted to receive 5,000 tons of solid waste per day, has a remaining disposal capacity of 113,972,637 cubic yards, and has an approximate cease operation date of December 2042 (CalRecycle 2019).

Construction waste is typically disposed of at inert landfills, which are facilities that accept materials such as soil, concrete, asphalt, and other construction and demolition debris. The Sycamore Landfill is the only landfill in the City that accepts inert waste. Commercial and residential trash hauling, as well as industrial solid waste and recycling collection and disposal services are provided by Waste Management Inc. under an exclusive franchise agreement with the City (City of Santee 2024).

4.13 – UTILITIES AND SERVICE SYSTEMS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.13-4
Electricity
Electrical power for the City is provided by San Diego Gas & Electric (SDG&E). The territory serviced by SDG&E encompasses approximately 4,100 square miles and 25 communities (SDG&E 2022). Electric service is currently provided by San Diego Gas & Electric and several above-ground and underground electrical lines are located adjacent to the Project site and adjacent streets.

Natural Gas
Natural gas service for the City is provided by SDG&E. There is currently no gas service to the Project site. The nearest SDG&E gas distribution pipeline is a high-pressure gas distribution main located approximately 230 feet southeast of the project site, within Woodside Avenue (SDG&E 2024).

Telecommunications Facilities
The existing telecommunication services in the vicinity of the Project site are supplied by various utility providers such as T-Mobile, Cox, and Verizon.

4.13.2 Relevant Plans, Policies, and Ordinances
Federal
Clean Water Act
The federal Clean Water Act (CWA) establishes the basic structure for regulating discharges of pollutants into the waters of the U.S. The CWA made it unlawful for any person to discharge any pollutant from a point source into navigable waters unless a permit was obtained under its provisions. The CWA assists in the development and implementation of waste treatment management plans and practices by requiring provisions for treatment of waste using best management practices (BMP) technology before there is any discharge of pollutants into receiving waters, as well as the confined disposal of pollution, so that it will not migrate to cause water or other environmental pollution.

Additionally, CWA funds the construction of sewage treatment plants under the construction grants program.

Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act (Code of Federal Regulations, Title 40, Section 268, Subpart D), contains regulations for municipal solid waste landfills and requires states to implement their own permitting programs that include federal landfill criteria. The federal regulations address the location, operation, design, and closure of landfills, as well as groundwater monitoring requirements.

National Pollutant Discharge Elimination System Permit Program The National Pollutant Discharge Elimination System (NPDES) permit program was established in the CWA to regulate municipal and industrial discharges to surface waters of the United States. Discharge from any point source is unlawful unless the discharge is in compliance with an NPDES permit. The federal NPDES permit regulations have been established for broad categories of discharges, including point-source municipal waste discharges and nonpoint-source stormwater runoff. NPDES permits generally identify effluent and receiving water limits on allowable concentrations and/or mass emissions of pollutants contained in the discharge; prohibitions on

4.13 – UTILITIES AND SERVICE SYSTEMS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.13-5
discharges not specifically allowed under the permit; and provisions that describe required actions by the discharger, including industrial pretreatment, pollution prevention, self-monitoring, and other activities.

State
California Code of Regulations, Titles 14 and 27
Title 14 (Natural Resources, Division 7) and Title 27 (Environmental Protection, Division 2 [Solid Waste]) of the California Code of Regulations govern the handling and disposal of solid waste and operation of landfills, transfer stations, and recycling facilities.

Assembly Bills 939 and 341: Solid Waste Reduction
The California Integrated Waste Management (CIWM) Act of 1989 (AB 939) (Public Resources Code Sections 41000-41460) was enacted as a result of a national crisis in landfill capacity, as well as a broad acceptance of a desired approach to solid waste management of reducing, reusing, and recycling. AB 939 mandated local jurisdictions to meet waste diversion goals of 25% by 1995 and 50% by 2020 and established an integrated framework for program implementation, solid waste planning, and solid waste facility and landfill compliance. AB 939 requires cities and counties to prepare, adopt, and submit to the California Department of Resources Recycling and Recovery (CalRecycle) a source reduction and recycling element to demonstrate how the jurisdiction will meet the diversion goals. Other elements included encouraging resource conservation and considering the effects of waste management operations. The diversion goals and program requirements are implemented through a disposal-based reporting system by local jurisdictions under CIWM board (CIWMB) regulatory oversight. Since the adoption of AB 939, landfill capacity is no longer considered a statewide crisis. AB 939 has achieved substantial progress in waste diversion, program implementation, solid waste planning, and protection of public health, safety, and the environment from landfills operations and solid waste facilities.

In 2011, AB 341 was passed, making a legislative declaration 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 the year 2020. AB 341 requires that local agencies adopt strategies that will enable 75% diversion of all solid waste by 2020. This bill requires all commercial businesses and public entities that generate 4 cubic yards or more of waste per week to have a recycling program in place.

Senate Bill 1374: Construction and Demolition Waste Reduction Senate Bill (SB) 1374 requires that annual reports submitted by local jurisdictions to CIWMB include a summary of the progress made in the diversion of construction and demolition waste materials. In addition, SB 1374 requires the CIWMB to adopt a model ordinance suitable for adoption by any local agency that required 50% to 75% diversion of construction and demolition waste materials from landfills. Local jurisdictions are not required to adopt their own construction and demolition ordinances, nor are they required to adopt CIWMB’s model by default. The City does not have a construction and demolition waste reduction ordinance; however, per mandatory CALGREEN standards (see below), projects are required to divert 65% of their construction and demolition waste from landfills.

Assembly Bill 1826: Mandatory Commercial Organics Recycling In October 2014, Governor Brown signed AB 1826 Chesbro (Chapter 727, Statutes of 2014) requiring businesses to recycle their organic waste on and after April 1, 2016, depending on the amount of waste generated per week.

4.13 – UTILITIES AND SERVICE SYSTEMS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.13-6
(Organic waste is defined as food waste, green waste, landscape, and pruning waste, nonhazardous wood waste, and food-soiled paper waste that is mixed in with food waste.) This law also requires local jurisdictions across the state to implement an organic waste recycling program to divert organic waste generated by businesses, including multifamily residential dwellings that consist of five or more units. This law phases in the mandatory recycling of commercial organics over time. In particular, 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 recycle organic waste.

Urban Water Management Plans (UWMP)
Pursuant to the California Urban Water Management Act (California Water Code Sections 10610-10656), urban water purveyors are required to prepare and update a UWMP every 5 years. UWMPs are prepared by California’s urban water suppliers to support long-term resource planning and ensure adequate water supplies. Every urban water supplier that either delivers more than 3,000 AFY of water annually or serves more than 3,000 connections are required to assess the reliability of its water sources over a 20-year period under normal-year, dry-year, and multiple-dry-year scenarios in a UWMP. UWMPs must be updated and submitted to the California Department of Water Resources every five years for review and approval. The Project site is within the area addressed by the PDMWD UWMP.

Senate Bill 610 and Senate Bill 221: Water Supply Assessments Senate Bills (SB) 610 and 221, amended into state law effective January 1, 2002, require the linkage between certain land use decisions made by cities and counties and water supply availability. The statutes require detailed information regarding water availability and reliability with respect to certain developments to be included in the administrative record to serve as an evidentiary basis for an approval action by the city or county on such projects.

Under SB 610, a water supply assessment must be furnished to the local government for inclusion in any environmental documentation for certain types of projects, as defined in Water Code Section 10912 [a] and as subject to the California Environmental Quality Act (CEQA). A fundamental source document for compliance with SB 610 is the UWMP. The UWMP can be used by the water supplier to meet the standard for SB 610. SB 221 applies to the Subdivision Map Act, requiring applicants, per a tentative map, to verify that the public water supplier has sufficient water available to serve the proposed development. Because the Project would be less than 650,000 square feet, a water supply assessment was not required.

Sanitary Sewer General Waste Discharge Requirements
On May 2, 2006, the State Water Resources Control Board (SWRCB) adopted a General Waste Discharge Requirement (Order No. 2006-0003) for all publicly owned sanitary sewer collection systems in California with more than 1.0 mile of sewer pipe. The order provides a consistent statewide approach to reducing sanitary sewer overflows by requiring public sewer system operators to take all feasible steps to control the volume of waste discharges into the system in order to prevent sanitary sewer waste from entering the storm sewer system, and to develop a Sewer System Management Plan. The General Waste Discharge Requirement also requires that storm sewer overflows be reported to the SWRCB using an online reporting system.

California Green Building Standards
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 of the California Code of Regulations, is commonly referred to as CALGreen and establishes minimum mandatory standards as well as voluntary standards pertaining

4.13 – UTILITIES AND SERVICE SYSTEMS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.13-7
to the planning and design of sustainable site development, energy efficiency, 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 new construction of residential and non-residential buildings. CALGreen standards are updated periodically. The latest version (CALGreen 2022) became effective on January 1, 2023.

Mandatory CALGreen standards pertaining to water, wastewater, and solid waste include the following (24 CCR Part 11):
▪ Mandatory reduction in indoor water use through compliance with specified flow rates for plumbing fixtures and fittings.
▪ Mandatory reduction in outdoor water use through compliance with a local water-efficient landscaping ordinance or the California Department of Water Resources’ Model Water Efficient Landscape Ordinance. ▪ Diversion of 65% of construction and demolition waste from landfills.

Porter-Cologne Water Quality Control Act
In 1969, the California Legislature enacted the Porter-Cologne Water Quality Control Act (“Porter-Cologne Act”) to preserve, enhance and restore the quality of the State's water resources. The Porter-Cologne Act established the SWRCB and the nine individual Regional Water Quality Control Boards (RWQCBs) as the principal state agencies with the responsibility for controlling water quality in California. Under the Porter-Cologne Act, water quality policy is established, water quality standards are enforced for both surface and groundwater, and the discharges of pollutants from point and non-point sources are regulated. The Porter-Cologne Act authorizes the SWRCB to establish water quality principles and guidelines for long-range resource planning, including groundwater and surface water management programs and control and use of recycled water.

California Health and Safety Code Section 115700
Under California Health and Safety Code Section 115700, a well is considered 'abandoned' or permanently inactive if it has not been used for one year, unless the owner demonstrates intention to use the well again. Section 115700 details procedures for the destruction or proper abandonment for permanently inactive wells.

Industrial General Permit
Industrial facilities such as manufacturers, landfills, mining, steam-generating electricity, hazardous waste facilities, transportation with vehicle maintenance, larger sewage and wastewater plants, recycling facilities, and oil and gas facilities are required to obtain coverage under the Statewide General Permit for Storm Water Discharges Associated with Industrial Activities, Order 2014-0057-DWQ (Industrial General Permit), which implements the federally required stormwater regulations in the state for stormwater associated with industrial activities.

Permittees are required to prepare a Stormwater Pollution Prevention Plan for operational activities and implement a long-term water quality sampling and monitoring program unless an exemption is granted.

Local
City of Santee Municipal Code
Chapter 9.06. Stormwater Management and Discharge Control, of the Santee Municipal Code establishes requirements for sanitary sewage facilities in structures, including pipe size. The City of Santee has adopted these to effectively prohibit non-stormwater discharges to the stormwater conveyance system, to eliminate illicit

4.13 – UTILITIES AND SERVICE SYSTEMS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.13-8
discharges and connections to the stormwater conveyance system, to reduce the discharge of pollutants from the stormwater conveyance systems to the maximum extent practicable to achieve applicable water quality objectives for surface waters in San Diego County. Additionally, to achieve compliance with Total Maximum Daily Load regulations. In order to obtain final occupancy approval, a project must be deemed compliant with the Clean Water Act, Porter-Cologne Act, and Regional MS4 Permit, to protect and enhance the water quality of the City’s watercourses, water bodies, and wetlands.

Chapter 11.40. Excavation and Grading, of the Santee Municipal Code, applies to the minimum requirements for grading, excavating, and filling of land and provides water quality protection provisions. Additionally, implements the issuance of permits and the enforcement of the chapter provisions.

Chapter 12.30. Development Impact Fees, of the Santee Municipal Code contains several development impact fees. These fees are intended to offset the impacts that new development has on public facilities. As such, these fees are imposed on new development. The drainage fee provides funds for the installation of needed drainage improvements identified in the City of Santee Citywide Drainage Study. Additionally, the Project applicant would pay any development impact fees that are required for the Project.

San Diego County Integrated Waste Management Plan
Pursuant to the Integrated Waste Management Act, the Countywide Integrated Waste Management Plan for San Diego County describes the goals, policies, and objectives of the county for coordinating efforts to divert, market, and dispose of solid waste during the planning period through the year 2017. Countywide policies for reducing waste and implementing the programs are identified in the individual jurisdiction Source Reduction and Recycling Elements and (Household Hazardous Waste Elements and are intended to reduce costs, streamline administration of programs, and encourage a coordinated and planned approach to integrated waste management.

To avoid duplication of effort, all of the jurisdictions in the county participate in the San Diego County Integrated Waste Management Local Task Force (LTF). The LTF coordinates mandated planning, oversees implementation of new or countywide integrated waste management programs, and carries out an active legislative program.

Regulatory reform, changes to state diversion requirements, and reduction of the costs of compliance are considered by the LTF, as well as other solid waste issues of regional or countywide concerns.

City of Santee General Plan
Objectives and policies related to utilities and service systems in the General Plan are located within the Land Use Element.

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

4.13 – UTILITIES AND SERVICE SYSTEMS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.13-9
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.

Policy 3.2 The City should encourage the development and use of recycled water for appropriate land uses to encourage the conservation of, and reduce demand for, potable water.

Policy 3.3 The City should consider the use of public / private partnerships when appropriate to facilitate introduction of desirable and innovative development within the City.

Policy 3.4 The City shall continue to update and implement a 5-year Capital Improvement Program to improve existing public facilities and develop necessary new public facilities.

Policy 3.3 The City should coordinate the scheduling of planned Capital Improvement Projects with other agencies and utilities to minimize disruptions of City streets and facilities.

Policy 3.5 The City shall require the placement of utility lines underground where feasible.

Policy 3.6 Development projects shall be reviewed to ensure that all necessary utilities are available to serve the project and that any land use incompatibilities or impacts resulting from public utilities shall be mitigated to the maximum extent possible.

Conservation Element
Objective 3.0 Maintain adequate domestic water supplies for all residents and uses within the City.

Policy 3.1 The City should encourage the use of drought-resistant vegetation and encourage the use of recycled water for irrigation for both private development as well as public projects and facilities.

Policy 3.2 The City shall encourage the development and utilization of innovative water conservation measures in all proposed developments.

Policy 3.3 The City should continue to support the Padre Dam Municipal Water District in expanding the water reclamation facility to its ultimate capacity and support the expansion of recycled water infrastructure.

Policy 3.4 The City should encourage the Padre Dam Municipal Water District to satisfy both existing and planned potable water and recycled water demands within the City and District service area prior to considering out-of-district contracts and agreements.

4.13 – UTILITIES AND SERVICE SYSTEMS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.13-10

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

Require or result in the relocation or construction of new or expanded water, wastewater treatment, or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects.

Have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry, and multiple dry years.

Result in a determination by the wastewater treatment provider, which serves or may serve the Project that it has adequate capacity to serve the Project’s projected demand in addition to the provider’s existing commitments.

Generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.

Comply with federal, state, and local management and reduction statutes and regulations related to solid waste.

4.13.4 Impacts Analysis
A. Would the Project require or result in the relocation or construction of new or expanded water, wastewater treatment, or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? Construction of New Utility Lines
Less-than-Significant Impact. As discussed above in Section 4.13.1, Existing Conditions, existing utility service lines are located within the vicinity of the Project site. As part of the Project, utility service lines, including those for water, wastewater, stormwater drainage, electric power, natural gas, and telecommunications services would be reconfigured from their current locations on and nearby the Project site to the proposed building. The following discussion provides a summary of Project utility work.
▪ Water. As discussed in Section 4.13.1, Existing Conditions, there is an existing water line within N.

Woodside Avenue. The Project would connect to the existing 12-inch diameter watermain within N.

Woodside Avenue by removing and replacing an existing segment of 12-inch diameter water main with new, 16-inch water main. From this 16-inch main, the Project would install laterals that would serve 2” domestic service, 2” landscape service, and a looped 12-inch fire service providing service to the building’s fire sprinkler system and on-site fire hydrants.
▪ Sanitary Sewer. Sanitary sewer service would be provided by the Padre Dam Municipal Water District. The Project would connect to the existing sewer manhole cover within the Project Driveway by installing a 6-inch diameter lateral connection.
▪ Stormwater. As discussed in Section 4.13.1, Existing Conditions, stormwater currently sheet flows over the parking lot to a low spot in the northwest corner of the site and overflows into the San Diego River over natural terrain. The sheet flow includes off-site water from an existing 24-inch culvert that originates from

4.13 – UTILITIES AND SERVICE SYSTEMS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.13-11
under CA-67 to the south of the Project. This culvert outlets at the entrance of the site, near the southern terminus of the driveway at N. Woodside Avenue. The culvert collects water from approximately 2.8 acres of tributary area from the southern side of the CA-67 that then flows through the culvert and across the Project site’s natural topography to the San Diego River. The Project’s storm drain improvements include intercepting the existing 24-inch culvert and installing an extension to the San Diego River to the north of the project site. This extension would bypass the proposed on-site storm drain system serving the Project and would maintain the existing drainage pattern for the 2.8-acre tributary area, consistent with the proposed design plan.
▪ The Project would include development of an on-site storm drain system that would accept flows from drain inlets at low spots throughout the site. This stormwater would be directed to subterranean infiltration and retention chambers located in the northern truck court. In a major storm event, overflow would occur via a pipe outlet into the San Diego River. A rip-rap pad at the outlet would provide energy dissipation and would prevent slope scour and erosion.
▪ Electric Power. As discussed in Section 4.13.1, Existing Conditions, the Project site is currently served by SDG&E and several above-ground and underground electrical lines which are located adjacent to the Project site and adjacent streets. Several SDG&E poles would be removed and replaced as part of the Project. Additionally, all above-ground electrical lines within the Project site would be undergrounded. ▪ Natural Gas. There is currently no gas service to the Project site, and the Project does not include plans to install new gas service.
▪ Telecommunications. Several proprietary telecommunication lines are located adjacent to the Project site. As part of the Project, lateral connections would be made to these existing, electric, and telecommunication lines.

Given that the activity of reconfiguring the existing utility lines would involve ground disturbance and the use of heavy machinery associated with trenching, the installation of these utility service lines could potentially result in environmental effects. For example, construction equipment would emit air quality pollutants and greenhouse gas emissions, trenching and excavation could potentially destroy cultural and tribal cultural resources if located within the subsurface, and the disturbance of soils could potentially result in an increased potential for erosion or for disturbed soils to enter into downstream waters. However, the extension of these utility service lines, including their disturbance footprints and construction techniques, as well as their associated impacts, is part of the Project analyzed herein. As such, any potential environmental impacts related to these components, such as those described above, are already accounted for in this Draft EIR as part of the impact assessment conducted for the entirety of the Project. Additionally, the Project would be required to comply with all regulatory requirements and mitigation measures outlined within this Draft EIR for the purposes of lessening or mitigating impacts associated with trenching activities and the use of heavy machinery. For example, as described in Section 5, Effects Found Not To Be Significant, of this Draft EIR, Project construction would occur in accordance with the requirements of the NPDES General Construction Permit and the Santee Municipal Code, which require the implementation of BMPs and pollutant control measures to minimize pollutants and reduce runoff to levels that comply with applicable water quality standards. The Project would not require the construction, expansion, or relocation of water, wastewater, stormwater drainage facilities, electric power, natural gas, and telecommunications facilities beyond those facilities identified above, as existing facilities are in-place and adequately sized to accommodate the Project. Therefore, no adverse physical effects beyond those already disclosed in this Draft EIR would occur as a result of implementation of the Project’s proposed utility system connections. Impacts would be less than significant.

4.13 – UTILITIES AND SERVICE SYSTEMS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.13-12
Capacity of Water, Wastewater Treatment, Storm Water Drainage, Electric Power, Natural Gas, and Telecommunications Facilities
Less-than-Significant Impact.

Water Conveyance and Treatment Facilities
The water conveyance facilities in the Project area are adequately sized to accommodate the Project. According to Appendix M, upsizing the existing segment of 12-inch diameter water main with new, 16-inch water main would meet fire flow requirements. Additionally, the Project would not require the installation or expansion of off-site facilities beyond those described above. With regard to water treatment facilities, as discussed under Threshold 4.13B, the Project’s water demand would not result in or require new or expanded water supplies beyond those that are anticipated within the PDMWD 2015 and 2020 UWMPs. As such, implementation of the Project would not result in the need to expand water treatment facilities. Therefore, impacts associated with water treatment facilities would be less than significant.

Wastewater Conveyance and Treatment Facilities
The wastewater conveyance facilities in the Project area are adequately sized to accommodate the Project and would not require the installation or expansion of off-site facilities beyond those described above. With regard to wastewater treatment facilities, as discussed in Threshold 4.13C, the Project would generate a nominal amount of wastewater in the context of the available capacity of PDMWD wastewater treatment facilities Based on the remaining treatment capacity, impacts associated with wastewater conveyance and treatment facilities would be less than significant.

Stormwater Drainage Facilities
The Preliminary Hydrology Report calculated peak runoff rates 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 such, the Project’s stormwater system would contribute less stormwater to the San Diego River and the existing culvert when compared to the existing conditions. According to the Preliminary Hydrology Report, all flows will be routed to an underground infiltration chamber in compliance with the County of San Diego Low Impact Development requirements. Therefore, impacts associated with stormwater drainage facilities would be less than significant.

Electric Power
Electric service is currently provided by SDG&E and several above ground and underground electrical lines are located adjacent to the Project site and adjacent streets. Several SDG&E poles would be removed and replaced as part of the Project. Additionally, all above-ground electrical lines within the Project site would be undergrounded.

Impacts would be less than significant.

Telecommunications
The Project would involve lateral connections to the existing telecommunication facilities. These facilities are adequately sized and would not require the installation or expansion of off-site facilities beyond those described above. Impacts would be less than significant.

4.13 – UTILITIES AND SERVICE SYSTEMS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.13-13
B. Would the Project have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry, and multiple dry years? Less-than-Significant Impact. Implementation of the Project would result in the construction of an industrial warehouse with associated office spaces, surface parking, and loading areas.

The 2020 PDMWD UWMP has planned for growth within its service area through their planning horizons (i.e., 20 years). As an urban water supplier, PDMWD is required to assess the reliability of its water supply service under a multiple-dry-year scenario. Based on historical extraction and estimated population growth rates, the projected water supply and demand for the single- and multiple-dry-year scenarios were calculated for the 2015 and 2020 UWMPs. As provided above in Table 4.13-1, PDMWD anticipates that has sufficient water supply to meet current and projected water demands through 2045 during normal-, historic single-dry-, and historic multiple-dry-year periods. These projections are based on a land use-based demand model that accounts for a variety of factors, including the land use plans of jurisdictions within PDMWD’s service area. The Project is consistent with the existing land use designation and zoning of the site.

Given that PDMWD has adequate existing supplies to serve the Project under normal-, historic single-dry-, and historic multiple-dry-year periods, the Project’s impact to water supply would be less than significant.

C. Would the Project result in a determination by the wastewater treatment provider, which serves or may serve the Project that it has adequate capacity to serve the Project’s projected demand in addition to the provider’s existing commitments?
Less-Than-Significant Impact. Wastewater generated by the Project would be treated at either the WRF or the PLF, which collectively have the capacity to treat 242 mgd of wastewater and treats, on average, 177 mgd of wastewater. Project operations are conservatively estimated to generate approximately 97,145 gallons per day, or

0.097 mgd. (The Project’s wastewater demand mirrors the water demand for Project operations and is conservative because Project operations include water use for landscape irrigation, which does not flow into the sewer system or require wastewater treatment). Projected wastewater from the Project would represent approximately 0.15% of the remaining capacity of the WRF and PLF treatment facilities. Given the remaining capacity of the WRF and PLF treatment facilities, the WRF and PLF would be able to accommodate the Project’s contribution of 0.097 mgd of wastewater. Therefore, impacts associated with wastewater treatment capacity would be less than significant.

D. Would the Project generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? Short-Term Construction Impacts
Less-Than-Significant Impact. Based on a review of the current structures located on the site, demolition activities are anticipated to generate approximately 18,381 tons of demolition materials (See Section 4.2, Air Quality). Waste also would be generated by the construction process, primarily consisting of discarded materials and packaging.

Based on a proposed building area of 300,145 square feet and a construction waste generation factor of 4.34 pounds per square foot (EPA 2009), approximately 651.3 tons of waste would be generated over the course of the

4.13 – UTILITIES AND SERVICE SYSTEMS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.13-14
Project’s construction phase ([300,145 sq. ft. × 4.34 pounds/square foot] ÷ 2,000 pounds/ton = 651.3 tons). In total, the Project would generate 19,032 tons of waste during construction (18,381 tons of demolition debris + 651.3 tons of construction waste = 19,032 tons).

As mentioned above, CALGreen requires that a minimum of 65% of all solid waste be diverted from landfills (by recycling, reusing, and other waste reduction strategies) consistent with the State’s solid waste reduction goals; therefore, approximately 12,371 tons of construction waste would be diverted (19,032 tons × 65% = 12,371 tons).

The remaining 6,661 tons of construction and demolition materials (19,032 tons × 35% = 6,661 tons) that is currently not required to be recycled, would either be disposed of or voluntarily recycled at a solid waste facility with available capacity.

Table 4.13-2, Construction Waste Summary, summarizes the amount of waste that would be generated, diverted, and landfilled during Project construction.

Table 4.13-2. Construction Waste Summary

Size
Generation
Rate (Tons/SF)
Waste
Generated
(Tons)
Waste Diverted
(Tons)
Waste
Landfilled
(Tons)
Demolition — — 18,381 11,948 6,433
Construction 300,145 SF 4.34 651.3 423 228
Total 19,032 12,371 6,661
Source: Appendix B and EPA 2009.

Note: SF = Square Feet
The Project’s demolition debris would be hauled from the site over the course of the Project’s demolition phase, which would last approximately one month (25 working days). This would correspond to approximately 257.3 tons of demolition waste per day of construction activity. The Project’s building construction would occur over a period of approximately 10 months (202 working days), which corresponds to approximately 1.13 tons of construction waste being generated per day of construction activity. As previously described, the Sycamore Landfill accepts inert solid waste, has a daily maximum permitted throughput of 5,000 tons/day, has a remaining capacity of 113,972,637 cubic yards, and is expected to remain open for another 18 years (CalRecycle 2019). Therefore, the Project’s daily peak demolition and construction waste delivery of 258.4 tons could be received by the Sycamore Landfill. Therefore, Project demolition and construction would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. Impacts during construction would be less than significant.

Long-Term Operational Impacts
Less-Than-Significant Impact. Once operational, the Project would produce solid waste on a regular basis associated with operation and maintenance activities. Using CalEEMod waste generation factors for the Industrial Park and Warehouse uses, the Project would generate approximately 141 tons of solid waste per year, or 0.4 tons per day (Appendix B). A minimum of 50% of all solid waste would be required to be recycled pursuant to AB 939, consistent with the State’s solid waste reduction goals; therefore, the Project would generate approximately 0.2 tons per day of solid waste requiring disposal at a landfill.

As previously described in Section 4.13.1, Waste Management Inc. provides solid waste collection and disposal within the City. Waste would likely be hauled to the Sycamore Landfill. The Sycamore Landfill has a permitted

4.13 – UTILITIES AND SERVICE SYSTEMS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.13-15
throughput of 5,000 tons/day and is expected to remain open for another 18 years. The increase of waste generated by the Project during operations would represent approximately 0.004% of the total daily capacity of permitted at the landfill.

Once the Sycamore Landfill reaches capacity, additional landfills and strategies would be identified, so that disposal needs continue to be met. Further, there are landfills within the County with up to 35 years of remaining life. For example, the Las Pulgas Landfill is expected to remain open another 35 years (CalRecycle 2023). As such, in the event of the closure of the Sycamore Landfill, other landfills in the region would be able to accommodate solid waste from the Project, and regional planning efforts would ensure continued landfill capacity in the foreseeable future. Therefore, the Project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. Impacts during operation would be less than significant.

E. Would the Project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
Less-Than-Significant Impact. As described above, solid waste from the Project would be transported to the Sycamore Landfill. This facility is regulated under federal, state, and local laws. Additionally, the City of Santee is required to comply with the solid waste reduction and diversion requirements set forth in AB 939, AB 341, AB 1327, and AB 1826. Per AB 341, businesses that generate 4 cubic yards or more of organic waste per week are required to arrange for organic waste recycling services. In addition, as preciously described, waste diversion and reduction during Project construction and operations would be completed in accordance with CALGreen standards and City diversion standards. As a result, the Project would comply with federal, state, and local management and reduction statutes and regulations related to solid waste and impacts would be considered less than significant.

4.13.5 Mitigation Measures and Level of Significance
After Mitigation
All impacts related to utilities and services systems would be less than significant. No mitigation is required.

4.13 – UTILITIES AND SERVICE SYSTEMS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.13-16

INTENTIONALLY LEFT BLANK

4.14 – WILDFIRE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.14-1

4.14 Wildfire
This section describes the existing wildfire 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 proposed Project.

Potential wildfire impacts resulting from construction and operation of the Project were evaluated based on a review of existing resources and applicable laws, regulations, guidelines, and standards. Additionally, this Environmental Impact Report (EIR) discusses the Fire Protection Plan (FPP) prepared for this Project and included as Appendix N.

This section focuses on the effect of the Project on wildfire risk. Impacts to public services are further discussed in Section 4.11, Public Services.

4.14.1 Existing Conditions
Wildfire is a continuous threat in Southern California and is particularly concerning in the wildland-urban interface, the geographic area where urban development either abuts or intermingles with wildland or vegetative fuels. During the summer season, dry vegetation, prolonged periods of drought, and Santa Ana wind conditions can combine to increase the risk of wildfires in the County.

Fire History
The Project area, like all of San Diego County, is subject to seasonal weather conditions that can heighten the likelihood of fire ignition and spread. Fire history is an important component of a wildfire analysis. Wildfire history information can provide an understanding of fire frequency, fire type, most vulnerable project areas, and significant ignition sources, amongst others. The California Department of Forestry and Fire (CAL FIRE) maintains the Fire and Resource Assessment Program database, which was used to evaluate the Project site’s fire history to determine whether large fires have occurred in the project area, and thus the likelihood of future fires. Per the recorded fire history database, which dates back to 1900, the site has not been subject to wildfire (CAL FIRE 2022). Multiple fires have occurred within 5-miles of the Project site, and recorded wildfires within 5 miles of the Project site range from 75 acres (Lakeside fire in 1980) to 270,686 acres (Cedar fire in 2003).

Fire Hazard Mapping
CAL FIRE’s Fire and Resource Assessment Program database also includes map data documenting areas of significant fire hazards in the state. These maps categorize geographic areas of the state into different Fire Hazard Severity Zones (FHSZs), ranging from moderate to very high. CAL FIRE uses FHSZs to classify anticipated fire-related hazards for the entire state, and includes classifications for State Responsibility Areas (SRAs), Local Responsibility Areas (LRAs), and Federal Responsibility Areas (FRAs). Fire hazard severity classifications take into account vegetation, topography, weather, crown fire production, and ember production and movement. As shown in Figure 4.14-1, Fire Hazard Severity Zones, the Project site is not within a Very High Fire Hazard Severity Zone (VHFHSZ), but there is a VHFHSZ within an LRA located directly adjacent to the Project site to the north and east (CAL FIRE 2023).

Vegetation Communities and Land Covers
Variations in vegetative cover type and species composition have a direct effect on fire behavior. Some plant communities and their associated plant species have increased flammability based on plant physiology (resin

4.14 – WILDFIRE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.14-2
content), biological function (flowering, retention of dead plant material), physical structure (leaf size, branching patterns), and overall fuel loading.

A critical factor to consider is the dynamic nature of vegetation communities. Fire presence and absence at varying cycles or regimes affect plant community succession. Succession of plant communities, most notably the gradual conversion of shrublands to grasslands with high frequency fires and grasslands to shrublands with fire exclusion, is highly dependent on the fire regime. Further, biomass and associated fuel loading will increase over time if disturbance or fuel reduction effects are not diligently implemented.

