— Santee City Council, August 27, 2025 (part 1 of 3)

Final Environmental Impact Report
Palisade Santee Commerce
Center Project
State Clearinghouse No. 2023090144
AUGUST 2025
Prepared for:

CITY OF SANTEE

PLANNING & BUILDING DEPARTMENT
10601 Magnolia Avenue
Santee, California 92071
Prepared by:
2280 Historic Decatur Road
San Diego, California 92106

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Table of Contents
SECTION PAGE NO.

Acronyms and abbreviations...................................................................................................................................... ACR-i Introduction to the Final EIR ................................................................................................................................. INTRO-1 Content and Format................................................................................................................................. INTRO-1 Public Review of the Draft EIR................................................................................................................. INTRO-1 Point of Contact........................................................................................................................................ INTRO-2 Responses to Comments ..........................................................................................................................................RTC-1 Comments Received....................................................................................................................................RTC-1 Thematic Responses ...................................................................................................................................RTC-3 Thematic Response 1: Transportation..........................................................................................RTC-3 Thematic Response 2: Noise.........................................................................................................RTC-8 Response to Comment Letter S1..............................................................................................................RTC-10 Response to Comment Letter O1........................................................................................................... RTC-117 Response to Comment Letter O2........................................................................................................... RTC-118 Response to Comment Letter O3........................................................................................................... RTC-130 Response to Comment Letter I1 ............................................................................................................ RTC-132 Response to Comment Letter I2 ............................................................................................................ RTC-133 Response to Comment Letter I3 ............................................................................................................ RTC-134 Response to Comment Letter I4 ............................................................................................................ RTC-136 Response to Comment Letter I5 ............................................................................................................ RTC-137 Response to Comment Letter I6 ............................................................................................................ RTC-139 Response to Comment Letter I7 ............................................................................................................ RTC-140 Response to Comment Letter I8 ............................................................................................................ RTC-142 Response to Comment Letter I9 ............................................................................................................ RTC-143 Response to Comment Letter I10.......................................................................................................... RTC-144 Response to Comment Letter I11.......................................................................................................... RTC-145 Response to Comment Letter I12.......................................................................................................... RTC-147 Response to Comment Letter I13.......................................................................................................... RTC-148 Response to Comment Letter I14.......................................................................................................... RTC-150 Response to Comment Letter I15.......................................................................................................... RTC-151 Response to Comment Letter I16.......................................................................................................... RTC-164 Response to Comment Letter I17.......................................................................................................... RTC-166 Response to Comment Letter I18.......................................................................................................... RTC-170 Response to Comment Letter I19.......................................................................................................... RTC-172 Response to Comment Letter I20.......................................................................................................... RTC-174 Response to Comment Letter I21.......................................................................................................... RTC-175

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Response to Comment Letter W1.......................................................................................................... RTC-177 Response to Comment Letter W2.......................................................................................................... RTC-180 Revisions to the Draft EIR ............................................................................................................................. REVISIONS-1 1 Executive Summary............................................................................................................ REVISIONS-1 3 Project Description ............................................................................................................. REVISIONS-2

4.12 Transportation .................................................................................................................... REVISIONS-2 1 Executive Summary.......................................................................................................................................... 1-1

1.1 Introduction......................................................................................................................................... 1-1

1.2 Project Location.................................................................................................................................. 1-1

1.3 Project Description ............................................................................................................................. 1-1

1.4 Project Objectives............................................................................................................................... 1-3

1.5 Project Design Features..................................................................................................................... 1-3

1.6 Requested Approvals ......................................................................................................................... 1-5

1.7 Summary of Impacts .......................................................................................................................... 1-6

1.8 Alternatives to the Project................................................................................................................1-34

1.9 Areas of Controversy/Issues to Be Resolved..................................................................................1-36 2 Introduction ...................................................................................................................................................... 2-1

2.1 Purpose of the California Environmental Quality Act Process ......................................................... 2-1

2.2 Legal Authority and Lead Agency....................................................................................................... 2-1

2.3 Responsible and Trustee Agencies ................................................................................................... 2-2

2.4 Summary of Project Analyzed in this Environmental Impact Report............................................... 2-3

2.5 Scope of Environmental Analysis ...................................................................................................... 2-3

2.5.1 Notice of Preparation Scoping Process ............................................................................... 2-3

2.5.2 Environmental Effects Found Not to Be Significant............................................................ 2-4

2.5.3 Environmental Issues Determined to be Potentially Significant........................................ 2-4

2.6 Organization of this Environmental Impact Report .......................................................................... 2-5

2.7 Documents Incorporated by Reference ............................................................................................ 2-6

2.8 Documents Prepared for the Project................................................................................................. 2-7

2.9 Review of the Draft Environmental Impact Report........................................................................... 2-7 3 Project Description........................................................................................................................................... 3-1

3.1 Project Location.................................................................................................................................. 3-1

3.2 Environmental Setting........................................................................................................................ 3-1

3.3 Proposed Project ..............................................................................................................................3-16

3.3.1 Project Components ...........................................................................................................3-17

3.3.2 Project Construction ...........................................................................................................3-43

3.3.3 Project Design Features .....................................................................................................3-44

3.4 Purpose and Need............................................................................................................................3-46

3.5 Project Objectives.............................................................................................................................3-46

3.6 Requested Approvals .......................................................................................................................3-47

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4 Environmental Analysis.................................................................................................................................... 4-1

4.1 Aesthetics ........................................................................................................................................4.1-1

4.1.1 Existing Conditions.............................................................................................................4.1-1

4.1.2 Relevant Plans, Policies, and Ordinances........................................................................4.1-3

4.1.3 Thresholds of Significance ................................................................................................4.1-6

4.1.4 Impacts Analysis ................................................................................................................4.1-6

4.1.5 Mitigation Measures and Level of Significance After Mitigation ..................................4.1-22

4.2 Air Quality .........................................................................................................................................4.2-1

4.2.1 Existing Conditions.............................................................................................................4.2-1

4.2.2 Relevant Plans, Policies, and Ordinances........................................................................4.2-9

4.2.3 Thresholds of Significance ..............................................................................................4.2-17

4.2.4 Impacts Analysis ..............................................................................................................4.2-25

4.2.5 Mitigation Measures and Level of Significance After Mitigation ..................................4.2-34

4.3 Biological Resources .......................................................................................................................4.3-1

4.3.1 Existing Conditions.............................................................................................................4.3-1

4.3.2 Relevant Plans, Policies, and Ordinances........................................................................4.3-6

4.3.3 Thresholds of Significance ..............................................................................................4.3-12

4.3.4 Impacts Analysis ..............................................................................................................4.3-13

4.3.5 Mitigation Measures and Level of Significance After Mitigation ..................................4.3-21

4.4 Cultural, Tribal Cultural, and Paleontological Resources..............................................................4.4-1

4.4.1 Existing Conditions.............................................................................................................4.4-1

4.4.2 Relevant Plans, Policies, and Ordinances........................................................................4.4-7

4.4.3 Thresholds of Significance ..............................................................................................4.4-12

4.4.4 Impact Analysis ................................................................................................................4.4-13

4.4.5 Mitigation Measures and Level of Significance After Mitigation ..................................4.4-15

4.5 Energy ..............................................................................................................................................4.5-1

4.5.1 Existing Conditions.............................................................................................................4.5-1

4.5.2 Relevant Plans, Policies, and Ordinances........................................................................4.5-2

4.5.3 Thresholds of Significance ..............................................................................................4.5-10

4.5.4 Impacts Analysis ..............................................................................................................4.5-11

4.5.5 Level of Significance After Mitigation .............................................................................4.5-17

4.6 Greenhouse Gas Emissions............................................................................................................4.6-1

4.6.1 Existing Conditions.............................................................................................................4.6-1

4.6.2 Relevant Plans, Policies, and Ordinances......................................................................4.6-10

4.6.3 Thresholds of Significance ..............................................................................................4.6-22

4.6.4 Impacts Analysis ..............................................................................................................4.6-25

4.6.5 Mitigation Measures and Level of Significance After Mitigation ..................................4.6-28

4.7 Hazards and Hazardous Materials .................................................................................................4.7-1

4.7.1 Existing Conditions.............................................................................................................4.7-1

4.7.2 Relevant Plans, Policies, and Ordinances........................................................................4.7-3

4.7.3 Thresholds of Significance ..............................................................................................4.7-12

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4.7.4 Impacts Analysis ..............................................................................................................4.7-12

4.7.5 Mitigation Measures and Level of Significance After Mitigation ..................................4.7-17

4.8 Hydrology and Water Quality...........................................................................................................4.8-1

4.8.1 Existing Conditions.............................................................................................................4.8-1

4.8.2 Relevant Plans, Policies, and Ordinances........................................................................4.8-9

4.8.3 Thresholds of Significance ..............................................................................................4.8-17

4.8.4 Impacts Analysis ..............................................................................................................4.8-18

4.8.5 Mitigation Measures and Level of Significance After Mitigation ..................................4.8-26

4.9 Land Use and Planning ...................................................................................................................4.9-1

4.9.1 Existing Conditions.............................................................................................................4.9-1

4.9.2 Relevant Plans, Policies, and Ordinances........................................................................4.9-2

4.9.3 Thresholds of Significance ................................................................................................4.9-4

4.9.4 Impacts Analysis ................................................................................................................4.9-4

4.9.5 Mitigation Measures and Level of Significance After Mitigation ..................................4.9-13

4.10 Noise ..............................................................................................................................................4.10-1

4.10.1 Existing Conditions...........................................................................................................4.10-1

4.10.2 Relevant Plans, Policies, and Ordinances......................................................................4.10-4

4.10.3 Thresholds of Significance ........................................................................................... 4.10-12

4.10.4 Impacts Analysis ........................................................................................................... 4.10-13

4.10.5 Mitigation Measures and Level of Significance After Mitigation ............................... 4.10-28

4.11 Public Services ..............................................................................................................................4.11-1

4.11.1 Existing Conditions...........................................................................................................4.11-1

4.11.2 Relevant Plans, Policies, and Ordinances......................................................................4.11-5

4.11.3 Thresholds of Significance ..............................................................................................4.11-7

4.11.4 Impacts Analysis ..............................................................................................................4.11-8

4.11.5 Mitigation Measures and Level of Significance After Mitigation ............................... 4.11-10

4.12 Transportation ...............................................................................................................................4.12-1

4.12.1 Existing Conditions...........................................................................................................4.12-1

4.12.2 Relevant Plans, Policies, and Ordinances......................................................................4.12-7

4.12.3 Thresholds of Significance ........................................................................................... 4.12-11

4.12.4 Impacts Analysis ........................................................................................................... 4.12-14

4.12.5 Project Design Features, Mitigation Measures, and Level of Significance After Mitigation.............................................................................................................. 4.12-33

4.13 Utilities and Service Systems........................................................................................................4.13-1

4.13.1 Existing Conditions...........................................................................................................4.13-1

4.13.2 Relevant Plans, Policies, and Ordinances......................................................................4.13-4

4.13.3 Thresholds of Significance ........................................................................................... 4.13-10

4.13.4 Impacts Analysis ........................................................................................................... 4.13-10

4.13.5 Mitigation Measures and Level of Significance After Mitigation ............................... 4.13-15

4.14 Wildfire ...........................................................................................................................................4.14-1

4.14.1 Existing Conditions...........................................................................................................4.14-1

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4.14.2 Relevant Plans, Policies, and Ordinances......................................................................4.14-5

4.14.3 Thresholds of Significance ........................................................................................... 4.14-10

4.14.4 Impacts Analysis ........................................................................................................... 4.14-11

4.14.5 Mitigation Measures and Level of Significance After Mitigation ............................... 4.14-18 5 Effects Found Not To Be Significant ............................................................................................................... 5-1

5.1 Agricultural and Forestry Resources ................................................................................................. 5-1

5.2 Geology and Soils ............................................................................................................................... 5-2

5.3 Mineral Resources ............................................................................................................................. 5-4

5.4 Population and Housing..................................................................................................................... 5-4

5.5 Recreation........................................................................................................................................... 5-5 6 Other CEQA Considerations............................................................................................................................. 6-1

6.1 Cumulative Impacts............................................................................................................................ 6-1

6.1.1 Cumulative Impact Analysis ................................................................................................. 6-5

6.2 Growth-Inducing Impacts .................................................................................................................6-27

6.3 Significant Irreversible Changes......................................................................................................6-28

6.3.1 Change in Land Use that Commits Future Generations to Similar Uses.........................6-29

6.3.2 Irreversible Damage from Environmental Accidents ........................................................6-29

6.3.3 Large Commitment of Nonrenewable Resources.............................................................6-29

6.4 Significant and Unavoidable Impacts..............................................................................................6-30 7 Alternatives....................................................................................................................................................... 7-1

7.1 Alternatives to the Proposed Project................................................................................................. 7-1

7.2 Considerations for Selection of Alternatives..................................................................................... 7-2

7.3 Project Alternatives Considered and Rejected ................................................................................. 7-5

7.4 Project Alternatives Under Further Consideration ............................................................................... 7-7

7.4.1 No Project/No Development Alternative (Alternative 1)..................................................... 7-8

7.4.2 Reduced Development Intensity Alternative (Alternative 2)................................................... 7-9

7.4.3 Refrigerated Warehouse Alternative (Alternative 3).............................................................7-13

7.5 Environmentally Superior Alternative..............................................................................................7-17 8 List of Preparers............................................................................................................................................... 8-1 9 References ....................................................................................................................................................... 9-1

FIGURES
RTC-1 Updated Intersection Improvements ..........................................................................................................RTC-5 3-1 Regional Map ................................................................................................................................................... 3-3 3-2 Project Location ............................................................................................................................................... 3-5 3-3 Project Aerial and Existing Uses...................................................................................................................... 3-7 3-4 Existing Conditions........................................................................................................................................... 3-9 3-5 General Plan Land Use ..................................................................................................................................3-11

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3-6 Zoning .............................................................................................................................................................3-13 3-7 Conceptual Site Plan......................................................................................................................................3-19 3-8 Representative Architectural Elevations.......................................................................................................3-21 3-9 Landscaping Plan...........................................................................................................................................3-23 3-10 Proposed Photometric Plan...........................................................................................................................3-25 3-11 Proposed Noise Barrier..................................................................................................................................3-29 3-12a View 1: Ground-Level Rendering of Industrial/Warehouse Building Office and Parking Areas ................3-31 3-12b View 2: Isometric............................................................................................................................................3-33 3-12c View 3: Isometric North Oriented View of Project Site and Surrounding Area ...........................................3-35 3-12d View 4: Isometric Southwest Oriented View Across San Diego River and towards Project Site................3-37 3-12e View 5: Isometric Southeast Oriented View Across San Diego River and towards Project Site ................3-39 3-12f View 6: Isometric Southwest Oriented View towards Project Site and Surrounding Visual Environment........................................................................................................................................3-41

4.1-1 Vantage Points ..............................................................................................................................................4.1-9

4.1-2 Vantage Point 1: River Trail Location #1 ...................................................................................................4.1-11

4.1-3 Vantage Point 2: River Trail Location #2 ...................................................................................................4.1-13

4.1-4 Vantage Point 3: Northcote Road ..............................................................................................................4.1-15

4.1-5 Example View towards Rattlesnake Mountain from Sandy Creek Drive .................................................4.1-17

4.1-6 Landscape Sections and River Trail View Corridors..................................................................................4.1-19

4.3-1 Biological Resources.....................................................................................................................................4.3-3

4.3-2 Impacts ........................................................................................................................................................4.3-17

4.8-1 San Diego River Watershed..........................................................................................................................4.8-3

4.8-2 Existing Hydrology Map.................................................................................................................................4.8-5

4.8-3 Flood Map....................................................................................................................................................4.8-11

4.8-4 Proposed Hydrology Map............................................................................................................................4.8-21

4.10-1 Noise Measurement Locations ..................................................................................................................4.10-5

4.10-2 City of Santee Noise / Land Use Compatibility Guide...............................................................................4.10-9

4.10-3 Predicted Daytime Onsite Operations Noise Contours (Leq)................................................................. 4.10-23

4.10-4 Predicted Nighttime Onsite Operations Noise Contours (Leq).............................................................. 4.10-25

4.11-1 Fire Stations in the City of Santee..............................................................................................................4.11-3

4.12-1 Transit Facilities ..........................................................................................................................................4.12-3

4.12-2 Bike Facilities ..............................................................................................................................................4.12-5

4.12-3 Project Trip Distribution........................................................................................................................... 4.12-15

4.12-4 Project Trip Assignment (Cars)................................................................................................................ 4.12-17

4.12-5 Project Trip Assignment (Trucks-PCE)..................................................................................................... 4.12-19

4.12-6 Total Project Trip Assignment (Cars and Trucks – PCE) ........................................................................ 4.12-21

4.12-7 SANDAG SB 743 Map.............................................................................................................................. 4.12-27

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4.14-1 Fire Hazard Severity Zones.........................................................................................................................4.14-3

4.14-2 Fire History................................................................................................................................................ 4.14-13 TABLES
RTC-1 Summary of Public Comments on the Draft EIR ........................................................................................RTC-1 1-1 Summary of Project Impacts ........................................................................................................................... 1-7 1-2 Summary of Notice of Preparation Comments.............................................................................................1-36 2-1 Summary of Notice of Preparation Comments............................................................................................... 2-3

4.1-1 Selected Public Vantage Points ...................................................................................................................4.1-7

4.2-1 SDAB Attainment Designation......................................................................................................................4.2-7

4.2-2 Local Ambient Air Quality Data.....................................................................................................................4.2-7

4.2-3 Ambient Air Quality Standards ...................................................................................................................4.2-10

4.2-4 SDAPCD Air Quality Significance Thresholds.............................................................................................4.2-17

4.2-5 Construction Scenario Assumptions..........................................................................................................4.2-18

4.2-6 Operational Truck Trip Distance.................................................................................................................4.2-21

4.2-7 AERMOD Principal Parameters ..................................................................................................................4.2-23

4.2-8 Operational Health Risk Assessment American Meteorological Society/U.S. Environmental Protection Agency Regulatory Model Operational Principal Parameters.................................................4.2-24

4.2-9 Estimated Maximum Daily Construction Criteria Air Pollutant Emissions ...............................................4.2-27

4.2-10 Estimated Maximum Daily Operational Criteria Air Pollutant Emissions.................................................4.2-28

4.2-11 Construction Activity Health Risk Assessment Results - Unmitigated .....................................................4.2-31

4.2-12 Operational Health Risk Assessment Results - Unmitigated....................................................................4.2-31

4.2-13 Combined Construction and Operational Health Risk Assessment Results - Unmitigated....................4.2-32

4.3-1 Vegetation Communities and Land Covers within the Project Site and 500-Foot Buffer.........................4.3-1

4.3-2 Impacts to Vegetation Communities and Land Covers within the Project Site.............................................4.3-15

4.5-1 Total Hours of Operation for Construction Equipment..............................................................................4.5-11

4.5-2 Construction Equipment Diesel Demand ..................................................................................................4.5-12

4.5-3 Construction Worker Vehicle Gasoline Demand .......................................................................................4.5-12

4.5-4 Construction Vendor Truck Diesel Demand ..............................................................................................4.5-12

4.5-5 Construction Haul Truck Diesel Demand...................................................................................................4.5-13

4.5-6 Mobile Source Fuel Consumption – Operation .........................................................................................4.5-15

4.6-1 Six Top GHG Producer Countries..................................................................................................................4.6-4

4.6-2 GHG Emissions Sources in California ..........................................................................................................4.6-5

4.6-3 San Diego County GHG Emissions by Sectors.............................................................................................4.6-5

4.6-4 City of Santee Community-Wide GHG Emissions by Sectors for 2013......................................................4.6-6

4.6-5 Estimated Annual Construction GHG Emissions.......................................................................................4.6-26

4.6-6 Summary of Estimated Annual GHG Emissions........................................................................................4.6-26

4.6-7 Sustainable Santee Action Plan Project Checklist....................................................................................4.6-27

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4.8-1 Basin Plan Beneficial Uses, Surface Water.................................................................................................4.8-2

4.8-2 Basin Plan Beneficial Uses, Groundwater...................................................................................................4.8-8

4.9-1 Consistency with City of Santee General Plan Goals, Objectives, and Policies.........................................4.9-5

4.9-2 Consistency with 2021 RP/SCS Goals ......................................................................................................4.9-12

4.10-1 Typical Sound Levels in the Environment and Industry ............................................................................4.10-2

4.10-2 Measured Baseline Outdoor Ambient Noise Levels..................................................................................4.10-4

4.10-3 Typical Construction Equipment Maximum Noise Levels...................................................................... 4.10-14

4.10-4 Estimated Distances between Construction Activities and the Nearest Noise-Sensitive Receptors....................................................................................................................... 4.10-15

4.10-5 Predicted Construction Noise Levels per Activity Phase ....................................................................... 4.10-15

4.10-6 Predicted Construction Traffic Noise Levels........................................................................................... 4.10-17

4.10-7 Predicted Traffic Noise Levels................................................................................................................. 4.10-20

4.10-8 Modeled Sound Power Levels (PWL) for Stationary Sources (HVAC).................................................... 4.10-21

4.11-1 Fire Stations in City of Santee ....................................................................................................................4.11-1

4.12-1 Project Trip Generation Summary........................................................................................................... 4.12-12

4.12-2 Project VMT Summary.............................................................................................................................. 4.12-26

4.12-3 Transportation Demand Management Measures.................................................................................. 4.12-29

4.13-1 Supply and Demand Comparison (Acre-Feet per Year) ............................................................................4.13-2

4.13-2 Construction Waste Summary................................................................................................................. 4.13-14 6-1 Geographic Scope of Cumulative Impact Analyses........................................................................................ 6-2 7-1 Project Alternatives Environmental Impacts Comparison ...........................................................................7-18

APPENDICES
A Initial Study, Notice of Preparation, and Scoping Comments B Air Quality and Greenhouse Gas Emission Technical Report C Biological Technical Report
D Arborist Report
E Archaeological Resources Inventory Report
F Historical Assessment
G Geotechnical Engineering Investigation
H Paleontological Resources Memorandum
I Phase I Environmental Site Assessment
J-1 Preliminary Hydrology Study
J-2 Storm Water Quality Management Plan
J-3 Letter to City of Santee regarding the 100-Year Floodplain K Noise Technical Report

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L Transportation Impact Study
M Water Study
N Fire Protection Plan
O AB 52 Letters and Receipts

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INTENTIONALLY LEFT BLANK
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
AUGUST 2025 ACR-i
Acronyms and Abbreviations
Acronym/Abbreviation Definition
AASHTO American Association of State Highway Transportation Officials ACM asbestos-containing material
ACWM asbestos-containing waste material
ADT Average Daily Traffic
AERMOD American Meteorological Society/EPA Regulatory Model AFY acre-feet per year
AIA Airport Influence Area
ALUCP Airport Land Use Compatibility Plan
ANSI American National Standards Institute
APN Assessor’s Parcel Number
AQMP Air Quality Monitoring Quality Management Plan
BLM Bureau of Land Management
BMP best management practice
BTR Biological Technical Report
BUG backlight, up light, and glare
CAA Clean Air Act
CAAQS California Ambient Air Quality Standards
CAL FIRE California Department of Forestry and Fire Protection CalEEMod California Emissions Estimator Model
CalEPA California Environmental Protection Agency
CAP climate action plan
CAPCOA California Air Pollution Control Officers Association CARB California Air Resources Board
CAS California Approved Samplers
CAT Climate Action Team
CBC California Building Code
CCR California Code of Regulations
CDFW California Department of Fish and Wildlife
CEC California Energy Code
CEC California Energy Commission
CEQA California Environmental Quality Act
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CERT Community Emergency Response Team
CESA California Endangered Species Act
CFC California Fire Code
CFC chlorofluorocarbon
CFR Code of Federal Regulations
CGP Construction General Permit
CH4 methane
CHRIS California Historical Resources Information System

ACRONYMS AND ABBREVIATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
AUGUST 2025 ACR-ii
Acronym/Abbreviation Definition
CIWM California Integrated Waste Management
CIWMB California Integrated Waste Management Board
CNEL Community Noise Equivalent Level
CNRA California Natural Resources Agency
CO2 carbon dioxide
CO2e carbon dioxide equivalent
CPUC California Public Utilities Commission
CRHR California Register of Historical Resources
CTR Commute Trip Reduction
CUP Conditional Use Permit
CWA Clean Water Act
dB decibel
dBA A-weighted decibel
DEH San Diego County Department of Environmental Health DER Distributed Energy Resources
DIF Development Impact Fee
DPM diesel particulate matter
DPR Department of Parks and Recreation
DTSC Department of Toxic Substances Control
EDR Environmental Data Resources Inc.

EIR Environmental Impact Report
EISA Energy Independence and Security Act
EO Executive Order
EOP Emergency Operations Plan
EPA U.S. Environmental Protection Agency
ESA Environmental Site Assessment
EV electric vehicle
FAA Federal Aviation Administration
FEMA Federal Emergency Management Agency
FESA federal Endangered Species Act
FHSZ Fire Hazard Severity Zone
FICON Federal Interagency Committee on Noise
FPP Fire Protection Plan
FRA Federal Responsibility Area
FTA Federal Transit Administration
GHG greenhouse gas
GUHSD Grossmont Union High School District
GWP global warming potential
HABS Historic American Buildings Survey
HAP hazardous air pollutant
HARP Hotspots Analysis Reporting Program
HCFC hydrochlorofluorocarbon
HCP Habitat Conservation Plan

ACRONYMS AND ABBREVIATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
AUGUST 2025 ACR-iii
Acronym/Abbreviation Definition
HFC hydrofluorocarbon
HHDT heavy-heavy duty truck
HMD Hazardous Materials Division
HRA health risk assessment
HUC hydrologic unit code
HVAC heating, ventilation, and air conditioning
ICC International Code Council
IEPR Integrated Energy Policy Report
IESNA Illuminating Engineering Society of North American IFC International Fire Code
IOS Industrial Outdoor Storage
IPCC Intergovernmental Panel on Climate Change
ISTEA Intermodal Surface Transportation Efficiency Act
ITE Institute of Transportation Engineers
ITS Intelligent Transportation System
LBP lead-based paint
LEED Leadership in Energy and Environmental Design
LHDT light-heavy duty truck
LID Low Impact Development
LOS level of service
LRA Local Responsibility Area
LTF Local Task Force
LZ lighting zone
MHDT medium-heavy duty truck
MHPA Multi-Habitat Planning Area
MLD Most Likely Descendant
MMT million metric tons
mph miles per hour
MPO metropolitan planning organization
MSCP Multiple Species Conservation Program
MT metric ton
MTS Metropolitan Transit System
N2O nitrous oxide
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NCCP Natural Community Conservation Plan
NESHAP National Emission Standards for Hazardous Air Pollutants NF3 nitrogen trifluoride
NFHL National Flood Hazard Layer
NHPA National Historic Preservation Act
NHTSA National Highway Traffic Safety Administration
NOP Notice of Preparation
NPDES National Pollutant Discharge Elimination System

ACRONYMS AND ABBREVIATIONS
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Acronym/Abbreviation Definition
NRHP National Register of Historic Places
NTU Nephelometric Turbidity Unit
O3 ozone
OBCF octave-band center frequency
OEHHA Office of Environmental Health Hazard Assessment
OHP Office of Historic Preservation
OPR Office of Planning and Research
OSHA Occupational Safety and Health Administration
PCE passenger car equivalence
PDF Project Design Feature
PDMWD Padre Dam Municipal Water District
PDP Priority Development Project
PFC perfluorocarbon
PLF Point Loma Facility
PM particulate matter
PPV peak particle velocity
PRC Public Resources Code
PV photovoltaic
RAQS Regional Air Quality Strategy
RAS Regional Arterial System
RCNM Roadway Construction Noise Model
RCRA Resource Conservation and Recovery Act
REC recognized environmental condition
RFS Renewable Fuel Standard
ROW right-of-way
RPS Renewables Portfolio Standard
RTCIP Regional Transportation Congestion Improvement Plan RTIP Regional Transportation Improvement Program
RTP Regional Transportation Plan
RWQCB Regional Water Quality Control Board
SAFE-1 Safer Affordable Fuel-Efficient Vehicles Rule Part One: One National Program SANDAG San Diego Association of Governments
SARA Superfund Amendments and Reauthorization Act
SCAB South Coast Air Basin
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SCIC South Coastal Information Center
SCS Sustainable Communities Strategy
SDAB San Diego Air Basin
SDAPCD San Diego Air Pollution Control District
SDCSD San Diego County Sheriff’s Department
SDCWA San Diego County Water Authority
SDG&E San Diego Gas & Electric

ACRONYMS AND ABBREVIATIONS
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Acronym/Abbreviation Definition
SDHC San Diego History Center
SDNHM San Diego Natural History Museum
SEMS Statewide Emergency Management System
SF6 sulfur hexafluoride
SFD Santee Fire Department
SGMA Sustainable Groundwater Management Act
SIAM Structure Ignition Assessment Model
SIP state implementation plan
SLEMSA Santee-Lakeside Emergency Medical Services Authority SLF Sacred Lands File
SLM sound level meter
SMC Santee Municipal Code
SPL sound pressure level
SRA State Responsibility Area
SSD Santee School District
SWPPP Stormwater Pollution Prevention Plan
SWQMP Storm Water Quality Management Plan
SWRCB State Water Resources Control Board
TAC Toxic Air Contaminant
TAZ traffic analysis zone
TCR Tribal Cultural Resource
TDM Transportation Demand Management
TDS total dissolved solids
TIS Transportation Impact Study
TMDL total maximum daily load
TSS total suspended solids
TWLTL two-way-left-turn lane
USACE U.S. Army Corps of Engineers
USFWS U.S. Fish and Wildlife Service
UWMP Urban Water Management Plan
VdB vibration decibel
VHFHSZ Very High Fire Hazard Severity Zone
VMT vehicle miles traveled
VOC volatile organic compound
WDR waste discharge requirement
WEAT worker environmental awareness training
WMA Watershed Management Area
WRF Water Recycling Facility
ZEV zero-emission vehicle

ACRONYMS AND ABBREVIATIONS
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
AUGUST 2025 ACR-vi

INTENTIONALLY LEFT BLANK
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Introduction to the Final EIR
In accordance with Section 15088 of the Guidelines for Implementation of the California Environmental Quality Act (State CEQA Guidelines), the City of Santee (City), as the Lead Agency under the California Environmental Quality Act (CEQA), has evaluated the comments received on the Draft Environmental Impact Report (EIR) (State Clearinghouse [SCH] No. 2023090144) for the proposed Palisade Santee Commerce Center Project (Project) and has prepared this Final EIR with written responses to the comments. This Final EIR has been prepared in accordance with CEQA and represents the independent judgment of the City as the Lead Agency.

According to State CEQA Guidelines Section 15132, the Final EIR shall consist of:

The draft EIR or a revision of the draft.

Comments and recommendations received on the draft EIR either verbatim or in summary.

A list of persons, organizations, and public agencies commenting on the draft EIR.

The responses of the Lead Agency to significant environmental points raised in the review and consultation process.
e) Any other information added by the Lead Agency.

The purpose of the Final EIR is to respond to all written comments received by the City regarding the environmental information and analyses contained in the Draft EIR. Additionally, any clarifications or revisions to the Draft EIR generated from responses to comments are stated in the Final EIR. In this Final EIR, the Draft EIR has been modified per the clarifications and revisions in the responses and is presented in the Revisions to the Draft EIR chapter.

In addition to the Final EIR (including supporting technical appendices), the City Council will also consider the adoption of a Mitigation Monitoring and Reporting Plan (MMRP), a Findings of Fact and Statement of Overriding Considerations document, staff reports, and resolutions prior to making a decision on the project.

Content and Format
This Final EIR includes three chapters as well as a reprinting of the Draft EIR reflecting text changes made during the Final EIR process. This introductory chapter is the first chapter in the Final EIR. The second chapter of this Final EIR includes the responses to all comments received during the public review period for the Draft EIR. The Responses to Comments chapter also includes a copy of all comment letters received within the public review period. The responses are annotated to correspond to each individual comment within each comment letter. The third chapter of this Final EIR shows the revisions to the Draft EIR that have been made to the text of the Draft EIR, with only the revised text included. Following these three chapters, this Final EIR includes a reprinting of the complete Draft EIR with text changes made consistent with the third chapter of this Final EIR.

Public Review of the Draft EIR
As required by Section 15087 of the State CEQA Guidelines, a Notice of Completion (NOC) and a Notice of Availability (NOA) of the Draft EIR for the Project were filed with the State Clearinghouse on April 21, 2025, and the NOA of the Draft EIR was also filed with the San Diego County Clerk. The Draft EIR was circulated for public review for a minimum of 45 days, from April 21, 2025 to June 2, 2025. The NOA, NOC, and the Draft EIR and supporting 1 – INTRODUCTION TO THE FINAL EIR
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technical appendices were also posted on the Governor’s Office of Land Use & Climate Innovation’s CEQANet Web Portal, and the NOA was sent to responsible agencies and other interested agencies and parties on or about April 21, 2025. Copies of the Draft EIR were also made available for public review at the City Department of Development Services (Building 4), the City’s Clerk’s Office (Building 3), the Santee County Library, and on the City’s website.

Point of Contact
The Lead Agency for the proposed Project is the City. Any questions or comments regarding the preparation of this document, its assumptions, or its conclusions, should be referred to:

Sandi Sawa, AICP, Director of Planning and Building
City of Santee, Planning & Building Department
10601 Magnolia Avenue
Santee, California 92071
Phone: 619.258.4100 ext. 167
Email: [email protected]
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Responses to Comments
During the public review period (April 21, 2025, through June 4, 2025) for the Draft Environmental Impact Report (EIR) for the Palisade Santee Commerce Center Project (proposed project), the City of Santee (City) received 25 comment letters. An additional comment letter was received following the close of the public comment period. Two of the comment letters received, including the late comment letter, were later withdrawn by the commenters. The thematic responses, comment letters, and the City’s responses to them are included in this chapter. The responses to comments are based on the California Environmental Quality Act (CEQA) Guidelines, Section 15088(c), Evaluation of and Response to Comments, which states the following:

The written response shall describe the disposition of significant environmental issues raised (e.g., revisions to the proposed project to mitigate anticipated impacts or objections). In particular, the major environmental issues raised when the Lead Agency’s position is at variance with recommendations and objections raised in the comments must be addressed in detail giving reasons why specific comments and suggestions were not accepted. There must be good faith, reasoned analysis in response. Conclusory statements unsupported by factual information will not suffice. The level of detail contained in the response, however, may correspond to the level of detail provided in the comment (i.e., responses to general comments may be general). A general response may be appropriate when a comment does not contain or specifically refer to readily available information, or does not explain the relevance of evidence submitted with the comment.

All comments received on the Draft EIR will, as part of the Final EIR, be provided to the City Council for their consideration during the hearing process.

Comments Received
Table RTC-1, Summary of Public Comments on the Draft EIR, lists the comment letters received from agencies, organizations, and individuals, including the two letters of withdrawal. Comments and responses to comments have been assigned a letter (S [State Agencies], O [Organizations], I [Individuals], and W [Withdrawals]). A copy of each comment letter with its corresponding responses is provided in this chapter.

As the CEQA Lead Agency and pursuant to California Public Resources Code, Section 21092.5, and CEQA Guidelines, Section 15088(b), the City provided the public agency that commented on the Draft EIR with a copy of the City’s response to those comments at least 10 days before certifying the EIR.

In accordance with Section 15132 of the State CEQA Guidelines, the agencies, organizations, and individuals that submitted comments regarding the Draft EIR within the public review period are listed below:

Table RTC-1. Summary of Public Comments on the Draft EIR No. Commenter Date
State Agencies
S1 California Department of Transportation (Caltrans) 6/4/2025 Organizations
O1 Tom Hissong, San Diego Parrot Head Club 5/29/2025

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Table RTC-1. Summary of Public Comments on the Draft EIR No. Commenter Date
O2 Hillcreek Neighbors 6/4/2025
O3 San Diego Archaeological Society 6/4/2025
Individuals
I1 Philip and Linda Decker 5/22/2025
I2 John Ryan 5/29/2025
I3 Vicki Krismer 5/23/2025
I4 Tri Dang 5/29/2025
I5 Stephanie Bowers 5/29/2025
I6 Dominic Daoust 5/29/2025
I7 Jason Lewis 5/30/2025
I8 Sara Hertweck 5/30/2025
I9 Torri Rodriguez 5/31/2025
I10 Dennis L. Canfield 5/31/2025
I11 Alishia Prescott 6/1/2025
I12 Kimberly Klingensmith 6/2/2025
I13 Mike Aiken 6/2/2025
I14 Jim Preihs 6/2/2025
I15 Carl and Mary Costantino 6/2/2025
I16 Torri Rodriguez 6/3/2025
I17 Chris Schneider 6/3/2025
I18 Evan McDonald 6/3/2025
I19 Beverly Pendarvis 6/4/2025
I20 Andrea Roth 6/4/2025
I21 Tracy Sundlun 6/4/2025
Withdrawn
W1 Advocates for the Environment 6/19/2025
W2 Golden State Environmental Justice Alliance 6/20/2025 The comment letters have been divided into individual comments, with each comment containing a single theme, issue, or concern. Each comment is bracketed and assigned a letter and number. Comment letters have been reduced to fit on the left side of a single page. The corresponding City response and letter-number combination is provided on the right side of the page.

In the responses to comments, revisions to the Draft EIR are indicated as underlined text (e.g., underlined text) and deletions as strikethrough text (e.g., strikethrough text). In Chapter 3, text changes resulting from the comments received are also shown as underlined and/or strikethrough text. Please note that the revisions do not affect the conclusions of the Draft EIR.

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Thematic Responses
Two topics were frequently raised in the comment letters received during the public review period: transportation and noise. Thematic responses are provided below to address these topics.

Thematic Response 1: Transportation
Revisions to PDF-TRA-1 and MM-TRA-2
Following the release of the Draft EIR for public review, the City and the Project applicant discussed changes to the Project design features (PDFs), particularly the PDF related to transportation/traffic. Changes to PDF-TRA-1 and mitigation measure MM-TRA-2 were further refined following the receipt of the comment letter from Caltrans (Letter S1). Figure RTC-1 has been included to graphically depict the type, extent, and responsibility of transportation improvements as modified by the text changes to PDF-TRA-1 and MM-TRA-2. The revisions to PDFTRA-1 and MM-TRA-2 are as follows:

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.

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.

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-ofway, 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 applicant will pay an in-lieu fee in the amount of $50,000 to the City to complete this work.

CEQA Guidelines Section 15088.5(a) states the following:

A lead agency is required to recirculate an EIR when significant new information is added to the EIR after public notice is given of the availability of the draft EIR for public review under Section 15087 but before certification. As used in this section, the term “information” can include changes in the project or environmental setting as well as additional data or other information. New information

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added to an EIR is not “significant” unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project’s proponents have declined to implement. “Significant new information” requiring recirculation include, for example, a disclosure showing that:
(1) A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented.
(2) A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance. (3) A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the environmental impacts of the project, but the project’s proponents decline to adopt it.
(4) The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded. (Mountain Lion Coalition v. Fish and Game Com. (1989) 214 Cal.App.3d 1043)
Section 15088.05(b) states that “Recirculation is not required where the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR.” In the present case, the revisions made to PDF-TRA-1 and MM-TRA-2 are not significant revisions because they merely provide additional information for implementation of PDF-TRA-1 and MM-TRA-2. The revisions do not involve changes to the improvements that would be constructed but rather provide options for completion/satisfaction of the improvements. Because the improvements discussed in PDF-TRA-1 and MM-TRA-2 would still be constructed, the information added is not considered to be “significant new information” under CEQA Guidelines Section 15088.5(a). Because the text changes in PDF-TRA-1 and MM-TRA-2 are not significant new information, recirculation of the Draft EIR is not required.

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Figure RTC-1 Updated Intersection Improvements

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Traffic – LOS vs VMT
Many comments received during the public review period expressed concern about traffic that would be generated by the proposed Project. In the past, environmental review of transportation impacts focused on the delay that vehicles experience at intersections and on roadway segments, which is often measured using level of service (LOS). Mitigation for impacts on vehicular delay often involves increasing capacity, such as widening a roadway or the size of an intersection, which in turn encourages more vehicular travel and greater pollutant emissions.