The vegetation types and land covers in the Project area were identified during field assessments conducted for the Project site. As detailed in Section 4.3, Biological Resources, the Project site is characterized by Non-native Grassland, Non-native Woodland, Disturbed Habitat, and Urban/Developed Land. Figure 4.3-1 of this EIR illustrates the distribution of vegetation communities and land covers in the study area.

Topography/Terrain
Topography influences fire risk by affecting fire spread rates. Typically, steep terrain results in faster fire spread upslope and slower spread down-slope. Terrain that forms a funneling effect, such as chimneys, chutes, or saddles on the landscape can result in especially intense fire behavior, including faster spread and higher intensity.

Conversely, flat terrain tends to have little effect on fire spread, resulting in fires that are driven by vegetation and wind. The Project site is relatively flat and primarily consists of previously disturbed land, non-native grassland, and non-native woodland. The San Diego River is located down-slope of the Project site to the north.

Climate, Weather and Wind
In the City of Santee, the summers are short, hot, arid, and mostly clear, and the winters are long, cool, and partly cloudy. During summer months (July through September), the average daily high temperature is above 84°F, and during the cooler, winter months (November through April), the average daily high temperature is below 72°F. The temperature varies throughout the year but is rarely below 34°F or above 97°F. Like much of Southern California, Santee experiences seasonal variation in monthly rainfall throughout the year, with the wetter months lasting from November through April.

The Project site, like much of Southern California, is influenced by prevailing wind patterns. Prevailing winds are winds that blow from a single direction over a specific area of the Earth. The predominant average hourly wind speed and direction in Santee varies throughout the year. The wind is most often from the west for 10 months, and the wind is most often from the east from late November to early February. The windier part of the year lasts for approximately 7 months (November to June), with average wind speeds of more than 7.0 miles per hour (WeatherSpark 2023).

City of El Cajon
City of Santee
City of Santee Mission Gorge Rd Woodside Ave
Orange RR
Ä52
Ä67
F
o
s t e r C r e e k
S a n D i e g o R i v e r
Project Boundary
Fire Hazard Severity Zones (FHSZ)
Local Responsibility Area (LRA)
Very High
State Responsibility Area (SRA)
Moderate
High
Very High
Fire Hazard Severity Zones
SOURCE: SANGIS Imagery 2023, Open Street Maps, CalFIRE FHSZ SRA 2007, LRA 2009 Date: 1/2/2024 - Last saved by: kzecher - Path: Z:\Projects\j1513801\MAPDOC\DOCUMENT\Draft_EIR\Draft_EIR_figures.aprx 0 500 1,000 2,000
Feet
FIGURE 4.14-1
Fire Hazard Severity Zones
Palisade Santee Commerce Center Project

4.14 – WILDFIRE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.14-4

INTENTIONALLY LEFT BLANK

4.14 – WILDFIRE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.14-5
Emergency Response
As referenced in the Project’s Fire Protection Plan (FPP) (see Appendix N of this Draft EIR), the Project site is located within the Santee Fire Department’s (SFD) jurisdictional response area. SFD currently operates two fire stations (Stations 4 and 5) with 53 uniformed personnel. Generally, each agency is responsible for structural fire protection and wildland fire protection within their area of responsibility. However, mutual aid agreements enable non-lead fire agencies to respond to fire emergencies outside their district boundaries. In the Project area, fire agencies cooperate on a statewide master mutual aid agreement for wildland fires and there are mutual aid agreements in place with neighboring fire agencies and typically include interdependencies that exist among the region’s fire protection agencies for structural and medical responses but are primarily associated with the peripheral “edges” of each agency’s boundary.

These agreements are voluntary, as no local governmental agency can exert authority over another.

SFD Fire Station 4, which is located at 8950 Cottonwood Avenue approximately 1.5 miles from the Project site, is the closest SFD station to the Project site and would likely be the first to respond. Station 4 is staffed by nine fulltime fire personnel. SFD Station 5, located at 9130 Carlton Oaks Drive, is the next closest fire station to the Project site, located approximately 4.6 miles from the project site. SFD Station 5 is staffed by eight full-time fire personnel.

Station 5 is equipped with one (1) Type 1 Paramedic Fire Engine and one (1) Rescue Ambulance.

4.14.2 Relevant Plans, Policies, and Ordinances
Federal
National Fire Protection Association Codes, Standards, Practices, and Guides National Fire Protection Association codes, standards, recommended practices, and guides are developed through a consensus standards development process approved by the American National Standards Institute. This process brings together professionals representing varied viewpoints and interests to achieve consensus on fire and other safety issues. National Fire Protection Association standards are recommended guidelines and nationally accepted good practices in fire protection but are not laws or codes unless adopted as such or referenced as such by the California Fire Code (CFC) or the local fire agency.

Federal Wildland Fire Management Policy
The Federal Wildland Fire Management Policy was developed in 1995, updated in 2001, and again in 2009 by the National Wildfire Coordinating Group, a federal multi-agency group that establishes consistent and coordinated fire management policy across multiple federal jurisdictions. An important component of the Federal Wildland Fire Management Policy is the acknowledgment of the essential role of fire in maintaining natural ecosystems. The Federal Wildland Fire Management Policy and its implementation are founded on the following guiding principles, found in the Guidance for Implementation of Federal Wildland Fire Management Policy (National Wildfire Coordinating Group 2009):
▪ Firefighter and public safety is the first priority in every fire management activity. ▪ The role of wildland fire as an essential ecological process and natural change agent will be incorporated into the planning process.
▪ Fire management plans, programs, and activities support land and resource management plans and their implementation.

4.14 – WILDFIRE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.14-6
▪ Sound risk management is a foundation for all fire management activities. ▪ Fire management programs and activities are economically viable, based upon values to be protected, costs, and land and resource management objectives.
▪ Fire management plans and activities are based upon the best available science. ▪ Fire management plans and activities incorporate public health and environmental quality considerations. ▪ Federal, state, tribal, local, interagency, and international coordination and cooperation are essential. ▪ Standardization of policies and procedures among federal agencies is an ongoing objective.

National Fire Plan
The National Fire Plan, officially titled Managing the Impacts of Wildfire on Communities and the Environment: A Report to the President In Response to the Wildfires of 2000, was a presidential directive in 2000 as a response to severe wildland fires that had burned throughout the United States. The National Fire Plan focuses on reducing fire impacts on rural communities and providing assurance for sufficient firefighting capacity in the future. The plan addresses five key points: firefighting, rehabilitation, hazardous fuels reduction, community assistance, and accountability. The plan provides technical, financial, and resource guidance and support for wildland fire management across the United States. The U.S. Department of Agriculture and the Department of the Interior are working to successfully implement the key points outlined in the plan (DOI/USDA 2000).

International Fire Code
Created by the International Code Council, the International Fire Code (IFC) addresses a wide array of conditions hazardous to life and property, including fire, explosions, and hazardous materials handling or usage (although not a federal regulation, but rather the product of the International Code Council). The International Fire Code places an emphasis on prescriptive and performance-based approaches to fire prevention and fire protection systems.

Updated every 3 years, the International Fire Code uses a hazards classification system to determine the appropriate measures to be incorporated to protect life and property (often times these measures include construction standards and specialized equipment). The International Fire Code uses a permit system (based on hazard classification) to ensure that required measures are instituted (International Code Council 2017).

State
California Government Code
California Government Code Sections 51175 through 51189 provide guidance for classifying lands in California as fire hazard areas and requirements for management of property within those lands. CAL FIRE is responsible for classifying FHSZs based on statewide criteria and makes the information available for public review. Further, local agencies must designate, by ordinance, VHFHSZs within their jurisdiction based on the recommendations of CAL FIRE.

Section 51182 sets forth requirements for maintaining property within fire hazard areas, such as defensible space, vegetative fuels management, and building materials and standards. Defensible space around structures in fire hazard areas must consist of 100 feet of fuel modification on each side of a structure, but not beyond the property line unless findings conclude that the clearing is necessary to significantly reduce the risk of structure ignition in the event of a wildfire. Clearance on adjacent property shall only be conducted following written consent by the adjacent owner. Further, trees must be trimmed from within 10 feet of the outlet of a chimney or stovepipe,

4.14 – WILDFIRE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.14-7
vegetation near buildings must be maintained, and roofs of structures must be cleared of vegetative materials.

Exemptions may apply for buildings with an exterior constructed entirely of nonflammable materials.

California Code of Regulations
Title 14 Natural Resources
Title 14, Division 1.5, Chapter 7, Subchapter 3, Fire Hazard, also sets forth requirements for defensible space if the distances specified above cannot be met. For example, options that have similar practical effects include noncombustible block walls or fences, 5 feet of noncombustible material horizontally around the structure, installing hardscape landscaping or reducing exposed windows on the side of the structure with a less-than-30-foot setback, or additional structure hardening such as those required in the California Building Code (CBC), California Code of Regulations Title 24, Part 2, Chapter 7A.

Title 24 California Building Standards Code
California Building Code
Part 2 of Title 24 contains the California Building Code (CBC). Chapter 7A of the CBC 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 CBC include areas identified as a FHSZ within an SRA 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 wildfire. New buildings located in such areas must comply with the ignition-resistant construction standards outlined in Chapter 7A.

California Fire Code
Part 9 of Title 24 contains the California Fire Code (CFC), which incorporates by adoption the International Fire Code with necessary California amendments. The purpose of this code 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. Chapter 49 of the CFC 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. The City adopted the 2022 CFC with local amendments in November 2022.

California Public Resources Code
California Public Resource Code, Section 4290, requires minimum fire safety standards related to defensible space that are applicable to residential, commercial, and industrial building construction in SRA lands and lands classified and designated as VHFHSZs. These regulations include road standards for fire apparatus access, standards for signs identifying roads and buildings, fuel breaks and green belts, and minimum water supply requirements. It

4.14 – WILDFIRE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.14-8
should be noted that these regulations do not supersede local regulations which equal or exceed minimum regulations required by the state.

California Public Resource Code, Section 4291, requires a reduction of fire hazards around buildings located adjacent to a mountainous area, forest-covered lands, brush-covered lands, grass-covered lands, or land that is covered in flammable material. It is required to maintain 100 feet of defensible space around all sides of a structure, but not beyond the property line unless required by state law, local ordinance, rule, or regulations. Further, California Public Resource Code, Section 4291 requires the removal of dead or dying vegetative materials from the roof of a structure, and trees and shrubs must be trimmed from within 10 feet of the outlet of a chimney or stovepipe. Exemptions may apply for buildings with an exterior constructed entirely of nonflammable materials.

Fire Hazard Severity Zones
CAL FIRE maps FHSZs based on fuel loading, slope, fire history, weather, and other relevant factors as directed by California Public Resources Code, Sections 4201–4204, and California Government Code Sections 51175–51189.

FHSZs are ranked from Moderate to Very High and are categorized for fire protection within an FRA, SRA, or LRA under the jurisdiction of a federal agency, CAL FIRE, or local agency, respectively. The Project site is within an LRA but not within a FHSZ, and is adjacent to a Moderate and VHFHSZ to the northeast in an SRA. The nearest VHFHSZ in an LRA is located immediately north of the Project site (CAL FIRE 2023; CAL FIRE 2009).

California Strategic Fire Plan
The 2018 Strategic Fire Plan for California reflects CAL FIRE’s focus on fire prevention and suppression activities to protect lives, property, and ecosystem services, and natural resource management to maintain the state’s forests as a resilient carbon sink to meet California’s climate change goals and to serve as important habitat for adaptation and mitigation. The Strategic Fire Plan for California provides a vision for a natural environment that is more fire resilient, buildings and infrastructure that are more fire resistant, and a society that is more aware of and responsive to the benefits and threats of wildland fire, all achieved through local, state, federal, tribal, and private partnerships (CAL FIRE 2018). Plan goals include the following:

Identify and evaluate wildland fire hazards and recognize life, property and natural resource assets at risk, including watershed, habitat, social and other values of functioning ecosystems. Facilitate the collaborative development and sharing of all analyses and data collection across all ownerships for consistency in type and kind.

Promote and support local land use planning processes as they relate to: (a) protection of life, property, and natural resources from risks associated with wildland fire, and (b) individual landowner objectives and responsibilities.

Support and participate in the collaborative development and implementation of local, county and regional plans that address fire protection and landowner objectives.

Increase fire prevention awareness, knowledge and actions implemented by individuals and communities to reduce human loss, property damage and impacts to natural resources from wildland fires.

Integrate fire and fuels management practices with landowner/land manager priorities across jurisdictions.

Determine the level of resources necessary to effectively identify, plan and implement fire prevention using adaptive management strategies.

Determine the level of fire suppression resources necessary to protect the values and assets at risk identified during planning processes.

4.14 – WILDFIRE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.14-9
Implement post-fire assessments and programs for the protection of life, property, and natural resource recovery.

Mutual Aid Agreements
The California Disaster and Civil Defense Master Mutual Aid Agreement, as provided by the California Emergency Services Act, provides statewide mutual aid between and among local jurisdictions and the state. The statewide mutual aid system exists to ensure that adequate resources, facilities, and other supports are provided to jurisdictions whenever resources prove to be inadequate for a given situation. Each jurisdiction controls its own personnel and facilities but can give and receive help whenever needed.

Local
California Disaster and Civil Defense Master Mutual Aid Agreement As provided for in the California Emergency Services Act, this 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 are 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.

San Diego County 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 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 source 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.

San Diego County Multiple- Jurisdictional Hazard Mitigation Plan The purpose of the County’s Multi-Jurisdictional Hazard Mitigation Plan (County of San Diego 2017) is to identify the County’s hazards, review and assess past disaster occurrences, estimate the probability of future occurrences, and set goals to mitigate potential risks to reduce or eliminate long-term risk to people and property from natural and human-made hazards. An important San Diego County Multi-Jurisdictional Hazard Mitigation Plan component is the Community Emergency Response Team (CERT), which educates community members about disaster preparedness and trains them in basic response skills, including fire safety.

Santee General Plan
Safety Element
The purpose of the Safety Element is 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. The following goals and policies are applicable:

4.14 – WILDFIRE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.14-10
Goal 4.0 Minimize injuries, loss of life and property damage resulting from fire hazards Policy 4.1 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.

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

Policy 4.3 The City shall require the installation of fire hydrants and establishment of emergency vehicle access, before construction with combustible materials can begin on an approved project.

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

Policy 4.5 The City should support State legislation that would provide tax incentives to encourage the repair or demolition of structures that could be considered fire hazards.

Policy 4.6 The City should support the continuation of the existing weed abatement program.

Policy 4.7 The City shall ensure that the distribution of fire hydrants and capacity of water lines is adequate through periodic review.

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.

Policy 4.9 All 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 4.10 Encourage 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 4.12 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.

4.14.3 Thresholds of Significance
The significance criteria used to evaluate the Project impacts to wildfire are based on Appendix G of the California Environmental Quality Act (CEQA) Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact

4.14 – WILDFIRE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.14-11
related to wildfire would occur if a Project located in or near SRAs or lands classified as very high fire hazard severity zones would:

Substantially impair an adopted emergency response plan or emergency evacuation plan.

Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose Project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire.

Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment.

Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.

4.14.4 Impacts Analysis
The Project site is not located in SRA lands or lands classified as VHFHSZ. However, LRA lands classified as VHFHSZs are located immediately north and east of the Project site. Additionally, there are SRA lands classified as very high less than a mile northeast of the project site.

A. Would the Project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Less-than-Significant Impact. As discussed in Section 4.12, Transportation, access to the Project site would be designed such that adequate emergency access would be provided in accordance with emergency apparatus access requirements. Access to the Project site would be provided via North Woodside Avenue. As mentioned in the Project’s Fire Protection Plan (FPP) (Appendix N of this EIR), the existing driveway currently bordering the east and south side of the Project site would be extended to loop around the entire Project site and widened to 60 feet 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.

Emergency response to the Project site would be provided by the Santee Fire Department, San Diego County Sheriff’s Department, and other responsible agencies. The SFD’s response times vary within the City, with the current goal being 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). The response time for fire department emergency response to the Project site can be calculated using the National Fire Protection Association (NFPA) 1710 and Insurance Services Office Public Protection Classification Program’s Response Time Standard formula (Time=0.65 + 1.7(Distance). Travel distances are derived from Google road data while travel times are calculated using response speeds of 35 mph. The Insurance Services Office response travel time formula discounts speed for intersections, vehicle deceleration and acceleration, and does not include turnout time. Automatic and/or Mutual Aid agreements with surrounding fire departments are in place and would potentially result in additional resources that are not analyzed herein.

4.14 – WILDFIRE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.14-12
SFD Station 4 is the closest fire station to the Project site and would likely be the first to respond. SFD Station 4 is approximately 1.5-mile from the entrance to the Project site and could respond to an incident within an approximately 3.2-minute travel time. 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 Santee-Lakeside 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).

San Diego County’s Hazard Mitigation Plan includes resources and information to assist county residents, public and private sector organizations, and others interested in participating in planning for natural hazards (County of San Diego 2023). As they relate to the Project, the mitigation objectives and actions outlined in the Hazard Mitigation Plan would require that the Project be designed and constructed in accordance with the current California Building and Fire Codes (and local amendments) would ensure that the Project is compliant with fire inspection standards and weed abatement to reduce the potential for vegetation fires (County of San Diego 2023). The Project would comply with all County, state, and local requirements related to fire safety, and the Project would comply with all requirements outlined in the Hazard Mitigation Plan.

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 EOP, primary evacuation routes consist of the major interstates and prime arterials. In the event of a wildfire, the City, in cooperation with Santee Fire Department, would utilize the County’s public notification systems and provide evacuation instructions. Emergency response to the Project site would be serviced by the Santee Fire Department, San Diego County Sheriff’s Department, and other responsible agencies. The City does not have any designated evacuation routes, although Interstate 67 is designated in the County’s General Plan Safety Element and the County’s Emergency Operations Plan as an evacuation route and is less than a mile from the Project site (County of San Diego 2022). North Woodside Avenue is just south of the Project site. and is a major north-south arterial. Additionally, the Project site is located in the southeastern part of the City, which sits in a transportation corridor formed by Interstates 52 and 67.

As referenced in Section 4.7 Hazards and Hazardous Materials, 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. Further, as shown in Figure 4.14-2, Wildfire History, wildfires in the City and surrounding areas have occurred in all directions around the project site, with the most recent fires between 2020-2022 happening 7 miles south of the project site. In the event that prevailing winds fan a fire so that it moves toward the Project site, evacuation of the potentially affected communities may be required.

In general, evacuees would take roads leading west toward the city boundary and toward El Cajon. With compliance with City and SFD requirements, the Project would not conflict with or impair implementation of the Hazard Mitigation Plan, and the County’s Emergency Operations Plan nor would the Project impair use of potential evacuation routes in the City, and impacts would be less than significant.

Ä67
Ä125
Ä52
Ä94
§¨8
Project Boundary
5 Mile Buffer
Wildfire Perimeters
1900-1949
1950-1959
1960-1969
1970-1979
1980-1989
1990-1999
2000-2009
2010-2019
2020-2022
Motorways
Public\Imagery_2019
RGB
Red: Band_1
Green: Band_2
Blue: Band_3
SOURCE: SanGIS, Open Street Maps, CDF2022
Date: 5/14/2024 - Last saved by: kholmes - Path: Z:\Projects\j1513801\MAPDOC\DOCUMENT\Draft_EIR\Draft_EIR_figures.aprx 0 0.5 1 n Miles
FIGURE 4.14-2
Fire History
Palisade Santee Commerce Center Project

4.14 – WILDFIRE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.14-14

INTENTIONALLY LEFT BLANK

4.14 – WILDFIRE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.14-15
B. Due to slope, prevailing winds, and other factors, would the Project exacerbate wildfire risks, and thereby expose Project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire? Less-than-Significant Impact. The Project site is not located in SRA lands or lands classified as VHFHSZ. However, the nearest VHFHSZ in the SRA is located less than 1 mile northeast of the Project site. Additionally, the Project site is adjacent to land to the northeast classified as VHFHSZ within the LRA. The Project could exacerbate wildfire risk and expose Project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire if the Project, combined with the climatic, topographic, vegetation, weather conditions, and other factors, would increase the risk of a wildfire occurring and increase the severity of such an occurrence.

Short-Term Construction Impacts
Construction of the Project would introduce potential ignition sources to the Project site, including the use of heavy machinery and the potential for sparks during welding activities or other hot work. However, the Project would be required to comply with City and state requirements for fire safety practices, to reduce the possibility of fires during construction activities. Further, vegetation would be removed from the site prior to the start of construction.

Adherence to City and state regulatory standards during Project construction would reduce the risk of wildfire ignition and spread during construction activities. Thus, short-term construction impacts associated with exacerbating wildfire risk would be less than significant.

Long-Term Operational Impacts
Slope
As discussed in the Geotechnical Report (Appendix G of this EIR), the Project site and surrounding area are relatively flat. The Project site contains mainly 0 to 2 percent slopes consisting of Visalia sandy loam soils and Riverwash (NorCal Engineering 2024). Upon Project implementation, the portions of the site that would be developed would be graded to a flat, level surface. The Project site and surrounding area do not contain slopes typical of exacerbating wildfire risk, and once developed, the Project would not result in steep slopes typical of exacerbating wildfire risk.

Prevailing Winds
Prevailing winds are winds that blow from a single direction over a specific area. As mentioned above, the predominant average hourly wind in the Project area is most often from the west for 10 months, and the wind is most often from the east from late November to early February. The windier part of the year lasts for approximately 7 months (November to June), with average wind speeds of more than 7.0 miles per hour (WeatherSpark 2023).

High wind velocities that could exacerbate wildfire risk are generally associated with downslope, canyon, and Santa Ana winds that can occur in the winter in this area. As discussed above, the Project site does not include topography that would create unusual weather conditions. Given that Project construction would not involve altering any slopes or creating any new wind patterns, it is not anticipated that the Project would exacerbate wildfire risk due to prevailing winds.

Other Factors
Other factors such as vegetation, building materials, setbacks and proposed on-site activities can also contribute to wildfire risk.

4.14 – WILDFIRE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.14-16
Vegetation
As discussed above, the vegetation of the Project site is characterized by Non-native Grassland, Non-native Woodland, Disturbed Habitat, and Urban/Developed. Further, the Project would convert vacant land with moderate vegetation cover into development consisting of large warehouse buildings, paved surface parking and maintained landscape areas. The proposed landscaping would be implemented according to Chapter 13.36 of the City’s Municipal Code and would include maintained landscaped areas. The proposed landscape plan does not have any flammable plants to ensure that it does not increase fire risk. As such, impacts would be less than significant.

Building Materials and Setbacks
Project buildings would be required to comply with the City’s Municipal Code, which adopts the 2022 CFC and includes provisions for fire safety and fire-resistive construction. Further, compliance with required setbacks would allow for space between Project buildings and off-site vegetation. Studies indicate that given certain assumptions (e.g., 10 meters of low-fuel landscape, no open windows), wildfire is unlikely to spread to buildings unless the fuel and heat requirements of the building are sufficient for ignition and continued combustion (Alexander et al. 1998; Cohen 1995). Construction materials and methods can prevent or minimize ignitions. According to previous research, post-fire assessments conducted in San Diego County indicate that updated building codes have shown success in preventing structural loss (IBHS 2008). The distance between a wildfire that is consuming wildland fuel and a building is the primary factor for structure ignition (not including burning embers) (Cohen 2000). Project structures would be set back from offsite fuels, and perimeter parking and drive aisles would serve as nonflammable fuel breaks. Low-ignitability buildings provide the option of reducing the wildland fire threat to structures without extensive wildland fuel reduction. The Project would be required to comply with construction methods outlined in the City’s Municipal Code, the CFC and CBC, which specify requirements for materials and construction methods for fire safety. The proposed building materials for Project structures include concrete, metal, aluminum entrance front framing, glass, and other fire-resistant materials. If structures have a sufficiently low ignitability, such as the Project’s structures, buildings can survive exposure to wildfire without major fire destruction.

Project Design Feature (PDF-WF-1)
As described in Chapter 3 of this EIR and consistent with recommendations of the Project’s FPP (see Appendix N of this EIR), the Project includes the following project design feature (PDF):

PDF-WF-1: Prior to the start of construction activities and issuance of grading permits and consistent with the Fire Protection Technical Report prepared for the Project (see Appendix N of this Draft EIR), the Project applicant, or its designee, shall ensure that the Project includes the following fire protection and life safety features,: (1) an encircling fire apparatus roadway; (2) a secure Knox box access; (3) dual fire department connections; (4) reliable water supply arrangements; (5) strategically placed fire department access points; (6) ample onsite fire hydrants; (7) an advanced ESFR sprinkler system; (8) a diesel fire pump; (9) a Class I manual wet standpipe system; (10) well-placed exits with illumination and signage; (11) readily accessible fire extinguishers; and (12) the implementation of recommended fire hazard mitigation strategies outlined in Section 7 of the Project FPP (see Appendix N of this Draft EIR).

4.14 – WILDFIRE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.14-17
Proposed Activities
The future tenant of the proposed industrial building is not known at this time. Project activities could introduce new potential sources of ignition to the Project site. The Project would support a variety of activities associated with the industrial/warehouse buildings, including the ingressing and egressing of passenger vehicles and trucks, the loading and unloading of trucks with designated truck courts/loading areas, and the internal and external movement of materials around the Project site via forklifts, pallet jacks, and similar equipment. In addition, the office space would support general internal office activities related to the industrial/warehouse uses. However, proposed activities do not consist of highly flammable activities typical of exacerbating fire risk, such as welding or other hot work. Given that the proposed use would not exacerbate fire risk and given that vegetation on site would consist of fire-resistant and irrigated landscaping, the likelihood of a fire starting on site and spreading to off-site areas would be minimal.

With adherence to the City’s Municipal Code, the low ignitability of the proposed structures, and implementation of fire-resistant, irrigated landscaping, the Project would not facilitate wildfire spread or exacerbate wildfire risk or expose people or structures, indirectly or directly, to significant wildfire risk. Further, the surrounding off-site fuels consist of moderately spaced vegetation, segmented by the San Diego River immediately north, with limited vegetation south given the urban uses and zoning. Although there have been fires shown in Figure 4.14-2, Wildfire History within a five-mile buffer, wildfires in the immediately surrounding area are not common. It is unlikely that Project occupants would be exposed to the uncontrolled spread of a wildfire or prolonged pollutant concentrations in the event of a wildfire. Additionally, as summarized above, in Chapter 3 of this EIR, and in the conclusion of the Project’s FPP, the Project includes project design features (PDF-WF-1) that exceed fire code requirements. Thus, the Project would not exacerbate risk by exposing project occupants to wildfire. 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, and with implementation of the low fuel volume landscape plan, impacts would be less than significant.

C. Would the Project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
Less-than-Significant Impact. The Project involves the development of a previously developed site to include an industrial/warehouse building, with associated office space, loading docks, trailer stalls, passenger vehicle parking spaces, and street, sidewalk, and landscape improvements. As discussed in Section 4.13, Utilities and Service Systems, the Project would include reconfiguration of existing service utilities (e.g., water, wastewater, stormwater drainage, electric power, natural gas, and telecommunications services). This also includes some additions. This would include a new 8-inch line for wastewater to connect to existing lines near to the project site, and as referenced in the Project’s FPP, two new Fire department connections, one in the southeast and one in the northwest corner of the building.

Given that the activity of connecting utilities from their current locations to the Project site and the new off-site improvements would require ground disturbance and the use of heavy machinery associated with trenching, the installation of these utility service lines could potentially result in temporary impacts to the environment and could exacerbate wildfire risk by introducing new potential sources of ignition, such as the use of heavy machinery, welding, or other hot work. However, as previously discussed, vegetation would be removed from the site prior to the start of construction, and the site would be graded to a flat, level surface, which would reduce the likelihood of fire ignition during installation and connection of utilities. The majority of the associated infrastructure and utility

4.14 – WILDFIRE
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 4.14-18
connections would occur on site or adjacent to the site and would not result in off-site environmental impacts or exacerbate wildfire risk.

The installation and maintenance of roads, service utilities, drainage and water quality improvements, and vegetation removal are part of the Project analyzed herein. As such, any potential temporary or ongoing environmental impacts related to these components of the Project have been accounted for and analyzed in this EIR as part of the impact assessment conducted for the entirety of the Project. Additionally, the Project would be required to comply with all regulatory requirements and mitigation measures outlined within this EIR for the purposes of mitigating impacts associated with trenching, grading, site work, and the use of heavy machinery. No adverse physical effects specifically related to wildfire or beyond those already disclosed throughout this EIR would occur as a result of implementation of the Project’s associated infrastructure. Therefore, the installation and maintenance of associated infrastructure would not exacerbate wildfire risk or result in impacts to the environment beyond those already disclosed in this EIR, and impacts would be less than significant.

D. Would the Project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? Less-than-Significant Impact. Vegetation plays a vital role in maintaining existing drainage patterns and the stability of soils. Removal of surface vegetation reduces the ability of the soil surface to absorb rainwater and can allow for increased runoff that may include large amounts of debris or mud-flows. If hydrophobic conditions exist post-fire, the rate of surface water runoff is increased as water percolation into the soil is reduced (Moench and Fusaro 2012). The potential for surface runoff and debris flows therefore increases for areas recently burned by large wildfires (Moench and Fusaro 2012). The Project site is located within the San Diego River Watershed. The San Diego River is located immediately north of the Project site. As discussed in the Geotechnical Report (Appendix G of this EIR), the Project site is relatively flat and is not within areas mapped as susceptible to subsidence, or landslides. Further, according to available wildfire history (see Figure 4.14-2, Wildfire History), wildfires have not burned onto or adjacent to the Project site, and conditions associated with post-fire slope instability do not exist.

As further discussed in Section 4.8, Hydrology and Water Quality, the northern perimeter of the Project site is located within a Special Flood Hazard Area, which is an area that presents a 1% annual chance of flooding, or the 100-year base floodplain with flood elevations provided (FEMA 2023). Although internal drainage patterns would be somewhat altered as a result of Project development, the Project would be similar to existing drainage conditions and would maintain adequate stormwater conveyance and would decrease runoff rates by capturing stormwater in proposed on-site storm drains and water quality basins. Therefore, the Project would not substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off site. Therefore, due to the proposed grading of the site, the relatively flat surrounding lands, and the fact that the site would be developed and paved, the likelihood for downslope or downstream flooding or landslides as a result of runoff, post-fire slope instability, or drainage changes would be minimal, and impacts would be less than significant.

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

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 5-1
5 Effects Found Not To Be Significant
Section 15128 of the California Environmental Quality Act (CEQA) Guidelines requires that an Environmental Impact Report (EIR) briefly describe potential environmental effects that were determined not to be significant and therefore were not discussed in detail in the EIR. The environmental issues discussed in the following sections are not considered significant for the Palisade Santee Commerce Center Project (Project), and the reasons for these lessthan-significant impact or no impact determinations are discussed herein.

5.1 Agricultural and Forestry Resources
Conversion of Agricultural Lands and Forestlands
The Project site is currently occupied by the Santee Drive-In Theatre with a few small buildings within the parcel.

The California Department of Conservation has not identified the site as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (DOC 2018). The Project site is designated as “Urban and Built-Up Land,” by the California Department of Conservation, which is not a category under this CEQA criterion. In this case, the California Department of Conservation’s designation of the Project site as “Urban and Built-Up Land” recognizes the fact that the site has a land use designation and zoning for light industrial uses, and has surrounding industrial land uses, which suggests a potential use for farmland is highly unlikely to occur because of the site location.

Because the site is not identified as Prime Farmland, Unique Farmland or Farmland of Statewide Importance, and because the “Urban and Built-Up Land” designation is not a category under this criterion, there would be no impact related to converting Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-agricultural use.

The Project site has a land use designation and zoning for light industrial uses. The site is not planned for or used for any agricultural or forestry purposes. According to the City’s Draft Program EIR for the Housing Element Rezone Program Implementation, there are no lands protected by a Williamson Act Contract within the City (City of Santee 2022). Therefore, there would be no impact related to conflict with existing zoning or a Williamson Act Contract.