Additionally, improvements to increase vehicular capacity can often discourage alternative forms of transportation such as biking and walking.

The state’s adoption of Senate Bill (SB) 743, Public Resources Code Section 21099(b)(2), and subsequent adoption of CEQA Guidelines Section 15064.3 provide that traffic delay under an LOS metric is no longer considered a significant environmental impact under CEQA. SB 743 directed that an alternative metric(s) be developed for analyzing transportation impacts in CEQA documents. State law now requires the use of a vehicle miles traveled (VMT) metric for land use development projects, which is intended to promote the state’s goals of reducing greenhouse gas emissions and traffic-related air pollution, while promoting the development of multimodal transportation system, and providing clean, efficient access to destinations. However, the proposed Project’s traffic analysis using the LOS metric was included in the Transportation Impact Study (TIS) (Appendix L of the Draft EIR) for informational purposes and to comply with City requirements.

Since adoption of SB 743, Caltrans has updated its guidelines for Land Development Review (LDR) and adopted the metric of VMT. Per Caltrans Vehicle Miles Traveled-Focused Transportation Impact Study Guide, May 20, 2020, LOS analyses or other vehicle operations analyses for land use projects are no longer requested or required by Caltrans.

The City of Santee adopted its VMT Analysis Guidelines in April, 2022. The Caltrans guidance supports the shift away from using LOS as a metric of analysis under CEQA, in accordance with implementing Senate Bill 743.

The TIS provides analysis of the proposed Project’s potential effects relative to General Plan consistency with LOS policies used by the City over each of the study intersections. Additionally, per City of Santee Mobility Element Policy 2.1, “The City shall encourage an automobile Level of Service “D” on street segments and at intersections throughout the circulation network while also maintaining or improving the effectiveness of the non-automotive components of the circulation system (i.e., pedestrians, bicyclists, and public transit). The City may approve a lower automobile LOS if it finds that the effectiveness of nonautomotive components of the circulation system would be maintained or improved as a result. In other cases, the City shall not approve any development that causes a drop in the level of service at a street segment or an intersection to LOS E or F, after feasible mitigation, without overriding social, economic, or other benefits. For impacts related to CEQA analysis(i.e., VMT analysis) mitigation measures may include Transportation Demand Management recommendations, such as transit facilities, bike facilities, telecommuting, rideshare programs, flex-time, carpool incentives, parking cash-out, complete or partial subsidization of transit passes, etc.

In conclusion, while many comments discuss existing traffic congestion in the area and express concern about worsening traffic with implementation of the Project, traffic delay is not an environmental impact under CEQA.

Because traffic delay and congestion are not considered an environmental impact, no mitigation is required.

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Traffic Safety and ICE/ISOAP Evaluation
Several comments were received that expressed concern for traffic safety, particularly with the addition of truck trips that would be generated by the proposed Project. Also, the comment letter from Caltrans posed specific questions regarding transportation safety impact review.

The Traffic Safety Bulletin 20-02-R1: Local Development Intergovernmental Review (LDR) Safety Review Practitioners Guidance, February 2024, provides instructions to Caltrans personnel who conduct road safety reviews for proposed land use projects and plans affecting the State Highway System (SHS), within the scope of the LDR process (Caltrans 2020). This Guidance establishes the recommended transportation safety impact review process for Caltrans and lead agencies for evaluating proposed land use projects. As required by the LDR Safety Review Guidance for land use plans, the proposed Project’s TIS includes queuing analysis for the Caltrans facility in the proposed project’s study area (i.e., N. Woodside Avenue/ Woodside Avenue – State Route 67 (SR-67) southbound (SB) Off-Ramp intersection). 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 and the analysis indicates there are currently no queuing issues that may potentially spill back onto the SR-67 mainline.

The Intersection Safety and Operational Assessment Process (ISOAP) is an update and renaming of Intersection Control Evaluation (ICE) and supersedes Traffic Operations Policy Directive 13-02 and the August 23, 2013 memorandum, Intersection Control Evaluation (ICE) and Design Guidance. The process is used by Caltrans to evaluate proposed traffic control and design geometrics for intersections and other access improvements proposed on the State Highway System.

As such, ISOAP analysis is beyond the scope of the Draft EIR or the proposed Project’s TIS.

SR-67/ Riverford Road Interchange
Multiple comments were received that questioned whether trucks traveling to or from the Project site would utilize the SR-67 interchange at Riverford Road, and some comments questioned the timing of the Caltrans improvements at that interchange. The SR-67/Riverford Road interchange improvements, a transportation project which would consolidate three intersections into two roundabouts on Riverford Road on both sides of SR-67, is proposed approximately one mile north of the proposed Project site. The Project’s study area does not include Riverford Road and its intersections with SR-67 because the proposed Project would not add 50 or more peak hour trips to those facilities. However, as shown in the State Route 67 and Riverford Road ICE Report, submitted to Caltrans in 2020, with the construction of proposed roundabouts, the closely spaced intersections of the SR-67 northbound offramp/Woodside Avenue, Woodside Avenue/Riverford Road, and SR-67 southbound ramps/Riverford Road would operate at LOS D or better for all movements with no spillback onto SR-67 mainline. Therefore, the SR-67/Riverford Road interchange project will improve LOS and traffic operations in the vicinity of the proposed Project.

The details on the timing of construction of this interchange are not available currently. Therefore, it is unknown if construction of any part of the SR-67/Riverford Road interchange would overlap with the construction of the proposed Project. However, construction of both projects would follow standard procedures for obtaining required encroachment and trip permits from Caltrans and ensure that appropriate traffic control and construction traffic management plans are prepared and implemented along Woodside Avenue.

Roadway Damage
Several comments express concern regarding roadway damage from the increased volume of trucks that would occur with the proposed Project. It should be noted that segments of Woodside Avenue are classified as Prime or Major

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Arterial in the City and classified as a Collector in the vicinity of the Project. In the City, Woodside Avenue is an important and designated truck route that connects the industrial areas to SR-52, SR-67 and SR-125. While roadway damage is not an environmental impact under CEQA, this brief response is being provided for informational purposes. The City’s Engineering Department is responsible for street maintenance and additional information can be found on the Department’s website at https://www.cityofsanteeca.gov/departments/engineering/street-maintenance. The City performs street maintenance and resurfacing based on the recommendations from the most recent Pavement Management Report, which identifies the best and highest use of the annual street maintenance budget based on a condition analysis of all streets within the City. Street resurfacing is funded by three sources: 1) TransNet, the halfcent sales tax administered by SANDAG; 2) Senate Bill (SB) 1, also referred to as Road Maintenance and Maintenance Account (RMRA) gas tax; and, 3) the City’s General Fund.

As noted in PDF-TRA-1, the 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 on 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. Woodside Avenue. Therefore, the pavement on Woodside Avenue would be improved to sustain increased truck volumes in the vicinity of the Project.

Thematic Response 2: Noise
Multiple comments were received regarding Project noise, with most concerned about operational noise. As discussed in Section 4.10, Noise, of the Draft EIR, a Noise Technical Report was prepared by Dudek in May 2024 and included as Appendix K to the Draft EIR. Many of the comments were general, lacking specific concerns regarding the assumptions or calculations in the technical report.

The City of Santee has established target maximum noise levels in the City, categorized by land use. The City’s General Plan Noise Element sets limitations on noise levels for receiving properties adjacent to the project site. The City has established a maximum noise level limit of 65 dBA Ldn for noise-sensitive land uses, such as the residences along Hillcreek Road, which the noise analyses have shown is not predicted to be exceeded during construction or operation of the Project. The City does not establish maximum operational level limits based upon the difference between measured ambient levels at noise-sensitive use property lines and predicted operational levels at proposed project property lines. Further, the City does not establish differing noise standards for weekdays and weekends. The assertion that “in many residential areas, Sundays are quieter than weekdays or Saturdays” is not based on any factual data or study; it is simply an assumption. Additionally, the noise analysis does account for the differences between day and nighttime truck operations, as shown in Appendix D of the noise memorandum (Appendix K of the Draft EIR).

The 8-foot noise barrier is not necessary for the proposed Project to avoid noise impacts and be considered less than significant. The wall was requested by the City and added by the Project applicant as a good faith measure to ease community concerns over visual and noise impacts. The wall itself attenuates predicted operation noise levels by approximately 2 to 3 dBA for the homes north of the San Diego River. Therefore, predicted operation noise levels without the wall are still well under the City threshold of 65 dBA Ldn at residential land uses. A higher wall would therefore be unnecessary, and the additional amount of noise reduction afforded by a taller wall would not be perceptible. The wall thickness is also irrelevant to the discussion of noise attenuation because diffraction of sound around noise walls limits their sound reduction effectiveness to the point at which a different material would not change its sound reduction effectiveness. The wall is expected to be a standard masonry wall of standard thickness to support the wall structure itself, which is adequate for a noise attenuating wall. Absorptive treatments may be

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placed on the wall, but would not change its noise reduction effectiveness and are again not necessary for the project to avoid noise impacts.

The Project conforms to the City’s noise threshold for industrial areas, which is 75 dBA Ldn at the property line. As shown in Figures 5 and 6 of the noise technical memorandum (Appendix K of the Draft EIR), the predicted noise level in the river area ranges from approximately 40 to 45 dBA during daytime hours and 35 to 40 dBA during nighttime hours, which is already under the existing ambient noise level as measured in the area. Further, wildlife noise impact evaluations generally use a 60 dBA threshold (refer to the San Diego Municipal Code, Land Development Code, Biology Guideline document, which discusses this threshold for relevant nesting bird species), which is far greater than the predicted operation noise levels beyond the project property boundary.

Regarding HVAC noise, the noise model assumed that the noise sources were distributed over a large portion of the roof area as a worst-case scenario. This is unlikely to be the case as generally HVAC sources are grouped together. Additionally, according to Project plans, a parapet would be installed on the building edge, which would further reduce the line-of-sight between the HVAC noise sources and the surrounding area. This parapet was not included in the modeling effort. Therefore, the noise analysis is considered a worst-case scenario with assumptions that actually overestimate the predicted noise levels.

One common concern expressed in the comments is for operational Project noise in violation of the City’s Municipal Code. The Project would include loading and unloading activities as part of Project operation. Therefore, Project operations would be subject to Municipal Code Section 5.04.130 which makes it unlawful for any person to engage in loading, unloading, opening, idling of trucks, closing or other handling of boxes, crates, containers, building materials, garbage cans, dumpsters or similar objects between the hours of 10:00 p.m. and 7:00 a.m. in such a manner as to cause a noise disturbance within or adjacent to a residential district. While the proposed Project may operate 24/7, loading/unloading and other noise generating activities would be restricted to the hours stated in the noise ordinance with which the proposed Project, like all operations within the City, is required to comply.

Municipal Code Section 5.04.160 applies to any noise source not specifically addressed in Chapter 5.04, Noise Abatement and Control, except where exempted or excluded by Section 5.04.170. Section 5.04.160 states that it is unlawful for any person to generate any noise on the public way that is louder than average conversational level at a distance of 50 feet or more, vertically or horizontally, from the source between 10:00 p.m. and 7:00 a.m. Also, between 10:00 p.m. and 7:00 a.m., no person is permitted to generate any noise on any private open space that is louder than average conversational level at a distance of 50 feet or more, measured from the property line of the property from which the noise is being generated.

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Response to Comment Letter S1
California Department of Transportation
Kimberly Dodson, Branch Chief
June 4, 2025
S1-1 The comment is an introduction to the comment letter describing the California Department of Transportation’s (Caltrans’s) goals and does not raise a significant new environmental issue regarding the adequacy or accuracy of the information provided in the Draft Environmental Impact Report (EIR). Therefore, no further response is required.

S1-2 The comment states that Caltrans previously reviewed the Transportation Impact Study (TIS) dated April 2024 and provided feedback in June 2024. The comment also states that Caltrans compared the previous version to the April 2025 [sic] and found that comments from June 2024 have not been addressed and there are direct impacts that need to be mitigated. While the letter stated that Caltrans compared the earlier version with the “current TIS dated April 2024,” it is assumed that Caltrans meant the current TIS dated April 2025.

Attached to this comment letter dated June 4, 2025, Caltrans has provided comments in the text of Appendix L (TIS). These comments are identified as Comments S1-39 through S1-51.

Responses to Caltrans’s specific comments on the TIS are provided with those comments. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-3 The comment states that the latest TIS removed details regarding roadway widening that triggered the Intersection Control

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Evaluation (ICE) and made the language very vague. Further, the comment states that the project is proposing to widen the roadway by 1,240 square feet and installing a new sidewalk, which would still trigger the ICE, which is now known as the Intersection Safety and Operational Assessment Process (ISOAP).

As described in Thematic Response 1: Transportation, the Project does not propose any roadway improvements to alleviate LOS or traffic effects at the N. Woodside Avenue and SR-67 SB Off-Ramp Intersection, per current CEQA guidelines for
determining transportation impacts. A queuing analysis of this ramp intersection included in the TIS (see Table 17) shows that under the Existing and Existing plus Project conditions, 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. This determination satisfies the Caltrans Local Development Intergovernmental Review (LDR) Safety Review Practitioners Guidance (February 2024) requirements and the Project would not cause any safety related impacts to Caltrans facilities. The Project does not trigger the ISOAP because it does not have any safety related impacts.

While the Project generates over 1,000 daily trips, it would not add 1,000 or more trips to the N. Woodside Avenue and SR-67 SB Off-Ramp Intersection or SR-67 mainline. The Project does not propose a change in traffic control or install a pedestrian hybrid beacon and nor make a major physical change such as widening to provide an additional through or turn lane. Therefore, the Project would not trigger an ISOAP analysis. See PDF-TRA-1, MM-TRA-1, and MM-TRA-2 for proposed improvements and
mitigation measures consistent with City requirements. This comment does not raise a new significant environmental issue

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regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-4 The comment states that previous comments for the N.

Woodside Avenue and SR-67 SB Off-Ramp Intersection
Improvement Project still apply. Please see Responses to Comments S1-39 through S1-51. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-5 The comment states that the latest TIS dated April 2024 [sic] with comments is attached, and that the project needs to show a layout and site plan of the proposed roadway widening and sidewalk improvements to the Woodside Avenue and SR-67
intersection.

Regarding the comments on the current TIS, please see
Responses to Comments S1-39 through S1-51. Regarding the layout and site plan, please see Figure RTC-1 illustrating Intersection Improvements at the N. Woodside Avenue and SR67 SB Off-Ramp Intersection. Also please see PDF-TRA-1. MMTRA-1, and MM-TRA-2 for proposed improvements. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-6 The comment requests clarification of whether a Caltrans Encroachment Permit will be needed, as well as clarification of the location of the pavement improvements identified in the Draft EIR. The encroachment permit may be required for
construction of a small portion of the sidewalk within the

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Caltrans right-of-way (ROW), as shown in Figure RTC-1 in this Final EIR. None of the proposed pavement improvements are within the Caltrans ROW. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-7 The comment directs the City to bring curb ramps at the SR-67 southbound off-ramp corner and North Woodside Avenue corner to the current standards with reference to Design Information Bulletin 82-06 for more information. Further, the comment requests confirmation of how the proposed sidewalk will be connected to existing sidewalks. Please see Figure RTC-1 in this Final EIR which illustrates the proposed Intersection
Improvements at the N. Woodside Avenue and SR-67 SB OffRamp Intersection for details of existing and new sidewalk along N. Woodside Avenue, shown in green and blue colors. The sidewalk in Caltrans ROW is shown in green and within the City’s ROW is shown in blue. The curb ramp at the SR-67 southbound off-ramp corner and North Woodside Avenue would be
constructed per applicable design standards. The pavement rehabilitation and re-striping is shown as well and would occur within the City’s ROW. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-8 The comment states that the TIS needs to include a safety review that follows the Caltrans “Local Development Review (LDR Safety Review Practitioner’s Guidance” document. Please see
Response to Comment S1-3 for discussion of consistency of the Project’s TIS with Caltrans’ safety review requirements. This comment does not raise a new significant environmental issue

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regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-9 The comment states that neither the Draft EIR nor the Preliminary Hydrology Study (Appendix J-1 of the Draft EIR) provides a response from the City of Santee pertaining to the FEMA floodplain. The comment requests documentation of the City’s concurrence that the Project will not impact the FEMA floodplain/floodway and will not require coordination with FEMA and/or preparation of a FEMA no-rise certification. As stated on Draft EIR pages 4.8-25 and 4.8-26, the Project site is adjacent to a regulatory floodway but the Project site has been designed to not impact the existing floodplain, and the Project structures would be located at least one foot above the floodplain. As the Draft EIR was prepared by the City and reflects the City’s evaluation of impacts, no additional documentation is
necessary. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

S1-10 The comment relates to system planning and requests clarification of which PRONTO monthly transit pass will be reimbursed. Item 3, Implement Subsidized or Discounted Transit Program, under MM-TRA-1 Trip Reduction Program in the Draft EIR and TIS mentions that a monthly transit pass would be provided or cost would be reimbursed to the employees who use transit to commute to the Project. The card can be used for all buses, Trolley, Sprinter, and Coaster, including services operated by the Metropolitan Transit System (MTS) and the North County Transit District (NCTD) in the San Diego region. Further details would be worked out between the employer and specific

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employees based on their travel needs. No further details can be provided at this time. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-11 The comment urges consideration of formalizing the southside of the San Diego River trail system adjacent to the project site and other businesses for purposes of more walking and green space access. The proposed Project does not trigger the formalization of such a system, however implementation of the proposed Project would not preclude formalizing this trail system. This comment does not raise a new significant
environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

S1-12 The comment relates to system planning and urges the City to look at the San Vicente Comprehensive Multimodal Corridor Plan (CMCP) for projects that may align with the proposed Project. The San Diego Association of Governments (SANDAG) and Caltrans are developing a Comprehensive Multimodal Corridor Plan (CMCP) for the San Vicente corridor. The CMCP proposes local road and network improvements to balance future
transportation needs while also preserving existing rural and community characteristics including the natural landscape of mountains, hills, valleys, lakes, and creeks. It focuses on improving transportation along SR-67 between Lakeside and Ramona. As such, the Woodside Avenue Safety Improvement Project and SR/67 Riverford Road Interchange Project are noted in the CMCP. The proposed Project would improve sidewalks and striping along N. Woodside Avenue as shown in Figure RTC-1 of this Final EIR. The Project would construct an eastbound left turn

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lane to facilitate safe truck turn movements to the Project driveway from N. Woodside Avenue. Additionally, the proposed Project would not conflict or impede implementation of this plan, or projects proposed as part of the CMCP in the future. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-13 The comment related to system planning and urges the City to review the SANDAG Regional Plan and the Draft Proposed 2025 Regional Plan. The Project’s consistency with the SANDAG Regional Plan has been evaluated in the Draft EIR, in Table 4.9-2 beginning on page 4.9-12 of the Draft EIR. As described in Table 4.9-2, the Project would be consistent with the applicable goals set forth by SANDAG in the 2021 Regional Plan. Therefore, impacts would be less than significant. Further, the VMT analysis and proposed mitigation measures will ensure the Project’s consistency with regional plan and policies. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

S1-14 The comment identifies five planning documents frequently utilized by Caltrans that may provide background on state and regional planning. Comment noted. The comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

S1-15 The comment identifies three existing Caltrans projects near the Project site. Comment noted. The comment does not raise a new significant environmental issue regarding the adequacy or

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accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

S1-16 The comment states that the project needs to remove the free right turn and “tee” up the intersection of North Woodside Avenue/SB SR-67 off-ramp. As shown in the TIS (Appendix L of the Draft EIR), the Project would not add any trips to the free (channelized) right turn available at the N. Woodside Avenue/S.

Woodside Avenue - SR-67 SB Off-Ramp. There are no queuing related impacts per the safety review of Caltrans facilities conducted in the Project’s TIS (Appendix L of the Draft EIR). As explained in the Thematic Response 1: Transportation, traffic delay under an LOS metric is no longer considered a significant environmental impact under CEQA. The Project proposes multimodal improvements such as construction of sidewalk at this intersection to connect to the existing sidewalk along Woodside Avenue. The bicycle lane at the intersection and along Woodside Avenue will be maintained as-is. Bicycle, pedestrian, and public transit access will be maintained during construction. For any construction work in the public ROW, the contractor shall prepare a Traffic Control Plan to ensure access for all road users is maintained during construction. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-17 The comment states that the Project needs to provide at minimum a 6-foot Class II bike lane through Caltrans ROW that connects the intersection of Woodside Avenue/SR-67 offramp on all legs of the intersection with the exception of the SR-67 offramp. There are existing bike lanes on all three legs of City streets. The striping on the southeast corner of the intersection is meant to be a bike lane, but that location is within Caltrans’

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jurisdiction. The proposed Project does not include any change to the existing bike lane along N. Woodside Avenue. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-18 The comment states that the minimum width of sidewalks in Caltrans right-of-way is 5 feet. Comment noted. The comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

S1-19 The comment states that a detour needs to be provided if there are any effects on pedestrian or bicycle facilities during construction.

The City of Santee requires preparation of a Traffic Control Plan for construction that includes roadways, which is the case with the proposed project. The City’s Traffic Engineering Division reviews traffic control plans, which shall follow the Manual on Uniform Traffic Control Devices California Edition (MUTCD) and the San Diego Regional Standard Drawings. The MUTCD includes
consideration for pedestrian and bicycle facilities. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-20 The comment states that mitigation to maintain bicycle, pedestrian, and public transit access during construction is in accordance with Caltrans’ goals and policies. As discussed above in Response to Comment S1-19, a TCP would be prepared for the Project. Regarding transit access, the Draft EIR (p. 4.12- 23) states that 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.

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Because there are no transit facilities that would be affected by Project construction and a TCP is required by the City for construction activities that would affect roadways (including sidewalks and bike lanes), the mitigation suggested by the comment is not necessary. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-21 The comment states that Caltrans is unable to confirm the location of the sidewalk and pavement improvements identified in the Draft EIR, and requests exhibits showing the proposed improvements.

While the text of both the Draft EIR and TIS (Appendix L) described the location and extent of the sidewalk and pavement
improvements, a graphical depiction of the improvements has been included as Figure RTC-1 within this Final EIR. The figure can be found within Thematic Response 1: Transportation. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-22 The comment requests the City verify the need for a retaining wall to support the proposed sidewalk connection where North Woodside Avenue meets the southbound off-ramp from SR-67, stating that the ground elevation at the adjacent property is much lower than at the proposed sidewalk. Based on the topographic survey, there is sufficient level ground to install the sidewalk without creating a retaining condition. The City will have the opportunity to confirm this conclusion during the plan check process after a full design has been prepared. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

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S1-23 The comment states that an encroachment permit will be required for any construction within Caltrans right-of-way, and notes that the western portion of the sidewalk connection, where N. Woodside Avenue meets the southbound off-ramp from SR-67 is within Caltrans ROW. The comment is noted. Figure RTC-1 of the Final EIR shows the portion of sidewalk within the Caltrans ROW in green color. For any construction in the Caltrans ROW, the applicant shall obtain required permits. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

S1-24 The comment states that the City should continue to coordinate with Caltrans to implement necessary improvements at
intersections and interchanges where the agencies have joint jurisdiction. Comment noted. The comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

S1-25 The comment states that Caltrans has discretionary authority over special permits for vehicle size or weight exceeding the maximum limitations of the California Vehicle Code. The comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no response is required.

S1-26 The comment states that a Traffic Control Plan must be submitted to Caltrans at least 30 days prior to the start of construction for work involving the interchanges at SR-67/North Woodside Avenue. Further, the comment notes that potential impacts to SR-67 and the traveling public should be addressed before work begins. This is a standard requirement for
construction impacting Caltrans facilities and would be complied

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with by the Project applicant. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-27 The comment states that the applicant must be informed that Caltrans is not responsible for existing or future traffic noise impacts associated with the existing configuration of SR-67. The applicant is aware of the existing and cumulative noise environment at the project site, which includes traffic noise from SR-67. The noise analysis prepared as part of the project includes current ambient noise measurements that reflect traffic noise from SR-67. In addition, the cumulative noise condition takes into consideration future noise from SR-67. The comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no response is required.

S1-28 The comment states that Caltrans is a Responsible Agency under CEQA and would appreciate meeting with the City to discuss the elements of the environmental document that Caltrans would use for their environmental compliance. As discussed on Draft EIR page 3-47, the City acknowledges that responsible and/or trustee agencies may use the Draft EIR for CEQA documentation for approvals under their authority. Additionally, Draft EIR page 3-48 states that Caltrans’ approval would be needed for improvements within Caltrans’ right-of-way (ROW). The City supports continued coordination with Caltrans. The comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no response is required.

S1-29 The comment states that an encroachment permit will be required prior to construction for any work within Caltrans right-of-way and

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provides information regarding what information will be needed.

The comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no response is required.

S1-30 The comment recommends that the Project identify and assess potential impacts caused by the Project or from mitigation efforts that occur within Caltrans ROW. Further, the comment states that Caltrans is interested in any additional mitigation measures identified in the Project’s Final EIR. As discussed in Thematic Response 1: Transportation, the text of PDF-TRA-1 and MM-TRA-2 have been revised. There are no changes proposed to MM-TRA-1.

This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-31 The comment recommends collaboration between the City of Santee and Caltrans. Comment noted. The comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no response is required.

S1-32 The comment states that perpetuation of survey monuments is required if they are being destroyed by construction. The Project applicant will adhere to all state laws, including those requiring perpetuation of survey monuments. The comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no response is required.

S1-33 The comment summarizes previous information about encroachment permits. The comment does not raise a new
significant environmental issue regarding the adequacy or

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accuracy of the information provided in the Draft EIR. Therefore, no response is required.

S1-34 The comment includes a letter dated July 24, 2024 and provides comments from Caltrans regarding conceptual design review of North Woodside Avenue and SR-67 southbound off-ramp
improvements. The letter is addressed to the Project applicant, not the City of Santee. Further, Project improvements have been revised since the date of the letter (July 24, 2025). Please see Thematic Response 1: Transportation for information regarding the current plans for improvements to be constructed as part of the proposed Project. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-35 This comment appears in an attachment to the letter referenced in Comment S1-34. The comment states that the proposed
widening from one lane to two triggers the ICE/ISOAP. Further, the Hybrid Roundabout Alternative is the only approved
intersection control type if widening or changing this intersection.

Please see response to comment S1-3 and Thematic Response 1: Transportation for information regarding the direct impacts per LOS and changes in proposed work at this intersection. For Project’s VMT impacts, feasible mitigation measures and applicable reduction percentages have been identified in the TIS and Draft EIR. The queuing analysis in the TIS uses the updated Project trip distribution percentages confirmed with the City’s traffic engineer and used in the TIS.

S1-36 This comment appears in an attachment to the letter referenced in Comment S1-34. The graphic depicts the Project Overview, Southbound SR-67 Off-Ramp/ N. Woodside Ave Intersection. The comment does not raise a new significant environmental issue

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regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no response is required.

S1-37 This comment appears in an attachment to the letter referenced in Comment S1-34. The graphic depicts the Turn Template Exhibit A, Southbound SR-67 Off-Ramp/ N. Woodside Ave Intersection. The comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no response is required.

S1-38 This comment appears in an attachment to the letter referenced in Comment S1-34. The graphic depicts the Turn Template Exhibit B, Southbound SR-67 Off-Ramp/ N. Woodside Ave Intersection. The comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no response is required.

S1-39 The comment includes Appendix L (TIS) as it appeared in the Draft EIR. The comments that follow are the comments made by Caltrans on Appendix L. The comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no response is required.

S1-40 The comment (imbedded within Figure 3, Project Trip Distribution, on page 15 of the TIS) states that the Caltrans comments from June 2024 have not been addressed.

Regarding the June 2024 comment letter, please see Response to Comment S1-34. Also note that the April 2024 version of the TIS that Caltrans reviewed and commented on in June 2024 was updated. The trip distribution rates were modified to reflect a portion of truck trips that would be expected to drive north along N. Woodside Avenue from the Project site. The comment does

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not specify which comments have not been addressed. The comment is general and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

S1-41 The comment notes that the VMT impacts discussed on page 35 of the TIS dated April 2025 (Appendix L of the Draft EIR) are the same as those reflected in the April 2024 draft version of the TIS reviewed by Caltrans. The comment is general and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no response is required.

S1-42 The comment states that previous comments from the June 2024 review were not addressed and still apply. The comment is on page 49 of the TIS (Appendix L of the Draft EIR) and located beneath Table 10, but does not point to specific information or specify the comments that were not addressed. The comment is general and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

S1-43 The comment states that there is a direct impact to a Caltrans intersection going from existing LOS C to LOS E under the Existing Plus Project scenario. This comment is on page 49 of the TIS (Appendix L of the Draft EIR) and points to line item 4 in Table 10, which is listed as the intersection of Woodside Avenue/ S.

Woodside Avenue – SR-67 SB Off-Ramp.

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S1-3 and Thematic Response 1: Transportation for more
information responsive to this comment. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-44 The comment states that previous comments from the June 2024 review were not addressed and still apply. The comment is on page 63 of the TIS (Appendix L of the Draft EIR) and located beneath Table 14, but does not point to specific information or specify the comments that were not addressed. The comment is general and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

S1-45 The comment states that there is a direct impact to a Caltrans intersection that requires mitigation. This comment is on page 63 of the TIS (Appendix L of the Draft EIR) and points to line item 4 in Table 14, which is listed as the intersection of N. Woodside Avenue/ S. Woodside Avenue – SR-67 SB Off-Ramp.

As stated on page 4.12-14 of the Draft EIR, “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.” Please see Thematic
Response 1: Transportation for information responsive to this comment. This comment does not raise a new significant
environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

S1-46 The comment states that previous comments from the June 2024 review were not addressed and still apply. The comment is on page 79 of the TIS (Appendix L of the Draft EIR) and located

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beneath Table 17, but does not point to specific information or specify the comments that were not addressed. The comment is general and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

S1-47 The comment states that the 95th percentile should be updated after trip distributions have been updated. This comment appears on page 79 of the TIS (Appendix L of the Draft EIR) and points to Table 17, Queuing Summary for Existing Conditions (95th Percentile Queue). Prior to release of the Draft EIR for public review, the Project’s trip distributions were updated, which are reflected in the TIS dated April 2025 (Appendix L of the Draft EIR). Figure 3 in the TIS illustrates the percentage distribution of cars and trucks along N. Woodside Avenue and the traffic study area approved by the City. The queuing analysis shown in Table 17 of the TIS uses the updated distribution compared to the April 2024 version of the traffic analysis. Therefore, no further analysis is required. Further, this comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project and no further response is required.

S1-48 The comment states that Table 19 is missing, which previously showed Queuing Summary for Near Term Conditions (95th
Percentile Queue) and states that the table and results should be resubmitted. Beginning on page 77 of the TIS, there is a Projectspecific analysis for the Caltrans ramp intersection using queuing analysis methodology for safety review per Caltrans LDR guidelines.

The LDR guidelines require that the project’s impact be compared to the existing scenario to determine whether a deficiency currently exists and if the project contributes to or worsens an existing condition. The analysis in the TIS indicated that under Existing Plus

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Project conditions, most queues would be accommodated within existing storage. Therefore, a near-term condition queuing analysis is not needed, and a corresponding table s not included in the TIS.

S1-49 The comment highlights text within PDF-TRA-1 and comments that the improvements of widening and sidewalk installation trigger the ISOAP, which supersedes the ICE. The comment also states that in previous reviews, Caltrans has made the Project applicant aware that there is an ICE Report for the approved hybrid roundabout. The comment appears on page 81 of the TIS (Appendix L of the Draft EIR). Please see Thematic Response 1:

Transportation for the updated language of PDF-TRA-1 and a discussion of the improvements. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-50 The comment states that there is no table showing the direct impacts being mitigated with the proposed widening and
sidewalk. Further, the comment states that the TIS fails to show how the roadway widening and sidewalk installation would bring LOS back to LOS D or better. Please see Thematic Response 1:

Transportation for information responsive to this comment. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

S1-51 The comment highlights text and comments that as previously mentioned in the June 2024 review, the improvement triggers

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the ISOAP and that plans have already been approved for a hybrid roundabout. Further, the comment states that the proposed Project would have direct impacts to the Caltrans intersection and further coordination with Caltrans will be required. Please see Thematic Response 1: Transportation and Response to Comment S1-3 for information responsive to this comment. This comment does not raise a new significant
environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

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Response to Comment Letter O1
San Diego Parrot Head Club
Tom Hissong, Vice President
May 29, 2025
O1-1 The comment expresses concern about the proposed Project, particularly regarding the number of trucks that would be on roads and freeway entrances. Further, the comment expresses concerns regarding noise, air quality, traffic congestion, and potential blocked views from the 50-foot building.

For more information regarding traffic concerns, please see Thematic Response 1: Transportation. For more information regarding noise, please see Thematic Response 2: Noise. Pollutant emissions and air quality impacts were evaluated in Section 4.2, Air Quality, of the Draft EIR. The analysis in that section demonstrated that the Project would result in less-than-significant air quality impacts and no mitigation was needed. Impacts related to views and visual character of the area were evaluated in Section 4.1, Aesthetics, of the Draft EIR. The analysis in Section 4.1 determined that there would be no significant impacts and no mitigation was required. Overall, the comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed project. Therefore, no further response is required.

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Response to Comment Letter O2
Hillcreek Neighbors
June 4, 2025
O2-1 The comment introduces the commenters as a group of residents in the neighborhood directly north and across the San Diego River from the Project site. The comment states that the residents have concerns regarding potential impacts of the Project during construction and operation. The comment also provides information regarding existing noises from the existing light industrial uses in the Project area. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed project. Therefore, no further response is required.

O2-2 The comment expresses concern that disturbances in the area will intensify and multiply with the proposed Project, and urges the City to consider cumulative and ongoing effects that development may have on the adjacent residential, biological, and recreational areas.

The Project’s noise impacts were evaluated in Section 4.10, Noise, of the Draft EIR. The analysis in that section concluded that all noise impacts would be less than significant and no mitigation is required. Impacts of the Project on biological resources were analyzed in Section 4.3, Biological Resources, of the Draft EIR. While the Project would have some potentially significant impacts on biological resources, implementation of mitigation measures MM-BIO-1, MM-BIO-2, MM-BIO-3, and MMBIO-4 would reduce all impacts to less-than-significant levels.

This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or

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accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

O2-3 The comment alleges that there is a disconnect between the proposed Project as described in the Draft EIR and the
assumptions and findings in the technical reports. Further, the comment states that it is not clear whether the facility would be a warehousing facility or similar that would generate more traffic and operational noise than a traditional warehouse. Finally, the comment also states that more clarity and transparency are necessary to understand potential impacts on neighborhoods.

The proposed Project is described in Chapter 3, Project Description, of the Draft EIR. Each of the supporting technical studies includes a description of the Project, though the specific language may be slightly different. The comment does not provide specific instances where the commenters may perceive a disconnect between the Project description among the Draft EIR and the supporting studies.

Regarding the use that would occupy the Project site, it would be required to be a use that is allowed within the Project site’s existing Light Industrial zoning designation. Should a use be contemplated at the Project site that is conditionally allowed in the LI zoning, an application to the City would be required and additional CEQA documentation may be required. Any uses not permitted in the LI zoning would not be permitted at the Project site. At this time, it is unknown what businesses would occupy the Project buildings. It is not unusual for buildings to be built without specific users being known. The assumptions and analysis in the Draft EIR, including its supporting technical reports, are based on the allowed uses within the LI zoning.

Therefore, the Draft EIR has not evaluated a specific business or particular use. The technical assumptions are based on the LI

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use, which means that as long as a future use is within the allowed uses within the LI zoning, all potential impacts have been disclosed. In the TIS (Appendix L of the draft EIR), however, Industrial Park use was evaluated, which is a more intensive use than a standard warehouse use. By using the Industrial Park use, the TIS accounted for more LI zoning uses than just standard warehouse use.

Regarding clarity and transparency, the comment does not identify specific information that is needed. As stated above, the specific users of the Project site are not yet known and the Draft EIR presents all information available and has evaluated the proposed Project consistent with the LI zoning.

Overall, this comment does not raise a new significant
environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

O2-4 The comment states that the Project would affect traffic congestion and air quality and that these topics require a more thorough evaluation. Further the comment states that it is assumed that the Project could receive deliveries seven days per week.

Please see Thematic Response 1: Transportation for information regarding traffic. Air quality impacts were evaluated in Section

4.2, Air Quality, of the Draft EIR. The analysis in that section demonstrated that the Project would result in less-thansignificant air quality impacts and no mitigation was needed. This comment is general in nature and does not raise a new
significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed project. Therefore, no further response is required.

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O2-5 The comment reviews details of the noise report, which is included as Appendix K to the Draft EIR. The comment states that a Sunday baseline should have been added to measure the maximum possible noise increase, particularly if truck
operations are to be allowed on Sundays. Please see Thematic Response 2: Noise for information responsive to this comment.

O2-6 The comment states that the final design should include landscaping, especially along the northern and western edges.

Landscaping and lighting improvements that are included as part of the Project are described beginning on page 3-7 of the Draft EIR, with landscaping depicted in Figure 3-9 of the Draft EIR. This comment does not raise a new significant
environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

O2-7 The comment expresses concern with the removal of existing pepper trees along the northern property line as the trees provide visual and noise buffers. Impacts related to views and visual character of the area were evaluated in Section 4.1, Aesthetics, of the Draft EIR. The analysis in Section 4.1 determined that there would not be significant impacts and no mitigation was required. As discussed on page 3-27 and shown in Figure 3-11 of the Draft EIR, an eight-foot-tall noise barrier located partially along the northern site boundary will be constructed as part of the Project. The Project’s noise impacts were evaluated in Section 4.10, Noise, of the Draft EIR. The analysis in that section concluded that all noise impacts would

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be less than significant and no mitigation is required. Refer also to Thematic Response 2: Noise for additional information responsive to this comment. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

O2-8 The comment requests an EIR alternative that would include provisions for temporary retention of on-site trees and other requirements related to trees. In the impact analysis beginning on page 4.3-20 of the Draft EIR, it is noted that implementation of the Project would require removal of existing trees. Mitigation measure MM-BIO-4 provides direction for tree replacement, encroachment, and preservation. With implementation of MMBIO-4, impacts to protected tree species would be reduced to a less-than-significant level. 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.

As discussed on page 7-1 of the Draft EIR, consistent with CEQA Guidelines Section 15126.6, the Alternatives chapter focuses on alternatives to the Project that are capable of avoiding or substantially reducing any significant adverse impacts
associated with the Project. Because impacts to trees would not be significant with implementation of MM-BIO-4, there is no need to develop an alternative that would address trees in accordance with the commenter’s suggestions. Further, CEQA Guidelines Section 15126.6(a) requires a reasonable range of alternatives, but does not require consideration of specific alternatives. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided

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in the Draft EIR for the proposed Project. Therefore, no further response is required.

O2-9 The comment expresses concern about Project lighting and requests clear details regarding all elements of Project lighting to ensure that there would be no light spillover into residential and park areas. Information regarding the Project’s lighting is presented beginning on page 3-17 of the Draft EIR. The analysis of lighting impacts is discussed beginning on page 4.1-21 of the Draft EIR.

According to the Site Photometric Plan prepared for the Project (Herdman Architecture + Design 2024), wall mounted light fixtures (53 in total) would be installed on the exterior façades of the building. Approximately half of the wall fixtures would be mounted at a height of 25 feet above ground surface and the remaining half would be mounted at a height of 9 feet above ground surface. In addition, approximately 18 pole mounted lights would be installed throughout the site parking lot and the site driveway. The mounting height of pole lights would be 25 feet above ground surface. All lighting fixtures would be hooded and downward casting. Fixture housing would feature a cast black painted metal finish. Lamp/light sources would be white, LEDs.