No portion of the site is considered forest land1 as defined in California Public Resources Code Section 12220(g).

Timberland2 (as defined by California Public Resources Code Section 4526) or timberland-zoned timberland production3 (as defined by Section 51104[g] of the Government Code) is not present on-site, nor are there any active or potential commercial timber operations present in the area. The proposed Project would not involve the conversion of forest land to non-forest use. Therefore, the Project would not conflict with lands zoned for forest land, timberland, or timberland production and there would be no impact. 1 “Forest land” is land that can support 10% native tree cover of any species, including hardwoods, under natural conditions, and that allows for management of one or more forest resources, including timber, aesthetics, fish and wildlife, biodiversity, water quality, recreation, and other public benefits.
2 “Timberland” means land, other than land owned by the federal government and land designated by the board as experimental forest land, which is available for, and capable of, growing a crop of trees of a commercial species used to produce lumber and other forest products, including Christmas trees. Commercial species shall be determined by the board on a district basis. 3 “Timberland production zone” means an area is devoted to and used for growing and harvesting timber, or for growing and harvesting timber and compatible uses.
5 – EFFECTS FOUND NOT TO BE SIGNIFICANT
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 5-2

5.2 Geology and Soils
Fault Rupture
The Alquist–Priolo Earthquake Zoning Act (Alquist–Priolo Act) requires the delineation of fault zones along active faults in California. The purpose of the Alquist–Priolo Act is to regulate development on or near active fault traces to reduce hazards associated with fault rupture. The Alquist–Priolo Earthquake Fault Zones are the regulatory zones that include surface traces of active faults. According to the California Geological Survey, the Project site is not located in an Alquist–Priolo Earthquake Fault Zone (CGS 2023). The nearest potentially active fault (i.e., Quaternary fault) is the Rose Canyon/Newport-Inglewood fault zone, located approximately 15 miles west of the Project site (CGS 2015). As a result, no impacts would occur with respect to active faulting.

Seismic Ground Shaking
Similar to other areas located in seismically active Southern California, the City is susceptible to strong ground shaking during an earthquake. However, the Project site is not located within an Alquist–Priolo Earthquake Fault Zone, and the site would not be affected by ground shaking more than any other area in this seismic region.

Pursuant to the 2022 California Building Code and Title 11, Buildings and Construction, of the Santee Municipal Code, the Project’s geotechnical report will be subject to review and approval by City staff prior to issuance of a grading permit. Compliance with the recommendations of the geotechnical report is mandated by Section

11.40.130 of the Santee Municipal Code, and compliance is subject to inspection by the City Building Official. With implementation of the recommendations of the Project’s geotechnical report, impacts associated with strong seismic ground shaking would be less than significant.

Seismic Related Ground Failure
Soil liquefaction is a seismically induced form of ground failure that has been a major cause of earthquake damage in Southern California. Liquefaction is a process by which water-saturated granular soils transform from a solid to a liquid state because of a sudden shock or strain, such as an earthquake. Lateral spreading occurs in liquefaction prone sediments on unsupported slopes. Based on Figure 8-3 of the City’s General Plan Safety Element, the Project site is located in area C3, which identifies the liquefaction potential as low to moderate (City of Santee 2003). A Project-specific liquefaction analysis was completed, assuming a magnitude 6.9 earthquake, historical high groundwater depth of 20 feet below ground surface, and a peak ground acceleration of 0.42g (percent of gravity).

Based on the analysis, seismic settlements of 7/8 inch or less are anticipated in the proposed building area, with differential settlements of approximately 0.25 inch over a horizontal distance of 50 feet (Appendix G). Pursuant to the 2022 California Building Code and Title 11, Buildings and Construction, of the Santee Municipal Code, the proposed building would be constructed in accordance with this liquefaction analysis. Therefore, impacts associated with potential seismic-related ground failure, including liquefaction, and associated lateral spreading, would be less than significant.

Landslide
Based on the Project-specific geotechnical report (Appendix G) and the City General Plan Safety Element (City of Santee 2003), the Project site is located on relatively flat to gently sloping terrace deposits/older alluvium, adjacent to the San Diego River, and would not be susceptible to landslides (City of Santee 2003). Grading for the Project would not result in slopes susceptible to landslides, as only the upper approximate 2 feet of soils would be 5 – EFFECTS FOUND NOT TO BE SIGNIFICANT
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 5-3
overexcavated and recompacted during grading (Appendix G). As a result, impacts related to landslides would be less than significant.

Soil Erosion and Topsoil Loss
The Project would involve earthwork and other construction activities that would disturb surface soils and temporarily expose soils to increased erosion potential. Common causes of soil erosion from construction sites include stormwater, wind, and soil being tracked off site by vehicles. Because more than 1 acre of ground disturbance would occur during Project grading and construction, the Project would be required to comply with the National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities, Order WQ 2022-0057-DWQ, NPDES No. CAS000002, also known as the Construction General Permit. The Construction General Permit requires implementation of a Stormwater Pollution Prevention Plan and associated Best Management Practices, which would minimize soil erosion during grading and construction. Upon completion of construction, the Project site would be developed with a warehouse building, surrounding paved parking lot, truck loading areas, and other improvements and landscaped areas. These paved areas would stabilize soils and eliminate long-term erosion. As a result, construction- and operations-related soil erosion impacts would be less than significant.

Unstable Geologic Unit or Soil
As discussed previously, the potential for the Project to result in or be affected by landslides is low, and this issue is not anticipated at the Project site. Based on a Project-specific liquefaction analysis, seismic settlements of 7/8 inch or less are anticipated in the proposed building area, with differential settlements of approximately 0.25 inch over a horizontal distance of 50 feet. Similarly, based on consolidation testing at the site, ground settlement of ¾ inch could occur uniformly across the site, and differential settlement up to 0.25 inch could occur (Appendix G).

The Project site is not located in an area prone to regional ground subsidence due to groundwater pumping, peat loss or oil extraction (USGS 2023). However, based on soil density testing at the site, subsidence up to 0.2 feet could occur due to earthwork operations. However, in compliance with the 2022 California Building Code and pursuant to Title 8, Buildings and Construction, of the Santee, California Municipal Code, the Project’s geotechnical report will be subject to review and approval by City staff prior to issuance of a grading permit. Compliance with the recommendations of the geotechnical report is mandated by Section 11.40.150 of the Santee, California Municipal Code, and compliance is subject to inspection by the City Building Official. With implementation of the recommendations of the Project’s geotechnical report, impacts would be less than significant.

Expansive Soil
Expansive soils are characterized by their potential shrink/swell behavior. Shrink/swell is the change in volume (expansion and contraction) that occurs in certain fine-grained clay sediments from the cycle of wetting and drying.

Clay minerals are known to expand with changes in moisture content. The higher the percentage of expansive minerals present in near-surface soils, the higher the potential for substantial expansion. Soil expansion tests were not completed as part of the geotechnical investigation; however, the Project site is underlain by terrace deposits and alluvium, consisting primarily of sands, which are not prone to expansion. Per the geotechnical report (Appendix G), additional soil sampling would be completed during final Project design and the Expansive Soil Guidelines in the geotechnical report would be adhered to during construction. As a result, impacts related to expansive soil would be less than significant.
5 – EFFECTS FOUND NOT TO BE SIGNIFICANT
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 5-4
Septic Tanks
The Project would connect to the City’s municipal sewer lines and would not require septic tanks or alternative wastewater disposal systems. Therefore, no impacts would occur.

5.3 Mineral Resources
Mineral Resources and Recovery Sites
The Project site is located in an urbanized portion of the City and is bound by existing utility and industrial development to the east, west and south. Mineral resource mining is not a compatible use with these land uses.

The San Diego River is adjacent and north of the site. While mining for construction sand has been permitted in portions of the San Diego River in the past, there are no mining permits near the project site. The Project site is not large enough to effectively extract mineral resources. Considering the existing surrounding land uses and the incompatibility of mineral resource extraction activities in the Project area, potential significant mineral resources within the Project area are considered unavailable for extraction. Therefore, impacts associated with mineral resources would be less than significant.

5.4 Population and Housing
Inducement Population Growth
The Project would require a temporary construction workforce and a permanent operational workforce, both of which could potentially induce population growth in the Project area. A temporary workforce would be needed to construct the warehouse buildings and associated improvements. The number of construction workers needed during any given period would largely depend on the specific stage of construction but would likely range from a dozen to several dozen workers on a daily basis. These short-term positions are anticipated to be filled primarily by construction workers who reside in the Project site’s vicinity; therefore, construction of the Project would not generate a permanent increase in population within the Project area.

Permanent employment at the completed 300,145 square feet commerce center is expected to generate 185 direct new jobs (London Moeder Advisors 2023). Although some of these jobs could result in relocation to the area, the increase in population would be minor.

According to the San Diego Association of Governments Demographics and Growth Forecast, employment in the City is anticipated to grow from 1,646,419 jobs in 2016 to 2,086,419 jobs in 2050 (SANDAG 2021). The Projectrelated increase in employment would be minimal in comparison to the anticipated increase in the Southern California Association of Governments Demographics and Growth Forecast.

Additionally, as of April 2023, the California Employment Development Department found that the unemployment rate for San Diego-Carlsbad Metropolitan Statistical Area, including the City of Santee, is at 3.3%, which is lower than the state average (4.3%) and higher than the national average (3.1%) for the same period (EDD 2023). As such, the Project’s temporary and permanent employment requirements could likely be met by the City’s existing labor force without people needing to relocate into the Project region, and the Project would not stimulate population growth or a population concentration above what is assumed in local and regional land use plans. With a total of 185 permanent direct employees estimated, it is reasonable to assume any relocations to the area as a result of the Project would be minor. Therefore, impacts would be less than significant. 5 – EFFECTS FOUND NOT TO BE SIGNIFICANT
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 5-5
Displacement of Existing Housing and People
The Project site currently does not contain any housing or other residential uses. Given that no residential uses are located on-site, it follows that the site does not support a residential population and there would be no displacement of people or housing. Therefore, no impact would occur.

5.5 Recreation
Existing, Expanded, and New Recreation Facilities
The Project would construct one industrial/warehouse building and associated improvements. The Project does not propose any residential uses and would not result in a substantial and unplanned increase in population growth within the Project area. As such, the Project would not increase the use of existing neighborhood parks or regional parks in the City and surrounding area. In addition, as an industrial use, the Project does not propose recreational facilities or require the construction or expansion of recreational facilities. Therefore, no impacts would occur. 5 – EFFECTS FOUND NOT TO BE SIGNIFICANT
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 5-6

INTENTIONALLY LEFT BLANK
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-1
6 Other CEQA Considerations

6.1 Cumulative Impacts
Section 15130(a) of the State CEQA Guidelines requires a discussion of the cumulative impacts of a project when the project’s incremental effect is cumulatively considerable. Cumulatively considerable, as defined in CEQA Guidelines Section 15065(a)(3), means that the “incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.” The State CEQA Guidelines Section 15355 defines a cumulative impact as two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts. Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time.

In many cases, the impact of an individual project may not be significant, but its cumulative impact may be significant when combined with impacts from other related projects. CEQA Guidelines Section 15130(b) states that “the discussion [of cumulative impacts] need not provide as great detail as is provided for the effects attributable to the project alone.” Section 15130(b) further states that a cumulative impacts discussion “should be guided by standards of practicality and reasonableness.”
Cumulative impacts can also occur from the interactive effects of a single project. For example, the combination of noise and dust generated during construction activities can be additive and can have a greater impact than either noise or dust alone. However, substantial cumulative impacts more often result from the combined effect of past, present, and future projects located in proximity to a proposed project. Thus, it is important for a cumulative impacts analysis to be viewed over time and in conjunction with other related past, present, and reasonably foreseeable future projects, the impacts of which might compound or interrelate with those of the project under review.

Probable future projects are those in the project vicinity that have the possibility of interacting with the project to generate a cumulative impact (based on proximity and construction schedule) and either:
▪ are partially occupied or under construction,
▪ have received final discretionary approvals but are not yet constructed, ▪ have applications accepted as complete by local agencies and are currently undergoing environmental review, or
▪ are projects that have been discussed publicly by an applicant or that otherwise become known to a local agency and have provided sufficient information about the project to allow at least a general analysis of environmental impacts.

CEQA Guidelines Section 15130 identifies two basic methods for establishing the cumulative environment in which a project is considered: the use of a list of past, present, and probable future projects, or the use of adopted projections from a general plan, other regional planning document, or a certified EIR for such a planning document.

This cumulative analysis uses a combination of the “list” approach and the “projections” approach to identify the cumulative setting.
6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-2
Geographic Scope
The geographic area that could be affected by the project varies depending on the type of environmental resource being considered. When the effects of the project are considered in combination with those other past, present, and probable future projects to identify cumulative impacts, the other projects that are considered may also vary depending on the type of environmental effects being assessed. Table 6-1 presents the general geographic areas associated with the different resources addressed in this analysis.

Table 6-1. Geographic Scope of Cumulative Impact Analyses Environmental Issue Geographic Scope of Cumulative Impact Analyses Aesthetics Project site and viewshed
Air Quality Region (pollutant emissions that affect the air basin), immediate project vicinity (pollutant emissions that are highly localized) Biological Resources Local and regional vicinity
Cultural Resources, Tribal Cultural
Resources, and Paleontological
Resources
Project site
Energy Region and immediate project vicinity
Greenhouse Gas Emissions Global/statewide
Hazards and Hazardous Materials Project site and immediate project vicinity Hydrology and Water Quality Project site and immediate project vicinity Land Use and Planning Project site and immediate project vicinity Noise Project site and immediate project vicinity
Public Services Project site and immediate project vicinity Transportation Project site and surrounding areas
Utilities and Service Systems Project site and surrounding areas Wildfire Project site and immediate project vicinity
Project List
For the analysis of cumulative impacts associated with the Project, a cumulative project list was developed through consultation with the City of Santee. Table 6-2 provides a list of these cumulative projects and their associated land use.

City
ID1 Project Status Address Land Use/Description
1 Warmington
Townhomes
Pending Entitlement 10939 Summit
Avenue
50 residential
condominium units
2 D'Lazio Condominiums Approved 8/23/06 -
Under Construction
8439 Fanita Drive 20 residential
condominium units
6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-3
City
ID1 Project Status Address Land Use/Description
3 Vactor Decanting
Station
Pending Entitlement 9534 Via Zapador Vactor truck dewatering station
4 Karl Strauss Approved 12/17/15 -
Not Built
300 Town Center
Parkway
Brewery, tasting room, &
restaurant
6 Prospect Estates II
Subdivision
Approved 10/9/19 -
Under Construction
8705 Marrokal Lane 38 condos, 15 single-family
homes
7 Palazzo Villas Approved 2/12/20 -
Not Built
8842 Olive Lane 8 residential condominium
units
8 Starbucks & 7-Eleven Approved 6/10/20 -
Not Built
8606 Graves Avenue 4,800 sq. ft. coffee shop &
convenience store
9 Tyler Street Subdivision Approved 4/24/24 -
Not Built
8500 Tyler Street 14 single-family homes
11 Shadowhill Commercial
Building
Pending Entitlement SW Corner Woodside
Ave. and Shadowhill
Rd.
6,197 sq. ft. commercial
building
12 County Animal Shelter Pending Entitlement Riverview Parkway 23,303 sq. ft. animal shelter
13 Woodspring Suites
Hotel
Approved 9/18/19 -
Under Construction
8807 Mission Gorge
Road
120-guestroom, 4-story
hotel
14 Carlton Oaks Country
Club
Pending Entitlement 7200 Inwood Drive 243 residential units & hotel
15 All Right Storage Approved 4/28/21 -
Not Built
8708 Cottonwood
Avenue
RV and self-storage facility
16 Prospect Avenue
Subdivision
Pending Entitlement 8732 Prospect
Avenue
4 single-family homes
17 New West Subdivision Approved 4/10/24 -
Not Built
9463 Slope Street 11 single-family homes
18 Graves Avenue RV &
Self Storage
Approved 9/25/24 –
Not Built
8355 Graves Avenue RV and self-storage facility
19 Laurel Heights
Condominiums
Approved 8/11/21 -
Under Construction
7750 Laurel Heights
Drive
80 residential
condominium units
20 Extra Space Storage Pending Entitlement 10815 Woodside Avenue
88,390 sq. ft. (3-story)
storage building
21 Popeye's Approved 12/14/22 -
Under Construction
10308 Mission Gorge
Road
1,740 sq. ft. drive-through
restaurant
22 Lake Canyon
Subdivision
Approved 12/14/22 -
Not Built
9210 Lake Canyon
Road
9 single-family homes
23 Atlas View Apartments Pending Entitlement 8726 Atlas View Drive 10 residential apartments 24 Fanita Drive
Townhomes
Approved 7/12/23 -
Not Built
8504 Fanita Drive 8 residential condominium
units
25 Southwest Signal
Building
Approved 10/10/23
– Not Built
10756 Rockvill Street 20,000 sq. ft. industrial
building
26 Lantern Crest Approved 2/22/23 -
Under Construction
300 Lantern Crest
Way
432- unit congregate care
facility w/ density bonus
27 Fanita Ranch Planned
Development
Approved 9/23/20 -
Not Built
Fanita Ranch Master-planned community
w/up to 3,008 homes
28 Paseo Pending Entitlement 701 Park Center Drive 53-unit condominium units 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-4
City
ID1 Project Status Address Land Use/Description
29 Excel Hotel Approved 4/26/23 -
Not Built
381 Town Center
Parkway
97 guestroom, 4-story hotel
30 Cuyamaca Business
Center
Approved 3/12/24 –
Not Built
9745 Cuyamaca
Street
6,280 sq. ft. medical office
building
31 Ukrainian Catholic
Church
Approved 11/8/23 -
Not Built
9308 Carlton Oaks
Drive
4,400 sq. ft. church
32 Atlas Cell Phone Tower Pending Entitlement 10400-CS Fanita Parkway
74' cell phone tower at
Santee Lakes
33 Lutapaj Specialty Food
Store
Approved 1/25/2024
- Not Built
282 Town Center
Parkway
2,016 sq. ft. specialty food
& tasting facility
34 Cuyamaca/Prospect
Starbucks
Approved 6/12/2024
- Not Built
8606 Cuyamaca
Street
1,270 sq. ft. drive-through
coffee shop
35 Walmart Housing Site Pending Entitlement NW of Mission Gorge Road/ Town Center
Parkway
115 residential townhomes
36 Santee Auto Center Approved 10/25/23
– Under Construction
10335 Mission Gorge
Road
Two car dealerships, auto
body shop, & car wash
37 Fordyce Construction
Office
Pending Entitlement 9735 Prospect
Avenue
11,295 sq. ft. commercial
office and warehouse
38 Habitat for Humanity
Townhomes
Approved 9/27/23 -
Not Built
8932 First Street 17 residential
condominium units
39 Super Star Car Wash Approved 3/27/24 -
Not Built
8837 Magnolia
Avenue
4,980 sq. ft. tunnel car
wash
40 Aubrey Glen
Townhomes
Pending Entitlement 7737 Mission Gorge
Road
52 residential
condominium units
41 Santee Community
Center
Pending Entitlement 10123 Riverwalk
Drive
12,500 sq. ft. Community
Center w/ event space
42 Cuyamaca St Right Turn
Pocket
Approved 3/22/23 -
Not Built
Cuyamaca St &
Mission Gorge Rd
New right-turn only lane
43 Parkvue Pending Entitlement Cottonwood Ave. &
Park Center
358 residential
condominium units
44 Soapy Joe's Approved 1/18/2024
- Not Built
9015 Mission Gorge
Road
Express Car Wash
conversion
45 Interim Fire Station Pending Entitlement 9532 Via Zapador Fire Station No. 20 relocation
46 AT&T Princess Joann
Tower
Pending Entitlement North of Cuyamaca
Street and west of
Princess Joann Road
Cell tower for AT&T
47 Valvoline Instant Oil
Change
Pending Entitlement 10463 Mission Gorge
Road
Valvoline Instant Oil
Change Station
N/A Lake Jennings
Marketplace
Approved 1/24/18 –
Not Built
Olde Hwy 80 and
Lake Jennings Road
Commercial shopping
center including gas station
with car wash
6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-5
City
ID1 Project Status Address Land Use/Description
N/A Riverford Road
Roundabouts
Pending Entitlement -
The project
anticipates delivering
the Project Approval
and Environmental
Document (PA&ED)
on 1/17/25
SR 67 and Riverford
Road - unincorporated
area of San Diego
County within the
Community of
Lakeside and a
portion in the City of
Santee
Consolidate three
intersections into two
roundabouts along
Riverford Road on
either side of the SR-67
N/A Hillside Meadows To be confirmed -
County/ PDS2022-
TM-5023TE
Lakeside - north and
south of the western
terminus of Mast
Boulevard, east of the
City of Santee, and
south of El Nopal
Residential
Notes:
1 Corresponds with the City’s Active Projects Log, available on the City’s website: https://www.cityofsanteeca.gov/ documents/planning-building/active-projects/active-projects-map.pdf

6.1.1 Cumulative Impact Analysis
Consistent with State CEQA Guidelines Section 15130, the discussion of cumulative impacts in this Draft EIR focuses on significant and potentially significant cumulative impacts. Section 15130(b) of the State CEQA Guidelines provides, in part, the following:
[t]he discussion of cumulative impacts shall reflect the severity of the impacts and their likelihood of occurrence, but the discussion need not provide as great detail as is provided for the effects attributable to the project alone. The discussion should be guided by the standards of practicality and reasonableness and should focus on the cumulative impact to which the identified other projects contribute rather than the attributes of other projects which do not contribute to the cumulative impact.

A proposed project is considered to have a significant cumulative effect if:
▪ the cumulative effects of development without the project are not significant and the project’s additional impact is substantial enough, when added to the cumulative effects, to result in a significant impact, or ▪ the cumulative effects of development without the project are already significant and the project contributes measurably to the effect.

The term “measurably” is subject to interpretation. The standards used herein to determine measurability are that the impact must be noticeable to a reasonable person or must exceed an established threshold of significance (defined throughout the resource sections in Chapter 4 of this Draft EIR). This cumulative analysis also assumes that all mitigation measures identified in Chapter 4 to mitigate project impacts are adopted and implemented.

The cumulative impact analysis provided in this chapter evaluates whether the residual impacts of the Project would cause a cumulatively significant impact or would contribute considerably to existing/anticipated (without the project) cumulatively significant effects. Where the Project would so contribute, additional mitigation is recommended where feasible.
6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-6
Aesthetics
Would the Project have a substantial adverse effect on a scenic vista? The geographic area for the consideration of cumulative impacts to scenic vistas is the Project viewshed. The Project was determined to have less than significant impacts to views from the San Diego River Trail/Walker Preserve Trail and views from Sandy Drive toward Rattlesnake Mountain. The Project site and future industrial/warehouse building development would not be visible from the projects considered in the cumulative analysis. The closest project to the San Diego River Trail/Walker Preserve Trail, Project #12 (23,303 sf County Animal Shelter on Riverview Parkway), would not be visible from the San Diego River Trail/Walker Preserve Trail due to the presence of intervening vegetation, development, and terrain. While most cumulative projects would not be visible from the San Diego River/Walker Preserve Trail, the Carlton Oaks Golf Course and Parkvue project would be located adjacent to and visible from the River. Also, based on location and presence of intervening vegetation and structures, development of the cumulative projects under consideration would not result in a potentially significant impact onto views of Rattlesnake Mountain. While the Project site and all projects in the cumulative scenario would have some semblance of visibility from Rattlesnake Mountain and prominent terrain in its surrounding preserve, development at these sites would be viewed alongside existing development in the broad, urbanized landscape of the Santee.

Thus, the Project’s contribution to substantial changes to scenic vistas would not be cumulatively considerable.

Would the Project substantially damage scenic resources, including, but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway?
There is one officially designated state scenic highway partially within Santee, State Route (SR) 52 as it travels adjacent to Mission Trails Regional Park (approximately Santo Road in San Diego to Mast Boulevard in Santee). SR52 (from Mast Boulevard in Santee to SR-67 in Santee) is an eligible state scenic highway within Santee. The Project is located approximately four miles east of the designated portion of SR 52 and approximately one mile north of the eligible portion of SR 52. Based on this distance and intervening natural topography and development, the Project site is not located within the viewshed of either segment of SR 52. While there are multiple cumulative projects along the eligible portion of SR 52, these are located within areas of existing development and would not substantially impact the viewshed of this eligible segment. Thus, the Project’s contribution to substantial changes to scenic vistas would not be cumulatively considerable.

In non-urbanized areas, would the Project substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage points). If the Project is in an urbanized area, would the Project conflict with applicable zoning and other regulations governing scenic quality?
The City of Santee shares a border with the City of El Cajon, and because the two cities’ combined population exceeds 100,000 persons, the City of Santee is considered an urbanized area per CEQA, and the first question of this threshold does not apply to the Project, as it is directed at non-urbanized areas (DOF 2023).

The Project would undergo review by City Staff for a new building within the Light Industrial zone (Section 13.14.040 of the Santee Municipal Code). Further, the proposed building would be visually compatible with existing warehouse and business park structures on neighboring properties and would be consistent with the site’s existing General Plan land use designation and zoning code. Presumably, as development occurs elsewhere throughout the City, any proposal to change the development intensity to exceed maximum design standards for a specific property would be resolved through an amendment to the applicable land use plan and/or obtainment of a conditional use permit. 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-7
Any action involving an amendment would be subject to CEQA and the amendment and evaluation of consistency with scenic quality regulations would be reviewed on a case-by-case basis. Should any amendment or proposed exceedance result in a significant environmental effect to visual character and quality, mitigation measures would be identified to reduce those impacts. Based on the evaluation presented above, the project’s contribution to any conflicts with applicable zoning and other regulations governing scenic quality would not be cumulatively considerable.

Would the Project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Construction night lighting was determined to be less than significant. Night construction is not anticipated to be required as Project construction would be limited to the City’s allowable construction hours of 7:00 a.m. and 7:00 p.m. Project operational lighting is designed consistent with the requirements of Section 13.30.030(B) of the Santee Municipal Code and more specifically, exterior lighting on the Project site would result in the adequate lighting of parking areas and would cast light downward where most lighting would fall onto the site (offsite light trespass would be minimal). Further, all measurable lighting (i.e., 0.1-foot candles or greater) would generally be contained within the site boundary. Regarding glare, the majority of the exterior building surfaces would consist of painted concrete (i.e., tilt-up concrete walls) and would not generate glare.

Similar to the Project, all projects considered in the cumulative scenario would be required to adhere to the City’s allowable construction hours and with the requirements of Section 13.30.030(B) of the Santee Municipal Code.

The cumulative projects are also generally located in/near residential areas and would be required to closely adhere to City standards to ensure that nearby residential land uses are not substantially affected by new sources of lighting and glare. Regarding glare, cumulative projects would include exterior lighting and typical sources of potential glare associated with the types of development. Specifically, cumulative projects would incorporate glass in exterior or site structures and would be required to disclose (through the City’s entitlement process) specifications of building materials and evaluate the potential for building materials to result in substantial glare. The new developments in the cumulative scenario would not traditionally include reflective glass or other highly reflective building materials.

Thus, the Project’s contribution to substantial effects of light and glare would not be cumulatively considerable.

Air Quality
In analyzing cumulative air quality impacts from a project, the analysis must specifically evaluate the project’s contribution to the cumulative increase in pollutants for which the San Diego Air Basin (SDAB) is designated as nonattainment for the California Ambient Air Quality Standards (CAAQS) and National Ambient Air Quality Standards (NAAQS). If the project does not exceed thresholds and is determined to have less than significant project-specific impacts, it may still contribute to a significant cumulative impact on air quality if the emissions from the project components, in combination with the emissions from other proposed or reasonably foreseeable future projects, are in excess of established thresholds. However, a project would only be considered to have a significant cumulative impact if its contribution accounts for a significant proportion of the cumulative total emissions (i.e., it represents a “cumulatively considerable contribution” to the cumulative air quality impact).

Additionally, for the SDAB, the Regional Air Quality Strategy (RAQS) serves as the long-term regional air quality planning document for the purpose of assessing cumulative operational emissions within the basin to ensure the SDAB continues to make progress toward NAAQS and CAAQS attainment status. As such, cumulative projects located in the San Diego region would have the potential to result in a cumulative impact to air quality if, in 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-8
combination, they would conflict with or obstruct implementation of the RAQS. Similarly, individual projects that are inconsistent with the regional planning documents on which the RAQS is based would have the potential to result in cumulative impacts if they represent development beyond regional projections.

Conflict with or obstruct implementation of the applicable air quality plan? As discussed in Section 4.2.4, 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 use 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.

The SDAB has been designated as a federal nonattainment area for O3 and a state nonattainment area for O3, PM10, and PM2.5. PM10 and PM2.5 emissions associated with construction generally result in near-field impacts. The nonattainment status is the result of cumulative emissions from all sources of these air pollutants and their precursors within the SDAB. As shown in Table 4.2-9 of this EIR, the emissions of all criteria pollutants from the Project’s construction would be below the significance levels. Construction would be short term, temporary in nature, and activities would be considered typical of an industrial project. Once construction is completed, construction-related emissions would cease. Operational emissions generated by the Project would not result in emissions that exceed significance thresholds for any criteria air pollutant.

Regarding long-term cumulative operational emissions in relation to consistency with local air quality plans, the state implementation plan (SIP) and RAQS serve as the primary air quality planning documents for the state and SDAB, respectively. The SIP and RAQS rely on San Diego Association of Governments (SANDAG) growth projections based on population, vehicle trends, and land use plans developed by the cities and by the County as part of the development of their general plans. Therefore, projects that propose development that is consistent with the growth anticipated by local plans would be consistent with the SIP and RAQS and would not be considered to result in cumulatively considerable impacts from operational emissions. As shown in Table 4.2-10 of this EIR and discussed in Section 2.5.1 of Appendix B, the Project’s operational emissions would be below the significance levels. Thus, it would be consistent at a regional level with the underlying growth forecasts in the SIP and RAQS.

Therefore, the Project’s adverse effects from short-term construction emissions and long-term operational emissions would not be cumulatively considerable.

Result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is nonattainment under an applicable federal or state ambient air quality standard? As discussed previously, air pollution by nature is largely a cumulative impact. The nonattainment status of regional pollutants is a result of past and present development, and the San Diego Air Pollution Control District (SDAPCD) develops and implement plans for future attainment of ambient air quality standards. The potential for the Project to result in a cumulatively considerable impact, specifically, a cumulatively considerable new increase of any criteria pollutant for which the project region is nonattainment under an applicable NAAQS and/or CAAQS is addressed in response to Threshold 4.2.4-B (see Section 4.2, Air Quality, of this EIR). Consistent with the finding for the Project, the cumulatively considerable net increase of any criteria pollutant for which the project region is in nonattainment would be less than significant during construction and operation for cumulative impacts. Therefore, the Project’s 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-9
adverse effects related to a net increase of any criteria pollutant for which the Project region is non-attainment would not be cumulatively considerable.

Expose sensitive receptors to substantial pollutant concentrations? As discussed in response to Threshold 4.2.4-C regarding sensitive receptors, the Project would result in a less-thansignificant impact for construction-related and operational impacts. The Project would also not cause or create a carbon monoxide (CO) hotspot. The Project would not emit substantial quantities of criteria pollutant emissions or toxic air contaminants (TACs) during operation. The impact of the Project, in addition to growth within ½-mile of the Project could further increase the exposure of air quality pollutants to sensitive receptors. Most of the cumulative projects within Table 6-2 are residential or commercial, and the majority of their emissions (mobile sources) are offsite.

Emissions during construction would disperse rapidly from the project sites and generally occur at magnitudes that would not affect substantial numbers of people. Consistent with the significance finding for the Project, during construction there would be a less than significant cumulative impact related to exposure of sensitive receptors to substantial pollutant concentrations from TACs. Consistent with the significance finding for the Project, during operation there would be a less than significant cumulative impact related to exposure of sensitive receptors to substantial pollutant concentrations from TACs. Therefore, the Project’s adverse effects related to exposing sensitive receptors to substantial pollutant concentrations would not be cumulatively considerable.

Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people? As discussed in response to Threshold 4.2.4-D in Section 4.2, Air Quality, of this EIR, the Project would result in a less than significant impact regarding emissions, such as odors during construction and operation, that would adversely affect a substantial number of people. Odor impacts are generally limited to the immediate area surrounding the source. SDAPCD Rule 51 (Nuisance) also prohibits emission of any material that causes nuisance to a considerable number of persons or endangers the comfort, health, or safety of any person.

The Project would not include operations of agricultural uses, wastewater treatment plants, food processing facilities, chemical plants, composting, refineries, landfills, dairies, or fiberglass molding facilities. As such, the Project is not expected to produce any nuisance odors due to its operation. In the event the Project is required to obtain a permit from SDAPCD, SDAPCD staff would review the Project for potential odor nuisance, and conditions may be applied (or control equipment required) where necessary to prevent occurrence of public nuisance. All cumulative projects would undergo project-specific evaluation during project application process that would identify and potential emissions or odor-causing uses. Should any potentially significant impacts be identified in those project-specific evaluations, mitigation would be implemented to reduce impacts to a less-than-significant level.

Because the Project was determined to have no significant impacts regarding emissions that would adversely affecting a substantial number of people, the Project’s impacts would not be cumulatively considerable.

Biological Resources
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? As described in Section 4.3, Biological Resources, of this EIR, no direct impacts would occur to special-status plant or wildlife species with Project implementation; however, the Project could result in direct and indirect impacts to nesting birds and nesting bird habitat. Project implementation also has the potential to result in indirect impacts to 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-10
special-status wildlife species; specifically, least Bell’s vireo, yellow-breasted chat, and yellow warbler, as well as special-status plant species occurring within the San Diego River corridor. Mitigation proposed for the Project would avoid and minimize the potential for direct and indirect impacts to these resources to a less-than-significant level (See Section 4.3 of this EIR). There are approximately six projects identified by the City of Santee’s Active Projects Log that are in various stages of development (i.e., under construction, approved – not built, or pending entitlement) located adjacent to the San Diego River. Similar to the proposed Project, these cumulative projects have the potential to result in indirect impacts to special-status plant or wildlife species located within the San Diego River.

All projects, including the proposed Project, would be required to comply with applicable federal and/or state regulations that provide protections for special-status plant and wildlife species, such as FESA or CESA. In addition, projects that affect special-status species may require approval from USFWS and/or CDFW. If significant impacts occur from a particular cumulative project, it is expected that project-specific mitigation measures would be implemented to avoid or minimize impacts to the extent feasible and in compliance with applicable federal and/or state regulations.

Furthermore, the Project site is within the boundaries of the MSCP Plan (City of San Diego 1998). 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 and to ensure sufficient biological resources are conserved to assist in the conservation and recovery of Covered Species under the MSCP. Therefore, any project within the City of Santee, including the proposed Project, would be required to be consistent with the Draft Santee MSCP Subarea Plan. Because cumulative projects and the proposed Project would be required to meet or exceed MSCP requirements directed toward regional conservation, and project-specific mitigation measures would be implemented, as required, to avoid or minimize potential impacts to sensitive plant and wildlife species, all projects within the boundaries of the MSCP Plan would contribute to species recovery. Therefore, the proposed Project’s contribution to adverse effects on species within the MSCP would not be cumulatively considerable.

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? There is no riparian habitat and 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) and the Draft Santee Subarea Plan. 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, direct impacts to non-native grassland would be less than significant with Project implementation. Project implementation has the potential to result in indirect impacts to riparian habitat and sensitive vegetation communities occurring adjacent to the Project site within the San Diego River corridor; therefore, mitigation measures are proposed that would avoid and minimize the potential for indirect impacts to these resources, which would mitigate potential indirect impacts to less than significant. There are approximately six projects identified by the City of Santee’s Active Projects Log that are in various stages of development (i.e., under construction, approved – not built, or pending entitlement) located adjacent to the San Diego River. Similar to the proposed Project, these cumulative projects have the potential to result in indirect impacts to sensitive natural communities or riparian habitat located within the San Diego River. However, similar to the Project, other cumulative projects located within the MSCP would be required to meet or exceed MSCP requirements directed toward regional conservation and that project-specific mitigation measures would be implemented, as required, to avoid or minimize potential direct or indirect impacts to riparian habitat or other 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-11
sensitive natural communities to a level of less-than-significant. Therefore, the Project’s contribution to adverse effects on riparian habitat or other sensitive natural communities with implementation of the Project’s mitigation measures would not be cumulatively considerable.

Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
All projects, regardless of which local jurisdiction they occur in would be required to comply with all applicable regional or local tree preservation policies or ordinances, such as the City of Santee Urban Forestry Ordinance. The ordinance gives the City of Santee control of all trees, shrubs, and other plantings in any street, park, public rightof-way, landscape maintenance district or easement, or other City owned property. City review and approval of development plans for the proposed Project and other cumulative projects would ensure that any proposed tree removal must conform to the applicable requirements of the Urban Forestry Ordinance and/or zoning codes. The Project does not conflict with any objectives or policies as presented in the Conservation Element of the Santee General Plan. Project implementation would require removal and encroachment upon most onsite trees. Therefore, implementation of mitigation is required, which would ensure compliance with the City’s Urban Forestry Ordinance to reduce the impact to less than significant. However, similar to the Project, cumulative projects would be required to comply with all applicable regional or local policies or ordinances as a condition of project approval. Therefore, the Project’s contribution to conflicts with any local policies or ordinances protecting biological resources would not be cumulatively considerable.

Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? The Project site is within the boundaries of the MSCP Plan (City of San Diego 1998) and the Draft Santee MSCP Subarea Plan. 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, the Project site is adjacent to Preserve areas associated with the San Diego River corridor. Mitigation measures 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 (see Section 4.3 of this EIR). Similar to the Project, cumulative projects located adjacent to the San Diego River Preserve identified in the Draft Santee MSCP Subarea Plan have the potential to result in indirect impacts to special-status species, sensitive vegetation communities, and/or jurisdictional aquatic resources. Any project within the MSCP Plan Area, including the proposed Project, would be required to be consistent with the MSCP. Because all projects within the MSCP Plan Area would be required to meet or exceed MSCP requirements directed toward regional conservation, and project-specific mitigation measures would be implemented to reduce impacts to sensitive plant and wildlife species to a level of less than significant, all projects would contribute to the attainment of conservation goals identified in regional or local HCPs. Therefore, the Project’s contribution to conflicts with an adopted HCP or NCCP would not be cumulatively considerable.

Cultural Resources, Tribal Cultural Resources, and Paleontological Resources Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5? Because all significant historic resources are unique and nonrenewable members of finite classes, meaning there are a limited number of significant historical resources, all adverse effects erode a dwindling resource base. The loss of any one historical site could affect the scientific value of others in a region because these resources are 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-12
best understood in the context of the entirety of the historic system of which they are a part. All cumulative projects have or will be evaluated for any project-specific impacts related to historic resources, with mitigation implemented for any potentially significant impacts.

As discussed in Section 4.4, Cultural, Tribal Cultural, and Paleontological Resources, the former Drive-In Theatre on the site appears eligible for listing in the National Register of Historic Places and the California Register of Historical Resources and is assumed to be a historical resource under CEQA (CEQA Guidelines §15064.5(a)(3).

Implementation of the project would demolishthe existing Drive-In Theatre structures on the Project site. As explained in the Historic Assessment (Appendix F), the Former Drive-In Theatre on the Project site has been determined to embody the distinctive characteristics of a type, period, and method of drive-in movie theatre construction during the 1960s-1970s. As described in Section 4.4 of this EIR, mitigation measures MM-HIS-1 through MM-HIS--4 would partially mitigate the project’s impacts on this historic resource, though not to a less than significant level. Because the project would result in the loss of a historic resource, the project’s incremental contribution to loss of historic resources would be cumulatively considerable; therefore, the Project’s contribution to the loss of -historical resources would be a significant and unavoidable cumulative impact.

Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?
Dudek’s archaeological resources inventory included a records search and site visit that assured no known archaeological resources were present or would be adversely changed with the implementation of the Project.

However, there exists a moderate potential for the inadvertent discovery of archaeological resources during Project implementation due to the presence of archaeological resources within a one-mile radius of the Project area, a positive search of the Native American Heritage Commission’s Sacred Lands File (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), and the Project’s proximity to the bank of the San Diego River. Implementation of the Project, in combination with cumulative projects, would involve ground-disturbing activities which could result in discovery of or damage to previously undiscovered archaeological resources as defined in State CEQA Guidelines Section 15064.5. This could result in potentially significant cumulative impacts to previously undiscovered or unrecorded archaeological sites and materials. However, when considered in combination with the impacts of other projects in the cumulative scenario, the project would not be cumulatively considerable because implementation of Mitigation Measures (MM-) CUL-1 would reduce project impacts associated with accidental damage to unknown resources to a less-than-significant level. Therefore, the Project’s potential contribution to impacts related to previously undiscovered archaeological resources would not be cumulatively considerable.

Disturb any human remains, including those interred outside of dedicated cemeteries? 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. Future proposed projects within the surrounding Project area could potentially disturb human remains. With incorporation of MM-CUL-2, impacts associated with human remains would be less than significant. As such, the Project’s potential contribution to impacts related to potential to disturb human remains would not be cumulatively considerable. 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-13
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)? Dudek’s cultural resources inventory included a records search, NAHC Sacred Lands File search, and site visit with a Native American monitor, none of which identified a known tribal cultural resource within the Project area. Further, the City did not receive any notice that tribal cultural resources were within the Project area through AB 52 consultation requests. As such, Project implementation will not have an adverse change to any known tribal cultural resources. However, there is a potential that unknown (buried) tribal cultural resources may be adversely changed during Project implementation. Cumulative projects within the surrounding Project area could potentially contribute to cumulative adverse changes to tribal cultural resources. As tribal cultural resources are often found along waterways and many of the cumulative projects are near the river, there is a strong possibility that cumulative projects could affect tribal cultural resources. Implementation of MM-CUL-1 would reduce Project impacts associated with accidental damage to currently unrecorded/unknown tribal cultural resources to a level of less than significant. Therefore, the Project’s potential contribution to impacts related to unknown tribal cultural resources would not be cumulatively considerable.

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? Dudek’s cultural resources inventory included a records search, NAHC Sacred Lands File search, and site visit with a Native American monitor, none of which identified a known tribal cultural resource within the Project area. Further, the City did not receive any notice that tribal cultural resources were within the Project area through AB 52 consultation requests. As such, Project implementation will not have an adverse change to any known tribal cultural resources.

However, there is a potential that unknown (buried) tribal cultural resources may be adversely changed during Project implementation. Cumulative projects within the surrounding Project area could potentially contribute to cumulative adverse changes to tribal cultural resources. As tribal cultural resources are often found along waterways and many of the cumulative projects are near the river, there is a strong possibility that cumulative projects could affect tribal cultural resources. Implementation of MM-CUL-1 would reduce Project impacts associated with accidental damage to currently unrecorded/unknown tribal cultural resources to a level of less than significant. Therefore, the Project’s potential contribution to impacts related to unknown tribal cultural resources would not be cumulatively considerable.

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

Potential cumulative impacts to paleontological resources would result from projects that combine to create an environment where fossils, exposed on the surface, are vulnerable to destruction by earthmoving equipment, looting by the public, and natural causes such as weathering and erosion. The majority of impacts to paleontological resources are site-specific and are therefore generally mitigated on a project-by-project basis. Cumulative projects 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-14
would be required to assess impacts to paleontological resources. Additionally, as needed, projects would incorporate individual mitigation for site-specific geological units present on each individual project site.

Furthermore, the Project does not propose construction (including grading/excavation) or design features that could directly or indirectly contribute to an increase in a cumulative impact to paleontological resources, as implementation of MM-CUL-3 would ensure any significant paleontological resources uncovered during Project excavations would be properly analyzed and salvaged by the on-site paleontological monitor. Therefore, the Project, in combination with past, present, and reasonably foreseeable future projects in the Project vicinity, would result in less-than-significant cumulative impacts to paleontological resources, and no further mitigation measures are required. Moreover, it is reasonable to assume that potential impacts from implementation of cumulative projects to paleontological resources would be avoided and/or mitigated with implementation of a paleontological mitigation program during excavations into paleontologically sensitive geological units. Therefore, the Project’s potential contribution to impacts related to paleontological resources would not be cumulatively considerable.

Energy
Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during Project construction or operation? Conflict with or obstruct a state or local plan for renewable energy or energy efficiency? Cumulative projects that could exacerbate the Project’s impacts include any projects that could result in wasteful, inefficient, or unnecessary use of energy. However, the City would require cumulative projects, as applicable, to conform to current federal, state, and local energy conservation standards, including the California Energy Code Building Energy Efficiency Standards (24 CCR Part 6), the CALGreen Code (24 CCR Part 11), and SB 743.

As a result, the Project, in combination with other reasonably foreseeable projects, would not cause a wasteful use of energy or other non-renewable natural resources. Therefore, the energy demand and use associated with the Project and cumulative projects would not substantially contribute to a cumulative impact on existing or proposed energy supplies or resources and would not cause a significant cumulative impact on energy resources. Therefore, the Project’s contribution to cumulative impacts would not be cumulatively considerable.

Greenhouse Gas Emissions
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.

Global climate change is a cumulative impact; a project participates in this potential impact through its incremental contribution combined with the cumulative increase of all other sources of greenhouse gases (GHGs). As previously discussed in Section 4.6.1, Existing Conditions, GHG emissions inherently contribute to cumulative impacts, and thus, any additional GHG emissions would result in a cumulative impact. As discussed in Section 3.2.3 of Appendix B of this EIR, the Sustainable Santee Plan Project Consistency Checklist (Checklist) is the tool for development projects to demonstrate consistency with the City of Santee’s (City’s) Sustainable Santee Plan, which is a qualified 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 Plan implementation and monitoring process and will support the achievement of individual GHG reduction measures as well as the City’s overall GHG 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-15
reduction goals. As shown in Table 20 of Appendix B to this EIR, the Project is consistent with the Sustainable Santee Plan Checklist adopted by the City to ensure that the emission targets identified in the Sustainable Santee Plan are achieved. The Sustainable Santee 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. Therefore, the Project’s contribution to cumulative generation of GHG emissions would not be cumulatively considerable.

Hazards and Hazardous Materials
Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.

Cumulative impacts related to hazards and hazardous materials would result from projects that combine to increase exposure to hazards and hazardous materials. As discussed in Section 4.7, Hazards and Hazardous Materials, the proposed Project would have a less-than-significant impact related to hazardous materials. Past, current, and reasonably foreseeable commercial projects in the region would result in the use and transport of incrementally more oils, greases, and petroleum products for operation purposes. Similar to the Project, cumulative projects would be required to adhere to current laws governing storage, transportation, and handling of hazardous materials.

Therefore, the Project’s potential contribution to impacts related to hazards associated with routine transport, use, or disposal of hazardous materials would not be cumulatively considerable.

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.

As discussed in Section 4.7, Hazards and Hazardous Materials, 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 managed in accordance with all federal, state, and local laws regulating the management and use. The Project and any other projects that could involve transport or handling of hazardous substances would involve mandatory compliance with these regulatory requirements to minimize the potential for public safety risks associated with exposure to hazards and hazardous materials. Therefore, the Project’s potential contribution to impacts related to reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment would not be cumulatively considerable.

Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within onequarter mile of an existing or proposed school.

As discussed in Section 4.7, Hazards and Hazardous Materials, Hill Creek Elementary School is located approximately 0.25 miles north of the Project site. As discussed above, the Project would result in less-thansignificant impacts related to hazards and hazardous materials because the Project would be required to comply with all applicable federal, state, and local laws regulating the management and use of hazardous materials. Other projects would also be required to follow regulations to properly handle any hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. Therefore, impacts of emission or handling of hazardous materials within one-quarter mile of an existing or proposed school would be less than significant under the cumulative condition. Therefore, the Project’s potential contribution to impacts related to emissions or handling of 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-16
hazardous materials within one-quarter mile of an existing or proposed school would not be cumulatively considerable.

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.

As discussed in Section 4.7, Hazards and Hazardous Materials, the RWQCB’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. 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).

The sites above are facilities located near the Project site that are included in government databases related to hazardous materials; however, these facilities are closed cases and would not have adverse impacts on the Project or any future projects. The Project site is not located on or near a listed hazardous material site. Each cumulative project has been or will be evaluated for proximity to listed sites during project processing. The Project’s potential contribution to impacts related to significant hazards to the public or the environment from a hazardous material site would not be cumulatively considerable.

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.

The nearest airport to the Project site is the Gillespie Field Airport, which is located approximately 1.5 miles southwest of the Project site. Additionally, 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. 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 2023). The applicant has agreed to these conditions. Other projects in the vicinity are required to follow the same FAA regulations; therefore, the Project’s potential contribution to impacts related to airspace safety hazards or conflicts would not be cumulatively considerable.

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

The Project site would be designed such that adequate emergency access would be provided in accordance with emergency apparatus access requirements. Additionally, all projects in Santee, including the proposed Project, would be required to avoid conflict with the City’s Emergency Preparedness Plan and potential emergency evacuation routes in the area. Compliance with applicable Fire and Building Codes, project specific needs assessments, and Fire Protection Technical Report requirements ensures that every project approved for construction includes adequate emergency access. Roads for all proposed projects are required to meet minimum widths, have all-weather surfaces, and be capable of supporting the imposed loads of responding emergency apparatus. The Project and all other future development projects in the service area are subject to review by the City’s fire department and would be required to comply with the County Fire Code, other relevant County Code 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-17
requirements, and other applicable local codes (e.g., City of Santee Municipal Code) and regulations related to fire safety, building construction, access, fire flow, and fuel modification. Therefore, the Project’s potential contribution to impacts related to impairment of an adopted emergency response plan would not be cumulatively considerable.

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, Hazards and Hazardous Materials, 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. Adherence to City and state regulatory standards during Project construction would reduce the risk of wildfire ignition and spread during construction activities. During operation, the Project would adhere to the City’s Municipal Code and the CFC to have and maintain fire protection and life safety systems (CFC Chapter 9).

Thus, the Project’s short-term construction impacts and 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 Cumulative projects would also be required to implement similar fire safety features and structure protection features to reduce wildfire-related impacts. Therefore, through compliance with existing regulations associated with wildland fires, impacts associated with wildfire would not be cumulatively considerable. Thus, the proposed project would not result in a cumulatively considerable impact to hazards and hazardous materials. Therefore, the Project’s potential contribution to impacts related to wildfire risks would not be cumulatively considerable.

Hydrology and Water Quality
Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality.

The geographic area under consideration for the topic of water quality includes the watershed of the San Diego River (see Figure 4.8-1, San Diego River Watershed). During construction activities, the Project site and cumulative projects would use hazardous materials (e.g., fuel, oil, paint) and an accidental spill of hazardous materials could result in inadvertent releases to surface waters, which could adversely affect surface or groundwater quality. In addition, construction would have the potential to result in local soil erosion during excavation, grading, trenching, and soil stockpiling. Erosion could result in sediment and other pollutants entering surface water bodies and adversely affecting water quality. However, the Project and similar cumulative projects would be required to comply with the Small MS4 Permit and NPDES Construction General Permit and associated SWPPP, designed to prevent impacts to water quality during construction. While it is possible that the Project and cumulative projects that contribute flows to the San Diego River could result in releases of sediment and/or pollutants that could adversely affect water quality, the responsible parties associated with the Project and the other cumulative projects would be required to control runoff and respond to spills to the established regulatory standards from the City of Santee, as discussed in Section 4.8, Hydrology and Water Quality, and in Section 4.7, Hazards and Hazardous Materials, of this Draft EIR. Compliance with water quality regulations would ensure that the cumulative construction impacts would not be considerable.

Once constructed, the stormwater design of the Project and the cumulative projects would incorporate the stormwater management requirements of Chapter 4 and Appendix E of the County of San Diego BMP Design Manual for Permanent Site Design, Stormwater Treatment, and Hydromodification Management (San Diego County BMP Design Manual, County of San Diego Public Works 2020). In addition, Project and cumulative project operations would comply with the City of Santee Guidelines for Surface Water Pollution Prevention, the City’s Storm Water Management and Discharge Control Ordinance, and the Small MS4 Permit. As a result, the Project and 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-18
cumulative projects would be required to incorporate on-site runoff management infrastructure, water quality BMPs, and adequate connections to the existing stormwater drainage system. Compliance with the San Diego County BMP Design Manual and implementation of City stormwater management measures would ensure that the cumulative operations impacts would not be considerable.

Thus, the Project’s potential contribution to impacts related to water quality would not be cumulatively considerable.

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

The geographic area under consideration for the topic of groundwater recharge includes the San Diego River Valley Groundwater Basin. 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. Cumulative project development could result in an increase in impervious surfaces and associated decrease in infiltration of rainfall, thus resulting in a minor decrease in groundwater recharge.

However, 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 2023). 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. Based on the limited impacts to local groundwater supplies, the cumulative groundwater recharge impacts would not be considerable.

The geographic area under consideration for the topic of groundwater supply includes the Santee Groundwater Basin. Domestic water service to the Project site and cumulative sites is provided by the Padre Dam Municipal Water District (PDMWD), which primarily relies on imported surface water from the San Diego County Water Authority. The PDMWD’s water supplies 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 and cumulative projects would not cause or contribute to a cumulatively significant impact related to groundwater supplies.

Thus, the Project’s potential contribution to impacts related to groundwater would not be cumulatively considerable.

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.

The geographic area under consideration for the topic of drainage includes the watershed of the San Diego River (see Figure 4.8-1, San Diego River Watershed). The stormwater design of the Project and the cumulative projects would incorporate the stormwater management requirements of Chapter 4 and Appendix E of the County of San Diego BMP Design Manual for Permanent Site Design, Stormwater Treatment, and Hydromodification Management (San Diego County BMP Design Manual, County of San Diego Public Works 2020). As a result, the Project and cumulative projects would be required to incorporate on-site runoff management infrastructure, water quality BMPs, 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-19
and adequate connections to the existing stormwater drainage system, thus minimizing impacts related to stormwater runoff. Thus, the Project’s potential contribution to impacts related to alteration of existing drainage pattern would not be cumulatively considerable.

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

The geographic area under consideration for the topic of flooding includes the watershed of the San Diego River (see Figure 4.8-1, San Diego River Watershed). 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 (FEMA 2024). During processing of the project applications, each cumulative project would be reviewed to determine whether or not it is located within a FEMA 100-year floodplain.

Should any of the cumulative projects be located within the floodplain, it would likely need to be revised or have mitigation imposed to reduce potential impacts related to pollutant risk during flooding. Neither the Project nor the cumulative projects are within a tsunami or seiche zone. As a result, cumulative project development would not risk release of pollutants due to project inundation and the Project’s potential contribution to impacts related to flooding would not be cumulatively considerable.

Land Use and Planning
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.

The proposed Project would be consistent with the site’s existing General Plan land use designation and zoning code. Presumably, as development occurs elsewhere throughout the City and the larger San Diego County area, any proposal to change the underlying land use or development intensity for a specific property would be resolved through an amendment to the applicable land use plan. Given that amendments to land use plans are discretionary in nature, any action involving an amendment would be subject to CEQA and reviewed on a case-by-case basis.

Should any amendment result in a significant environmental effect, mitigation measures would be identified to reduce those impacts. Given these factors, the Project would not result in any cumulatively considerable land use and planning conflicts in the context of compliance with applicable environmental plans, policies, and regulations beyond those identified in other sections of this EIR. Thus, the Project’s potential contribution to impacts related to land use and planning conflicts would not be cumulatively considerable.

Noise
Future development within the City, including the Project, would affect the future (cumulative) ambient noise environment. While it is difficult to precisely predict how the ambient noise conditions within the area would change, it is expected that traffic noise levels would increase due to the additional traffic generated by the Project and other development in the City. In the cumulative scenario, ongoing development in the City would be expected to increase the ambient noise environment in the area as a result of increased traffic volumes, increased residential population and commercial activities.

The primary factor for the cumulative noise impact analysis is the consideration of future traffic volumes.

Non-transportation noise sources (e.g., Project operation) and construction noise impacts are typically Projectspecific and highly localized. Construction activities associated with anticipated development within the area would contribute temporarily to the noise levels in the cumulative ambient noise environment, but in a highly localized 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-20
and transient manner. As other development occurs in the area, noise from different types of uses (e.g., traffic, aircraft, fixed noise sources) would continue to combine, albeit on a localized basis, to cause increases in overall background noise conditions within the area. As a result, such sources do not significantly contribute to cumulative noise impacts at distant locations and are not evaluated on a cumulative level.

This section provides an analysis of cumulative impacts from construction and operation of the Project and other past, present, and reasonably foreseeable future projects, as required by Section 15130 of the State CEQA Guidelines.

Noise in Excess of Standards
Implementation of the Project as well as cumulative development Projects within its vicinity would all be subject to applicable noise standards (descriptions of the standards applicable within the City of Santee are described in Section 4.10, Noise, of this EIR). On this basis, and because noise impacts of the Project with respect to relevant standards would be less than significant, the Project would not contribute to cumulative exceedances of noise standards, and its incremental effect would be a less-than-significant impact.

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.

Temporary/Periodic Increases in Ambient Noise Levels
As discussed in Section 4.10, Noise, the Project would result in temporary noise increases during on- and off-site (e.g., sidewalks and roadway striping) construction activities; however, short-term construction noise of the Project is predicted to be well below the Federal Transit Administration (FTA) guidance of 80 dBA Leq over an 8-hour period, and therefore is less than significant. The construction period of the Project has the potential to overlap with the construction of other development projects in the City. Due to the decrease in noise levels with distance and the presence of physical barriers (i.e., intervening buildings and topography), noise due to construction of other projects would not meaningfully combine with future development under the Project to produce a cumulative noise effect during construction. By way of illustration, if there are two concurrent construction projects of comparable sound emission intensity, and the activity nearest to the studied noise-sensitive receptor is compliant with the City’s applicable noise threshold, the other activity could be no closer than three times the distance of the receptor to the nearest activity and not make a cumulatively measurable contribution to the total and still result in a City-compliant noise exposure level. If two concurrent Projects were close to a receptor, the cumulative noise would be one of the following:
▪ the louder (in dBA) of the two concurrent activities; or, ▪ a logarithmic sum of the two activity noise levels that, per acoustic principles, cannot be more than 3 dBA greater than the louder of the two individual noise-producing activities.

In sum, cumulative construction noise is likely to be dominated by the closest or loudest activity to the receptor, and the combination will be no more than a barely perceptible difference (i.e., up to a 3 dBA change). Based on the cumulative project list, there are no construction projects that would potentially contribute construction noise that would, in combination with the Project, result in cumulative impacts. Thus, cumulative impacts associated with temporary increases in ambient noise levels would be considered less than significant. 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-21
Permanent Increase in Ambient Noise Levels
Off-Site Traffic
As discussed in Section 4.10, Noise, the nearest noise-sensitive receptors to the south of the Project site are already dominated by much higher levels of traffic noise from nearby adjacent roadways such as SR-67, while noisesensitive receptors to the north of the Project site 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 (see Table 4.10-7 in Section 4.10) and with respect to project-generated changes to future traffic noise would be less than significant. Future development from implementation of the Project along with other cumulative projects would generate off-site traffic noise. When calculating future traffic impacts, the traffic study included traffic attributed to both the Project and cumulative projects. Thus, future traffic noise prediction results with and without the Project already account for the cumulative impacts from cumulative projects contributing to traffic increases. Since the noise impacts are generated directly from the traffic analysis results, the existing traffic with and without Project predicted increases in traffic noise levels described already reflect cumulative impacts (see the Noise Technical Report, included as Appendix K to this Draft EIR. As described herein, the noise level increases associated with both of these scenarios would not exceed applicable standards. As such, anticipated increases would be below the significance thresholds; hence, the incremental effect of the Project on off-site traffic noise is not cumulatively considerable.

Stationary Sources
As discussed in Section 4.10, Noise, of this EIR, noise from operation of stationary mechanical equipment added to the outdoor ambient sound environment as a result of Project implementation would include permanent on-site noise sources (e.g., rooftop HVAC equipment and exhaust ports). A cumulative impact could occur if noise produced from such sources due to implementation of the Project were to combine with noise produced from the operation of other cumulative projects in the vicinity to create a cumulatively significant permanent increase in ambient noise levels. However, noise emission from HVAC equipment and exhaust attenuates with distance and can be occluded by structures and terrain. Additionally, the operation of the Project, along with the operation of other cumulative projects, would be subject to applicable requirements from the City’s noise ordinance, which limits the exterior noise levels at residences. Hence, for these two reasons, cumulative impacts to outdoor ambient noise levels resulting from Project stationary sources would be less than significant.

Thus, the Project’s potential contribution to impacts related to temporary or permanent increases in ambient noise levels would not be cumulatively considerable.

Result in generation of excessive groundborne vibration or groundborne noise levels.

Ground-borne vibration attenuates very rapidly with distance. For example, at 25 feet from an operating heavy dozer the reported vibration level is 0.089 ips PPV; at a distance of 50 feet the vibration level would be 0.03 inch per second (ips) peak particle velocity (PPV); at 200 feet the vibration level would be 0.004 ips PPV. No portion of the Project construction limits would be closer than approximately 0.6 miles from any of the cumulative Projects. With a Project construction-related vibration contribution of no greater than 0.004 ips PPV added to construction vibration levels occurring at the nearest cumulative Project sites, there would be a less than significant impact.

Thus, the Project’s potential contribution to impacts related to generation of excessive ground-borne vibration or ground-borne noise levels would not be cumulatively considerable. 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-22
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.

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 southwest of the Project boundary. Several nearby Projects in the cumulative project list (Table 6-2 above) are also located within 2 miles of a public airport; however, operations from the public airport do not affect the noise exposure for the Project. Therefore, noise associated with aircraft overflights for any of the cumulative projects would be less than significant, and the Project’s contribution would not be cumulatively considerable.

Public Services and Recreation
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 fire protection and police services.

As described in Section 4.11, Public Services and Recreation, of this EIR, the Project would result in no impact related to adverse physical impacts or performance objectives associated with schools, parks, or other facilities (e.g., libraries, etc). Therefore, the Project would not contribute to cumulative impacts to these services and is not discussed further.

As discussed in Section 4.11, the Project would potentially result in a slight, incremental increase in calls to the fire and/or police department for service to the Project site in comparison to the existing conditions; however, the increase is expected to be nominal and would not result in the need for the construction of new facilities.

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 fire and police services. Thus, the Project’s impact on fire and police services is considered less than significant. Cumulative growth within the City could result in a need for additional fire and police protection services to serve new development. It is expected that cumulative projects would also be required to pay a fair share of development impact fees to the City prior to the issuance of building permits. These fees would help offset incremental impacts to resources and facilities by helping to fund capital projects, as needed. When staff and facilities are expanded to serve future development in the Project area and surrounding cities, any physical expansion or alteration of facilities would be subject to environmental review. Therefore, the Project’s contribution to any such impacts would not be cumulatively considerable.

Transportation
Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.

As described under cumulative discussion for Land Use and Planning above, the proposed Project would be consistent with the site’s existing General Plan land use designation and zoning code, The Project’s Transportation Impact Study (TIS) evaluated cumulative projects in the area to analyze a Near Term Cumulative and also analyzed a Horizon Year consistent with City’s General Plan Mobility Element and demonstrated consistency with City’s General Plan goals and policies. The roadway and intersection improvements for cumulative conditions have been 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-23
outlined in the project’s TIS (Appendix L of this EIR) to improve vehicular, bike and pedestrian mobility conditions in the study area outlined for the Project. Similarly, all cumulative projects would be evaluated to provide improvements for the circulation system and be required to demonstrate consistency with the General Plan’s adopted policies, plans, or programs regarding circulation, active transportation, or public transit facilities.

Therefore, the Project’s contribution to impacts related to a program, plan, ordinance, or policy related to addressing the circulation system would not be cumulatively considerable.

Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b).