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onsite with limited occurrences of lighting (0.1-0.4 footcandles) extending north of the site’s northwestern corner (light levels in this area would be reduced to 0.0-foot candles approximately 20 feet north of the project boundary). Light levels extending north of the Project site would be 0.0 footcandles or low (generally, 0.1-

0.3 footcandles) and would quickly reduce in intensity with increased distance from the source and Project site. On page 4.1- 22 of the Draft EIR, the analysis concluded that the Project would have a less-than-significant impact related to lighting. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

O2-10 The comment expresses concern with operational noise and notes that existing noise readily carries across the river, directly impacting the quality of life of residents in the area. Please see Thematic Response 2: Noise for information responsive to this comment. This comment does not raise a new significant
environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

O2-11 The comment questions the reference to a noise report (Sauter [sic] 2014) in the noise study (Appendix K of the Draft EIR) and the noise section of the Draft EIR (Section 4.10). Further, the comment questions the difference in project types between the one in the Salter 2014 reference and the proposed Project. The noise memorandum uses the Salter study as a basis for prediction of truck noise operations at loading docks. It provides sound data for a sample facility using similar operations to what are expected in the planned facility, and the data are as current today as they were 10 years ago for these kinds of sound sources

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O2-12
and operations. This is not the basis for the entire memorandum; it is simply a methodology used to analyze the addition of truck operations in conjunction with other operational noise sources.

The comment does not appear to offer an alternative
methodology or corrective measures that would be acceptable for the prediction of future operational noise related to truck operations. Predictions must be made prior to construction to ensure compatibility with City thresholds, and given the nature of the permit application, this is the best methodology that can be done to determine the potential for that compatibility. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

The comment claims that the conclusion that noise impacts would be less than significant cannot be supported and that additional consideration should be given to permit conditions restricting truck activities and an alternative featuring rotation of the Project building. Please see Thematic Response 2: Noise for information responsive to this comment. Also, please see Response to Comment O2-11 regarding the methodology of the noise technical analysis. Regarding an alternative featuring rotation of the Project building, the noise analysis determined that noise impacts from the proposed Project would be less than significant. Because CEQA alternatives are intending that would reduce significant impacts, including a building rotation as suggested by the comment. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

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O2-13 The comment states that the Project, which is reviewed as a 24/7 operation, does not intend to request a variance/exception to the City’s noise ordinance. The comment also urges all future uses not be allowed to operate beyond day and time limits imposed by the noise ordinance Please see Thematic Response 2: Noise for information responsive to this comment. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

O2-14 The comment alleges that the proposed 8-foot noise barrier may not provide adequate mitigation and questions why taller walls were not considered. Further, the comment requests additional information regarding wall depth and material. Please see Thematic Response 2: Noise for information responsive to this comment. This comment does not raise a new significant
environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

O2-15 The comment states the intent of Policy 1.5 of the Noise Element and questions whether or not this project would conflict with provisions of an adopted Habitat Conservation Plan (HCP), Natural Community Conservation Plan (NCCP) or other approved local, regional or state habitat conservation plan. The comment also states that noise reduction strategies in site design, landscaping and buffer separation should have been addressed in the Draft EIR.

The analysis of potential conflicts with an adopted HCP, NCCP or other conservation plans is specifically addressed under Threshold F of Section 4.3, Biological Resources, of the Draft EIR.

While an HCP has not yet been adopted for the City of Santee,

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this analysis acknowledges that “the Project site is adjacent to the Preserve areas associated with the San Diego River corridor as identified in the Draft Santee Multiple Species Conservation Plan (MSCP) Subarea Plan.” The analysis concludes that MM BIO-2 and MM BIO-3 are proposed to prevent any indirect impacts on resources within the San Diego River Preserve, and the proposed project would not prevent the Draft Santee MSCP Subarea Plan from being approved or compromise continued implementation of the MSCP in the San Diego County. Thus, impacts related to HCPs would be less than significant.

With respect to noise, refer to Thematic Response 2; Noise.

O2-16 The comment questions whether the HVAC systems located on the Project building’s roof would increase noise significantly, especially given building height. As discussed on page 4.10-21 of the Draft EIR, the noise analysis completed for the Project included assumptions regarding HVAC equipment from a combination of inputs that include square footage values for the proposed Project’s proposed office spaces, Project applicant response to data requests, and manufacturer sound power level data. For the analysis of noise from HVAC equipment operation, eight air conditioning units were modeled on the roofs of the Project building.

Thus, the noise analysis assumed multiple rooftop HVAC units during Project operation. As stated in Section 4.10, Noise, of the Draft EIR, impacts related to noise would be less than significant and no mitigation is required. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy

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of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

O2-17 The comment questions who will be responsible for ensuring Project construction activity only occurs during the times allowed by the municipal code. Further, the comment asks whether neighbors and surrounding businesses would be notified if the City approves construction work to occur outside of the window provided by the City’s Municipal Code. Page 4.10-12 of the Draft EIR states the following:

Construction activities are subject to Section

5.04.090 of the City’s Noise Ordinance, which
specifically prohibits the operation of any single
or combination of powered construction
equipment at any construction site on Mondays
through Thursday except between the hours of
7:00 a.m. and 7:00 p.m. Further, construction
equipment with a manufacturer's noise rating of
85 dBA Lmax or greater may only operate at a
specific location for 10 consecutive workdays. A
notice must be provided to all property owners
within 300 feet if work is scheduled for more
than 10 days and must be provided no later
than 10 days prior to the start of the
construction.

Concerns about construction noise occurring outside of the window established by the code are to be filed with the City’s Code Compliance Division.

This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information

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provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

O2-18 The comment requests a minimum of three noticed public hearings prior to consideration of EIR certification and Project approvals so that there is ample opportunity for public input. For this and all projects with applications seeking approval from the City, all public notices are done in compliance with CEQA requirements and the City’s Municipal Code. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

O2-19 The comment commends the Project applicant’s willingness to engage with the homeowners and looks forward to continued collaboration. Comment noted. The comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed project. Therefore, no further response is required.

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Response to Comment Letter O3
San Diego County Archaeological Society
James W. Royle, Jr., Chairperson
June 2, 2025
O3-1 The comment expresses the San Diego County Archaeological Society’s agreement with the impact analyses and mitigation measures of the Draft EIR, Appendix E (Archaeological Inventory), and Appendix F (Historical Assessment). The comment is noted.

This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed project. Therefore, no further response is required.

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Response to Comment Letter I1
Philip and Linda Decker
May 22, 2025
I1-1 The comment expresses opposition to the Project, citing added traffic and big trucks and trailers clogging the streets. Please see Thematic Response 1: Transportation for a discussion regarding transportation impacts. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed project. Therefore, no further response is required.

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Response to Comment Letter I2
John Ryan
May 29, 2025
I2-1 The comment expresses opposition to the Project, citing large building size, smog, traffic, and blocking of views. Please see Thematic Response 1: Transportation for a discussion regarding transportation impacts. Impacts related to views and visual character of the area were evaluated in Section 4.1, Aesthetics, of the Draft EIR. The analysis in Section 4.1 determined that there would be no significant impacts and no mitigation was required.

Pollutant emissions and air quality impacts were evaluated in Section 4.2, Air Quality, of the Draft EIR. The analysis in that section demonstrated that the Project would result in less-than-significant air quality impacts and no mitigation was needed. This comment is general in nature and does not raise a new significant
environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

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Response to Comment Letter I3
Vicki Krismer
May 23, 2025
I3-1 The comment states that the Project will have negative impacts on the Santee community, including negative impacts on the environment, physical and mental health issues, and daily life.

This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

I3-2 The comment remarks that the SR-67 southbound offramp and the SR-67 northbound on-ramp at Riverford Road are very congested. Please see Thematic Response 1: Transportation for a discussion regarding transportation impacts. This comment is general in nature and does not raise a new significant
environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

I3-3 The comment states that the Project would take away freeway access and safety, and the intersection of North Woodside Avenue and Riverford Road does not have sufficient space for the amount of traffic the Project would generate. Please see Thematic Response 1: Transportation for a discussion regarding transportation impacts. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

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I3-4 The comment states that the City changed its noise restrictions.

The comment also states that allowing the building to be 50-feet tall instead of requiring compliance with the 40-foot maximum is reckless and does not consider the quality of life for Santee residents. The City has not changed its noise restrictions. Also, the Project applicant has not requested that noise restrictions for the Project site be altered in any way. Section 4.1, Aesthetics, of the Draft EIR evaluated the potential impacts of the Project related to scenic views, scenic resources, existing visual character, and lighting and glare. The analyses in this section considered the 50-foot height of the proposed building. This section concluded that the proposed Project would not result in any significant impacts related to aesthetics. This comment is general in nature and does not raise a new significant
environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

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Response to Comment Letter I4
Tri Dang
May 29, 2025
I4-1 The comment expresses concern regarding safety risks associated with increased truck traffic in the area and requests an alternative route for trucks from the site to northbound SR67, one that is away from the residential area. As discussed beginning on page 4.12-12 of the Draft EIR, only 10% of truck trips are expected to head east on Woodside Avenue to access northbound SR-67. It is assumed that the majority of truck trips leaving the Project site would head west on Woodside Avenue to access SR-52 via City-designated truck routes, thereby avoiding the residential areas south and east of the Project Site. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

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Response to Comment Letter I5
Stephanie Bowers
May 29, 2025
I5-1 The comment states that the Project borders a fragile ecosystem and that the Project will irrevocably damage this natural space.

It should be noted that as stated on Draft EIR page 3-2, the Project site is within the Light industrial (IL) zoning; there is no change of use or zoning proposed. Additionally, the Project site is surrounded on three sides by industrial uses. Section 4.3, Biological Resources, of the Draft EIR evaluated potential impacts from the proposed Project on biological resources, including those located adjacent to the site. The analysis in that section concluded that with implementation of the
recommended mitigation measures, the proposed Project would not have a direct or indirect significant effect on biological resources. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed project. Therefore, no further response is required.

I5-2 The comment expresses concern regarding roadway congestion, truck weight, and traffic safety hazards. Please see Thematic Response 1: Transportation for a discussion regarding
transportation impacts. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed project. Therefore, no further response is required.

I5-3 The comment urges City officials to reconsider approval of the Project because of the impacts on the environment and the community. Comment noted. This comment is general in nature and does not raise a new significant environmental issue

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regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

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Response to Comment Letter I6
Dominic Daoust
May 29, 2025
I6-1 The comment states that the proposed Project poses a threat to the health, safety, and livability of the community. Comment noted. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

I6-2 The comment expresses concern about truck traffic, diesel exhaust, noise, and blocked views. Please see Thematic
Response 1: Transportation for a discussion regarding
transportation impacts. Impacts related to aesthetics and air quality are analyzed in Draft EIR Sections 4.1 and 4.2, respectively. Please see Thematic Response 2: Noise for a discussion regarding noise impacts. All impacts related to aesthetics, air quality, and noise were determined to be less than significant and no mitigation is required. This comment is general in nature and does not raise a significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I6-3 The comment urges the City to reject the proposed Project or require a redesign that aligns with the well-being of Santee residents. Comment noted. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

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Response to Comment Letter I7
Jason Lewis
June 2, 2025
I7-1 The comment expresses concern regarding increased traffic at the Riverford Road and SR-67 intersection and street damage.

Please see Thematic Response 1: Transportation for a
discussion regarding transportation impacts. This comment is general in nature and does not raise a new significant
environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I7-2 The comment expresses concern about views of the proposed 50- foot tall Project building. Section 4.1, Aesthetics, of the Draft EIR evaluated the potential impacts of the Project related to scenic views, scenic resources, existing visual character, and lighting and glare. This section concluded that the proposed Project would not result in any significant impacts related to aesthetics. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I7-3 The comment states that the sound of heavy truck operations will be a nuisance. Comment noted. Section 4.10, Noise, of the Draft EIR evaluated the potential noise impacts that would result from Project construction and operation. The section concluded that the proposed project would not result in any significant impacts related to noise. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or

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accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

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Response to Comment Letter I8
Sara Hertweck
May 30, 2025
I8-1 The comment expresses concern regarding the Project, specifically current infrastructure not being able to handle heavy truck traffic. Comment noted. Please see Thematic Response 1:

Transportation for a discussion regarding transportation impacts. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I8-2 The comment states that the construction of a warehouse next to green space is horrific and unwanted. Comment noted.

Section 4.3, Biological Resources, of the Draft EIR evaluated potential impacts from the proposed Project on biological resources, including those located adjacent to the site. The analysis in that section concluded that with implementation of the recommended mitigation measures, the Project would not have a significant direct or indirect effect on biological resources.

This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I8-3 The comment urges the City to consider the Project’s effects on residential areas. Comment noted. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

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Response to Comment Letter I9
Torri Rodriguez
May 31, 2025
I9-1 The comment expresses concern that the characteristics of the proposed Project are not appropriate in the light industrial zoning. Comment noted. As discussed beginning on page 4.9-4 of the Draft EIR, the proposed Project would be consistent with Chapter 13.14 of the City’s Municipal Code, which states that industrial and related uses including warehousing/distribution, assembly and light manufacturing, repair facilities, and business parks, including corporate offices, are allowed. This comment is general in nature and does not raise a new significant
environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I9-2 The comment expresses general concerns regarding noise, traffic congestion, and road damage. Comment noted. Please see Thematic Response 1: Transportation and Thematic
Response 2: Noise for information responsive to this comment.

This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed project. Therefore, no further response is required.

I9-3 The comment expresses a lack of support for the project.

Comment noted. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

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Response to Comment Letter I10
Dennis L. Canfield
May 31, 2025
I10-1 The comment expresses opposition to the Project, citing concerns regarding truck traffic, noise, and limited road access.

Comment noted. Please see Thematic Response 1:

Transportation and Thematic Response 2: Noise for information responsive to this comment. The comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

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Response to Comment Letter I11
Alishia Prescott
June 1, 2025
I11-1 The comment expresses opposition to the Project. Comment noted. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I11-2 The comment expresses concern regarding the increase in commercial truck traffic, which would result in congested roads, longer commutes, and safety risks. Comment noted. Please see Thematic Response 1: Transportation for a discussion regarding transportation impacts. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

I11-3 The comment expresses concern about noise from operations, deliveries, and loading docks impacting residential zones and open space. Comment noted. Please see Thematic Response 2:

Noise for a discussion regarding noise impacts. This comment is general in nature and does not raise a new significant
environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

I11-4 The comment expresses concern regarding worsening air quality during Project construction and operation, which would
jeopardize the health of Santee residents. Comment noted.

Section 4.2, Air Quality, of the Draft EIR evaluated potential impacts related to air quality during construction and operation

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of the proposed Project. The analysis in that section concluded that Project impacts would be less than significant. Additionally, health risk assessments were performed for both construction and operation beginning on page 4.2-30 of the Draft EIR. Both assessments concluded that neither Project construction nor operation would expose sensitive receptors to substantial pollutant concentrations and impacts would be less than significant. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

I11-5 The comment states that the Project threatens to undermine the character of Santee and urges local decision-makers to reject the project. Comment noted. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

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Response to Comment Letter I12
Kimberly Klingensmith
June 2, 2025
I12-1 The comment expresses opposition to the Project, citing concerns about traffic congestion from truck traffic particularly at SR-67 and Riverford Road. Please see Thematic Response 1:

Transportation for a discussion regarding transportation impacts. This comment is general in nature and does not raise a significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

I12-2 The comment expresses concern about views of the large Project building and lack of road improvements. Please see Thematic response 1: Transportation for information regarding roadway improvements. Section 4.1, Aesthetics, of the Draft EIR evaluated the potential impacts of the Project related to scenic views, scenic resources, existing visual character, and lighting and glare. The analysis in that section considered the 50-foot height of the proposed building. This section concluded that the proposed Project would not result in any significant impacts related to aesthetics. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

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Response to Comment Letter I13
Mike Aiken
June 2, 2025
I13-1 The comment expresses support for the Project. Comment noted. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

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Response to Comment Letter I14
Jim Preihs
June 2, 2025
I14-1 The comment opposes the Project, citing concerns regarding traffic, traffic accidents, and road damage. Comment noted.

The comment asks how the commenter can participate in
discussions regarding the Project. Please see Thematic
Response 1: Transportation for information responsive to this comment. Regarding participation in discussions about the proposed Project, interested persons and organizations can participate during the public comment portion of the public hearing that will be held by the Santee City Council. The date on which the proposed Project will be heard has not yet been determined. However, a public hearing notice will be
circulated and posted in accordance with City public hearing notice requirements. This comment does not raise a new
significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

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Response to Comment Letter I15
Carl and Mary Costantino
June 2, 2025
I15-1 The comment states that there is an attachment to the email that contains additional concerns about truck traffic. Comment noted.

I15-2 The comment expresses opposition to the Project, stating that the proposed Project is too big for the area. Further, the comment states that while the area is zoned Light Industrial (IL), it was never designed or built for continuous heavy truck traffic resulting from a large-scale distribution hub with 46 truck loading docks.

Comment noted. Please see Thematic Response 1:

Transportation. Regarding use of the Project site, there is no information stating that the site would be used for a distribution center. The technical reports supporting the Draft EIR and the Draft EIR itself used assumptions based on allowed uses within the IL district. Santee Municipal Code Table 13.14.030A identifies the various permitted, conditionally permitted, and disallowed uses within the IL district. Under section B of the table, general warehousing/wholesale and distribution is shown as a permitted use within the IL zoning district. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

I15-3 The comment states that the only way in and out (of the Project site) is via North Woodside Road, which is a two-lane road that can barely handle existing traffic congestion. Further, the

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comment re-states information from the Draft EIR regarding the number of peak and off-peak truck trips that would be added.

Finally, the comment states that the EIR traffic study is deficient because it does not include the east end of N Woodside, Riverford Road/Hwy 67/Woodside Road intersection. Please see Thematic Response 1: Transportation.

An analysis of Existing, Near Term and Horizon year analysis has been conducted for the Project’s traffic study area. As noted in Section 8.3, Improvement Measures, of the TIS, the Project would construct a dedicated eastbound left turn lane at the Project Access Driveway/Woodside Avenue. This would facilitate Project traffic to enter the Project driveway from N. Woodside Avenue and reduce potential delays to through traffic along the roadway. The Project would implement MM-TRA-1 Trip Reduction Program to reduce single occupancy vehicle trips and VMT, which would reduce traffic generated from the Project. As noted in Section 6.1 Cumulative Projects of the TIS, the SR-67/Riverford Road interchange improvements, a transportation project that would consolidate three intersections into two roundabouts on Riverford Road on both sides of SR-67, is proposed approximately 1 mile north of the Project site.

The Project’s study area does not include Riverford Road and its intersections with SR-67 because the project would not add 50 or more peak hour trips to those facilities. However, as shown in the State Route 67 and Riverford Road Intersection Control Evaluation Report, submitted to Caltrans in 2020, with the construction of proposed roundabouts, the closely spaced intersections of the SR67 northbound off-ramp/Woodside Avenue, Woodside Avenue/Riverford Road, and SR-67 southbound ramps/Riverford Road would operate at LOS D or better for all movements with no spillback onto SR-67 mainline. Therefore, the SR-67/Riverford Road

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interchange project will improve LOS and traffic operations in the vicinity of the Project.

I15-4 The comment states that eastern access to North Woodside from southbound SR-67 requires crossing several lanes of traffic on Riverford Road, and a hard right turn from a single lane over the San Diego River Bridge. The comment identifies the eastern end of North Woodside Road as having two sharp curves. Further, the comment identifies the Riverford Road/North Woodside, SB-67 Off/On Ramp, Woodside Avenue and northbound SR-67 areas as frequently gridlocked and that Caltrans identifies this as a “Problem Area” with major construction planned to occur Fall 2027 till the end of 2029. Please see Response to Comment I15- 3 above. This comment does not raise a new significant
environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

I15-5 The comment states that the western end is a very busy intersection of North Woodside, “South” Woodside, and another SR-67 offramp onto Woodside, which turns into Mission Gorge Road. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I15-6 The comment states that southbound SR-67 to North Woodside Road is not viable for most large trucks because they cannot make the U-turn from the southbound SR-67 offramp onto North

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Woodside Road. The truck trip distribution assumptions were developed using logical traffic patterns to and from the Project to access the nearest Caltrans ramps and facilities. Based on the potential destinations of trucks, it is anticipated that only a small percentage of truck traffic would travel northbound along SR-67 from the Project. As shown in the Project’s TIS, the trucks to and from the Project would not generally use southbound SR-67 to N.

Woodside Road. A majority of the truck would access the site by traveling along N. Woodside Avenue, using the intersection with Magnolia Avenue. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

I15-7 The comment identifies three routes trucks traveling on northbound SR-67 can use to access the Project site. Comment noted. This comment does not raise a new significant
environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I15-8 The comment states that the proposed Project building height would be a maximum of 50 feet, roughly equivalent to five stories, while most buildings in Santee are one or two stories with the maximum being approximately 30 feet tall. While the comment notes that most buildings in the area are one or two stories, the maximum height permitted in the IL zoning is 40 feet. The decision of whether or not to grant the permit to allow a maximum height of 50 feet is one to be made by the City Council when considering the proposed project. Note that the Draft EIR assumed a maximum building height of 50 feet, and the
conclusions of the Aesthetics analysis include that maximum building height. This comment does not raise a new significant

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environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

I15-9 The comment expresses the opinion that with up to 46 semi-truck loading docks, the Project is designed to be a
warehouse/distribution hub. Further, the comment states that such use means excessive truck traffic, exhaust, and noise.

Regarding use of the Project building and site, the Draft EIR assumed uses would be consistent with those allowed in the IL zoning. As discussed in Response to Comment I15-2 above, warehousing/distribution is a permitted use within the IL zone district. Therefore, the conclusions in the Draft EIR reflect use of the Project site consistent with allowed uses in the IL zoning.

Should any uses be proposed at the Project site that are not permitted within the IL zone district, such use would be subject to an application to the City and additional CEQA review.

Regarding traffic, please see Thematic response 1:

Transportation. Air quality impacts were evaluated in Section 4.2, Air Quality, of the Draft EIR. The analysis in that section demonstrated that the Project would result in less-than-significant air quality impacts and no mitigation was needed. Regarding noise, please see Thematic Response 2: Noise.

I15-10 The comment states that the Project’s hours of operation would be 24/7, in excess of the Santee Municipal Code,which limits operational noise between 7:00 a.m. and 7:00 p.m. Please see Thematic Response 2: Noise for information responsive to this comment. This

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comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

I15-11 The comment states that North Woodside Road is not designed for truck trips. Please see Thematic Response 1: Transportation for information responsive to this comment. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

I15-12 The comment questions whether an occupancy study has been conducted and whether the Project building will sit vacant. Further, the comment states that the commenter has noticed at least 10 “available” signs. Occupancy rates of buildings in the area are not an environmental impact under CEQA, and therefore was not evaluated in the Draft EIR. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

I15-13 The comment questions how a building that approximately twice as tall as surrounding buildings could have “No Significant Impacts” to surrounding visual scenic vistas. Section 4.1, Aesthetics, of the Draft EIR evaluated the potential impacts of the Project related to scenic views, scenic resources, existing visual character, and lighting and glare. Under CEQA, views analyzed are generally those from public rights of way or from places where the views of the general public may be impacted. As discussed on Draft EIR page 4.1-7 and in Table 4.1-1, three public vantage points were selected and visual simulations were developed based on these viewpoints. The locations of representative vantage points are shown on Figure 4.1-1, Vantage Points, and

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the existing condition and 3D simulations from the three vantage points are shown on Figures 4.1-2, 4.1-3, and 4.1-4. The analysis concluded that the proposed Project would not result in any significant impacts related to aesthetics. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

I15-14 The comment states that the renderings of the Project building show the building to be approximately the same height as surrounding buildings, and the comment questions whether this is accurate as the Project application includes a request to increase the maximum building height to 50 feet. Further, the comment states that the renderings are deceptive because they show the building from an elevated position, which appears to lessen the impact of the building height on the surrounding area.

The comment is noted.

While the renderings shown in Figures 3.12a-f are mostly from elevated positions, the visual simulations shown in Figures 4.1-2 through 4.1-6 are based on ground level views. Because the proposed Project building would not substantially obstruct, interrupt, or otherwise degrade views, impacts to scenic vistas from public vantage points would be less than significant.

I15-15 The comment states that people using the Walker Preserve Trail will be looking at a concrete monolith. The comment is noted.

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Two of the three vantage points selected for the visual simulations are from the Walker Preserve Trail, as discussed on Draft EIR page

4.1-7 and in Table 4.1-1, and shown in Figure 4.1-1. The visual simulations of these two vantage points are shown in Figures 4.1- 2 and 4.1-3. As viewed from the river trail, the San Diego River riparian corridor (specifically, dense trees and shrubs) dominates the foreground and existing features on the Project site (located south of the river) do not obstruct or interrupt existing views from the trail to the San Diego River riparian corridor or background hillsides. Also, Figure 4.1-6 shows landscape sections and sightlines from the trail.

I15-16 The comment states that views from the Braverman, Shadow Hills, and Creekside neighborhoods would also be impacted.

Comment noted. Please see Response to Comment I15-15
above. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I15-17 The comment states that the Project building would be visible from SB-67. Comment noted. As discussed on Draft EIR page 4.1- 7 and in Table 4.1-1, and shown in Figure 4.1-1, visual simulations were developed from the vantage point of Northcote Road, which is on the other side of SR-67 from the Project site.

That vantage point is at approximately the same elevation as SR67, and SR-67 appears in Figure 4.1-4. The proposed building would be visible from segments of SR-67 and nearby roadways to the north including Northcote Road but the introduction of the

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Project would not result in substantial blockage of a scenic vista or resource. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I15-18 The comment states that the pepper trees provide noise blocking and visual aesthetics. Comment noted. Please see Thematic response 2: Noise for a discussion of the noise barrier that is part of the proposed Project. . This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I15-19 The comment summarizes that the Project is too big and out of scope for the area and that Alternative 2 should be considered.

Comment noted. Please see Response to Comment O2-8 for a discussion of Project alternatives. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I15-20 The comment summarizes prior comments regarding excessive traffic and truck congestion, increased noise, exhaust fumes, and light pollution. Comment noted. Please see Thematic Response 1: Transportation and Thematic Response 2: Noise. This
comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I15-21 The comment states that the Project would overlap with major construction at the SR-67 interchange. See Thematic Response 1: Transportation regarding the SR-67/Riverford Road

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interchange improvement. In its regular course of business, the City coordinates with other agencies, including Caltrans, when projects by other agencies will take place within City boundaries.

This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I15-22 The comment makes a statement that the Project will affect scenic views and vistas. Comment noted. As discussed
previously, Section 4.1, Aesthetics, of the Draft EIR evaluated potential impacts to scenic views and vistas and concluded that the Project would not have a significant impact. This comment is general in nature and does not raise a new significant
environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I15-23 The comment requests that the City deny the proposed Project and consider Alternative 2. Comment noted. This comment is general in nature and does not raise a new significant
environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I15-24 The comment is identical to Comment I15-2. Please see the response to that comment.

I15-25 The comment is identical to Comment I15-3. Please see the response to that comment.

I15-26 The comment is identical to Comment I15-4 Please see the response to that comment.

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I15-27 The comment is identical to Comment I15-5. Please see the response to that comment.

I15-28 The comment is identical to Comment I15-6. Please see the response to that comment.I15-29 The comment is identical to Comment I15-7. Please see the response to that comment.

I15-30 The comment is identical to Comment I15-8. Please see the response to that comment.

I15-31 The comment is identical to Comment I15-9. Please see the response to that comment.

I15-32 The comment is identical to Comment I15-10. Please see the response to that comment.

I15-33 The comment is identical to Comment I15-11. Please see the response to that comment.

I15-34 The comment is identical to Comment I15-12. Please see the response to that comment.

I15-35 The comment is identical to Comment I15-13. Please see the response to that comment.

I15-36 The comment is identical to Comment I15-14. Please see the response to that comment.

I15-37 The comment is identical to Comment I15-15. Please see the response to that comment.

I15-38 The comment is identical to Comment I15-16. Please see the response to that comment.

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I15-39 The comment is identical to Comment I15-17. Please see the response to that comment.

I15-40 The comment is identical to Comment I15-18. Please see the response to that comment.

I15-41 The comment is identical to Comment I15-19. Please see the response to that comment.

I15-42 The comment is identical to Comment I15-20. Please see the response to that comment.

I15-43 The comment is identical to Comment I15-21. Please see the response to that comment.

I15-44 The comment is identical to Comment I15-22. Please see the response to that comment.

I15-45 The comment is identical to Comment I15-23. Please see the response to that comment.

I15-46 The comment provides a graphic showing access to the Project site via N. Woodside Avenue from two interchanges. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I15-47 The comment provides a graphic showing a hard u-turn for semi trucks making a right from the SR-67 southbound off-ramp onto N. Woodside. This comment is general in nature and does not raise a new significant environmental issue regarding the

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adequacy or accuracy of the information provided in the Draft EIR.

Therefore, no further response is required.

I15-48 The comment provides graphics related to the Riverford Road interchange with SR-67 and states that the TIS is deficient because it does not include the Riverford Road/SR-67/Woodside Avenue interchange. Comment noted. Please see Response to Comment I15-3. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

I15-49 The comment shows Draft EIR Table 4.12-1, which is the Project Trip Generation Summary, The comment does not include any additional information. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

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Response to Comment Letter I16
Torri Rodriguez
June 3, 3035
I16-1 The comment expresses concern about the proposed Project, stating that while the zoning is Light Industrial, what is being proposed is not “light.” Please see Response to Comment I9-1 and Response to Comment I15-2 regarding the permitted uses within the IL zone district. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

I16-2 The comment states that the proposed Project would create a “monstrous hub” and expresses concerns about noise, traffic congestion, and road damage. Further, the comment states that local roads were not intended for so many trucks. Comment noted.

Please see Response to Comment I9-2, Thematic Response 1:

Transportation, and Thematic Response 2: Noise for information responsive to this comment. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

I16-3 The comment states that the commenter does not support the Project and would like to know what can be done to prevent the Project from moving forward. Comment noted. Please see
Response to Comment I9-3. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed project. Therefore, no further response is required. During the public hearing on the Project, members of the public can voice their concerns about the Project

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to the decisions makers. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

I16-4 The comment contains the text of the commenter’s first comment, Letter I9, received on May 31, 2025. Responses to this comment can be found in the responses to Letter I9. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

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Response to Comment Letter I17
Chris Schneider
June 3, 2025
I17-1 The comment expresses opposition to the Project and notes that the Draft EIR states that some environmental impacts of the Project cannot be reduced to a less-than-significant level.

CEQA is primarily a disclosure document, requiring that all environmental impacts be disclosed prior to a lead agency making a decision on a project. Under CEQA, significant and unavoidable impacts do not preclude a project from being approved. A lead agency may choose to approve a project if it finds that there are overriding considerations that the lead agency believes would warrant approving a project. This document is called a Statement of Overriding Considerations and must be adopted by the lead agency when choosing to approve a project with significant and unavoidable
environmental impacts.

In the case of the proposed Project, the City Council of the City of Santee will be making a decision whether to approve the Project.

If the City Council chooses to approve the Project, a Statement of Overriding Considerations would be part of the approval documents. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

I17-2 The comment states that the Project would demolish the former drive-in theater and that CEQA requires meaningful preservation where feasible. As discussed in the Historical Assessment (Appendix F of the Draft EIR) and Section 4.4 of the Draft EIR, the

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loss of the former drive-in theater would be a significant and unavoidable impact. Mitigation has been included for this impact, though mitigation would be unable to reduce impacts to a less-thansignificant level due to the loss of the resources. Please see Response to Comment I17-1 for information regarding significant and unavoidable impacts. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

I17-3 The comment states that the Project would exceed CEQA thresholds for VMT. Comment noted. Please see Thematic Response 1:

Transportation for more information. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

I17-4 The comment states that the City should not approve a project that contributes to regional emissions and traffic congestion. Comment noted. Please see Thematic Response 1: Transportation. Pollutant emissions and air quality impacts were evaluated in Section 4.2, Air Quality, of the Draft EIR. The analysis in that section demonstrated that the Project would result in less-than-significant air quality impacts and no mitigation was needed. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

I17-5 The comment summarizes Project activities that would affect biological resources and states the opinion that a facility of this scale is inappropriate next to a sensitive natural area. Comment noted. Section 4.3, Biological Resources, of the Draft EIR evaluated potential impacts from the proposed Project on biological resources, including those located adjacent to the site.

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The analysis in that section concluded that with implementation of the recommended mitigation measures, the proposed Project would not have a significant direct or indirect effect on biological resources. Further, the comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I17-6 The comment states that the EIR is deficient for not evaluating an alternative that retains the drive-in structure or reduces the Project’s VMT footprint. As discussed in Response to Comment O2-8, an EIR need not include all potential alternatives.

Instead, an EIR must include a reasonable range of
alternatives that would obtain most of the project objectives.

In this case, as discussed beginning on page 7-5 of the Draft EIR, alternative land uses and alternative sites were
considered but rejected from further analysis. The alternatives carried forward for analysis in the Draft EIR represent a reasonable range of alternatives that could reduce impacts and meet Project objectives. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

I17-7 The comment expresses the opinion that the Project building would be incompatible with surrounding uses, particularly along the river corridor. Comment noted. As discussed
beginning on page 3-2 of the Draft EIR, the Project site is surrounded on three sides by existing light industrial
development. The Project site is also within the IL zone district, which permits light industrial uses such as the proposed Project. Various sections of the Draft EIR evaluate compatibility issues, including air quality, aesthetics, and biological

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resources. With the exception of historic resources and transportation, the Project would have less-than-significant impacts on the environment, which includes the surrounding community. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I17-8 The comment urges the City Council to reject the Project, require a new alternative, and safeguard Santee’s cultural, environmental, and community assets. Comment noted. This comment is general in nature and does not raise a new
significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR.

Therefore, no further response is required.

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Response to Comment Letter I18
Evan McDonald
June 3, 2025
I18-1 The comment expresses support for the Project. Comment noted. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR.

Therefore, no further response is required.

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Response to Comment Letter I19
Beverly Pendarvis
June 4, 2025
I19-1 The comment discusses the commenter’s experience living in the area and watching other projects get approved. Comment noted. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I19-2 The comment expresses the opinion that the Project building will be an eyesore. Comment noted. Impacts related to views and visual character of the area were evaluated in Section 4.1, Aesthetics, of the Draft EIR. The analysis in Section 4.1 determined that there would be no significant impacts and no mitigation was required. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I19-3 The comment states that local roads were not meant to be used by semi trucks on a 24/7 basis. Comment noted. Please see Thematic Response 1: Transportation for information responsive to this comment. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project.

Therefore, no further response is required.

I19-4 The comment expresses hope that the City Council will listen to residents. Comment noted. This comment is general in nature and does not raise a new significant environmental issue

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regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

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Response to Comment Letter I20
Andrea Roth
June 4, 2025
I20-1 The comment expresses concern about existing road conditions, traffic congestion and emergency evacuation in the area. Please see Thematic Response 1: Transportation for more information.

I20-2 The comment states that the river area would be impacted by noise, diesel exhaust, and collisions. Please see Thematic Response 1: Transportation and Thematic Response 2: Noise.

Pollutant emissions and air quality impacts were evaluated in Section 4.2, Air Quality, of the Draft EIR. The analysis in that section demonstrated that the Project would result in less-thansignificant air quality impacts and no mitigation was needed. This comment is general in nature and does not raise a new
significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I20-3 The comment states that the Project is not “Light Industrial” by any means. Comment noted. Please see Response to Comment I15-2 regarding the IL zone district uses. This comment does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR for the proposed Project. Therefore, no further response is required.

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Response to Comment Letter I21
Tracy Sundlun
June 4, 2025
I21-1 The comment introduces the attached letter or recommendation for the Project. The comment is noted. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

I21-2 The comment expresses support for the Project. Comment noted. This comment is general in nature and does not raise a new significant environmental issue regarding the adequacy or accuracy of the information provided in the Draft EIR. Therefore, no further response is required.

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Response to Comment Letter W1
Advocates for the Environment
Aria Soeprono, Staff Attorney
June 19, 2025
W1-1 The comment requests withdrawal of the comment letter previously submitted by the organization. The comment letter has been withdrawn.

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Response to Comment Letter W2
Golden State Environmental Justice Alliance
Joe Bourgeois, Executive Director
June 20, 2025
W2-1 The comment requests withdrawal of the comment letter previously submitted by the organization. The comment letter has been withdrawn.

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Revisions to the Draft EIR
Revisions to the Draft Environmental Impact Report (Draft EIR) are noted below. An underline indicates additions to the text; strikethrough indicates deletions to the text. Changes have been analyzed and responded to in the second chapter of this Final EIR, Response to Comments. The changes to the Draft EIR do not affect the overall conclusions of the environmental document. Changes are listed by page and, where appropriate, by paragraph.

These revisions to the text of the Draft EIR address the technical comments on the Draft EIR, which circulated for public review from April 21, 2025, through June 4, 2025. These revisions are not considered to result in any new or substantially greater significant impacts as compared to those identified in the Draft EIR. None of the revisions constitute significant new information or substantial Project changes that, in accordance with CEQA Guidelines Section 15088.5, would trigger the need to recirculate portions or all of the Draft EIR. 1 Executive Summary
The text for PDF-TRA-2 on page 1-5 is revised as follows:

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.

The text of MM-TRA-2 beginning on page 1-30 is revised as follows:

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 Ave. 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 rightof-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 applicant will pay an in-lieu fee in the amount of $50,000 to the City to complete this work. 3 – REVISIONS TO THE DRAFT EIR
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3 Project Description
The text of PDF-TRA-1 beginning on page 3-45 is revised as follows:

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.

4.12 Transportation
The fourth paragraph beginning on page 4.12-23 is revised as follows:

The proposed project would result in a traffic effect at the N. Woodside Avenue/Woodside Avenue - SR-67 SB Off-Ramp 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 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). 3 – REVISIONS TO THE DRAFT EIR
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The text of PDF-TRA-1 beginning on page 4.12-33 is revised as follows:

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.

The text of MM-TRA-2 on page 4.12-35 is revised as follows:

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. 3 – REVISIONS TO THE DRAFT EIR
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1 Executive Summary

1.1 Introduction
This Environmental Impact Report (EIR) has been prepared by the City of Santee (City) as lead agency pursuant to the California Environmental Quality Act (CEQA) and the CEQA. This EIR has been prepared to evaluate the environmental impacts associated with implementation of the Palisade Santee Commerce Center Project (Project).

This EIR is an informational document intended for use by the City, other public agencies, and members of the public in evaluating the potential environmental effects of the Project.

CEQA requires that local government agencies, before taking action on projects over which they have discretionary approval authority, consider the environmental consequences of such projects. An EIR is a document designed to provide to the public and to local and state governmental agency decision makers an analysis of potential environmental consequences of a project to support informed decision making.

The City prepared this EIR to provide the public and responsible agencies information about the potential adverse impacts on the local and regional environment associated with implementation of the Project. This EIR was prepared pursuant to CEQA, codified as California Public Resources Code Section 21000 et seq., and the CEQA Guidelines in the California Code of Regulations, Title 14, Section 15000 et seq.

This summary provides a brief synopsis of the Project, results of the environmental analysis contained within this environmental document, alternatives to the Project that were considered, and major areas of controversy and issues to be resolved by decision-makers. This summary does not contain the extensive background and analysis found throughout the individual chapters within the EIR. Therefore, the reader should review the entire document to fully understand the Project and its environmental effects.

1.2 Project Location
The Project site is located in the southeastern part of the City of Santee (City), which is located within the East County region of San Diego County, between the Pacific Ocean and the Cleveland National Forest. The City is bordered on the east by the unincorporated San Diego County communities of Lakeside and Eucalyptus Hills and the City of El Cajon to the south. The Project site is located at 10990 N. Woodside Avenue and is bounded by the San Diego River to the north; industrial buildings to the east and west; and by industrial buildings, Wheatlands Avenue, and California State Route (SR) 67 to the south. Regional access to the proposed Project is provided via SR-67 located approximately 0.1 miles south of the Project site. Local access to the Project is provided via N.