If a project is consistent with the assumptions in the SANDAG 2021 Regional Plan, the existing conditions projectlevel analysis is sufficient to determine cumulative impacts. If a project is not consistent with the assumptions in the SANDAG 2021 Regional Plan, a cumulative analysis may be necessary. A project effect on vehicle miles travelled (VMT) under cumulative conditions would be considered significant if the cumulative VMT/capita or VMT/employee under the future year “plus project” condition exceeds the base year thresholds (i.e., 18.9).

The project is consistent with the General Plan land use designation and zoning for the project site and would provide employment as proposed in the traffic analysis zone. The VMT/employee under Year 2035 or cumulative conditions is 20.1, which exceeds the existing threshold of 18.9 VMT per employee. Therefore, it can be concluded that the project would also result in a significant cumulative impact. MM-TRA-1 Trip Reduction Program, would be implemented by the project’s tenants to reduce the project’s VMT. Because the Project’s VMT would not be reduced to below significance threshold even with the implementation of MM-TRA-1, the Project’s incremental contribution to VMT impact would be cumulatively considerable; therefore, the Project’s contribution to VMT impacts would be a significant and unavoidable cumulative impact.

Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).

Cumulative projects would be required to comply with all applicable local provisions related to roadway design hazards, and access driveways would be constructed in accordance with City’s manual on Design Standards and Standard Drawings (April 2014). As shown in Section 4.12, the project access at Woodside Avenue and N. Woodside Avenue/S. Woodside Avenue - SR-67 SB Off-Ramp intersection has been evaluated for Near Term and Horizon Year without and with Project conditions which includes traffic generated by cumulative projects in the area and recommendations for improvement to lane geometry and bike and pedestrian facilities. The proposed improvements at the project access and implementation of Project Design Feature PDF-TRA-1 Multi-modal Intersection Improvements at the N. Woodside Avenue/S. Woodside Avenue - SR-67 SB Off-Ramp intersection would reduce hazards due to geometric design features in cumulative conditions. Therefore, the Project would not increase hazards due to geometric design features or incompatible use under cumulative conditions and would not be cumulatively considerable.

Result in inadequate emergency access.

Adequate emergency access and compliance with emergency access and design standards would be ensured by the City and responsible emergency service agencies for all cumulative projects in the vicinity of the project. Similar to the Project’s access driveway intersection, access to cumulative projects would be designed in accordance with City standards, reviewed by City’s Fire Department and San Diego County Sheriff, and would be accessible to emergency responders during construction and operation of each cumulative project. Therefore, impacts related to 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-24
inadequate emergency access would be less than significant under cumulative conditions and would not be cumulatively considerable.

Utilities and Service Systems
Require or result in the relocation or construction of new or expanded water, wastewater treatment, or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects.

As discussed in Section 4.13, Utilities and Public Services, existing utility service lines are located within the vicinity of the Project site and would be reconfigured from their current locations on and nearby the Project site to the proposed building. This also includes a new 8-inch line for wastewater to connect to existing lines nearby the project site. However, the Project would not require the construction, expansion, or relocation of facilities beyond the reconfiguration of hookup to the onsite proposed building because existing facilities are in-place and adequately sized to accommodate the Project. Therefore, no adverse physical effects beyond those already disclosed in this Draft EIR would occur as a result of implementation of the Project’s proposed utility system connections, and the impact is considered less than significant. Similar to the project, cumulative projects would be required to comply with local and State requirements associated with utility infrastructure, which would reduce any potential environmental effects to less-than-significant levels. Therefore, the Project’s contribution to potential environmental effects associated with infrastructure construction or relocation of cumulative projects would not be cumulatively considerable.

Have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry, and multiple dry years.

As discussed in Section 4.13, Utilities and Public Services, implementation of the Project would result in the construction of an industrial warehouse with associated office spaces, surface parking, and loading areas.

According to CalEEMod (Appendix B of this Draft EIR), the proposed Project is estimated to result in an increase in potable water demand of 97,145 gallons per day (gpd), which is equivalent to approximately 108.8 acrefeet per year (AFY). As provided in Table 4.13-1 of this EIR, sufficient water supply is anticipated to meet current and projected water demands through 2045 during normal-, historic single-dry-, and historic multiple-dry-year periods. Given that PDMWD has adequate existing supplies to serve the Project under normal-, historic single-dry-, and historic multiple-dry-year periods, the Project’s impact to water supply would be less than significant. Similar to the Project, cumulative projects would also be required to demonstrate sufficient water supplies are available to serve each project. As such, the Project’s contribution to cumulative impacts related to water supply would not be cumulatively considerable.

As discussed in Section 4.13, Utilities and Public Services, wastewater generated by the Project would be treated at either the WRF or the PLF and projected wastewater from the Project (0.097 mgd) would represent approximately

0.15% of the remaining capacity of the WRF and PLF treatment facilities. Therefore, impacts associated with wastewater treatment capacity would be less than significant. Similar to the Project, cumulative projects would be required to demonstrate whether these wastewater providers would have adequate capacity to meet projected demand of the project in order to serve each cumulative project. As such, the Project’s contribution to cumulative impacts related to wastewater treatment capacity would not be cumulatively considerable. 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-25
Generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.

As discussed in Section 4.13, Utilities and Public Services, the Project’s total estimated demolition debris to be hauled offsite would be approximately 257.3 tons of demolition waste per day of construction activity and the Project’s total building construction waste would generate approximately 1.13 tons per day during construction activities. The Sycamore Landfill accepts inert solid waste, has a daily maximum permitted throughput of 5,000 tons/day, has a remaining capacity of 113,972,637 cubic yards, and is expected to remain open for another 18 years (CalRecycle 2019). Therefore, the Project’s daily peak demolition and construction waste delivery of 258.4 tons could be received by the Sycamore Landfill. Thus, Project demolition and construction would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.

Once operational, the Project would produce solid waste on a regular basis associated with operation and maintenance activities. Using CalEEMod waste generation factors for the Industrial Park and Warehouse uses, the Project would generate approximately 141 tons of solid waste per year, or 0.4 tons per day, and a minimum of 50% of all solid waste would be required to be recycled pursuant to AB 939, consistent with the State’s solid waste reduction goals; therefore, the Project would generate approximately 0.2 tons per day of solid waste requiring disposal at a landfill. The increase of waste generated by the Project during operations would represent approximately 0.004% of the total daily capacity permitted at the landfill and is expected to remain open for another 18 years. Once the Sycamore Landfill reaches capacity, additional landfills and strategies would be identified, so that disposal needs continue to be met. Further, there are landfills within the County with up to 35 years of remaining life. For example, the Las Pulgas Landfill is expected to remain open another 35 years (CalRecycle 2023).

As such, in the event of the closure of the Sycamore Landfill, other landfills in the region would be able to accommodate solid waste from the Project, and regional planning efforts would ensure continued landfill capacity in the foreseeable future. Therefore, the Project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.

Similar to the Project, cumulative projects would be required to comply with State and local standards regarding construction and operational waste and would be required to demonstrate whether nearby landfills have adequate capacity to meet projected demand. As such, the Project’s contribution to cumulative impacts related to solid waste generation would not be cumulatively considerable.

Comply with federal, state, and local management and reduction statutes and regulations related to solid waste.

As described above, solid waste from the Project would be transported to the Sycamore Landfill. This facility is regulated under federal, state, and local laws. Additionally, the City of Santee is required to comply with the solid waste reduction and diversion requirements set forth in AB 939, AB 341, AB 1327, and AB 1826. Per AB 341, businesses that generate 4 cubic yards or more of organic waste per week are required to arrange for organic waste recycling services. In addition, waste diversion and reduction during Project construction and operations would be completed in accordance with CALGreen standards and City diversion standards. As a result, the Project would comply with federal, state, and local management and reduction statutes and regulations related to solid waste and impacts would be considered less than significant. Similar to the Project, cumulative projects would be required to comply with federal, state, and local management and reduction statutes and regulations related to solid waste. As such, the Project’s contribution to cumulative impacts related to solid waste would not be cumulatively considerable. 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-26
Wildfire
Substantially impair an adopted emergency response plan or emergency evacuation plan.

The Project site would be designed such that adequate emergency access would be provided in accordance with emergency apparatus access requirements. Additionally, all related projects would be required to avoid conflict with the County Hazard Mitigation Plan and County Emergency Operations Plan and potential emergency evacuation routes in the area. Similar to the Project, compliance with the applicable Fire and Building Codes, along with Project specific needs assessments and Fire Protection Technical Report requirements, ensure that every project approved for construction includes adequate emergency access. Roads for all proposed projects are required to meet minimum widths, have all-weather surfaces, and be capable of supporting the imposed loads of responding emergency apparatus. The Project and all other future development projects in the service area would be subject to review by the Santee Fire Department and would be required to comply with all applicable State and County Building and Fire Code requirements and other applicable local codes (e.g., City of Santee Municipal Code) and regulations related to fire safety, building construction, access, fire flow, and fuel modification. Therefore, the Project’s contribution to cumulative impacts related to impairment of an adopted emergency response or evacuation plan would not be cumulatively considerable.

Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose Project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire.

The cumulative context considered for wildfire impacts is San Diego County, and more specifically, the San Diego River watershed, which encompasses 434 square miles (Appendix G). As discussed in Section 4.14, Wildfire, CAL FIRE has mapped areas of fire hazards in the state based on fuels, terrain, weather, and other relevant factors. The Project site is not within a Very High Fire Hazard Severity Zones (VHFHSZ), but there is a VHFHSZ within a Local Responsibility Area (LRA) located directly adjacent to the Project site to the north and east (CAL FIRE 2023). The Project site is fully developed and the surrounding area does not contain slopes typical of exacerbating wildfire risk.Once redeveloped with the proposed Project, the Project site would not result in steep slopes typical of exacerbating wildfire risk. It is also not anticipated that the Project and associated landscaping proposed would exacerbate wildfire risk due to prevailing winds. As such, Project impacts would be less than significant. The Project, combined with other projects in the region, would increase the population and/or activities and potential ignition sources in the area, which may increase the potential of a wildfire and increase the number of people and structures exposed to risk of loss, injury, or death from wildfires. However, all future projects would be required to comply with applicable fire and building codes, which have been increasingly strengthened as a result of severe wildfires that have occurred in the last two decades. The fire and building codes include fire prevention and protection features that reduce the likelihood of a fire igniting on a site and spreading to off-site vegetated areas. Therefore, the Project’s contribution to impacts related to slope, prevailing wind, or other factors contributing to exacerbating wildfire risk and exposing project occupants would not be cumulatively considerable.

The Project would include reconfiguration of existing service utilities, including two new Fire department connections, one in the southeast and one in the northwest corner of the building. As the reconfiguration and upgrades would be on the Project site, the Project would not result in off-site impacts. The Project and all other future development projects in the service area would be subject to review by the fire department and would be required to comply with 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-27
the County Fire Code and other relevant County Code requirements and other applicable local codes (e.g., City of Santee Municipal Code) and regulations related to fire safety, building construction, access, fire flow, and fuel modification. Therefore, the Project’s contribution to impacts related to maintenance or installation of associated infrastructure on fire risk would not be cumulatively considerable.

Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes The Project site has been designed to match the existing contours along the San Diego River as to not impact the existing floodplain. Future drainage conditions would be very similar to existing drainage conditions. Adequate stormwater conveyance would be maintained and runoff rates would be decreased by capturing stormwater in proposed on-site storm drains and water quality basins. The Project area is relatively flat, and it is not anticipated that cumulative projects would combine to result in significant wildfire impacts related to slope, prevailing winds, downstream flooding or landslide, slope instability, or drainage changes. Additionally, as mentioned in Hydrology and Water Quality above, each cumulative project would be reviewed to determine whether or not it is located within a FEMA 100-year floodplain. The Project site is not within the FEMA floodplain (FEMA 2024). Therefore, the Project contributions to impacts related to exposing people or structures to significant risks as a result of runoff, post fire instability, or drainage changes would not be cumulatively considerable,

6.2 Growth-Inducing Impacts
As stated in Section 15126.2(e) of the California Environmental Quality Act (CEQA) Guidelines, an EIR is required to include a discussion of a project’s growth-inducing effects. The CEQA Guidelines generally describe such effects as follows: (1) fosters economic growth, population growth, or construction of additional housing in the surrounding environment; (2) removes obstacles to population growth (e.g., a major expansion of a wastewater treatment facility that allows for more construction in the service area); (3) increases in population that tax existing services requiring construction of new facilities that could cause significant environmental effects; and (4) encourages and facilitates other activities that could significantly affect the environment, either individually or cumulatively.

The proposed Palisade Santee Commerce Center Project would require a temporary construction workforce and a permanent operational workforce, both of which could potentially induce population growth in the Project area. The temporary workforce would be needed to construct the one industrial/warehouse building and associated improvements. The number of construction workers needed during any given period would largely depend on the specific stage of construction but would likely range from a dozen to several dozen workers on a daily basis.

Because the future tenants are not known yet, the number of jobs that the Project would generate cannot be precisely determined. Thus, for purposes of analyses, employment estimates were based on Institute of Transportation Engineers trip generation data and industry standards for number of employees per 2,000 sf of warehouse area (London Moeder Advisors 2023). The Project would include 300,145 square feet of industrial/warehouse space. Permanent employment at the completed commerce center is expected to generate 185 direct new jobs (London Moeder Advisors 2023).

According to the City of Santee, as of 2020, the population of the City of Santee (City) was approximately 58,000 residents (City of Santee 2023). The San Diego Association of Government (SANDAG) anticipates the City will grow to more than approximately 63,812 residents by the year of 2035 (City of Santee 2022). As such, the Projectrelated increase of 185 permanent direct employees would represent a nominal percentage of the City’s projected future population upon General Plan buildout. As such, the Project’s permanent employment requirements could 6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-28
likely be met by the City’s existing labor force without people needing to relocate into the Project region, and the Project would not stimulate population growth or a population concentration above what is assumed in local and regional land use plans.

Projects that physically remove obstacles to growth, or projects that indirectly induce growth, are those that may provide a catalyst for future unrelated development in the area. The Project would involve removing and replacing an existing segment of 12-inch diameter water main with a new, 16-inch water main at the Project site. The purpose of the larger water main onsite is solely to serve the needs of the Project, and not to provide capacity for future projects or growth. In addition, since the surrounding Project area is already served by existing wet and dry utilities, the Project would not expand sanitary sewer or stormwater drainage infrastructure into areas not previously served by such utilities.

Further, given that the surrounding Project area is already served by existing wet and dry utilities, it is unlikely that the Project would tax existing community service facilities or require construction or expansion of new regionalscale facilities with capacity to serve more than just the Project. Although roadway improvements are planned as part of the Project, the construction of these roadways is necessary to provide for adequate circulation in the Project area; thus, the Project would not result in indirect population growth by providing vehicular access to an area presently lacking such access.

Based on the proximity of the Project site to existing facilities, the average response times in the Project area, the ability for nearby cities to respond to emergency calls, and the fact that the Project site is already located within the Santee Fire Department and Santee Sheriff’s Department service areas, the Project would be adequately served by public services without the construction of new, or the expansion of existing, facilities. Although the Project could potentially result in an incremental increase in calls for service to the Project site compared to existing conditions, this increase is expected to be nominal (as opposed to new residential or commercial/retail land uses, which result in greater calls for service) and would not result in the need for new or expanded fire or police facilities. Lastly, since the Project would not directly or indirectly induce unplanned population growth in the City, it is not anticipated that many people would relocate to the City as a result of the Project, and an increase in school-age children requiring public education is not expected to occur as a result. Thus, the need for new or expanded school facilities is not required.

In conclusion, the Project could cause population growth through new job opportunities. However, this growth falls well within City and regional growth projections for population and housing. The Project would not remove obstacles to population growth and would not cause an increase in population such that new community facilities or infrastructure would be required outside of the Project site. Lastly, the Project is not expected to encourage or facilitate other activities that could significantly affect the environment, as explained above. For these reasons, the Project is not considered to be significantly growth inducing.

6.3 Significant Irreversible Changes
The CEQA Guidelines require that an EIR address any significant irreversible changes that would be caused by implementation of a project. According to CEQA Guidelines Section 15126.2(d), such a change would involve one or more of the scenarios discussed below;
6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-29

6.3.1 Change in Land Use that Commits Future Generations to Similar Uses
According to the City’s General Plan and the City’s Zoning Map, the land use and zoning designations for the Project site are Light Industrial (IL) (City of Santee 2003, 2017). The proposed Project would be consistent with Chapter

13.14.020 of the City’s Municipal Code, which states that this land use designation is “intended primarily for light industrial uses such as manufacturing, assembly, research and development and similar industrial uses, as well as limited commercial and office uses which are compatible and appropriate in this district”. The zoning is consistent with the Light Industrial land use designation of the General Plan (City of Santee 2003). As such, although construction of the Project would develop a total of 300,145 square feet of industrial/warehouse space on the Project site, the City already committed the site to industrial/warehouse (and similar) uses when the City designated and zoned the site as Light Industrial (LI) (City of Santee 2003, 2017).

Land uses surrounding the Project site primarily consist of light industrial uses, along with some scattered commercial, residential, and utility uses. General Industrial/Residential land use and zoning designations are located within approximately .5 miles of the Project site, with General Industrial located on the northern side of the Project site and Residential on the southern side of the site. Since the Project site is located within an existing urbanized area, including adjacent to other industrial uses, the Project would not result in land use changes that would commit future generations to uses that do not occur in the Project area. Thus, implementation would not commit future generations to new uses, given that this proposed use is already found in the project area.

6.3.2 Irreversible Damage from Environmental Accidents
Potential environmental accidents of concern include those events that would adversely affect the environment or public due to the type of quantity of materials released and the receptors exposed to that release. Construction activities associated with the Project would involve some risk of environmental accidents. However, these activities would be conducted in accordance with all applicable federal, state, and local regulations, and would follow professional industry standards for safety. Once operational, any materials associated with environmental accidents would comply with applicable federal, state, and local regulations. Use of any such materials would not be expected to cause irreversible damage due to the type or quantity of materials released and the receptors exposed to that release.

6.3.3 Large Commitment of Nonrenewable Resources
Commitment of nonrenewable resources includes issues related to increased energy consumption, loss of agricultural lands, and lost access to mining reserves. There would be an irretrievable commitment of labor, capital, and materials used during the construction and operation of the Project. Nonrenewable resources would primarily be committed in the form of fossil fuels such as fuel, oil, natural gas, and gasoline used by equipment associated with construction of the Project. Consumption of other nonrenewable or slowly renewable resources would also occur. These resources would include lumber and other forest products, sand and gravel, asphalt, and metals such as steel, copper, and lead. However, the amount and rate of consumption of these resources would not result in significant environmental impacts because warehouse development is not associated with an unnecessary, inefficient, or wasteful use of resources.
6 – OTHER CEQA CONSIDERATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 6-30
To ensure that energy implications are considered in project decisions, CEQA requires that EIRs include a discussion of the potential energy impacts of proposed projects, with particular emphasis on avoiding or reducing inefficient, wasteful, and unnecessary consumption of energy (California Public Resources Code Section 21100[b][3]). Energy conservation implies that a project’s cost-effectiveness be reviewed not only in dollars, but also in terms of energy requirements. For many projects, cost-effectiveness may be determined more by energy efficiency than by initial dollar costs. A lead agency may consider the extent to which an energy source serving a project has already undergone environmental review that adequately analyzed and mitigated the effects of energy production.

Consistent with California Public Resources Code Section 211009(b)(3), CEQA Guidelines Appendix G, and a ruling set forth by the court in California Clean Energy Committee v. City of Woodland, potentially significant energy implications of a project must be considered in an EIR to the extent relevant and appliable to that project.

Accordingly, based on the energy consumption thresholds set forth in both Appendix F and Appendix G of the CEQA Guidelines, the Project’s estimated energy demands (both short-term construction and long-term operational demands) were evaluated (see Section 4.5, Energy, of this EIR). The overall purpose of the energy analysis was to evaluate whether the Project would result in the wasteful, inefficient, or unnecessary consumption of energy.

As further assessed in the energy analysis, for new development, such as that proposed by the Project, compliance with California Title 24 energy efficiency requirements is considered demonstrable evidence of efficient use of energy. The Project would provide for and promote energy efficiencies beyond those required under other applicable federal and state standards and regulations, and in doing so would meet or exceed all Title 24 standards. On this basis, the Project would not result in the inefficient, wasteful, or unnecessary consumption of energy.

6.4 Significant and Unavoidable Impacts
Pursuant to CEQA Guidelines Section 15126.2(c), an EIR must address any significant environmental impacts, including those that can be mitigated but not reduced to less than significant as a result of implementation of a project. As discussed throughout Chapter 4, Environmental Analysis, of this EIR, at the Project and cumulative levels, the Project would result in significant and unavoidable impacts related to cultural resources (historical resources only) and transportation (VMT only). For all other environmental issue areas, the Project would result in either less-than-significant impacts with mitigation, less-than-significant impacts, or no impact.

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-1
7 Alternatives

7.1 Alternatives to the Proposed Project
In accordance with CEQA Guidelines Section 15126.6, this EIR chapter contains a comparative evaluation of the Palisade Santee Commerce Center Project with alternatives to the Project, including a No Project Alternative.

Consistent with CEQA Guidelines Section 15126.6, this chapter focuses on alternatives to the Project that are capable of avoiding or substantially reducing any significant adverse impacts associated with the Project, even if the alternatives may impede attainment of Project objectives or prove less cost efficient. In addition, implementation of a Project alternative may potentially result in new impacts that would not have resulted from the Project.

The CEQA Guidelines require that the analysis of alternatives provide sufficient information about each alternative to allow meaningful evaluation, analysis, and comparison with a proposed project. Specifically, CEQA Guidelines Section 15126.6(a) outlines the scope of alternatives to a proposed project that must be evaluated:

An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project.

Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation. An EIR is not required to consider alternatives which are infeasible. The lead agency is responsible for selection of a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason.

Under case law and CEQA Guidelines Section 15126.6(f), the discussion of alternatives is subject to a rule of reason and need not be exhaustive. CEQA Guidelines Section 15126.6(d) states that “if an alternative would cause one or more significant effects in addition to those that would be caused by the project as proposed, the significant effects of the alternatives shall be discussed, but in less detail than the significant effects of the project as proposed.” Determining factors that may be used to eliminate alternatives from detailed consideration in an EIR are (a) failure to meet most of the basic project objectives, (b) infeasibility, or (c) inability to avoid significant environmental impacts. CEQA Guidelines Section 15364 defines “feasibility” as “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors.”
An EIR need not consider a project alternative whose effects cannot be reasonably ascertained, whose implementation is remote and speculative, or whose execution does not substantially lessen or avoid the significant effects of a proposed project.

As discussed throughout Chapter 4, Environmental Analysis, and Chapter 6, Other CEQA Considerations, of this EIR, at the project and cumulative levels, the Project would result in significant and unavoidable cultural resources and transportation impacts. For all other environmental issue areas, the Project would result in less than significant impacts with mitigation incorporated, less-than-significant impacts, or no impact. 7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-2

7.2 Considerations for Selection of Alternatives
Project Objectives
Section 15124(b) of the CEQA Guidelines requires that an EIR include a statement of the project objectives that “include the underlying purpose of the project and may discuss the project benefits.” The following objectives have been identified for the Project:
▪ Objective 1: Establish a jobs-producing and tax-generating commerce center land use near transportation corridors that is constructed to high standards of quality and provides diverse economic opportunities for those residing and wishing to invest within the City of Santee. ▪ Objective 2: Develop a high-quality development for uses in Santee that are designed to meet contemporary industry standards, can accommodate a wide variety of users, and are economically competitive with similar developments in the local area and region.
▪ Objective 3: Develop a facility within the East County region of San Diego County and in close proximity to SR52 and SR-67 that can be used as part of the Southern California supply chain and goods movement network. ▪ Objective 4: Create a fiscally sound and employment-generating project within an established industrial area. ▪ Objective 5: Concentrate non-residential uses in areas designated for industrial uses which are near existing roadways, highways, and freeways in an effort to isolate and reduce any potential environmental impacts related to truck traffic congestion, air emissions, and industrial noise to the greatest extent feasible.

Summary of Project Impacts
Potentially feasible alternatives were developed with consideration of avoiding or lessening the significant adverse effects of the Project identified throughout this EIR. The following is a summary of significant impacts associated with the proposed Project:

Biological Resources
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. Therefore, with implementation of Mitigation Measure (MM) BIO-1 and BIO-4, direct impacts to nesting birds or their habitat would be less than significant. (Less Than Significant with Mitigation Incorporated).

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, With implementation of MMBIO-1 (Pre-Construction Nesting Bird Survey) and MM-BIO-2 (Construction-Related Indirect Impacts to SpecialStatus Species, Sensitive Vegetation Communities, and Jurisdictional Aquatic Resources), the effect of construction-related indirect impacts to least Bell’s vireo, yellow-breasted chat, yellow warbler, and special-status plant species would be less than significant. (Less Than Significant with Mitigation Incorporated) Long-Term: Potential long-term, indirect impacts 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. With implementation of MM-BIO-3 (Long-Term Indirect Impacts to Special-Status Species, Sensitive Vegetation Communities, and Jurisdictional Aquatic Resources), the effect of potential long-term indirect impacts to least Bell’s 7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-3
vireo, yellow-breasted chat, yellow warbler, and special-status plant species would be reduced to less than significant. (Less Than Significant with Mitigation Incorporated) Construction-related: Sensitive vegetation communities and/or the San Diego River wildlife corridor may be indirectly impacted during construction of the proposed Project. 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 and/or wildlife corridors to less than significant. (Less Than Significant with Mitigation Incorporated) Long-Term: Potential long-term, indirect impacts could result from development near sensitive vegetation communities and/or the San Diego River wildlife corridor that could degrade habitat; increase invasive plant species that may degrade habitat; and trampling of vegetation and soil compaction by humans, could affect soil moisture, water penetration, surface flows, erosion, and wildlife corridors. 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 sensitive vegetation communities to less than significant. (Less Than Significant with Mitigation Incorporated)
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. 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 to jurisdictional aquatic resources to less than significant. (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 to jurisdictional aquatic resources to less than significant. (Less Than Significant with Mitigation Incorporated)
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.

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. With implementation of MM-BIO-4, the proposed Project would comply with the Urban Forestry Ordinance, and impacts would be less than significant. (Less Than Significant with Mitigation Incorporated) Cultural, Tribal Cultural, and Paleontological Resources As explained in the Historic Assessment (Appendix F), the Former Drive-In Theatre has been conservatively determined to embody the distinctive characteristics of a type, period, and method of drive-in movie theatre 7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-4
construction during the 1960s-1970s. Therefore, the Former Drive-In Theatre on the Property is conservatively determined to be eligible for listing in the National Register of Historic Places and the California Register of Historical Resources and is conservatively assumed to be a historical resource under CEQA (CEQA Guidelines §15064.5(a)(3)), and the demolition of the Former Drive-In Theatre would result in a substantial adverse change in the significance of a historic resource. With implementation of MM-HIS-1, MM-HIS-2, MM-HIS-3, and MM-HIS-4, the Project’s historic resource impact would not be reduced below significance threshold. Therefore, the impact would remain significant and unavoidable. (Significant and Unavoidable) As explained in the Historic Assessment (Appendix F), the Former Drive-In Theatre on the Project site has been determined to embody the distinctive characteristics of a type, period, and method of drive-in movie theatre construction during the 1960s-1970s. Implementation of MM-HIS-1 through MM-HIS--4 would partially mitigate the project’s impacts on this historic resource, though not to a less than considerable level. Because the project would result in the loss of a historic resource, the project’s incremental contribution to loss of historic resources would be cumulatively considerable; therefore, the Project’s contribution to the loss of historical resources would be a significant and unavoidable cumulative impact. (Significant and Unavoidable Cumulative Impact) In the unexpected event that human remains are unearthed during construction activities, impacts would be potentially significant. With implementation of MM-CUL-2, potential impacts associated with human remains would be less than significant. (Less Than Significant with Mitigation Incorporated) 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 Measure MM-CUL-1 is required to reduce potential impacts to unanticipated discovery of cultural resources and TCRs. With implementation of MM-CUL-1, potential impacts associated with any buried, currently unrecorded/unknown tribal cultural resources would be less than significant. (Less Than Significant with Mitigation Incorporated)
As demonstrated in Appendices G and H, no paleontological resources were identified within the Project site, and the Project site is not anticipated to be underlain by unique geologic features. With implementation of Mitigation Measure MM-CUL-3, potential impacts related to unanticipated discovery of paleontological resources would be less than significant. (Less Than Significant with Mitigation Incorporated) Transportation
The Project would generate VMT in excess of the significance threshold. Since the Project’s daily trip generation estimate would be below 2,400 average daily trips, and the Project’s census tract includes other employee-based uses, a project-specific model run by SANDAG would not be required. The results of the SANDAG SB 743 VMT maps have been used in the Project’s VMT analysis. Compared to the regional mean of 18.9 VMT per employee, the VMT per employee of the Project’s census tract is 22.2 VMT. Because the Project’s VMT is higher than the regional average of the census tract it is located within, the Project would result in a significant VMT impact. A VMT reduction of 11.3% would be achieved through the implementation of CTR measures. A reduction of 15% is required to reduce the VMT per employee to at or below regional level. Implementation of MM-TRA-1 (Trip Reduction Program) and MM-TRA-2 (Construction of Sidewalk) would reduce the Project’s VMT but not below significance threshold even with the implementation of MM-TRA-1 and MM-TRA-2, the Project’s VMT impact would remain significant and unavoidable. (Significant and Unavoidable Impact)
7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-5
The Project is consistent with the General Plan land use of the Project site and would provide employment as proposed in the traffic analysis zone. The VMT/employee under Year 2035 or cumulative conditions is 20.1, which exceeds the existing threshold of 18.9 VMT per employee. Therefore, it can be concluded that the Project would also result in a significant cumulative impact. MM-TRA-1 (Trip Reduction Program) would be implemented by the Project’s tenants and MM-TRA-2 (Construction of Sidewalk) would be implemented by the Project applicant to reduce the Project’s VMT. Because the Project’s VMT would not be reduced to below significance threshold even with the implementation of MM-TRA-1 and MM-TRA-2, the Project’s incremental contribution to VMT impact would be cumulatively considerable; therefore, the Project’s contribution to VMT impacts would be a significant and unavoidable cumulative impact. (Significant and Unavoidable Cumulative Impact)

7.3 Project Alternatives Considered and Rejected
An EIR is required to identify any alternatives that were considered by the lead agency but were rejected as infeasible. Among the factors described by CEQA Guidelines Section 15126.6 in determining whether to exclude alternatives from detailed consideration in an EIR are failure to meet most of the basic objectives of the project, infeasibility, or inability to avoid significant environmental impacts.

With respect to the feasibility of potential alternatives to a proposed project, CEQA Guidelines Section 15126.6(t)(l) states the following:

Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries ... and whether the proponent can reasonably acquire, control, or otherwise have access to the alternative site.

In determining an appropriate range of Project alternatives to be evaluated in this EIR, a number of possible alternatives were initially considered and then rejected. Project alternatives were rejected because they could not accomplish the basic objectives of the Project, they would not have resulted in a reduction of significant adverse environmental impacts, or they were considered infeasible to construct or operate.

Alternative Land Uses
According to the City’s General Plan, the City’s industrial land is highly constrained and is being underutilized (City of Santee 2003). The purpose of the Light Industrial (IL) zone is to create employment-generating uses in an industrial park setting. The IL zone is intended to provide for service commercial, light industrial, light manufacturing, and industrial support uses, mainly conducted in enclosed buildings. Important goals of the development standards for this zone are to utilize industrial land, have accessibility to major transportation routes, and compatibility with the adjacent commercial, residential, and recreational uses. Permitted uses in the IL designation include manufacturing and assembly, electronics, research and development, and light warehousing uses. The minimum size for a Light Industrial project site is 20,000 square feet and building heights over 40’-0” require aCUP-.