Woodside Avenue.

1.3 Project Description
Project Summary
The proposed Project includes the demolition and/or removal of all existing on-site structures and the construction of a 300,145 square foot industrial/warehousing building. The Project would include 290,145 square feet of warehouse space and 10,000 square feet of office space. In addition to the industrial building, the Project would 1 – EXECUTIVE SUMMARY
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include up to 42 dock-high doors, four grade-level doors, two truck courts, 301 passenger-vehicle parking spaces, 30- and 40-foot-wide fire access lanes along the building perimeter, landscaping, and fencing along portions of the developed perimeter with automated gates at certain driveway locations. The Project would also include associated utility, stormwater treatment, and roadway improvements (Figure 3-7, Conceptual Site Plan). This building is designed to be used primarily to support warehousing and distribution, manufacturing, assembly, and/or research and development operations, and related office uses.

The Project would include landscaping for the passenger vehicle parking area, around the portions of the building visible from off-site areas, as well as the site’s frontages. Landscaping along the site’s frontages would include a mixture of trees, shrubs, and groundcover. The Project would also include new sources of lighting that would be a mix of pole-mounted and wall-mounted lighting fixtures installed in parking and truck loading areas, along building exteriors, near the building office, and the site entrance off North Woodside Avenue.

The Project would be responsible for constructing frontage improvements including sidewalks along the northern side of N. Woodside Avenue and a connection to the existing sidewalk along N. Woodside Avenue that lies to the west of the Project’s driveway. No sidewalk exists to the east and accordingly no new sidewalk is required to be constructed. The Project would also install a crosswalk to improve pedestrian circulation at the Project Access Driveway/N. Woodside Avenue.

The existing driveway that occupies the flag of the Project’s lot between N. Woodside Avenue and the main area of the Project site would be extended to loop around the entire Project site in order to allow fire lane access from all sides of the building. The width of the internal roadway is between 30 feet to 40 feet. Signage and striping would be provided to demarcate fire lanes and clear spaces throughout the site. All gated entryways would include rapidaccess Knox boxes to provide emergency access to gated areas. The Project would also include the construction of a dedicated eastbound left turn lane at the Project Access Driveway/Woodside Avenue.

Project Construction
Construction is expected to commence in or around the fourth quarter of 2025 and last approximately 15 months. The duration of construction activity was estimated based on consultation with the Project Applicant and past project experience. This schedule represents a conservative analysis should construction occur any time after the respective dates, since emissions factors for construction decrease as the analysis year increases due to emissions regulations becoming more stringent. During typical Project-related construction activities, equipment is expected to operate 8 hours per day, Mondays through Saturdays, during the permitted daytime hours of 7:00 a.m. to 7:00 p.m. per Santee Municipal Code Section 5.04.090. 1 – EXECUTIVE SUMMARY
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1.4 Project Objectives
Consistent with the Project’s purpose and need, the primary objectives sought by the Project are as follows:
▪ 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 SR-52 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.

1.5 Project Design Features
The Project would implement the following Project Design Features (PDFs).

PDF-AQ-1: Prior to the start of construction activities and issuance of grading permits, the Project applicant, or its designee, shall ensure that all 75 horsepower or greater diesel-powered equipment are powered with California Air Resources Board (CARB)-certified Tier 4 Interim engines or better.

PDF-AQ-2: Require the cargo handling equipment utilized during facility operations after the completion of construction to include forklifts (forklifts and pallet jacks) and yard tractors operating with Tier 4 Interim engines or better.

PDF-AQ-3: During all grading and site preparation activities, the on-site construction superintendent shall ensure implementation of standard best management practices as required by the San Diego Air Pollution Control District (SDAPCD) Rules 50, 51, 52, 54 and 55, Fugitive Dust Control.

PDF-AQ-4: During all grading and site preparation activities, the on-site construction superintendent shall ensure implementation of applicable California Department of Resources Recycling and Recovery (CalRecycle) Sustainable (Green) Building Program Measures, as specified on the CalRecycle website.

PDF-AQ-5: The Project shall apply only coatings that meet the requirements of San Diego Air Pollution Control District’s (SDAPCD) Rule 67.0.1, Architectural Coatings. 1 – EXECUTIVE SUMMARY
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PDF-GHG-1: Per the Sustainable Santee Action Plan Checklist, the Project will include 450kW of solar PV based on 3 kW per 2,000 SF of building area.

PDF-GHG-2: Per the Sustainable Santee Action Plan Checklist, the Project will meet or exceed CALGreen Tier 2 Standards in effect at the time of the building permit application to the satisfaction of the Director of Planning and Building. Documentation shall be provided to the City demonstrating that the Project meets this requirement prior to the issuance of the building permit.

PDF-GHG-3: Per the Sustainable Santee Action Plan Checklist, the Project utilizes tree planting for shade and energy efficiency such as tree planting in parking lots and streetscapes.

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

PDF-GHG-4: Per the Sustainable Santee Action Plan Checklist, roof structures will be designed to include “cool roofs” materials with a minimum aged reflectance and thermal emittance values equal to or greater than the current CALGreen Table A5.106.11.3, Tier 1.

PDF-GHG-5: Per the Sustainable Santee Action Plan Checklist, proposed Project streets will include sidewalks, crosswalks, and other infrastructure that promotes non-motorized transportation options. The Project will include street, sidewalk, and landscape improvements.

PDF-GHG-6: Per the Sustainable Santee Action Plan Checklist, electric vehicle chargers will be installed in all new commercial developments. The Project includes 16 EVCS (EV Capable Stall with EVSE).

PDF-GHG-7: Per the Sustainable Santee Action Plan Checklist, for new industrial and other Land Uses employing 200 or more employees, e-chargers shall be installed for 5 percent of the total parking spaces. The Project includes 301 total parking spaces (301 x 0.05 = 15 spaces).

The Project includes 16 EVCS with EVSE.

PDF-GHG-8: Per the Sustainable Santee Action Plan Checklist, the Project will reduce waste at landfills.

The Project will include storage areas for recyclables and green waste as well as food waste.

PDF-GHG-9: The Project shall utilize high-efficiency equipment and fixtures consistent with the current California Green Building Standards Code and Title 24 of the California Code of Regulations.

PDF-GHG-10: The Project shall comply with the Santee Water Efficient Landscape Ordinance. The ordinance promotes water conservation and efficiency by imposing various requirements related to evapotranspiration rates, irrigation efficiency, and plant factors.

PDF-GHG-11: The Project shall comply with Chapters 9.02 and 9.04 of the Santee Municipal Code that pertain to solid waste management and demolition and construction debris recycling. 1 – EXECUTIVE SUMMARY
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PDF-NOI-1: The Project will construct an 8'-0" tall approximately 568-foot-long wall along the northern perimeter of the project site. A portion of this wall will include an overlapping wall section to allow for drainage and access. The Project will begin the installation of this wall concurrently with the commencement of rough grading and complete its installation prior to the start of precise grading.

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 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 on 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. 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.

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).

1.6 Requested Approvals
The following discretionary and ministerial actions under the jurisdiction of the City and other agencies would be required. This EIR covers all state and local government, and quasi-government approvals that may be needed to implement the Project, whether or not they are explicitly listed in this section or elsewhere in this EIR (14 CCR 15124[d]).
1 – EXECUTIVE SUMMARY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
APRIL 2025 1-6
City of Santee Discretionary Approval
Consistent with the City’s General Plan, and Municipal Code, the Project requires certain entitlements be submitted, reviewed, and approved by the City. The requested entitlements include:

City Council
▪ Certification of EIR. The City Council to decide to certify or reject this EIR, along with appropriate CEQA Findings and the mitigation monitoring and reporting program. ▪ Conditional Use Permit. Project implementation would require approval of a Conditional Use Permit to allow for an increase in building height from the allowed 40’ to 50’. ▪ Development Review Permit. Project implementation would require approval of a Development Review Permit to allow for the demolition of existing structures on site and for the development of a new industrial building greater than 50,000 square feet in floor area and associated improvements.

The City will use this EIR and associated documentation in its decision to approve or deny the required discretionary permits. Other responsible and/or trustee agencies can use this EIR and supporting documentation in their decision-making process to issue additional approvals. These additional approvals may include approvals such as a site-specific Stormwater Pollution Prevention Plan.

City of Santee Ministerial Approvals
▪ Permits associated with the improvements to Woodside Avenue. ▪ Any other ministerial actions required by the City including post-entitlement grading and building permits Other Agency Approvals
▪ Proposed improvements within the Caltrans right-of-way (ROW) at the N. Woodside Avenue/S. Woodside Avenue - SR-67 SB Off-Ramp intersection would be subject to approval by Caltrans. ▪ Compliance with State Water Resources Control Board (SWRCB) National Pollutant Discharge Elimination System (NPDES) Stormwater General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities.

1.7 Summary of Impacts
Table 1-1 presents a summary of the Project’s significant environmental impacts and mitigation measures that would reduce or avoid those effects, and the level of significance of the impact after implementation of the mitigation measures. With the exception of those specific impacts identified in Table 1-1, the Project would result in less than significant or no impacts with regard to all other resource areas evaluated. Cumulative impacts of the Project were evaluated in Section 6.1, Cumulative Impacts, of the Draft EIR. For cumulative impacts that would not be significant, the cumulative impacts and their conclusions are not included in Table 1-1. For areas where the cumulative impacts would be potentially significant and would require mitigation, these impacts, mitigation measures, and conclusions are included in Table 1-1.
1 – EXECUTIVE SUMMARY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138 APRIL 2025 1-7 Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
Aesthetics
Would the Project have a
substantial adverse effect on a
scenic vista?
Less-than-
significant
N/A Less
-than-
significant
Would the Project substantially
damage scenic resources,
including, but not limited to
trees, rock outcroppings, and
historic buildings within a state
scenic highway?
No Impact N/A No Impact
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?
Less-than-
significant
N/A Less-than-
significant
Would the Project create a new
source of substantial light or
glare which would adversely
affect day or nighttime views in
the area?
Less-than-
significant
N/A Less
-than-
significant
Air Quality
Would the Project conflict with
or obstruct implementation of
the applicable air quality plan?
Less-than-
significant
N/A Less-than-
significant
1 – EXECUTIVE SUMMARY
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APRIL 2025 1-8
Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
Would the Project result in a
cumulatively considerable net
increase of any criteria
pollutant for which the Project
region is non-attainment under
an applicable federal or state
ambient air quality standard?
Less-thansignificantN/A Less-thansignificant
Would the Project expose
sensitive receptors to
substantial pollutant
concentrations?
Less-thansignificant
N/A Less-thansignificant
Would the Project result in
other emissions (such as those
leading to odors) adversely
affecting a substantial number
of people?
Less-thansignificantN/A Less-thansignificant
Biological Resources
Would the Project have a
substantial adverse effect,
either directly or through
habitat modifications, on any
species identified as a
candidate, sensitive, or special
status species in local or
regional plans, policies, or
regulations, or by the California
Department of Fish and Game
or U.S. Fish and Wildlife
Service?
Potentially
significant
impact
MM-BIO-1. Pre-Construction Nesting Bird Survey. Construction within all potential nesting resource areas within the Project site (i.e., non-native woodland areas and ornamental trees) and areas of the Project site within 500 feet of the San Diego River should be avoided during the migratory bird nesting season (typically January 1 through September 30). If construction activities (i.e., grading, tree removal, external construction involving heavy equipment generating noise in excess of 60dBA (leq)) must occur during the bird nesting season, an avian nesting survey of all potential nesting resource areas (e.g., non-native woodland areas and ornamental trees) within the Project site and areas of the San Diego River within 500 feet of all impact areas must be conducted to determine the presence/absence of special-status species, protected migratory birds, and active nests. The avian nesting survey shall be performed by a qualified wildlife biologist within 14 days prior to the start of construction and one more survey pass within 24 hours of initiation of construction activities in accordance with the Migratory Bird Treaty Act and California Fish and Game Code Sections 3503, 3503.5, and 3513. If construction activities are on hold for more than 30 days, Less-thansignificant impact
with mitigation
incorporated
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Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
then pre-construction surveys would need to be reinitiated. If an active bird nest is found, the nest shall be flagged and mapped on the construction plans, along with an appropriate buffer established around the nest, which will be determined by the biologist based on the species’ sensitivity to disturbance (typically 300 feet for passerines and 500 feet for raptors and special-status species), existing nearby conditions (e.g., natural habitat versus roads or existing noisy activities), existing buffering features (e.g., topography, tall and dense trees, buildings), legal status of species (i.e., listed versus non-listed), general sensitivities of the species (e.g., disturbance tolerant or urban versus non disturbance tolerant), and other variables. The nest area shall be avoided until the nest is vacated and the juveniles have fledged. The nest area shall be demarcated in the field with flagging and stakes or construction fencing. On-site construction monitoring shall also be conducted when an active nest buffer is in place. No Project activities shall encroach into established buffers without the consent of a monitoring biologist. The buffer shall remain in place until it is determined that the nestlings have fledged and the nest is no longer active.

MM-BIO-2. Construction-Related Indirect Impacts to Special-Status Species, Sensitive Vegetation Communities, and Jurisdictional Aquatic Resources. Prior to approval of grading plans and issuance of a grading permit, construction plans and conditions of approval shall include the following to address potential indirect impacts to special-status species occurring within all suitable habitat associated with the San Diego River corridor (i.e., within 500 feet of the Project site):
▪ Biological Monitoring. A qualified Project biologist approved by the City of Santee shall monitor ground-disturbing and vegetation clearing activities for the duration of the Project to ensure that practicable measures are being employed to avoid incidental disturbance of habitat, species of concern, and other sensitive biological resources outside the Project footprint. Once ground-disturbing and vegetation clearing activities are complete, the Project biologist shall conduct weekly checks to inspect construction fencing and ensure that all applicable requirements from the mitigation measures are being upheld.
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Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
▪ Worker Environmental Awareness Training. Prior to grading, a preconstruction meeting shall be required that includes a training session for Project personnel by a qualified biologist. The training shall include (1) a description of the species of concern and its habitats; (2) the general provisions of the applicable regulations pertaining to biological resources, including the Endangered Species Act and the Clean Water Act; (3) the need to adhere to the provisions of the Endangered Species Act, the Clean Water Act, and other applicable regulations; (4) the penalties associated with violating the provisions of the Endangered Species Act, Clean Water Act, and other applicable regulations; (5) the general measures that are being implemented to conserve the species of concern as they relate to the Project; and (6) the access routes to and Project site boundaries within which the Project activities must be accomplished. Additionally, the training shall include the measures and mitigation requirements for the applicable resources. Copies of the mitigation measures and any required permits from the resource agencies shall be made available to construction personnel. ▪ Delineation of Property Boundaries. Before beginning activities that would cause impacts, the contractor shall, in consultation with the biological monitor, clearly delineate the boundaries with fencing, stakes, or flags, consistent with the grading plan, within which the impacts will take place. All impacts outside the fenced, staked, or flagged areas shall be avoided, and all fencing, stakes, and flags shall be maintained until the completion of impacts in that area. In addition, any avoided environmental resources shall be clearly delineated. Prior to implementing construction activities, the biological monitor shall verify that the flagging clearly delineates the construction limits and any sensitive environmental resources to be avoided. ▪ Standard Dust Control Measures. Standard dust control measures as per the San Diego County Air Pollution Control District shall be implemented to reduce impacts on nearby plants and wildlife. Measures include controlling speed to 15 miles per hour or less on unpaved roads, replacing ground cover in disturbed areas as quickly as possible, frequently watering active work sites, installing shaker plates, and suspending excavation and grading operations during periods of high winds.
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Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
▪ Stormwater Pollution Prevention Plan. Prior to issuance of a grading permit for construction, the applicant shall submit a Stormwater Pollution Prevention Plan (SWPPP) to the City of Santee that specifies best management practices to prevent all construction pollutants from contacting stormwater, with the intent of keeping sedimentation or any other pollutants from moving off site and into receiving waters. The requirements of the SWPPP shall be incorporated into design specifications and construction contracts. Best management practice categories employed on site shall include erosion control, sediment control, and non-stormwater good housekeeping. Best management practices recommended for the construction phase shall include, but not be limited to, the following:
- Limiting grading to the minimum area necessary for construction, operation, and decommissioning of the Project.
- Limiting vegetation disturbance/removal to the maximum extent practicable.
- Implementing fiber rolls and sandbags around drainage areas and the site perimeter.
- Stockpiling and disposing of demolition debris, concrete, and soil properly. - Installing a stabilized construction entrance/exit and stabilizing disturbed areas.
- Installing proper protections for fueling and maintaining equipment and vehicles.
- Managing waste, aggressively controlling litter, and implementing sediment controls.
- Stabilizing soil in disturbed areas through revegetation.

The following water quality measures shall be included in the SWPPP:
▪ Erodible fill material shall not be deposited into water courses. Brush, loose soils, or other similar debris material shall not be stockpiled within the stream channel or on its banks.
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Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
▪ The Project shall be designed to avoid the placement of equipment and personnel within the stream channel or on sand and gravel bars, banks, and adjacent upland habitats used by target species of concern, as feasible.

Project activities that cannot be conducted without placing equipment or personnel in sensitive habitats shall be timed to avoid the breeding season of riparian species.
▪ Water pollution and erosion control plans shall be developed and implemented in accordance with the Regional Water Quality Control Board. ▪ Minimize Spills of Hazardous Materials. All vehicles and equipment shall be maintained in proper condition to minimize the potential for fugitive emissions of motor oil, antifreeze, hydraulic fluid, grease, or other hazardous materials. Hazardous spills shall be immediately cleaned up and the contaminated soil shall be properly handled and disposed of at a licensed facility. Servicing of construction equipment shall take place only at a designated staging area. The staging area will be located on the south side of the Project site, away from the San Diego River, and no stockpiles will be allowed adjacent to the San Diego River corridor.
▪ Wildlife Hazards. The following measures shall be implemented to ensure that wildlife do not become trapped, entangled, injured, or poisoned by construction activities:
- Structures in which wildlife may become trapped (e.g., open pipes, pits, trenches) shall be tightly covered at the end of each work day. If covering the structure is not possible, an escape ramp shall be provided to allow any wildlife that falls in to safely escape.
- Debris piles, construction materials, equipment, and other items that may be used as wildlife refuge shall be inspected for wildlife at the start of each work day and prior to disturbance. If wildlife is discovered, it shall either be moved out of harm’s way by a qualified biologist or allowed to move off of the Project site on its own.
- Nets and mesh shall be made of loose weave material that is not fused at the intersections of the weave because nets with welded weaves present an entanglement risk.
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Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
- Toxic materials and garbage shall be removed from the work site and safely stored or disposed of at the end of each work day. ▪ Invasive Weeds. To reduce the spread of invasive plant species, landscape plants shall not be on the most recent version of the California Invasive Plant Council’s Invasive Plant Inventory (http://www.calipc.org/ip/inventory/index.php). ▪ Night Work. All construction activities shall be conducted during the daytime, and lights shall not be kept on overnight in the construction area, as practicable. If night lighting is required during construction activities, all exterior lighting along undeveloped land shall be fully shielded and directed downward in a manner that will prevent light spillage or glare into the adjacent open space.