The availability of a site comparable in size to that of the Project site is extremely rare within the City, so consideration was given to alternatives that involve a comprehensive change in the site’s land use and zoning designations to take advantage of the availability of a singular, relatively large, site within the City. Land uses considered included residential, commercial/retail, and mixed-use types of industrial uses. As discussed within Section 3.2, Environmental Setting, the Project site is located within an established industrial area and is 7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-6
surrounded on three sides by industrial and manufacturing uses. Given the proximity of other existing industrial uses in both the immediate and broader Project area, residential, commercial/retail, and mixed-use alternative land uses would likely not be compatible with the neighboring industrial operations around the Project site.

Accordingly, the Project site would be an undesirable location for residential, commercial/retail, and mixed-use developments. More importantly, such uses would not meet all of the Project Objectives, which include establishing a jobs-producing and tax-generating commerce center land use near transportation corridors (Objective 1), developing a high-quality industrial building with light manufacturing and distribution facilities for related uses in Santee that are designed to meet contemporary industry standards (Objective 2), developing a light manufacturing and distribution building with loading in close proximity to SR-52 and SR-67 that can be used as part of the Southern California supply chain and goods movement network (Objective 3), creating a fiscally sound and employmentgenerating industrial building within an established industrial area (Objective 4), and concentrating non-residential uses in areas designated for industrial use which are near existing roadways, highways, and freeways (Objective 5).

An Industrial Outdoor Storage (IOS) yard was considered as an alternative industrial use. Under the IOS use, the Project site would be utilized to store contractor’s equipment, truck trailer parking, and/or shipping containers in a paved, outdoor lot. The improvements would include a small office that is approximately 2,000 square feet. In this scenario, the size of the building, square footage of office space, and number of employees would be reduced.

However, truck trips to and from the site would remain approximately the same because the quantity of stored materials would be equivalent to the Project. Noise impacts would be substantially higher because all business activities under this alternative would be conducted outdoors, whereas the Project would have activities within the buildings. Stormwater impacts would be equivalent to the Project scenario because a treatment system would be installed as part of the IOS use. However, the IOS alternative industrial use was rejected because it did not meet the Project Objectives, including establishing a jobs-producing and tax-generating commerce center land use near transportation corridors (Objective 1), developing a high-quality industrial building with light manufacturing and distribution facilities for related uses in Santee that are designed to meet contemporary industry standards (Objective 2), developing light manufacturing and distribution building with loading in close proximity to SR-52 and SR-67 that can be used as part of the Southern California supply chain and goods movement network (Objective 3), and creating a fiscally sound and employment-generating industrial building within an established industrial area (Objective 4).

A self-storage facility was also considered as an alternative use. Under a self-storage use, a series of one-story, metal buildings would be built along an interconnected series of access roads, while leaving the original concessions building, sign, and screens in place. The net square footage of potential self-storage facilities would be less than that proposed by the Project. Noise impacts would be similar to or less than the project. Stormwater impacts would be equivalent to the Project because a treatment system would be installed. With the exception of the paving, the existing drive-in theatre facilities would remain untouched. Accordingly, a self-storage use would result in a less than significant impact to historic resources. However, the self-storage use was also rejected because it did not meet the Project Objectives, including establishing a jobs-producing and tax-generating commerce center land use near transportation corridors (Objective 1), developing a high-quality industrial building with light manufacturing and distribution facilities for related uses in Santee that are designed to meet contemporary industry standards (Objective 2), developing light manufacturing and distribution building with loading in close proximity to SR-52 and SR-67 that can be used as part of the Southern California supply chain and goods movement network (Objective 3), and creating a fiscally sound and employment-generating industrial building within an established industrial area (Objective 4). 7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-7
Alternate Sites
CEQA does not require that an analysis of alternate sites always be included in an EIR. However, if the surrounding circumstances make it reasonable to consider an alternate site, then a project alternative should be considered and analyzed in the EIR. Pursuant to CEQA Guidelines Section 15126.6(f)(2), in making the decision to include or exclude analysis of an alternate site, the “key question and first step in analysis is whether any of the significant effects of the project would be avoided or substantially lessened by putting the project in another location. Only locations that would avoid or substantially lessen any of the significant effects of the project need to be considered for inclusion in the EIR.”
Development of the Project in an alternate location would generally have similar impacts as would occur with implementation of the Project at its proposed location, although impacts related to biological resources and historic resources would be reduced. The IL and General Industrial (IG)-designated land areas within the City of Santee are almost entirely developed and no similarly sized parcels are available for the Project.

Further, if the alternate site were to be located farther from major regional transportation routes (e.g., SR 67 and other local truck routes), operational impacts associated with traffic congestion, truck noise, and tailpipe air contaminant emissions would likely be greater than those associated with the Project and disclosed in this EIR, as the vehicles would need to travel farther on local roads to reach regional highway systems.

Moreover, according to the San Diego Association of Governments (SANDAG) Comprehensive Regional Goods Movement Plan and Implementation Strategy, the region will run out of suitably zoned vacant land designated for warehouse facilities in or around 2028. At that time, forecasts show that the demand for warehousing space will be more than 1 billion square feet. The Comprehensive Regional Goods Movement Plan and Implementation Strategy also states that unless other land not currently zoned for warehousing becomes available, the Southern California Association of Governments (SCAG) forecasts that by 2035, a projected shortfall of space of approximately 227 million square feet will occur (SCAG 2012). Thus, it is likely that selection of an alternate site would merely displace the development activity proposed by the Project to another location, resulting in the same or greater environmental effects (although impacts related to biological resources and historic resources would be reduced), given the regional demand for logistics and warehousing space in the SANDAG and SCAG region.

Additionally, Assembly Bill 98 (AB 98) was recently signed into law and includes several new requirements for warehouse project applications filed after September 30, 2024. AB 98 becomes effective on Jan. 1, 2026. If an alternative site location were to be considered, it would constitute a new project and would therefore be subject to the additional requirements and restrictions of this new law.

7.4 Project Alternatives Under Further Consideration
The following provides analysis of the No Project/No Development Alternative (Alternative 1) and the two build alternatives: the Reduced Development Intensity Alternative (Alternative 2) and the Refrigerated Warehouse Alternative (Alternative 3).

The evaluation below provides a relative comparison between the Project and each of the three Project alternatives.

The analysis considers the issue areas evaluated in Chapter 4, Environment Analysis, and the cumulative analysis in Chapter 6, Other CEQA Considerations, of this EIR. In many cases, the Project and a Project alternative may share the same level of significance (i.e., both scenarios would result in a less-than-significant impact). However, although they might share the same level of significance under CEQA, the actual degree of impact may be slightly different 7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-8
for each scenario, and this relative difference is the basis for a conclusion of greater or lesser impacts compared to the Project.

An environmentally superior alternative is identified among the alternatives evaluated in this EIR. An alternative would be environmentally superior to the Project if it would result in fewer or less significant environmental impacts while achieving most of the Project objectives.

7.4.1 No Project/No Development Alternative (Alternative 1) Project Alternative 1
Under Alternative 1, construction of the Project would not occur, and the existing environment would remain in its current state. The Project site would remain unchanged, and development activities related to construction and operation of the proposed industrial/warehouse building, associated office spaces, surface parking and loading areas, and all other proposed on- and off-site improvements would not occur.

In the short term, consistent with the existing conditions, the Project site would continue to be underutilized. Under Alternative 1, the Project site would remain with a non-operating drive-in theatre that includes two movie screens, two ticket booths, and a building containing restrooms and a snack bar, which could be used as a swap meet on weekends. The sitewould presumably continue to be utilized for a swap meet on the weekends, and subject to vegetation occurring similar to the existing conditions. It is assumed any existing maintenance and/or security activity at the site would remain unchanged from existing conditions.

Comparative Analysis of Environmental Effects
The Project site would remain unchanged, on-site conditions would remain similar to existing conditions, and because development activities associated with the Project would not occur, nearly all environmental impacts would be reduced or avoided compared with Project conditions. Thus, there would be no potentially significant impacts related to biological resources; cultural, tribal cultural, and paleontological resources (project and cumulative); and transportation (project and cumulative).

Alternative 1 would not result in any ground disturbance that would potentially affect biological resources or unknown cultural, tribal cultural, or paleontological resources. As such, the less than significant impacts with mitigation incorporated that would potentially occur related to these resources under the development of the proposed Project would not occur under Alternative 1.

The significant and unavoidable impact with mitigation incorporated to historic resources (project and cumulative) that would occur with removal of the drive-in theatre by the Project would not occur under Alternative 1. In addition, the significant and unavoidable impact with mitigation incorporated related to vehicle miles travelled (VMT) (project and cumulative) that would occur related to transportation under the development of the proposed Project would not occur under Alternative 1.

Relationship to the Project Objectives
Alternative 1 would not meet any of the project objectives as it would not develop a jobs-producing and taxgenerating commerce center land use near transportation corridors that is constructed to high standards of quality and provides diverse economic opportunities for those residing and wishing to invest within the City of Santee (Objective 1); a high-quality development for uses in Santee that are designed to meet contemporary industry 7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-9
standards, can accommodate a wide variety of users, and are economically competitive with similar developments in the local area and region (Objective 2); a facility within the East County region of San Diego County and in close proximity to SR-52 and SR-67 that can be used as part of the Southern California supply chain and goods movement network (Objective 3); a fiscally sound and employment-generating project within an established industrial area (Objective 4); and/or result in a project that concentrates non-residential uses in areas designated for industrial uses which are near existing roadways, highways, and freeways in an effort to isolate and reduce any potential environmental impacts related to truck traffic congestion, air emissions, and industrial noise to the greatest extent feasible (Objective 5).

7.4.2 Reduced Development Intensity Alternative (Alternative 2) Project Alternative 2
Under Alternative 2, the Project site would be redeveloped with a smaller warehouse building with the remainder of the Project site utilized for outdoor storage. Per Table 13.14.030A of the Santee Municipal Code, outdoor storage is allowable as an accessory use to a permitted use within the IL zone with the approval of a minor conditional use permit. Accessory outdoor storage uses must comply with Section 13.14.030(G)(2)) of the Santee Municipal Code which sets forth several requirements for screening, heights of stored material, locations of the stored material within the site, and access requirements. In addition, depending on the type of material to be stored, the installation of a canopy or outdoor roof structure may be required to shield the material from the elements to allow for the proper functioning of stormwater systems.

Under Alternative 2, the Project site would be redeveloped with an approximately 120,000 square feet (sf) warehouse-type building (an approximately 60% reduction in building size compared to the Project), an approximately 150,000 sf area dedicated to outdoor storage use, and reduced parking to accommodate the reduced development intensity. This alternative assumes compliance with Santee Zoning Code Section

13.14.030(G)(2) regarding outdoor storage. The reduced development footprint for Alternative 2 would be setback further south of the northern Project boundary and existing trees and a movie screen along the northern boundary of the Property would be retained in-place.

Comparative Analysis of Environmental Effects
Less than significant impacts of the proposed Project related to aesthetics, air quality, biological resources (with mitigation), energy, greenhouse gas emissions, hazards and hazardous materials, noise, public services, and wildfire would be lesser in magnitude under Alternative 2 overall because the development footprint would be smaller and farther from the northern boundary of the site. Relative to the Project, Alternative 2 would result in similar impacts related to hydrology and water quality, land use and planning, and utilities and service systems.

Potentially significant impacts of the proposed Project related to biological resources and cultural, tribal cultural, and paleontological resources would be lesser in magnitude under Alternative 2 overall because the building and development footprint would be smaller, setback farther from the northern site boundary, and avoid the removal of the movie screen and trees along the northern site boundary. Potentially significant impacts related to transportation under Alternative 2 would be similar to the proposed Project as the reduction in building area and workers would not reduce the site’s VMT.

The following analysis compares the Project’s potentially significant environmental effects with those of Alternative 2. 7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-10
Aesthetics
Alternative 2 would result in development of a smaller building that would reduce the scale and massing to approximately 40 percent compared to the proposed Project building. Alternative 2 would include approximately 150,000 sf of outdoor storage. The building under Alternative 2 would be 40 feet in height, consistent with the maximum allowable height specified by the Zoning Code for the IL zone. No CUP would be required to increase the building height. In addition, the building would be setback further from the northern Property boundary and would be obscured by existing trees; this would setback and obscure views of the development from trails and residences located north of the Project site. Similar to the Project, development of Alternative 2 would result in less than significant aesthetic impacts; however, development of Alternative 2 would further lessen aesthetic impacts to views from trails and residential areas located north of the Project site.

Air Quality
Alternative 2 would develop the site with a 120,000-sf warehouse building and an approximately 150,000-sf outdoor storage area. With a reduction in building area compared to the Project, construction-related emissions associated with development of Alternative 2 would be of lesser magnitude compared to the proposed Project.

Alternative 2 would also generate fewer employees and vehicle trips per day due to the reduced development intensity compared to the Project. Similar to the Project, development of Alternative 2 would result in less than significant air quality impacts; however, development of Alternative 2 would further lessen construction- and operational-related air quality impacts because of the overall reduced development intensity.

Biological Resources
Similar to the Project, Alternative 2 would result in potential direct impacts to nesting birds and/or their habitat; 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); indirect impacts to sensitive vegetation communities occurring adjacent to the Project site; indirect impacts to jurisdictional aquatic resources occurring within 500 feet of the Project site associated with the San Diego River; indirect impacts to the San Diego River corridor, which occurs adjacent to the Project site and may function as a local wildlife corridor; direct and indirect impacts to trees. However, MM-BIO-1 through MM-BIO-4 could be implemented under Alternative 2 to reduce biological impacts to less than significant. Relative to the Project, all impacts to biological resources under Alternative 2 would be lesser in magnitude because fewer trees would be removed or indirectly impacted by the development and the setback of the development from the northern Property boundary would result in a larger buffer between biological resources near the San Diego River corridor. Therefore, potential impacts to biological resources would be lesser in magnitude under Alternative 2 overall.

Cultural, Tribal Cultural, and Paleontological Resources Similar to the Project, Alternative 2 would result in ground disturbing construction activities onsite that could result in a potentially significant impact related to discovery of buried archaeological resources, previously unknown or undiscovered human remains, tribal cultural resources, and previously unknown or undiscovered paleontological resources. However, MM-CUL-1 and MM-CUL-2 could be implemented under Alternative 2 to reduce the potential impacts to less than significant. Implementation of Alternative 2 would also result in the loss of significant features of the Santee Drive-In Theatre site similar to the Project but would retain the movie screen near the northwest Property boundary to partially mitigate this impact. In addition, MM-HIS-1 through MM-HIS-4 could be implemented under Alternative 2. Similar to the Project, the overall impact to historic resources would remain significant and 7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-11
unavoidable with incorporation of MM-HIS-1 through MM-HIS-4; however, impacts to historic resources would be of lesser magnitude under Alternative 2 because the former Drive-In Theatre movie screen located along the northwest Property boundary would be retained.

Energy
Like the Project, Alternative 2 would require the use of various forms of energy during construction and operation.

However, Alternative 2 includes a smaller building with outdoor storage, construction energy demand would be expected to be lesser than the Project. Alternative 2 would also generate fewer vehicle trips and would have less building space than the Project. Due to the reduced construction, building area, and number of employees, Alternative 2 would be expected to have a reduced energy demand when compared with the Project. Like the Project, Alternative 2 would have a less-than-significant impact related to energy, but Alternative 2 would have a lesser impact due to its reduced energy demand during construction and operation.

Greenhouse Gas Emissions
As discussed in Section 4.6, Greenhouse Gas Emissions, the Project would generate greenhouse gas (GHG) emissions during construction and operation, but these impacts would be less than significant. Alternative 2 would also generate GHG emissions, though a lower level of emissions would be expected under Alternative 2 because of the reduced building space and anticipated lower number of employees traveling to and from the site each day.

Therefore, Alternative 2 would be expected to have a lesser impact than the Project with regard to GHG emissions.

Hazards and Hazardous Materials
Alternative 2 would result in development of a smaller building that would be setback further from the northern Property boundary along the San Diego River corridor. Similar to the Project, development of Alternative 2 would result in less than significant impacts related to hazards and hazardous materials; however, development of Alternative 2 would further lessen these impacts overall because Alternative 2 would have a smaller extent of site development and would be setback further from potential wildfire fuels north of the property boundary.

Hydrology and Water Quality
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 in compliance with the San Diego County BMP Design Manual and the City of Santee Guidelines for Surface Water Pollution Prevention Manual. Stormwater would continue to flow to the north of the site via an underground infiltration system located in the northern portion of the site. Under Alternative 2, the on-site storm drain system and infiltration system would be similar to the proposed Project and consistent with San Diego County LID requirements. Similar to the Project, development of Alternative 2 would result in less than significant impacts to hydrology and water quality; although development of Alternative 2 would result in a reduced extent of development, hydrology and water quality impacts would be similar overall because storm drain improvements throughout the site would still be required.

Land Use and Planning
As discussed in Section 4.9, Land Use and Planning, the Project would not divide an established community and would be consistent with the following plans: City of Santee General Plan and Zoning Code, SANDAG 2021 Regional Plan/Sustainable Communities Strategy (RP/SCS), SDAPCD regulations and requirements, and the San Diego 7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-12
County Regional Transportation Congestion Improvement Program/Regional Arterial System (RTCIP/RAS).

Alternative 2 is similar to the Project in that it would develop a warehouse consistent with local land use plans and policies. As described above, outdoor storage would be permitted within the IL zone with the approval of a conditional use permit. Like the Project, development of Alternative 2 would result in less than significant impacts related to land use and would be similar to the Project overall.

Noise
As discussed in Section 4.10, Noise, of this EIR, the analysis determined that the Project would not result in exceedances of local noise standards and concluded that the Project would result in less-than-significant construction- and operationrelated noise impacts. Like the Project, Alternative 2 would include new sources of temporary construction and permanent operational noise, andwould include a noise barrier. However, because Alternative 2would develop a smaller building and development footprint and would be setback further from sensitive noise receptors north of the Project site, it is expected that construction and operational noise impacts would be of lesser magnitude compared to the Project.

Public Services
As discussed in Section 4.11, Public Services, of this EIR, the Project would result in less than significant impacts related to fire protection and police services and no impact related to parks, schools, and other public services because such services are generally based on population, not building size. While the Project would add new employees within the service areas of fire, law enforcement, parks, schools, and other public services, the increase would be nominal in light of existing population and employment numbers. In addition, required payment of development impact fees (DIFs) would ensure the Project contributes its fair share towards Santee Fire Department (SFD) facility improvements and equipment. Similar to the Project, development of Alternative 2 would result in less than significant impacts related to public services; however, development of Alternative 2 would further lessen these impacts overall because Alternative 2 would have a smaller extent of site development and would be anticipated to employ fewer workers compared to the Project.

Transportation
VMT is largely dependent on the specific land use type of a particular project and the location of that project. While a reduction in a Project’s size could reduce the overall VMT associated with a given project, reducing a project’s square footage would not necessarily have an effect on VMT per capita or employee, which are efficiency metrics.

Thus, while the building under Alternative 2 would be reduced by approximately 60% compared to the Project, VMT per employee would essentially remain constant. In addition, because a reduction in Project size would correlate to a similar reduction in on-site workforce, the Project’s VMT per employee would also stay relatively the same under Alternative 2 as the Project’s VMT per employee. It should be noted that truck trips are not required to be included in the VMT estimation per SB 743 requirements. Therefore, transportation impacts with regard to VMT would be similar to the Project’s impact under Alternative 2.

Utilities and Service Systems
Under Alternative 2, a reduced building area and development intensity overall would be onsite. The reduced intensity of development on the site would also be expected to require fewer workers compared to the Project. With a reduction in building area and the number of employees, Alternative 2 would be expected to have a lower water demand, wastewater generation, and solid waste generation than the Project. However, Alternative 2 would require the same on- and off-site improvements as needed for the Project. As such, the same wet and dry utilities would be 7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-13
required, with construction and operational characteristics of these on- and offsite improvements being similar to the Project. Therefore, utilities and service systems impacts would be similar under Alternative 2.

Wildfire
As discussed in Section 4.14, Wildfire, of this EIR, the distance between a wildfire that is consuming wildland fuel and a building is the primary factor for structure ignition (not including burning embers) (Cohen 2000). Compared to the proposed Project, the building under Alternative 2 would be further set back from offsite wildland fuels located north of the Project site. Similar to the Project, development of Alternative 2 would result in less than significant wildfire impacts; however, the increased distance between the proposed building under Alternative 2 and wildland fuels north of the Project site would further lessen the potential for wildfire impacts.

Relationship to the Project Objectives
Alternative 2 would partially meet Objective 1 because it would result in development of new jobs and tax-generating business near transportation corridors but would not create a commerce center. Alternative 2 would not meet Objective 2 as it would not be able to accommodate a wide variety of users due to the limited building size and substantial outdoor storage area. Alternative 2 would meet Objective 3 as it would develop a facility in close proximity to SR-52 and SR-67 that can be used as part of the Southern California supply chain and goods movement network. Alternative 2 would mostly meet Objective 4, but not to the same extent as the Project because Alternative 2 would have limited flexibility, making it more difficult to develop a fiscally-sound use. Also, Alternative 2 would generate fewer new jobs that the Project, making Alternative 2 meet this portion of Objective 4 to a lesser degree than the Project. Finally, Alternative 2 would meet Objective 5 as it would develop a non-residential use in an industrial area. Given the reduced intensity of development under Alternative 2, this alternative would be expected to result in fewer truck trips, lesser air emissions, and less industrial noise than the Project. As such, Alternative 2 would meet most of the Project Objectives, but would fall short of meeting Objective 2.

7.4.3 Refrigerated Warehouse Alternative (Alternative 3) Project Alternative 3
Under Alternative 3, the Project site would be redeveloped with a smaller warehouse-type building of approximately 200,000 sf and up to 40 feet in height. It is assumed that the warehouse would include 100,000 square feet for cold storage space, 95,000 square feet for general warehousing uses, and 5,000 square feet for office use.

Compared to the proposed Project, the project footprint for Alternative 3 would be smaller and setback further south of the northern Project boundary. It is assumed that existing trees and movie screen along the northern boundary of the Property would be retained in-place. Per Table 13.14.030(A) of the Santee Municipal Code, cold storage would fall under the “Fruit or vegetable products manufacturing, including frozen foods” use and would be permitted within the IL zone with the approval of a conditional use permit. The reduced development would require fewer employees. Proposed parking at the site would require fewer parking stalls compared to the proposed Project and would be utilized for the staging and storage of refrigerated trailers, which would be connected to exterior electrical receptacles to keep their contents cold or temporarily operated under their own power via diesel generators. This alternative assumes compliance with all zoning and development regulations for the IL zoning. 7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-14
Comparative Analysis of Environmental Effects
Less than significant impacts of the proposed Project related to air quality, energy, and greenhouse gas emissions would be greater in magnitude under Alternative 3 overall because the building would accommodate cold storage uses. Less than significant impacts of the proposed Project related to aesthetics, hazards and hazardous materials, noise, public services, and wildfire would be lesser in magnitude under Alternative 3 overall because the development footprint would be smaller and setback farther from the northern boundary of the site. Relative to the Project, Alternative 3 would result in similar impacts related to hydrology and water quality, land use and planning, and utilities and service systems, and unknown cultural, tribal cultural, and paleontological resources. The significant and unavoidable transportation impact (VMT generation) of the proposed Project would be similar in magnitude under Alternative 3 because the reduction in building area and workers would not reduce the site’s VMT.

The Project’s potentially significant impact to biological resources would be lesser in magnitude under Alternative 3 because fewer trees would be removed or indirectly impacted by the development, and the setback of the development from the northern Property boundary would result in a larger buffer from biological resources in the San Diego River corridor. The Project’s significant and unavoidable impact to historic resources of the proposed Project would be lesser in magnitude under Alternative 3 because the former Drive-In Theatre movie screen located along the northwest Property boundary would be retained.

The following analysis compares the Project’s potentially significant environmental effects with those of Alternative 3.

Aesthetics
Alternative 3 would result in development of a smaller building that would reduce the scale and massing. In addition, the building would be setback further from the northern Property boundary and would be obscured by existing trees; this would setback and obscure views of the development from trails and residences located north of the Project site. Similar to the Project, development of Alternative 3 would result in less than significant aesthetic impacts; however, development of Alternative 3 would further lessen aesthetic impacts to views from trails and residential areas located north of the Project site.

Air Quality
Alternative 3 would result in development of a cold storage warehouse building that is 100,000 sf smaller than the proposed Project. Given the smaller development size, construction-related emissions associated with development of Alternative 3 would be of lesser magnitude compared to the proposed Project. Alternative 3 would also generate fewer vehicle trips per day due to the reduced building size. However, operational emissions of NOx and PM10 from the refrigeration component of Alternative 3 would be of greater magnitude compared to the Project. As such, operational air contaminant emissions under Alternative 3 would be of greater magnitude overall compared to the Project.

Biological Resources
Similar to the Project, Alternative 3 would result in potential direct impacts to nesting birds and/or their habitat; 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); indirect impacts to sensitive vegetation communities occurring adjacent to the Project site; indirect impacts to jurisdictional aquatic resources occurring within 500 feet of the Project site associated with the San Diego River; indirect impacts to the San Diego River corridor, which occurs adjacent to the Project site and may function as a local wildlife corridor; direct and indirect impacts to trees. However, MM-BIO-1 through MM-BIO-4 could be implemented under Alternative 7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-15
3 to reduce biological impacts to less than significant. Relative to the Project, all impacts to biological resources under Alternative 3 would be lesser in magnitude because fewer trees would be removed or indirectly impacted by the reduced development and the setback of the development from the northern Property boundary would result in a larger buffer between biological resources near the San Diego River corridor. Therefore, potential impacts to biological resources would be lesser in magnitude under Alternative 3 overall.

Cultural, Tribal Cultural, and Paleontological Resources Similar to the Project, Alternative 3 would result in ground disturbing construction activities onsite that could result in a potentially significant impact related to discovery of buried archaeological resources, previously unknown or undiscovered human remains, tribal cultural resources, and previously unknown or undiscovered paleontological resources. However, MM-CUL-1 and MM-CUL-2 could be implemented under Alternative 3 to reduce the potential impacts to less than significant. Implementation of Alternative 3 would also result in the loss of significant features of the Santee Drive-In Theatre site similar to the project but would retain the movie screen near the northwest Property boundary to partially mitigate this impact. In addition, MM-HIS-1 through MM-HIS-4 could be implemented under Alternative 3. Similar to the Project, the overall impact to historic resources would remain significant and unavoidable with incorporation of MM-HIS-1 through MM-HIS-4; however, impacts to historic resources would be of lesser magnitude under Alternative 3 because the former Drive-In Theatre movie screen located along the northwest Property boundary would be retained.

Energy
The level of construction activities would be reduced under Alternative 3 compared to the Project. Thus, construction-related energy usage would be lessened. Alternative 3 would also generate fewer vehicle trips per day and would have less building space than the Project as proposed. Compared to the Project, energy consumption associated with long-term operations would be of greater magnitude under Alternative 3 because of the cold storage component. Similar to the Project, development of Alternative 3 would result in less than significant energy impacts; however, development of Alternative 3 would further lessen construction-related energy impacts, and a greater magnitude of long-term operational energy impacts would occur overall compared to the Project.

Greenhouse Gas Emissions
Similar to air quality, the extent of construction activities would be reduced under Alternative 3 compared to the Project. Thus, construction-related GHG emissions would be lessened. Alternative 3 would also generate fewer vehicle trips per day due to the reduction in the amount of building space. GHG emissions associated with longterm operation of Alternative 3 would be greater compared to the Project because of the cold storage component.

As such, construction-related emissions under Alternative 3 would be of lesser magnitude; however, operation of Alternative 3 would result in a greater magnitude of GHG emissions overall compared to the Project.

Hazards and Hazardous Materials
Alternative 3 would result in development of a smaller building that would be setback further from the northern Property boundary along the San Diego River corridor. Similar to the Project, development of Alternative 3 would result in less than significant impacts related to hazards and hazardous materials; however, development of Alternative 3 would further lessen these impacts overall because Alternative 3 would have a smaller extent of site development and would be setback further from potential wildfire fuels north of the property boundary. 7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-16
Hydrology and Water Quality
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 In compliance with the San Diego County BMP Design Manual and the City of Santee Guidelines for Surface Water Pollution Prevention manual. Stormwater would continue to flow to the north of the site via an underground infiltration system located in the northern portion of the site. Under Alternative 3, the on-site storm drain system and infiltration system would be similar to the proposed Project and consistent with San Diego County LID requirements. Similar to the Project, development of Alternative 3 would result in less than significant impacts to hydrology and water quality. Although development of Alternative 3 would result in a reduced extent of development, hydrology and water quality impacts would be similar overall because storm drain improvements throughout the site would still be required.

Land Use
As discussed in Section 4.9, Land Use and Planning, the Project would not divide an established community and would be consistent with the following plans: City of Santee General Plan and Zoning Code, SANDAG 2021 Regional Plan/Sustainable Communities Strategy (RP/SCS), SDAPCD regulations and requirements, and the San Diego County Regional Transportation Congestion Improvement Program/Regional Arterial System (RTCIP/RAS).

Alternative 3 is similar to the Project in that it would develop a warehouse consistent with local land use plans and policies. As described above, cold storage would be permitted within the IL zone with the approval of a conditional use permit. Like the Project, development of Alternative 3 would result in less than significant impacts related to land use and would be similar to the Project overall.

Noise
As discussed in Section 4.10, Noise, of this EIR, the analysis determined that the Project would not result in exceedances of local noise standards and concluded that the Project would result in less-than-significant constructionand operation-related noise impacts. Like the Project, Alternative 3 would include new sources of temporary construction and permanent operational noise, and would include a noise barrier. However, because Alternative 3 would develop a smaller building and development footprint and would be setback further from sensitive noise receptors north of the Project site, it is expected that construction and operational noise impacts would be of lesser magnitude compared to the Project.

Public Services
As discussed in Section 4.11, Public Services, of this EIR, the Project would result in less than significant impacts related to fire protection and police services and no impact related to parks, schools, and other public services because such services are generally based on population, not building size. While the Project would add new employees within the service areas of fire, law enforcement, parks, schools, and other public services, the increase would be nominal in light of existing population and employment numbers. In addition, required payment of development impact fees (DIFs) would ensure the Project contributes its fair share towards Santee Fire Department (SFD) facility improvements and equipment. Similar to the Project, development of Alternative 3 would result in less than significant impacts related to public services; however, development of Alternative 3 would further lessen these impacts overall because Alternative 3 would have a smaller extent of site development and would be anticipated to employ fewer workers compared to the Project. 7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-17
Transportation
VMT is largely dependent on the specific land use type of a particular project and the location of that project. While a reduction in a Project’s size could reduce the overall VMT associated with a given project, reducing a project’s square footage would not necessarily have an effect on VMT per capita or employee, which are efficiency metrics.

Thus, while the building under Alternative 3 would be reduced by approximately 100,000 square feet compared to the Project, VMT per employee would essentially remain constant. In addition, because a reduction in Project size would correlate to a similar reduction in on-site workforce, the Project’s VMT per employee would also stay relatively the same under Alternative 3 as the Project’s VMT per employee. It should be noted that truck trips are not required to be included in the VMT estimation per SB 743 requirements. Therefore, transportation impacts with regard to VMT would be similar to the Project’s impact under Alternative 3.

Utilities and Service Systems
Under Alternative 3, the Project would be constructed and operated as planned on the Project site, with the exception that the size of the proposed development would be reduced by 100,000 square feet and would include cold storage warehousing. All other on- and off-site improvements proposed as part of the Project are assumed to still be required under Alternative 3. As such, the same wet and dry utilities would be required, with construction and operational characteristics of these on- and offsite improvements being similar to the Project. Therefore, utilities and service systems impacts would be similar under Alternative 3.

Wildfire
As discussed in Section 4.14, Wildfire, of this EIR, the distance between a wildfire that is consuming wildland fuel and a building is the primary factor for structure ignition (not including burning embers) (Cohen 2000). Compared to the proposed Project, the building under Alternative 3 would be further set back from offsite wildland fuels located north of the Project site. Similar to the Project, development of Alternative 3 would result in less than significant wildfire impacts; however, the increased distance between the proposed building under Alternative 3 and wildland fuels north of the Project site would further lessen the potential for wildfire impacts.

Relationship to Project Objectives
Alternative 3 would meet Objectives 1, 3, 4, and 5, as it would develop a high-quality, jobs-producing, and taxgenerating commerce center within an existing industrial area located near transportation corridors, including SR52 and SR-67. Alternative 3 would not fully meet Objective 2 in that a reduced development at the site would result in a much less economically competitive development compared to similar developments in the local area and region. As such, Alternative 3 would meet most of the project objectives, but would fall short of meeting Objective 2.

7.5 Environmentally Superior Alternative
Section 15126(e)(2) of the State CEQA Guidelines requires an EIR to identify an “environmentally superior alternative.” If the No Project/No Development Alternative is the environmentally superior alternative, the EIR must also identify an environmentally superior alternative from among the other Project alternatives.

Table 7-1 compares the Project’s potentially significant environmental effects with those of the alternatives considered above. Shown in italics, this table also includes three (3) resource areas identified as less than 7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-18
significant under the Project (e.g., air quality, energy, greenhouse gas emissions) that could potentially result in an impact greater in magnitude compared to the Project under Alternatives 3.

Alternative 1 (No Project/No Development Alternative) would be the environmentally superior alternative because all of the significant impacts of the Project would be avoided and no environmental impacts would occur. However, Alternative 1 would not meet any of the Project’s Objectives. Alternative 2 (Reduced Development Intensity Alternative) would result in the same potentially significant and unavoidable impacts as the Project, though impacts to biological resources and historic resources would be of a lesser magnitude compared to the Project. Thus, Alternative 2 would be identified as another Environmentally Superior Alternative to the Project. Compared to the Project, Alternative 3 (Refrigerated Warehouse Alternative) would result in similar impacts to hydrology and water quality, land use and planning, transportation, and utilities and service systems, and would result in greater impacts to air quality, energy, and greenhouse gas emissions. Alternative 2 and Alternative 3 would meet most of the project objectives, though not to the same extent as the Project, and would fall short of meeting Objective 2. Because Alternative 2 would result in reduced environmental impact to most resources compared to the Project and Alternative 3, Alternative 2 would be considered environmentally superior. This alternative could also meet most of the project’s objectives. It should be noted that Alternative 2 would not avoid significant unavoidable impacts of the Project.

Table 7-1. Project Alternatives Environmental Impacts Comparison Environmental Issue Project
No Project/No
Development
Alternative
(Alternative 1)
Reduced
Development
Intensity
Alternative
(Alternative 2)
Refrigerated
Warehouse
Alternative
(Alternative 3)
Aesthetics Less than Significant Lesser Lesser Lesser
Air Quality Less than Significant Lesser Lesser Greater Biological
Resources
Less-than-Significant
with Mitigation
Incorporated
Lesser Lesser Lesser
Cultural, Tribal
Cultural, and
Paleontological
Resources
Significant and
Unavoidable
Lesser Lesser Lesser
Energy Less than Significant Lesser Lesser Greater
Greenhouse Gas
Emissions
Less than Significant Lesser Lesser Greater
Hazards and
Hazardous Materials
Less than Significant Lesser Lesser Lesser
Hydrology and Water
Quality
Less than Significant Lesser Similar Similar
Land Use and
Planning
Less than Significant Lesser Similar Similar
Noise Less than Significant Lesser Lesser Lesser
Public Services Less than Significant Lesser Lesser Lesser Transportation and
Traffic
Significant and
Unavoidable with
Mitigation Incorporated
Lesser Similar Similar
7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-19
Table 7-1. Project Alternatives Environmental Impacts Comparison Environmental Issue Project
No Project/No
Development
Alternative
(Alternative 1)
Reduced
Development
Intensity
Alternative
(Alternative 2)
Refrigerated
Warehouse
Alternative
(Alternative 3)
Utilities and Service
Systems
Less than Significant Lesser Similar Similar
Wildfire Less than Significant Lesser Lesser Lesser
7 – ALTERNATIVES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 7-20

INTENTIONALLY LEFT BLANK
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 8-1
8 List of Preparers
Report Preparers
City of Santee (Lead Agency)
Sandi Sawa, AICP, Director of Planning & Building/City Planner Marni Borg, Principal Environmental Planner
Michael Coyne, Former Principal Planner
Minjie Mei, Principal Traffic Engineer
Claire Singh, Senior Civil Engineer
Dudek (Environmental Consultant)
Kristen Stoner, Senior Project Manager
Corinne Resha, Senior Project Manager
Hayley Ward, Environmental Analyst
Mollie Brogdon, Environmental Analyst
Clarisa Olaguez, Environmental Analyst
Tuesday Christopher, Environmental Analyst
Jessica Booth, Environmental Analyst
Jennifer Reed, Senior Air Quality Specialist
David Larocca, Air Quality Specialist
Brock Ortega, Senior Biologist
Danielle Mullen, Biologist
Chris Kallstrand, Arborist
Fallin Steffen, Architectural Historian-Cultural Resources Matthew DeCarlo, Archaeologist
Roshanne Bakhtiary, Archaeologist
Michael Williams, Paleontologist
Jason Collins, Paleontologist
Perry Russell, Senior Geologist
Jim Cowan, Senior Acoustician
Cole Martin, Environmental Acoustician
Sabita Tewani, Senior Transportation Planner
Dennis Pascua, Transportation Services Manager
Dana Link-Herrera, Wildfire and Hazardous Materials Specialist Alison Sells, Wildfire Specialist
Joshua Sanders, Visual Resources Specialist
Kyle Holmes, GIS and Graphics
Kelsey Bacon, GIS and Graphics
Stephanie Hanson-McKenzie, GIS and Graphics
Kathryn Landoe, Technical Editor
Morgan Maddox-Ramsey, Publications Specialist
Felisa Pugay, Publications Specialist
8 – LIST OF PREPARERS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 8-2
EIR Contributors
EIR contributors prepared technical reports that have been included in the EIR.

Scott A. Moomjian (Historical Assessment of the 10990 North Woodside Avenue Property Santee, California 92071)
Scott A. Moomjian, Attorney at Law
NorCal Engineering (Updated Geotechnical Engineering Investigation) Kieth D. Tucker, Project Engineer
Scott D. Spensiero, Project Manager
Hazard Management Consulting Inc. (Phase I Environmental Site Assessment) Mark Cousineau, NREP
DRC Engineering, Inc (Preliminary Hydrology Study, Storm Water Quality Management Plan) Matthew Hellesen, RCE 45629
HDR (Water Study for Development at 10990 North Woodside Drive) Joel Engleson
Younghusband Consulting, Inc (YCI) (Preliminary Fire Protection Technical Report Palisade Santee Commerce Center 10990 Woodside Ave., Santee, CA 92071) John E. Younghusband, P.E.

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-1
9 References
Chapter 1: Executive Summary
None
Chapter 2: Introduction
None
Chapter 3: Project Description
City of Santee. 2003. Santee General Plan. Adopted August 27, 2003. https://www.cityofsanteeca.gov/services/ development-services/planning-and-zoning-services/general-plan.

City of Santee. 2017. City of Santee Land Use Map. Adopted August 27, 2003. Updated July 2017. https://www.cityofsanteeca.gov/home/showpublisheddocument/8547/636362228959170000 City of Santee. 2020. City of Santee Zoning District Map. Adopted August 27, 2003. Updated January 8, 2020. https://www.cityofsanteeca.gov/home/showpublisheddocument/8549/637952158010870000 City of Santee. 2022. City of Santee Housing Element Sixth Cycle 2021-2029. Adopted May 11, 2022 City Council Resolution No. 056-2022. https://www.cityofsanteeca.gov/home/showpublisheddocument/ 8551/638066250344200000
City of Santee. 2023. “About Santee”. Accessed March 20, 2023. https://www.cityofsanteeca.gov/ our-community/about-santee
Kidder Mathews. 2023. San Diego Industrial Market Trends. 4Q 2023. https://kidder.com/wp-content/ uploads/market_report/industrial-market-research-san-diego-2023-4q.pdf Hellesen, Matthew. " RE: 10990 N. Woodside Ave. - Request for Data Inputs." Received by William Jacobs, August 21, 2023.

Chapter 4: Environmental Analysis
None
Section 4.1: Aesthetics
Caltrans. 2024a. California State Scenic Highway System Map. https://caltrans.maps.arcgis.com/apps/ webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa. Accessed May 7, 2024.

Caltrans. 2024b. California State Scenic Highway System Map. https://dot.ca.gov/programs/design/ lap-landscape-architecture-and-community-livability/lap-liv-i-scenic-highways. Accessed May 7, 2024. 9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-2
City of Santee. 2003. Santee General Plan. Adopted August 27, 2003. https://www.cityofsanteeca.gov/services/ development-services/planning-and-zoning-services/general-plan.

City of Santee. 2023a. “About Santee.” Accessed March 20, 2023. https://www.cityofsanteeca.gov/our-city/ about-santee-new.

City of Santee. 2023b. Municipal Code. Updated July 2023. https://library.qcode.us/lib/santee_ca/pub/ municipal_code/item/title_13-chapter_13_14-13_14_040
DOF. 2023. E-1 Cities, Counties, and the State Population and Housing Estimates with Annual Percent Change — January 1, 2022 and 2023. Accessed September 12, 2023. https://dof.ca.gov/forecasting/ demographics/estimates-e1/.

Herdman Architecture + Design. 2024. Site Photometric Plan – Sheet FC-1.0. January 10, 2024. Thid Submittal Plans.

NLPIP (National Lighting Product Information Program). 2007. Lighting Answers. Volume 7 Issue 2. March 2003 revised February 2007.

Section 4.2: Air Quality
14 CCR 15000–15387 and Appendices A–N. Guidelines for Implementation of the California Environmental Quality Act, as amended.
17 CCR 93000. Substances Identified as Toxic Air Contaminants.

CAPCOA (California Air Pollution Control Officers Association). 2021. California Emissions Estimator Model (CalEEMod) User’s Guide Version 2020.4.0. May.

CARB (California Air Resources Board). 2000. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. October 2000. Available: http://www.arb.ca.gov/diesel/documents/ rrpfinal.pdf. Accessed May 2022.

CARB. 2016. “Ambient Air Quality Standards.” May 5, 2016. Available: http://www.arb.ca.gov/research/aaqs/ aaqs2.pdf. Accessed May 2022.

CARB. 2017. California’s 2017 Climate Change Scoping Plan. November. Available: https://ww2.arb.ca.gov/ sites/default/files/classic/cc/scopingplan/scoping_plan_2017.pdf. Accessed May 2022.

CARB 2019. CARB Carbon Monoxide and Health. https://ww2.arb.ca.gov/resources/carbon-monoxide-andhealth#:~:text=Carbon%20monoxide%20is%20harmful%20because,oxygen%20delivery%20to%20the% 20brain. Accessed May 2022.

CARB. 2022a. “Glossary of Air Pollutant Terms.” Accessed May 2022. CARB website. http://www.arb.ca.gov/ html/gloss.htm.

CARB. 2022b. “Overview: Diesel Exhaust and Health.” Available: https://www.arb.ca.gov/research/diesel/ diesel-health.htm. Accessed May 2022.
9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-3
CARB. 2022c. “iADAM: Air Quality Data Statistics.” Available: http://arb.ca.gov/adam. Accessed May 2022.

CARB 2023. CARB Air Quality and Meteorological Information Systems. https://www.arb.ca.gov/aqmis2/ aqmis2.php?_ga=2.209769298.677055909.1717704199-1882937233.1712864421. Accessed May 2022.

City of Santee 2019. Sustainable Santee Plan. Accessed June 2024. https://www.cityofsanteeca.gov/home/ showpublisheddocument/18422/637185004712370000
County of San Diego 2007. Guidelines for Determining Significance and Report Format and Content Requirements – Air Quality. Department of Planning and Land Use, Department of Public Works.

March 19, 2007.

County of San Diego. 2019. “San Diego County Annual Communicable Disease Report 2018.” County of San Diego, Health and Human Services Agency, Public Health Services, Epidemiology and Immunization Services Branch. October 2019.

County of San Diego. 2021. Monthly Communicable Disease Report. Available: https://www.sandiegocounty.gov/ content/dam/sdc/hhsa/programs/phs/Epidemiology/Monthly%20CD%20Report_May%202021.pdf.

Accessed May 2022.

EPA (U.S. Environmental Protection Agency). 2009. “Integrated Science Assessment for Particulate Matter.” EPA/600/R-08/139F.

EPA 2013. Integrated Science Assessment of Ozone and Related Photochemical Oxidants. U.S. EPA, EPA/ 600R-10/076F, 2013.

EPA. 2016. “Criteria Air Pollutants.” July 21, 2016. Accessed August 2016. https://www.epa.gov/ criteria-air-pollutants.EPA. 2021. Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990–2019. https://www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks-1990-2019.

EPA. 2022. “AirData: Access to Air Pollution Data.” Available: http://www.epa.gov/airdata/ad_rep_mon.html.

Accessed May 2022.

EPA 2023. “AirData: Access to Air Pollution Data.” http://www.epa.gov/airdata/ad_rep_mon.html.

EPA 2023a. EPA Criteria Air Pollutants. https://www.epa.gov/criteria-air-pollutants. Accessed May 2022.

OEHHA (Office of Environmental Health Hazard Assessment). 2015. Air Toxics Hot Spots Program Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments 2015.

February 2015. Available: http://oehha.ca.gov/air/hot_spots/2015/2015GuidanceManual.pdf.

Accessed May 2022.

SANDAG (San Diego Association of Governments). 2015. 2015 Regional Plan. Available:
https://www.sdforward.com/2019-federal-rtp/2015-regional-plan. Accessed May 2022.

SANDAG. 2017a. “Series 13: 2050 Regional Growth Forecast.” Available: http://www.sandag.org/index.asp? classid=12&subclassid=84&projectid=503&fuseaction=projects.detail. Accessed May 2022. 9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-4
SANDAG. 2017b. “Comprehensive Transportation Projects: 2050 Regional Transportation Plan.” Available:
http://www.sandag.org/index.asp?projectid=349&fuseaction=projects.detail. Accessed May 2022.

SCAPMD (South Coast Air Quality Management District. 1993. CEQA Air Quality Handbook. Available:

SDAPCD (San Diego Air Pollution Control District). 1976. Rules and Regulations. Regulation IV. Prohibitions. Rule

51. Nuisance. Effective November 8. Available: https://www.sdapcd.org/content/dam/sdapcd/ documents/rules/current-rules/Rule-51.pdf. Accessed May 2022.

SDAPCD. 1997. Rules and Regulations. Regulation IV. Prohibitions. Rule 50. Visible Emissions. Effective August

13. Available: https://www.sdapcd.org/content/dam/sdapcd/documents/rules/current-rules/ Rule-50.pdf. Accessed May 2022.

SDAPCD. 2005. Measures to Reduce Particulate Matter in San Diego County. December 2005. Available:
http://sntbberry.cityofsanteeca.gov/sites/FanitaRanch/Public/Remainder%20of%20the%20Record/(2)% 20Reference%20Documents%20from%20EIR%20&%20Technical%20Reports/Tab%20203% 20-%202005-12%20SDAPCD_Measures%20to%20Reduce%20Particulate%20Matter.pdf. Accessed May 2022.

SDAPCD. 2009b. Rules and Regulations. Regulation IV. Prohibitions. Rule 55. Fugitive Dust. Adopted June 24, 2009; effective December 24, 2009. Available: https://www.sdapcd.org/content/dam/sdapcd/ documents/rules/current-rules/Rule-55.pdf. Accessed May 2022.

SDAPCD. 2015. Rules and Regulations. Regulation IV. Prohibitions. Rule 67.0.1. Architectural Coatings. Revised June 24, 2015. Available: https://www.sdapcd.org/content/dam/sdapcd/documents/rules/rule-archive/ 2021/Rule-67.0.1.pdf. Accessed May 2022.

SDAPCD. 2016a. SDAPCD Regulation II: Permits; Rule 20.2: New Source Review—Non-Major Sources.

January 29, 2016. Available: https://www.sdapcd.org/content/dam/sdapcd/documents/rules/ current-rules/Rule-20.2.pdf. Accessed May 2022.

SDAPCD. 2016b. 2008 Eight-Hour Ozone Attainment Plan for San Diego County. Updated December 2016. http://www.sdapcd.org/content/dam/sdc/apcd/PDF/Air%20Quality%20Planning/8-Hr-O3% 20Attain%20Plan-08%20Std.pdf.

SDAPCD 2020. SDAPCD San Diego 2022 Regional Air Quality Strategy (RAQS) https://www.sdapcd.org/ content/sdapcd/planning.html. March 2023.

SDAPCD. 2022a. Supplemental Guidelines for Submission of Air Toxics “Hot Spots” Program Health Risk Assessments (HRAs). April. Available: https://www.sdapcd.org/content/dam/sdapcd/ documents/permits/air-toxics/Hot-Spots-Guidelines.pdf. Accessed May 2022.

SDAPCD. 2022b. Attainment Status. Available: https://www.sdapcd.org/content/sdapcd/planning/ attainment-status.html. Accessed May 2022.

WRCC (Western Regional Climate Center). 2016. “Vista 2. Temperature and Precipitation.” Accessed May 2022. https://wrcc.dri.edu/cgi-bin/cliMAIN.pl?ca9378.
9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-5
Section 4.3: Biological Resources
CDFW (California Department of Fish and Wildlife). 2023. “California Natural Communities List.” Sacramento, California: CDFW, Vegetation Classification and Mapping Program. June 1, 2023. Accessed July 2023. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=153398&inline.

City of San Diego. 1997. Final EIR/EIS Issuance of Take Authorizations for Threatened and Endangered Species due to Urban Growth within the Multiple Species Conservation Program (MSCP) Planning Area. LDR No. 93-0287. SCH No. 93121073. January 1997. https://www.sandiegocounty.gov/content/dam/ sdc/pds/mscp/docs/SCMSCP/MSCPFinalEIRVol2.pdf.

City of San Diego. 1998. Final MSCP Plan. Prepared by MSCP Policy Committee and MSCP Working Group.

San Diego, California: MSCP Policy Committee and MSCP Working Group. August 1998. http://www.sandiegocounty.gov/content/dam/sdc/pds/mscp/docs/SCMSCP/ FinalMSCPProgramPlan.pdf.

City of Santee 2003. City of Santee General Plan, Conservation Element. https://www.cityofsanteeca.gov/ home/showpublisheddocument/7199/636336570186700000. Adopted August 23, 2003.

City of Santee. 2020. Santee Municipal Code. https://library.qcode.us/lib/santee_ca/pub/municipal_code/ item/title_8-chapter_8_06.

City of Santee. 2023. Notice of Preparation for the Santee Subarea Plan Program Environmental Impact Report.

March 2023. https://www.cityofsanteeca.gov/home/showpublisheddocument/23374/ 638156253470070000
Holland, R.F. 1986. Preliminary Descriptions of the Terrestrial Natural Communities of California. NongameHeritage Program, California Department of Fish and Game. October 1986.

Oberbauer, T., M. Kelly, and J. Buegge. 2008. Draft Vegetation Communities of San Diego County. March 2008. http://www.sdcanyonlands.org/pdfs/veg_comm_sdcounty_2008_doc.pdf.

SWRCB (State Water Resources Control Board). 2021. State Policy for Water Quality Control: State Wetland Definition and Procedures for Discharges of Dredged or Fill Material to Waters of the State. Adopted April 2, 2019; revised April 6, 2021. https://www.waterboards.ca.gov/water_issues/programs/ cwa401/docs/2021/procedures.pdf.

Section 4.4: Cultural, Tribal Cultural, and Paleontological Resources Abbott, P.L. 1999. The Rise and Fall of San Diego: 150 Million Years of History Recorded in Sedimentary Rocks.

San Diego, California: Sunbelt Publications.

BLM (Bureau of Land Management). 2023.General Land Office Records Search for 10990 Woodside Ave N., Santee, CA 92071. Accessed May 5, 2023. https://glorecords.blm.gov/.

California Geological Survey (CGS). 2002. California Geomorphic Provinces: Note 36. 4 pp. 9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-6
Cohen, K.M., S.C. Finney, P.L. Gibbard, and J.-X. Fan. 2023. “The ICS International Chronostratigraphic Chart.” Episodes 36: 199–-204. 2013; updated. Available at: https://stratigraphy.org/ICSchart/ ChronostratChart2023-09.pdf.

Morton, D.M. and F.K. Miller. 2006. Geologic Map of the San Bernardino and Santa Ana 30-minute x 60-minute quadrangles, California, Geology and Description of Map Units, Version 1.0: U.S. Geological Survey, OpenFile Report OF-2006-1217. 194 pp.

NETR (National Environmental Title Research). 2023. Address Search for 10990 Woodside Ave N., Santee, CA 92071. Accessed May 5, 2023. https://www.historicaerials.com/.

Todd, V.R., Alvarez, R.M., and Techni Graphic Systems, Inc., 2004. Preliminary geologic map of the El Cajon 30’ X 60’ quadrangle, southern California: U.S. Geological Survey, Open-File Report OF-2004-1361, scale 1:100,000.

USGS (United States Geological Survey). 2023. Address Search for 10990 Woodside Ave N., City of Santee, California. Accessed May 5, 2023.https://www.historicaerials.com/.

Section 4.5: Energy
CEC (California Energy Commission). 2015. Commission Report: California Energy Demand Updated Forecast, 2015–2025. CEC-200-2014-009-CMF. February 2015. Accessed October 16, 2023. https://www.sandiegocounty.gov/content/dam/sdc/pds/ceqa/JVR/AdminRecord/ IncorporatedByReference/Section-3-1-2---Energy-References/CEC%202015a.pdf.

CEC. 2016. 2015 Integrated Energy Policy Report. CEC-100-2015-001-CMF. June 29, 2016. Accessed February 18, 2019. http://docketpublic.energy.ca.gov/PublicDocuments/15-IEPR-01/ TN212017_20160629T154354_2015_Integrated_Energy_ Policy_Report_Small_File_Size.pdf.

CEC. 2018a. “2019 Building Energy Efficiency Standards Fact Sheet.” March 2018. https://www.energy.ca.gov/ default/files/2020-03/Title_24_2019_Building_Standards_FAQ_ada.pdf.

CEC. 2018b. 2018 Integrated Energy Policy Report Update. August 2018. Accessed October 6, 2022. https://www.energy.ca.gov/data-reports/reports/integrated-energy-policy-report/ 2018-integrated-energy-policy-report-update.

CEC. 2019. 2019 Building Energy Efficiency Standards. Available: https://www.energy.ca.gov/programs-andtopics/programs/building-energy-efficiency-standards/2019-building-energy-efficiency. Accessed October 2023. CEC. 2020. “Electricity Consumption by County” [webpage]. Accessed May 2022. http://www.ecdms.energy.ca.gov/elecbycounty.aspx.

CEC. 2020. Electricity Consumption by County, San Diego County, 2020. Accessed June 2024. https://ecdms.energy.ca.gov/elecbycounty.aspx.

CEC. 2021. 2021 Building Energy Efficiency Standards Summary. Accessed October 2023. https://www.energy.ca.gov/sites/default/files/2021-08/CEC_2022_ EnergyCodeUpdateSummary_ADA.pdf.
9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-7
CEC. 2022a. “Gas Consumption by Entity” [database]. Accessed May 2022. http://www.ecdms.energy.ca.gov/ gasbyutil.aspx.

CEC. 2022b. “Gas Consumption by County” [database]. Accessed May 2022. http://www.ecdms.energy.ca.gov/ gasbycounty.aspx.

CEC. 2023. California Energy Demand Forecast, 2021-2035. https://www.energy.ca.gov/data-reports/ reports/integrated-energy-policy-report/2021-integrated-energy-policy-report/2021-1.

City of Santee. 2019. Sustainable Santee Plan. Accessed June 2024. https://www.cityofsanteeca.gov/home/showpublisheddocument/18422/637185004712370000 CPUC. 2022. “Natural Gas and California” [webpage]. Accessed September 2022. https://www.cpuc.ca.gov/natural_gas/.

CPUC. 2023. “Natural Gas and California.” Accessed October 2023. https://www.cpuc.ca.gov/ industries-and-topics/natural-gas/natural-gas-and-california.

DMV (California Department of Motor Vehicles). 2022. “Vehicles Registered by County in 2021” [database]. https://www.dmv.ca.gov/portal/dmv-research-reports/research-development-data-dashboards/ vehicles-registered-by-county/.

EIA (U.S. Energy Information Administration). 2018. “California State Profile and Energy Estimates – Table F15:

Total Petroleum Consumption Estimates, 2016.” California: State Profile and Energy Estimates. http://www.eia.gov/state/seds/data.cfm?incfile=/state/seds/sep_fuel/html/fuel_use_pa.html&sid= US&sid=CA.

EIA. 2019. “California State Energy Profile.” Last updated November 15, 2018. https://www.eia.gov/state/ print.php?sid=CA.

EIA. 2020a. “California Electricity Profile 2019.” EIA, Electricity. Released November 2, 2020. https://www.eia.gov/electricity/state/california/index.cfm.

EIA. 2020b. “California State Energy Profile.” Last updated January 16, 2020. https://www.eia.gov/state/ print.php?sid=CA.

EIA. 2021. “Natural Gas Consumption by End Use (California, 2019).” EIA, Natural Gas. Released February 26, 2021. https://www.eia.gov/dnav/ng/ng_cons_sum_dcu_SCA_a.htm.

EPA (U.S. Environmental Protection Agency). 2022. “Energy Independence and Security Act of 2007” [webpage].

Updated June 29, 2022. Accessed October 13, 2022. https://www.epa.gov/greeningepa/ energy-independence-and-security-act-2007.

EPA and NHTSA (National Highway Transportation Safety Administration). 2016. “EPA and NHTSA Adopt Standards to Reduce Greenhouse Gas Emissions and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles for Model Year 2018 and Beyond.” EPA-420-F-16-044. Regulatory Announcement. EPA, Office of Transportation and Air Quality. August 2016.
9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-8
EPA and NHTSA. 2018. The Safer Affordable Fuel-Efficient 'SAFE' Vehicles Rule for Model Years 2021-2026 Passenger Vehicles and Light Trucks. Proposed Rule August 2018. Accessed May 2019. https://www.govinfo.gov/content/pkg/FR-2018-08-24/pdf/2018-16820.pdf.

GO-Biz (California Governor’s Office of Business and Economic Development). 2021. California Zero-Emission Vehicle Market Development Strategy. February 2021. Accessed October 6, 2023. https://business.ca.gov/wp-content/uploads/2021/02/ZEV_Strategy_Feb2021.pdf.

SDG&E (San Diego Gas & Electric). 2022. “About Us” [webpage]. Accessed October 13, 2022. https://www.sdge.com/more-information/our-company/about-us.

SDG&E. 2023. “Energy Data Access.” Energy Data Request Program. https://energydata.sdge.com/.

The Climate Registry. 2019. “Default Emission Factors.” May 1, 2019. Accessed October 17, 2023. https://files.ceqanet.opr.ca.gov/123569-2/attachment/lvRWwjK7OBJyjGQmZvL0MVvKraHCiePwRVagWeEr6ULpUsqmbQpPyoogtF0gjHpsL8hYddKBozNxgEd0.

Section 4.6: Greenhouse Gas Emissions
14 CCR 15000–15387 and Appendices A–N. Guidelines for Implementation of the California Environmental Quality Act, as amended.
17 CCR 93000. Substances Identified as Toxic Air Contaminants.

CalRecycle. 2015. AB341 Report to the Legislature (DRRR-2015-1538 https://www2.calrecycle.ca.gov/ Publications/Details/1538. CalRecyle.

CAPCOA. 2021. California Emissions Estimator Model (CalEEMod) User’s Guide Version 2020.4.0. May.

CARB. 2008. Climate Change Scoping Plan. December. Available: https://ww2.arb.ca.gov/sites/default/files/ classic/cc/scopingplan/document/adopted_scoping_plan.pdf. Accessed May 2022.

CARB. 2014. First Update to the Climate Change Scoping Plan Building on the Framework Pursuant to AB 32 – The California Global Warming Solutions Act of 2006. May 2014. Available: https://ww2.arb.ca.gov/sites /default/files/classic/cc/scopingplan/2013_update/first_update_climate_change_scoping_plan.pdf.

Accessed May 2022.

CARB. 2015. CARB Glossary. https://ww2.arb.ca.gov/glossary. Accessed May 2022.

CARB. 2017. California’s 2017 Climate Change Scoping Plan. November. Available: https://ww2.arb.ca.gov/ sites/default/files/classic/cc/scopingplan/scoping_plan_2017.pdf. Accessed May 2022.

CARB. 2022a. Current California GHG Emission Inventory Data 2000-2019 GHG Inventory (2021 Edition). April 1.

Available: https://ww2.arb.ca.gov/ghg-inventory-data. Accessed May 2022.

CARB. 2022b. 2022 Scoping Plan Documents. https://ww2.arb.ca.gov/resources/documents/2022-scopingplan-documents 9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-9
CAT. 2024.California EPA. Climate Action Team 2023 Report Card. https://calepa.ca.gov/climate-action/ Accessed June 2024.

CEC. 2018. 2019 Building Energy Efficiency Standards. Available: https://www.energy.ca.gov/programs-andtopics/programs/building-energy-efficiency-standards/2019-building-energy-efficiency. Accessed May 2022.

CEC. 2021. California Energy Commission (CEC). 2022 Building Energy Efficiency Standards. https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards/ 2022-building-energy-efficiency
City of Santee. 2017, 2020. City of Santee Municipal Code. City Zoning Code. https://ecode360.com/SA5010.

Accessed May 2022.

City of Santee. 2019. Sustainable Santee Plan. Accessed June 2024. https://www.cityofsanteeca.gov/home/ showpublisheddocument/18422/637185004712370000
CNRA. 2009a. Final Statement of Reasons for Regulatory Action. December. Available: https://resources.ca.gov/ CNRALegacyFiles/ceqa/docs/Final_Statement_of_Reasons.pdf. Accessed May 2022.

CNRA. 2009b. 2009 California Climate Adaptation Strategy. Available: https://resources.ca.gov/ CNRALegacyFiles/docs/climate/Statewide_Adaptation_Strategy.pdf. Accessed May 2022.

CNRA. 2014. Safeguarding California: Reducing Climate Risk. Available: https://cawaterlibrary.net/document/ safeguarding-california-reducing-climate-risk-an-update-to-the-2009-california-climate-adaptationstrategy/. Accessed May 2022.

CNRA. 2019. California’s Fourth Climate Change Assessment: San Diego Region Report. March 2019. Accessed April 2022 at https://www.energy.ca.gov/sites/default/files/2019-11/Reg_Report-SUM-CCCA4-2018- 009_SanDiego_ADA.pdf.

EPA (U.S. Environmental Protection Agency). 2016. Glossary of Climate Change Terms. https://19january2017snapshot.epa.gov/climatechange/glossary-climate-change-terms_.html. Accessed May 2022.

EPA. 2021. Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990–2019. https://www.epa.gov/ ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks-1990-2019.

EPA. 2022b. Basics of Climate Change. February 23. Available: https://www.epa.gov/climatechange-science/ basics-climate-change. Accessed May 2022.

EPA. 2022c. Midterm Evaluation of Light-Duty Vehicle Greenhouse Gas Emissions Standards for Model Years 2022-2025. Available: https://www.epa.gov/regulations-emissions-vehicles-and-engines/ midterm-evaluation-light-duty-vehicle-greenhouse-gas. Accessed May 2022. 9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-10
EPA and NHTSA (Department of Transportation’s National Highway Traffic Safety Administration). 2016. EPA and NHTSA Adopt Standards to Reduce Greenhouse Gas Emissions and Improve Fuel Efficiency of Mediumand Heavy-Duty Vehicles for Model Year 2018 and Beyond. August 2016. Available:
https://nepis.epa.gov/Exe/ZyPDF.cgi/P100P7NL.PDF?Dockey=P100P7NL.PDF. Accessed May 2022.

EPA and NHTSA. 2018. The Safer Affordable Fuel-Efficient 'SAFE' Vehicles Rule for Model Years 2021-2026 Passenger Vehicles and Light Trucks. Proposed Rule August 2018. Available: https://www.govinfo.gov/ content/pkg/FR-2018-08-24/pdf/2018-16820.pdf. Accessed May 2022.

EPIC. 2015. 2012 Greenhouse Gas Emissions Inventory and Projections for the San Diego Region. August.

Available: https://www.sdforward.com/pdfs/Final_PDFs/AppendixD.pdf. Accessed May 2022.

IPCC. 1995. Intergovernmental Panel on Climate Change (IPCC). IPCC Second Assessment Report Climate Change 1995. http://www.ipcc.ch/pdf/climate-changes-1995/ipcc-2nd-assessment/2nd-assessment-en.pdf IPCC (Intergovernmental Panel on Climate Change). 2007. Climate Change 2007: The Physical Science Basis.

Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor and H.L.

Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA, 996 pp.

Accessed May 2019. http://www.ipcc.ch/pdf/assessment-report/ar4/wg1/ar4_wg1_full_report.pdf.

IPCC. 2014. Climate Change 2014 Synthesis Report: A Report of the Intergovernmental Panel on Climate Change. Contribution of Working Groups I, II and III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change. Accessed May 2019. http://www.ipcc.ch/report/ar5/syr/.

IPCC. 2018: Summary for Policymakers. In: Global Warming of 1.5°C. An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and efforts to eradicate poverty [Masson-Delmotte, V., P. Zhai, H.-O. Pörtner, D.

Roberts, J. Skea, P.R. Shukla, A. Pirani, W. Moufouma-Okia, C. Péan, R. Pidcock, S. Connors, J.B.R.

Matthews, Y. Chen, X. Zhou, M.I. Gomis, E. Lonnoy, T. Maycock, M. Tignor, and T. Waterfield (eds.)]. In Press. Available: https://www.ipcc.ch/site/assets/uploads/sites/2/2019/05/ SR15_SPM_version_report_LR.pdf. Accessed May 2022.

OEHHA. 2018. Indicators of Climate Change. August 30. Available: https://oehha.ca.gov/climatechange/document/indicators-climate-change-california. Accessed May 2022.

OPR. 2007. Senate Bill No. 97 Chapter 185. Available: https://opr.ca.gov/docs/SB_97_bill_ 20070824_chaptered.pdf. Accessed May 2022.

PBL (PBL Netherlands Environmental Assessment Agency). 2020. Trends in Global CO2 and Total Greenhouse Gas Emissions, 2020 Report. December 2020. https://www.pbl.nl/sites/default/files/downloads/ pbl-2020-trends-in-global-co2-and_total-greenhouse-gas-emissions-2020-report_4331.pdf.

SANDAG. 2015. 2015 Regional Plan. Available: https://www.sdforward.com/2019-federal-rtp/2015-regionalplan. Accessed May 2022. 9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-11
SANDAG. 2021. SANDAG 2021 Regional Plan. Adopted December 10, 2021. Accessed April 2022. https://sdforward.com/mobility-planning/2021-regional-plan Section 4.7: Hazards and Hazardous Materials
CAL FIRE (California Department of Forestry and Fire Protection). 2023. FHSZ Viewer. Accessed June 2023. https://calfire-forestry.maps.arcgis.com/apps/webappviewer/index.html?id= 988d431a42b242b29d89597ab693d008
CalEPA (California Environmental Protection Agency). 2023a. “About Us.” Accessed June 2023. https://calepa.ca.gov/about/.

CalEPA. 2023b. “Background and History.” Accessed June 2023. https://calepa.ca.gov/sitecleanup/ corteselist/Background/.

City of Santee. 2003. Santee General Plan Safety Element. Accessed June 2023. https://www.cityofsanteeca.gov/documents/planning-building/general-plan/gp-safety-element.pdf City of Santee. 2023. City of Santee Hazard Mitigation Plan 2023. Accessed June 2023. https://www.sandiegocounty.gov/content/dam/sdc/oes/emergency_management/HazMit/2023/ 2023%20City%20of%20Santee%20Haz%20Mit%20Annex_Final%20.pdf City of Santee. 2023c. Santee, California Municipal Code. Accessed June 2023. https://ecode360.com/SA5010 County of San Diego. 2017. Multi-Jurisdictional Hazard Mitigation Plan. Prepared by the County of San Diego Office of Emergency Services and the San Diego County Unified Disaster Council. October 2017.

Accessed June 2023. https://www.sandiegocounty.gov/content/dam/sdc/oes/ emergency_management/HazMit/2018/2018%20Hazard%20Mitigation%20Plan.pdf.

County of San Diego. 2020. County of San Diego 2020 Consolidated Fire Code. Accessed June 2023. https://www.sandiegocounty.gov/content/dam/sdc/sdcfa/documents/prevention/ 2020-County-Consolidated-Fire-Code-FINAL.pdf.

County of San Diego. 2022. San Diego County Emergency Operations Plan. Prepared by the Unified San Diego County Emergency Services Organization and the County of San Diego. Approved August 30, 2022. https://www.sandiegocounty.gov/content/sdc/oes/emergency_management/oes_jl_oparea.html#:~:text =San%20Diego%20County%20Emergency%20Operations%20Plan%20The%20San,county%20to% 20respond%20to%20major%20emergencies%20and%20disasters.

DEH (San Diego County Department of Environmental Health). 2023. “Hazardous Materials Division” Accessed June 2023. https://www.sandiegocounty.gov/content/sdc/deh/hazmat.html.

DTSC (Department of Toxic Substances Control). 2023. Envirostor. Accessed June 2023. https://www.envirostor.dtsc.ca.gov/public/map/?myaddress=10990+N+Woodside+Avenue+Santee.

EPA. 2022a. “Summary of the Toxic Substances Control Act.” Last updated October 4, 2022. Accessed June 2023. https://www.epa.gov/laws-regulations/summary-toxic-substances-control-act. 9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-12
EPA. 2022b. “Resources Conservation and Recovery Act (RCRA) Overview.” Last updated June 29, 2022.

Accessed June 2022. https://www.epa.gov/rcra/resource-conservation-and-recovery-act-rcra-overview.

EPA (U.S. Environmental Protection Agency). EPA. 2023a. “Superfund: CERCLA Overview.” Last updated January 24, 2023. Accessed June 2023. https://www.epa.gov/superfund/superfund-cercla-overview.

EPA. 2023b. “The Superfund Amendments and Reauthorization Act (SARA).” Last updated April 10, 2023.

Accessed June 2023. https://www.epa.gov/superfund/superfund-amendments-andreauthorization-act-sara.

EPA. 2024. “Overview of the Asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP).” Accessed May 20th,2024. https://www.epa.gov/asbestos/overview-asbestos-national-emissionstandards-hazardous-air-pollutants-neshap.

FAA (Federal Aviation Administration). 2023a. “Safety: The Foundation of Everything We Do.” Accessed June 2023. https://www.faa.gov/about/mission/activities.

FAA (Federal Aviation Administration). 2023b. “Determination of No Hazard to Air Navigation.” Letter report from N. Sanders (Technician, FAA) to W. Jacobs (North Palisade Opco, LLC). December 27, 2023.

FEMA (Federal Emergency Management Agency). 1999. Federal Response Plan. April 1999. http://biotech.law.lsu.edu/blaw/FEMA/frpfull.pdf.

OES (California Governor’s Office of Emergency Services). 2017. California Emergency Services Act, California Disaster Assistance Act, Emergency Compacts, and California Disaster and Civil Defense Master Mutual Aid Agreement. https://www.caloes.ca.gov/wp-content/uploads/Preparedness/Documents/ California_State_Emergency_Plan_2017.pdf.

OSHA (Occupational Safety and Health Administration). 2014. “At-A-Glance OSHA.” OSHA 3439 2014. https://www.osha.gov/Publications/3439at-a-glance.pdf.

SDCRAA (San Diego County Regional Airport Authority). 2010. Gillespie Field Airport Land Use Compatibility Plan.

Adopted January 25, 2010. Amended December 20, 2010. https://www.cityofsanteeca.gov/ documents/planning-building/plans/gillespie-field-airport-land-use-compatibility-plan.pdf SWRCB (California State Water Resources Control Board). 2023. Geotracker. Accessed June 2023. https://geotracker.waterboards.ca.gov/map/?CMD=runreport&myaddress=10990+N+Woodside+ Avenue+Santee#.

Section 4.8: Hydrology and Water Quality
BSI Consultants. 1990. City of Santee Citywide Drainage Study. Prepared for the City of Santee. February 1990.

Accessed September 27, 2023. https://www.cityofsanteeca.gov/documents/engineering/flood-zonedrainage/citywide-drainage-study.pdf. 9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-13
California DWR (Department of Water Resources). 2004. San Diego River Valley Groundwater Basin. California Groundwater Bulletin 118. Accessed September 24, 2023. https://water.ca.gov/-/media/DWR-Website/ Web-Pages/Programs/Groundwater-Management/Bulletin-118/Files/2003-Basin-Descriptions/ 9_015_SanDiegoRiverValley.pdf.

City of Santee. 2015. Guidelines for Surface Water Pollution Prevention. Accessed September 25, 2023. https://www.cityofsanteeca.gov/documents/engineering/storm-water/general/guidelines-for-swpp.pdf.

City of Santee. 2016. City of Santee BMP Design Manual For Permanent Site Design, Storm Water Treatment and Hydromodification Management. Accessed July 2024. https://www.cityofsanteeca.gov/documents/ engineering/storm-water/regulations-plans-reports/bmp-design-manual.pdf.

City of Santee. 2023 (July 20). City of Santee Master Drainage Study Update. Prepared by Rick Engineering Company, San Diego, California.

County of San Diego. 2023. Our San Diego River Watershed. Accessed September 23, 2023. https://www.sandiegocounty.gov/content/dam/sdc/dpw/WATERSHED_PROTECTION_PROGRAM/watersh edpdf/Watersheds/Watershed_SDR.pdf.

County of San Diego Public Works. 2020. County of San Diego BMP Design Manual for Permanent Site Design, Storm Water Treatment, and Hydromodification Management. Second Update to February 2016 Manual, effective September 15, 2020. Accessed September 25, 2023. https://www.sandiegocounty.gov/ content/dam/sdc/dpw/WATERSHED_PROTECTION_PROGRAM/watershedpdf/Dev_Sup/BMPDM_ Chapters_Sep2020.pdf.

FEMA (Federal Emergency Management Agency). 2023. FEMA’s National Flood Hazard Layer (NFHL) Viewer.

Accessed September 2023. https://hazards-fema.maps.arcgis.com/apps/webappviewer/index.html? id=8b0adb51996444d4879338b5529aa9cd.

Geosyntec. 2019. Water Quality Technical Report, San Diego State University Mission Valley Campus Project.

Prepared for Gatzke Dillon & Balance LLP, December 2019.

Groundwater Exchange. 2023. San Diego River Valley. Accessed September 24, 2023. https://groundwaterexchange.org/basin/san-diego-river-valley/.

PDMWD (Padre Dam Municipal Water District). 2021. 2020 Urban Water Management Plan. Dated June 2021.

Accessed September 23, 2023. https://www.padredam.org/DocumentCenter/View/5620/2020-UrbanWater-Management-Plan?bidId=.

PDMWD. 2023. Water Supply. Accessed September 25, 2023. https://www.padredam.org/140/Water-Supply.

Project Clean Water. 2022. San Diego River. Accessed September 23, 2023. https://projectcleanwater.org/ watersheds/san-diego-river-wma/.

San Diego County Water Authority. 2023. Groundwater. Accessed September 24, 2023. https://www.sdcwa.org/ your-water/local-water-supplies/groundwater/.
9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-14
San Diego RWQCB (Regional Water Quality Control Board). 2021. Water Quality Control Plan for the San Diego Basin. Accessed September 24, 2023. https://www.waterboards.ca.gov/sandiego/water_issues/ programs/basin_plan/.

SDSU (San Diego State University). 2020. Final, San Diego State University Mission Valley Campus Master Plan Environmental Impact Report. Prepared by Dudek, January 2020.

SWRCB (State Water Resources Control Board). 2023a. Impaired Water Bodies. Accessed September 24, 2023. https://www.waterboards.ca.gov/water_issues/programs/tmdl/integrated2014_2016.shtml.

SWRCB. 2023b. GSA Map Viewer. Accessed September 24, 2023. https://sgma.water.ca.gov/webgis/index.jsp? jsonfile=https%3a%2f%2fsgma.water.ca.gov%2fportal%2fresources%2fjs%2fmapconfigs%2fGsaMaster.js.

Section 4.9: Land Use and Planning
City of Santee. 2003. Santee General Plan, Land Use Element and Safety Element. Accessed June 2024. https://www.cityofsanteeca.gov/government/planning-and-building/land-use-code/general-plan City of Santee. 2023. About Santee. Accessed June 2023. https://www.cityofsanteeca.gov/our-city/ about-santee-new.

SANDAG (San Diego Association of Governments). 2021. 2021 Regional Plan. https://www.sandag.org/ regional-plan/2021-regional-plan/-/media/8D0F181A086844E3A84C3D44576BED6B.ashx SANDAG. 2023. Regional Transportation Congestion Improvement Program. Accessed June 2023. https://www.sandag.org/funding/transnet/regional-transportation-congestion-management-program SDAPCD (San Diego Air Pollution Control District). 2013. Air Quality Monitoring Quality Management Plan (QMP).

Accessed June 2023. https://www.sdapcd.org/content/dam/sdapcd/documents/monitoring/ SDAPCD-QMP.pdf
Section 4.10: Noise
Baltrënas, P., D. Kazlauskas, & E. Petraitis. 2004. Testing on noise level prevailing at motor vehicle parking lots and numeral simulation of its dispersion. Journal of Environmental Engineering and Landscape Management, 12:2, 63-70
Caltrans (California Department of Transportation). 2013. Technical Noise Supplement to the Traffic Noise Analysis Protocol. September.

Caltrans. 2020. Transportation and Construction Vibration Guidance Manual. Division of Environmental Analysis, Environmental Engineering, Hazardous Waste, Air, Noise, Paleontology Office. Sacramento, California. April.

City of Santee. 2003. General Plan. https://www.cityofsanteeca.gov/services/development-services/ planning-and-zoning-services/general-plan
City of Santee. January 2023. Municipal Code. https://library.qcode.us/lib/santee_ca/pub/ municipal_code/item/title_5-chapter_5_04.
9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-15
DOT (U.S. Department of Transportation). 2006. FHWA Roadway Construction Noise Model: User’s Guide. Final Report. FHWA-HEP-06-015. DOT-VNTSC-FHWA-06-02. Cambridge, Massachusetts: DOT, Research and Innovative Technology Administration. Final Report. August.

FHWA (Federal Highway Administration). December 8, 2008. Roadway Construction Noise Model (RCNM), Software Version 1.1. U.S. Department of Transportation, Research and Innovative Technology Administration, John A.

Volpe National Transportation Systems Center, Environmental Measurement and Modeling Division.

Washington, D.C.

FICON. 1992. Federal Agency Review of Selected Airport Noise Analysis Issues. Federal Interagency Committee on Noise. August 1992.

FTA (Federal Transit Administration). 2018. Transit Noise and Vibration Impact Assessment. FTA Report No. 0123. September.

International Code Council (ICC). 2019. 2019 California Green Building Standards Code, Title 24, Part 11, Chapter 5. First Printing. July. https://codes.iccsafe.org/content/CAGBSC2019/chapter-5-nonresidentialInternational Organization of Standardization (ISO). 1996. Standard 9613-2 (Acoustics – Attenuation of sound during propagation outdoors – Part 2: General method of calculation). Geneva.

OPR (Governor’s Office of Planning and Research). 2017. State of California General Plan Guidelines. July 2017.

Salter, Charles. March 2014. Midpoint at 237: Loading Dock Noise Study. San Jose, California.

Section 4.11: Public Services
City of Santee. 2003. Santee General Plan. Adopted August 27, 2003. https://www.cityofsanteeca.gov/services/ development-services/planning-and-zoning-services/general-plan.

City of Santee. 2022. City of Santee Housing Element Rezone Program Implementation PEIR SCH #2021100263. https://files.ceqanet.opr.ca.gov/273555-2/attachment/
kPH36a-BvtIip2P3KMGeAHkcfdsGgmkgqQJYD4ZUNn_k4z-gun6gsBes2_lJtclkVL588OeyTA6H10Ct0.

City of Santee. 2023. Santee Parks, Fields and Trails. Accessed June 2023. https://www.cityofsanteeca.gov/ our-city/parks-civic-center-rooms/city-parks-674.

GUHSD (Grossmont Union High School District). 2024. GUHSD School Locator. Accessed May 2024. https://www.guhsd.net/Schools/School-Enrollment-Information/Attendance-Boundaries/.

SDCSD (San Diego County Sheriff’s Department). 2023. San Diego County Sheriff’s Department 2023 Annual Report. Accessed June 2024. https://www.sdsheriff.gov/home/showpublisheddocument/ 8200/638515391306970000.

SDCSD. 2024. San Diego Sheriff Department. Santee Station. Accessed June 2023. https://www.sdsheriff.gov/ Home/Components/FacilityDirectory/FacilityDirectory/42/ 9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-16
SSD (Santee School District). 2023. Santee School District Boundary. Accessed January 2024. https://locator.pea.powerschool.com/?StudyID=112731%09.

Section 4.12: Transportation
AASHTO (American Association of State Highway and Transportation Officials). A policy on Geometric Design of Highways and Streets. 2018. 7th Edition
Caltrans (California Department of Transportation). 2020. Vehicle Miles Traveled-Focused Transportation Impact Study Guide. May 20, 2020.

CAPCOA (California Air Pollution Control Officers Association). 2021. Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity.

City of Santee. 2017. General Plan Mobility Element, Adopted October 25, 2017.

City of Santee. 2021. City of Santee, Active Santee Plan. January 2021. Available: active-santee-plan.pdf (cityofsanteeca.gov)
City of Santee. 2022. City of Santee VMT Analysis Guidelines. April 13, 2022 ITE (Institute of Transportation Engineers). 2021. Trip Generation Manual. 11th ed.

OPR (California Governor’s Office of Planning and Research). 2018. Technical Advisory on Evaluating Transportation Impacts in CEQA. December 2018. Accessed October 2023. http://opr.ca.gov/ docs/20190122-743_Technical_Advisory.pdf.

SANDAG (San Diego Association of Governments). 2002. Brief Guide of Vehicular Trip Generation Rates for the San Diego Region. April 2002.

SANDAG. 2021. 2021 Regional Plan. December 2021. https://www.sandag.org/regional-plan/2021-regionalplan/-/media/8D0F181A086844E3A84C3D44576BED6B.ashx.

SCAQMD (South Coast Air Quality Management District). 2014. Warehouse Truck Trip Study Data Results and Usage. Inland Empire Logistics Council. June 2014. https://www.aqmd.gov/docs/defaultsource/ceqa/handbook/high-cube-warehouse-trip-rate-study-for-air-quality-analysis/ final-ielc_6-19-2014.pdf?sfvrsn=2.

Section 4.13: Utilities and Services Systems
CALGreen (California Green Building Standards Code). 2022. 2022 California Green Building Standards Code California Code of Regulations Title 24, Part 11 with August 2019 Supplement. https://codes.iccsafe.org/ content/CAGBSC2019/cover.

CalRecycle. 2019. SWIS Facility/Site Summary Sycamore Landfill (37-AA-0023). https://www2.calrecycle.ca.gov/ SolidWaste/Site/Summary/2871
9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-17
CalRecycle. 2023. SWIS Facility/Site Summary Las Pulgas Landfill (37-AA-0903). https://www2.calrecycle.ca.gov/ SolidWaste/Site/Summary/2901
City of San Diego. 2023. Point Loma Wastewater Treatment Plant. https://www.sandiego.gov/public-utilities/ customer-service/water-wastewater-facilities/point-loma City of Santee. 2003. Santee General Plan. Adopted August 27, 2003. https://www.cityofsanteeca.gov/ departments/city-clerk/document-central/planning-building/general-plan City of Santee. 2024. Solid Waste and Recycling Services. https://www.cityofsanteeca.gov/services/ solid-waste-recycling-services
EPA (Environmental Protection Agency). 2009. Building-Related Construction and Demolition Amounts. 2009.

PDMWD (Padre Dam Municipal Water District). 2019. Sewer System Management Plan. Updated April 2019. https://www.padredam.org/DocumentCenter/View/3555/SSMP-April-2019 PDMWD. 2021. 2020 Urban Water Management Plan. Dated June 2021. Accessed July 2023. https://www.padredam.org/DocumentCenter/View/5620/2020-Urban-Water-Management-Plan?bidId=.

PDMWD. 2022. 2022 Padre Dam Municipal Water District Final Master Plan Update. Accessed July 2023. https://www.padredam.org/DocumentCenter/View/5861/Padre-Dam-Master-Plan-UpdateReport?bidId=.

PDMWD. 2023. Water Recycling Facility. https://www.padredam.org/130/Water-RecyclingFacility#:~:text=Relocated%20to%20its%20present%20site%20north%20of%20Santee,nitrogen% 20and%20phosphorous%20without%20the%20use%20of%20chemicals.

SDG&E (San Diego Gas & Electric). 2022. About Us. https://www.sdge.com/more-information/our-company/ about-us.

SDG&E. 2024. High Pressure Gas Pipeline Map. Accessed May 2024. https://www.sdge.com/safety/ gas-safety/pipeline-map.

Section 4.14: Wildfire
Alexander, M.E., B.J. Stocks, B.M. Wotton, M.D. Flannigan, J.B. Todd, B.W. Butler, and R.A. Lanoville. 1998. The International Crown Fire Modeling Experiment: An Overview and Progress Report. In: Proceedings of the Second Symposium on Fire and Forest Meteorology. January 12–14, 1998; Phoenix, Arizona. Boston, Massachusetts: American Meteorological Society, 20–23.

CAL FIRE (California Department of Fire and Forestry). 2009. Fire Hazard Severity Zones Maps. Map: Very High Fire Hazard Severity Zones in the LRA – Santee. Dated June 11, 2009. Accessed January 30, 2024. https://cdnverify.osfm.fire.ca.gov/media/5968/santee.pdf.

CAL FIRE. 2018. 2018 Strategic Fire Plan for California. August 22, 2018. 9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-18
CAL FIRE. 2022. Historic Fire Perimeters 2022. https://calfire-forestry.maps.arcgis.com/apps/mapviewer/ index.html?layers=e3802d2abf8741a187e73a9db49d68fe.

CAL FIRE. 2023. FHSZ Viewer. Accessed September 12, 2023. https://egis.fire.ca.gov/FHSZ/.

City of Santee. 2003. Santee General Plan. Accessed June 2024. https://www.cityofsanteeca.gov/government/ planning-and-building/land-use-code/general-plan.

City of Santee. 2023. City of Santee Hazard Mitigation Plan 2023. Accessed June 2023. https://www.sandiegocounty.gov/content/dam/sdc/oes/emergency_management/HazMit/2023/ 2023%20City%20of%20Santee%20Haz%20Mit%20Annex_Final%20.pdf Cohen, J.D. 1995. Structure Ignition Assessment Model (SIAM). In Proceedings of the Biswell Symposium: Fire Issues and Solutions in Urban Interface and Wildland Ecosystems. Weise, D.R., and R.E. Martin, technical coordinators. February 15–17, 1994; Walnut Creek, CA. Gen. Tech. Rep. PSW-GTR-158. Albany, California: Pacific Southwest Research Station, Forest Service, U.S. Department of Agriculture; 85–92.

Cohen, J.D. 2000. Preventing Disaster: Home Ignitability in the Wildland-Urban Interface. Journal of Forestry 98(3): 15–21.

County of San Diego. 2017. Multi-Jurisdictional Hazard Mitigation Plan. Prepared by the County of San Diego Office of Emergency Services and the San Diego County Unified Disaster Council. October 2017.

Accessed June 2023. https://www.sandiegocounty.gov/content/dam/sdc/oes/ emergency_management/HazMit/2018/2018%20Hazard%20Mitigation%20Plan.pdf.

County of San Diego. 2022. General Plan Safety Element. Accessed February 8th, 2024.

County of San Diego. 2023. Multi-Jurisdictional Hazard Mitigation Plan. Accessed June 2024. https://www.sandiegocounty.gov/content/dam/sdc/oes/emergency_management/HazMit/2023/ MJHMP_SD%20County%20Base%20Plan%202023.pdf.

DOI and USDA (U.S. Department of the Interior and U.S. Department of Agriculture). 2000. Managing the Impact of Wildfires on Communities and the Environment. https://www.forestsandrangelands.gov/ documents/resources/reports/2001/8-20-en.pdf.

FEMA (Federal Emergency Management Agency). 2023. FEMA’s National Flood Hazard Layer (NFHL) Viewer.

Accessed September 2023. https://hazards-fema.maps.arcgis.com/apps/webappviewer/ index.html?id=8b0adb51996444d4879338b5529aa9cd.

IBHS (Institute for Business and Home Safety). 2008. Mega Fires: The Case for Mitigation. https://disastersafety.org/wp-content/uploads/wildfire_megafires_full.pdf. 9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-19
International Code Council. 2017. 2017 International Fire Code. https://codes.iccsafe.org/content/IFC2018/ effective-use-of-the-international-fire-code.

Moench, R. and J. Fusaro. 2012. Soil Erosion Control after Wildfire. https://extension.colostate.edu/ wp-content/uploads/2023/05/Soil-Erosion-Control-After-Wildfire-FINAL.pdf.

National Wildfire Coordinating Group. 2009. Guidance for Implementation of Federal Wildland Fire Management Policy. February 13, 2009.

NorCal Engineering. 2024. Geotechnical Engineering Investigation. Proposed Industrial Warehouse Development.

WeatherSpark. 2023. Climate and Average Weather Year Round in Santee. Accessed September 12, 2023. https://weatherspark.com/y/2071/Average-Weather-in-Santee-California-United-States-YearRound#Sections-Summary.

Chapter 5: Effects Found Not To Be Significant
CGS (California Geological Survey). 2015. Fault Activity Map of California. Accessed September 22, 2023. https://maps.conservation.ca.gov/cgs/fam/.

CGS. 2023. Earthquake Zones of Required Investigation. Accessed September 22, 2023. https://maps.conservation.ca.gov/cgs/EQZApp/app/
City of Santee. 2003. Santee General Plan. Adopted August 27, 2003. https://www.cityofsanteeca.gov/services/ development-services/planning-and-zoning-services/general-plan.

City of Santee. 2022. Draft Program Environmental Impact Report (DPEIR) for the City of Santee Housing Element Rezone Program Implementation SCH #2021100263. June 17, 2022. https://www.cityofsanteeca.gov/ home/showpublisheddocument/22332/637910492391800000
DOC. 2018. California Important Farmland: 1984-2020. https://maps.conservation.ca.gov/dlrp/ciftimeseries/.

EDD. 2023. Monthly Labor Force Data for Cities and Census Designated Places (CDP) April 2023 – Preliminary Data Not Seasonally Adjusted. https://labormarketinfo.edd.ca.gov/file/lfmonth/sand$pds.pdf London Moeder Advisors. 2023, January. Economic and Fiscal Impact Analysis for Woodside Avenue Industrial Project. Prepared for North Palisades Partners.

Santee, California Municipal Code. 2023. Municipal Code. https://library.qcode.us/lib/santee_ca/ pub/municipal_code.

SANDAG (San Diego Association of Governments). 2021. The 2021 Regional Plan. https://www.sandag.org/r egional-plan/2021-regional-plan/-/media/8D0F181A086844E3A84C3D44576BED6B.ashx USGS (United States Geological Survey). 2023. Areas of Land Subsidence in California. Accessed September 23, 2023. https://ca.water.usgs.gov/land_subsidence/california-subsidence-areas.html. 9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-20
Chapter 6: Other CEQA Considerations
CAL FIRE. 2023. FHSZ Viewer. Accessed September 12, 2023. https://egis.fire.ca.gov/FHSZ/.

CalRecycle. 2019. SWIS Facility/Site Summary Sycamore Landfill (37-AA-0023). https://www2.calrecycle.ca.gov/ SolidWaste/Site/Summary/2871.

CalRecycle. 2023. SWIS Facility/Site Summary Las Pulgas Landfill (37-AA-0903). https://www2.calrecycle.ca.gov/ SolidWaste/Site/Summary/2901.

City of San Diego. 1998. City of San Diego. 1998. Final MSCP Plan. Prepared by MSCP Policy Committee and MSCP Working Group. San Diego, California: MSCP Policy Committee and MSCP Working Group.

August 1998. http://www.sandiegocounty.gov/content/dam/sdc/pds/mscp/docs/SCMSCP/ FinalMSCPProgramPlan.pdf.City of Santee. 2003. City of Santee General Plan, Chapter 6, Conservation Element. https://www.cityofsanteeca.gov/home/showpublisheddocument/7199/ 636336570186700000.

City of Santee. 2003. Santee General Plan, Land Use Element. Accessed June 2024. https://www.cityofsanteeca.gov/government/planning-and-building/land-use-code/general-plan.

City of Santee. 2017. City of Santee Land Use Map. Accessed June 2023. https://www.cityofsanteeca.gov/ home/showpublisheddocument/8547/636362228959170000
City of Santee. 2022. Housing Element. Accessed June 2023. https://www.cityofsanteeca.gov/home/ showpublisheddocument/8551/638066250344200000
City of Santee. 2023. About Santee. Accessed June 2023. https://www.cityofsanteeca.gov/our-city/ about-santee-new.

DOF (California Department of Finance). 2023. E-1: City/County Population Estimates with Annual Percent Change January 1, 2022, and 2023. Accessed June 2023. https://view.officeapps.live.com/op/ view.aspx?src=https%3A%2F%2Fdof.ca.gov%2Fwp-content%2Fuploads%2Fsites%2F352% 2FForecasting%2FDemographics%2FDocuments%2FE-1_2023_InternetVersion.xlsx& wdOrigin=BROWSELINK
DTSC (Department of Toxic Substances Control). 2023. Envirostor. Accessed June 2023. https://www.envirostor.dtsc.ca.gov/public/map/?myaddress=10990+N+Woodside+Avenue+Santee.

FAA (Federal Aviation Administration). 2023. “Determination of No Hazard to Air Navigation.” Letter report from N.

Sanders (Technician, FAA) to W. Jacobs (North Palisade Opco, LLC). December 27, 2023.FEMA (Federal Emergency Management Agency). 2024. FEMA Flood Map Service Center: Search by Address. Accessed May 21, 2024. https://msc.fema.gov/portal/search#searchresultsanchor. 9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-21
London Moeder Advisors. 2023. Economic & Fiscal Impact Analysis for Woodside Ave. Industrial Project. Prepared for North Palisade Partners.

SANDAG 2021 Regional Plan
San Diego County Water Authority. 2023. Groundwater. Accessed September 24, 2023. https://www.sdcwa.org/ your-water/local-water-supplies/groundwater/.

SDCRAA (San Diego County Regional Airport Authority). 2010. Gillespie Field Airport Land Use Compatibility Plan.

Adopted January 25, 2010. Amended December 20, 2010. https://www.san.org/DesktopModules/ Bring2mind/DMX/API/Entries/Download?EntryId=16146&Command=Core_Download&language= en-US&PortalId=0&TabId=807.SWRCB. 2023. GSA Map Viewer. Accessed September 24, 2023. https://sgma.water.ca.gov/webgis/index.jsp?jsonfile=https%3a%2f%2fsgma.water.ca.gov%2fportal% 2fresources%2fjs%2fmapconfigs%2fGsaMaster.js.

Chapter 7: Alternatives
City of Santee. 2003. Santee General Plan, Land Use Element and Safety Element. Accessed June 2024. https://www.cityofsanteeca.gov/government/planning-and-building/land-use-code/general-plan Cohen, J.D. 2000. Preventing Disaster: Home Ignitability in the Wildland-Urban Interface. Journal of Forestry 98(3): 15–21.

SCAG 2012. Southern California Association of Governments. On the Move. Southern California Delivers the Goods. https://scag.ca.gov/sites/main/files/file-attachments/crgm_onthemove_execsummary.pdf.

Chapter 8: List of Preparers
None
9 – REFERENCES
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 9-22

INTENTIONALLY LEFT BLANK

Santee City CouncilAugust 27, 2025

Santee City Council
August 27, 2025