MM-BIO-3: Long-Term Indirect Impacts to Special-Status Species, Sensitive Vegetation Communities, and Jurisdictional Aquatic Resources. Prior to approval of grading plans and issuance of a grading permit, construction plans and conditions of approval shall include the following to address potential indirect impacts to special-status species occurring within all suitable habitat associated with the San Diego River corridor (i.e., within 500 feet of the Project site):
▪ Runoff: Future development within 500 feet of suitable habitat for specialstatus species shall incorporate measures, including measures required through the National Pollutant Discharge Elimination System, to ensure that the quantity and quality of runoff discharged is not altered in an adverse way when compared with existing conditions. In particular, measures such as an infiltration system designed to capture and treat stormwater pollutants, consistent with commercial/industrial developments and associated parking lots, and including oil, grease, metals, trash, and debris, shall be put in place to avoid discharge of untreated surface runoff from developed and paved areas into proposed open space or suitable habitat for special-status species. Stormwater systems shall be designed to prevent the release of toxins, chemicals, petroleum products, exotic plant materials, or other elements that might degrade or harm biological resources or ecosystem processes. This can be accomplished using a variety of methods, including natural detention basins, grass swales, or mechanical trapping devices. 1 – EXECUTIVE SUMMARY
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Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
Regular maintenance shall occur to ensure effective operation of runoff control systems.
▪ Lighting: Project lighting would be designed consistent with the requirements of Section 13.30.030(B) of the Santee Municipal Code. Night lighting shall be directed away from proposed open space and/or suitable habitat for special-status species to protect species from direct night lighting. Shielding, including use of light controlling devices such as light guards, shall be incorporated in Project designs to ensure that ambient lighting is not increased.
▪ Invasive Species: Landscape Plans shall incorporate native species that occur in the region. Invasive, non-native plant species listed on the most recent California Invasive Plant Council’s Invasive Plant Inventory (https://www.cal-ipc.org/plants/inventory/) with a rating of moderate or high shall not be included in landscaping.
▪ Barriers: The proposed Project shall incorporate barriers, where appropriate, to minimize unauthorized public access, domestic animal predation, illegal trespass, or dumping in open space and/or suitable habitat for specialstatus wildlife (e.g. San Diego River corridor). Such barriers may include native landscaping, rocks/boulders, fencing, walls, signage, and/or other appropriate mechanisms.

MM-BIO-4: Tree Replacement, Encroachment, and Preservation. Prior to approval of grading plans and issuance of a grading permit, construction plans, conditions of approval, and the Project’s Landscape Plan shall include the following to address tree removal, encroachment into protected zone, and retained trees:
▪ Replacement: The proposed site plan would require removal of 109 trees.

Tree replacement shall occur at a 1:1 mitigation ratio with 15-gallon trees and be included in the Project’s Landscape Plan, which shall also include recommendations for long-term maintenance and care for regulated trees that will be retained on site.
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Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
▪ Encroachment into Protected Zone and Retained Trees: The Project would encroach upon 24 trees and preserve 7 trees. As such, the recommendations provided in the Tree Protection Measures from the Arborist Report for the Palisade Santee Commerce Center Project (prepared by Dudek in April 2023) designed to mitigate impacts from construction encroachment into the protected zone of the preserved and encroached upon trees shall be implemented. These Tree Protection Measures are consistent with best management practices for tree protection on construction sites and would help minimize impacts to preserved and encroached trees. These measures shall be implemented prior to, during, and following construction. This includes measures such as exclusion fencing and worker training to avoid direct impacts to trees, and measures such as irrigation and monthly inspections by a certified arborist to promote the long-term health of retained trees.

Would the Project have a
substantial adverse effect on
any riparian habitat or other
sensitive natural community
identified in local or regional
plans, policies, regulations, or
by the California Department of
Fish and Game or U.S. Fish and
Wildlife Service?
Potentially
significant
impact
MM-BIO-2
MM-BIO-3
Less-thansignificant impact
with mitigation
incorporated
Would the Project have a
substantial adverse effect on
state or federally protected
wetlands (including, but not
limited to, marsh, vernal pool,
coastal, etc.) through direct
removal, filling, hydrological
interruption, or other means?
Potentially
significant
impact
MM-BIO-2
MM-BIO-3
Less-thansignificant impact
with mitigation
incorporated
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Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
Would the Project interfere
substantially with the movement
of any native resident or migratory
fish or wildlife species or with
established native resident or
migratory wildlife corridors, or
impede the use of native wildlife
nursery sites?
Potentially
significant
impact
MM-BIO-2
MM-BIO-3
Less-thansignificant impact
with mitigation
incorporated
Would the Project conflict with
any local policies or ordinances
protecting biological resources,
such as a tree preservation
policy or ordinance?
Potentially
significant
impact
MM-BIO-4 Less-thansignificant impact
with mitigation
incorporated
Would the project conflict with
the provisions of an adopted
Habitat Conservation Plan,
Natural Community
Conservation Plan, or other
approved local, regional, or
state habitat conservation
plan?
Less-thansignificant
MM-BIO-2
MM-BIO-3
Less-thansignificant impact
with mitigation
incorporated
Would the Project have a
cumulative effect on biological
resources?
Potentially
significant
impact
MM-BIO-1
MM-BIO-2
MM-BIO-3
MM-BIO-4
Less-thansignificant impact
with mitigation
incorporated
Cultural, Tribal Cultural, and Paleontological Resources Would the Project cause a
substantial adverse change in
the significance of a historical
resource as defined in CEQA
Guidelines Section §15064.5?
Potentially
significant
impact
MM-HIS-1. Historical American Building Survey (HABS). Prior to the issuance of a demolition permit, the Applicant shall submit a Historic American Buildings Survey (HABS) Level II to the City of Santee for review and approval. This mitigation measure will provide an in-depth record of the Property’s current state, including high-resolution photographs, detailed architectural drawings, and text explaining the drawings and photographs. The (HABS) Level II survey will Significant and
unavoidable
impact
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Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
help preserve a visual and documented history of the Property that may otherwise be lost after demolition. The submitted documentation not only serves to memorialize the Property for future generations but also allows for a future public appreciation of the Property’s significance within the community. The HABS documentation shall explicitly illustrate the significance of the Santee Drive-In Theatre for archival purposes, as specified below. The HABS will be made available for archival storage to the San Diego County Public Library, the San Diego History Center (SDHC), and the City of Santee. The HABS and shall include the following:

A. Drawings. The HABS documentation shall include measured drawings, including Site Plan, Elevations, and known Construction Details prepared for the following structures/objects: Entrance Sign; Concessions Building; Movie Screens; and Ticket Booths.

B. Photographs. The HABS documentation shall include professional-quality photographic documentation of the Entrance Sign; Concessions Building; Movie Screens; and Ticket Booths prior to any construction on the Property.

The photographs should be 35-millimeter black-and-white photographs; 4x6- inch standard format; taken of all four structure/object exterior elevations; and be of archival quality and easily reproducible. Once the HABS documentation is deemed complete, one set of original HABS photographs shall be submitted for archival storage to the San Diego County Public Library, the San Diego History Center, and the City of Santee.

C. Written History and Description. The HABS documentation shall include a written history and description of the Santee Drive-In Theatre, developed in accordance with standards and format meeting the Department of the Interior’s National Park Service requirements. The history will begin with a statement of significance supported by the development of the architectural and historical context in which the site was originally constructed and subsequently evolved. The written history will also include an architectural description and bibliographic information. The written history and description will also include a methodology section specifying the name of the researcher, date of research, and sources consulted.
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Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
MM-HIS-2. Interpretative Display. Prior to the issuance of the certificate of occupancy for the Project, the Applicant shall work with the City of Santee to create an approximately 24-inch by 48-inch metal plaque or display outlining the history of the Santee Drive-In Theatre, including events and activities associated with the site.

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

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

MM-HIS-3. Rehabilitation & Relocation of the Entrance Sign. The City and the Applicant may mutually agree to either preserve the Entrance Sign on the Property or relocate it to a City-owned property within the Arts and Entertainment neighborhood. Prior to the issuance of a demolition permit for the Project, the Applicant shall submit a plan to the City of Santee for approval to rehabilitate and temporarily store the Entrance Sign, which consists of the neon tubing outlining the word “Santee,” the neon star, and the marquee. The plan, which is 1 – EXECUTIVE SUMMARY
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Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
to be approved by the City, shall include information and details related to the rehabilitation, temporary storage and ultimate location of the Entrance Sign.

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

The Entrance Sign is one of the most recognizable visual elements of the Santee Drive-In Theatre. Preserving this sign as a tangible, physical object ensures that the history of the Drive-In Theatre remains in order to be appreciated and viewed by the public. The Entrance Sign will provide a direct nexus to the history of the Drive-in Theatre and as outlined in Mitigation Measure MM-HIS-2, and the Entrance Sign will be complemented by an Interpretive Display. Together, the Entrance Sign and the Interpretive Display will provide historical context, detailing the Drive-In Theatre’s history.
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Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
MM-HIS-4. Historical Preservation Funding. In the event the Interpretive Display and Entrance Sign are relocated to City property, the City will be responsible for the long-term management of the Interpretive Display and Entrance Sign.

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

Would the Project cause a
substantial adverse change in
the significance of an
archaeological resource
pursuant to CEQA Guidelines
Section 15064.5?
Potentially
significant
impact
MM-CUL-1. In order to mitigate impacts to cultural resources to a level that is less than significant, procedures for proper treatment of unanticipated archaeological finds must comply with the California Environmental Quality Act (CEQA) Guidelines. Adherence to the following requirements during initial earthdisturbing activities will assure the proper treatment of unanticipated archaeological or Native American cultural material:

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

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

Construction activities may continue in other areas but should be redirected a safe distance from the find. The archaeological monitor shall evaluate and minimally document isolates and clearly non-significant deposits in the field.

If the discovery is evaluated and found to be significant under CEQA and avoidance is not feasible, additional work such as data recovery may be warranted. A data recovery plan shall be developed by the qualified archaeologist in consultation with the City and Native American Less-thansignificant impact
with mitigation
incorporated
1 – EXECUTIVE SUMMARY
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Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
representatives, if applicable. Ground disturbance can continue only after the resources has been properly mitigated and with approval by the City.

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

1. If any human remains are discovered, the construction personnel or the appropriate representative shall contact the County Coroner and the City.

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

Less-thansignificant impact
with mitigation
incorporated
Would the Project cause a
substantial adverse change in
the significance of a tribal
cultural resource, defined in
Public Resources Code Section
21074 as either a site, feature,
place, cultural landscape that is
geographically defined in terms
of the size and scope of the
landscape, sacred place, or
Less-thansignificantN/A Less-thansignificant
1 – EXECUTIVE SUMMARY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138 APRIL 2025 1-22 Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
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)?
Would the Project cause a
substantial adverse change in
the significance of a tribal
cultural resource, defined in
Public Resources Code Section
21074 as either a site, feature,
place, cultural landscape that
is geographically defined in
terms of the size and scope of
the landscape, sacred place, or
object with cultural value to a
California Native American
tribe, and that is a resource
determined by the lead agency,
in its discretion and supported
by substantial evidence, to be
significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section
5024.1? In applying the
criteria set forth in subdivision
(c) of Public Resource Code
Section 5024.1, the lead
agency shall consider the
significance of the resource to
Potentially
significant
impact
MM-CUL1 Less
-than-
significant impact
with mitigation
incorporated
1 – EXECUTIVE SUMMARY
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APRIL 2025 1-23
Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
a California Native American
tribe.

Would the Project directly or
indirectly destroy a unique
paleontological resource or site
or unique geologic feature?
Potentially
significant
impact
MM-CUL-3. Inadvertent Discovery. Prior to ground-disturbing activities, the qualified paleontologist shall be retained and prepare a WEAT (worker environmental awareness training). The paleontologist, or their designee, shall present the WEAT for the construction crew members informing them of the potential to inadvertently encounter paleontological resources and the proper procedures to be enacted in the event of an inadvertent discovery. The WEAT may be done during a pre-construction meeting or morning tailboard safety meeting as long as it is done prior to ground disturbance. A qualified project paleontologist is a person with a doctorate or master’s degree in paleontology or related field and who has knowledge of the County of San Diego paleontology and documented experience in professional paleontological procedures and techniques. The applicant shall ensure that construction personnel attend the training and sign an attendance acknowledgement form. The applicant shall retain documentation demonstrating attendance. The qualified paleontologist shall observe all initial ground disturbing activities including grading and excavation. In the unlikely event that paleontological resources (i.e., fossils) are exposed during construction activities, all construction work occurring within 50 feet of the find shall immediately stop and the lead agency representative contacted. The qualified paleontologist shall review the unanticipated find to determine the significance. If the discovery proves potentially significant under CEQA as determined by the qualified paleontologist, and the area cannot be feasibly avoided, paleontological monitoring may be warranted at the discretion of the qualified paleontologist.

Less-thansignificant impact
with mitigation
incorporated
Would the Project have a
cumulative effect on cultural
resources?
Potentially
significant
impact
MM-HIS-1
MM-HIS-2
MM-HIS-3
MM-HIS-4
MM-CUL-1
MM-CUL-2
MM-CUL-3
Significant and
unavoidable
impact
1 – EXECUTIVE SUMMARY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138 APRIL 2025 1-24 Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
Energy
Would the Project result in
potentially significant
environmental impact due to
wasteful, inefficient, or
unnecessary consumption of
energy resources, during
Project construction or
operation?
Less-than-
significant
N/A Less
-than-
significant
Would the Project conflict with
or obstruct a state or local plan
for renewable energy or energy
efficiency?
Less-than-
significant
N/A Less-than-
significant
Greenhouse Gas Emissions
Would the Project generate
greenhouse gas emissions,
either directly or indirectly, that
may have a significant impact
on the environment?
Less-than-
significant
N/A Less-than-
significant
Would the Project conflict with
an applicable plan, policy, or
regulation adopted for the
purpose of reducing the
emissions of greenhouse
gases?
Less-than-
significant
N/A Less
-than-
significant
Hazards and Hazardous Materials
Would the Project create a
significant hazard to the public
or the environment through the
routine transport, use, or
disposal of hazardous
materials?
Less-than-
significant
N/A Less-than-
significant
1 – EXECUTIVE SUMMARY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138 APRIL 2025 1-25 Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
Would the Project create a
significant hazard to the public
or the environment through
reasonably foreseeable upset
and accident conditions
involving the release of
hazardous materials into the
environment?
Less-than-
significant
N/A Less-than-
significant
Would the Projectemit
hazardous emissions or handle
hazardous or acutely hazardous
materials, substances, or waste
within one-quarter mile of an
existing or proposed school?
Less-than-
significant
N/A Less
-than-
significant
Would the Project be located on
a site which is included on a list
of hazardous materials sites
compiled pursuant to
Government Code Section
65962.5 and, as a result, would
create a significant hazard to
the public or the environment?
Less-than-
significant
N/A Less
-than-
significant
Would the Project be located
within an airport land use plan,
be within two miles of a public
airport, and result in a safety
hazard or excessive noise for
people residing or working in
the Project area?
Less-than-
significant
N/A Less-than-
significant
Would the Project impair
implementation of or physically
interfere with an adopted
Less-than-
significant
N/A Less
-than-
significant
1 – EXECUTIVE SUMMARY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138 APRIL 2025 1-26 Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
emergency response plan or
emergency evacuation plan?
Would the Project expose
people or structures, either
directly or indirectly, to a
significant risk of loss, injury, or
death involving wildland fires?
Less-than-
significant
N/A Less-than-
significant
Hydrology and Water Quality
Would the Project violate any
water quality standards or
waste discharge requirements
or otherwise substantially
degrade surface or groundwater
quality?
Less-than-
significant
N/A Less-than-
significant
Would the Project substantially
decrease groundwater supplies
or interfere substantially with
groundwater recharge such that
the Project may impede
sustainable groundwater
management of the basin?
Less-than-
significant
N/A Less
-than-
significant
Would the Project substantially
alter the existing drainage
pattern of the site or area,
including through the alteration
of the course of a stream or
river or through the addition of
impervious surfaces, in a
manner which would:
i) result in substantial erosion
or siltation on or off-site;
ii) substantially increase the
rate or amount of surface
Less-than-
significant
N/A Less
-than-
significant
1 – EXECUTIVE SUMMARY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138 APRIL 2025 1-27 Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
runoff in a manner which
would result in flooding on
or off site;
iii)create or contribute runoff
water which would exceed
the capacity of existing or
planned stormwater
drainage systems or
provide substantial
additional sources of
polluted runoff; or
iv)impede or redirect flood
flows?
Would the Project in flood
hazard, tsunami, or seiche
zones, risk release of pollutants
due to project inundation?
Less-than-
significant
N/A Less-than-
significant
Would the Project conflict with
or obstruct implementation of a
water quality control plan or
sustainable groundwater
management plan?
No Impact N/A No Impact
Land Use and Planning
Would the Project divide an
established community?
Less-than-
significant
N/A Less-than-
significant
Would the Project cause a
significant environmental
impact due to a conflict with
any land use plan, policy, or
regulation adopted for the
purpose of avoiding or
mitigating an environmental
effect?
No Impact N/A No Impact
1 – EXECUTIVE SUMMARY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138 APRIL 2025 1-28 Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
Noise
Would the Project result in
generation of a substantial
temporary or permanent
increase in ambient noise levels
in the vicinity of the Project in
excess of standards
established in the local general
plan or noise ordinance, or
applicable standards of other
agencies?
Less-than-
significant
N/A Less
-than-
significant
Would the Project result in
generation of excessive
groundborne vibration or
groundborne noise levels?
Less-than-
significant
N/A Less
-than-
significant
For a project located within the
vicinity of a private airstrip or an
airport land use plan or, where
such a plan has not been
adopted, within two miles of a
public airport or public use
airport, would the Project
expose people residing or
working in the Project area to
excessive noise levels.

Less-than-
significant
N/A Less-than-
significant
Public Services
Would the Project result in
substantial adverse physical
impacts associated with the
provision of new or physically
altered governmental facilities,
or the need for new or
Less-than-
significant
N/A Less
-than-
significant
1 – EXECUTIVE SUMMARY
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APRIL 2025 1-29
Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
physically altered governmental
facilities, the construction of
which could cause significant
environmental impacts, in order
to maintain acceptable service
ratios, response times, or other
performance objectives for any
of the public services:
i. Fire protection?
ii. Police protection?
iii. Schools?
iv. Parks?
v. Other public facilities?
Transportation
Would the Project conflict or be
inconsistent with CEQA
Guidelines section 15064.3,
subdivision (b)?
Potentially
significant
impact
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 onsite ride matching) and the incentive programs available to carpools.

Significant and
unavoidable
impact
1 – EXECUTIVE SUMMARY
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Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
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.

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 ride-sharing vehicles, designating adequate passenger loading and unloading and waiting areas for ridesharing 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 nonsingle 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 requirement. 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 Ave. 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 1 – EXECUTIVE SUMMARY
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Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
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 applicant will pay an in-lieu fee in the amount of $50,000 to the City to complete this work.

Would the Project have a
cumulative effect with regard to
transportation?
Potentially
significant
impact
MM-TRA-1
MM-TRA-2
Significant and
unavoidable
impact
Utilities
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?
Less-thansignificant
N/A Less-thansignificant
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-thansignificantN/A Less-thansignificant
Would the Project result in a
determination by the
wastewater treatment provider,
which serves or may serve the
Project that it has adequate
Less-thansignificantN/A Less-thansignificant
1 – EXECUTIVE SUMMARY
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138 APRIL 2025 1-32 Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
capacity to serve the Project’s
projected demand in addition to
the provider’s existing
commitments?
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?
Less-than-
significant
N/A Less
-than-
significant
Would the Project comply with
federal, state, and local
management and reduction
statutes and regulations related
to solid waste?
Less-than-
significant
N/A Less
-than-
significant
Wildfire
Would the Project impair
implementation of or physically
interfere with an adopted
emergency response plan or
emergency evacuation plan?
Less-than-
significant
N/A Less-than-
significant
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
N/A Less-than-
significant
Would the Project require the
installation or maintenance of
associated infrastructure (such
Less-than-
significant
N/A Less
-than-
significant
1 – EXECUTIVE SUMMARY
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Table 1-1. Summary of Project Impacts
Environmental Topic Impact? Mitigation Measures
Level of
Significance
After Mitigation
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?
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-thansignificantN/A Less-thansignificant
1 – EXECUTIVE SUMMARY
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Significant and Unavoidable Impacts
As identified in Table 1-1, the Project would result in significant and unavoidable impacts with regard to historical resources and transportation. These impacts are discussed in further detail below. ▪ Cultural, Tribal Cultural, and Paleontological Resources. 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).) A “substantial adverse change in the significance of an historical resource” reflecting a significant effect under CEQA means “physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired” (CEQA Guidelines Section 15064.5(b)(1).) Based on the foregoing conservative assumptions, the demolition of the Former Drive-In Theatre would result in a substantial adverse change in the significance of an historic resource under CEQA. Because the Project’s impact would not be reduced below significance threshold, even with implementation of MM-HIS-1, MM-HIS-2, MM-HIS-3, and MM-HIS-4, the Project’s historic resource impact would remain significant and unavoidable. ▪ Transportation. The Project would generate VMT in excess of the significance threshold even with the implementation of mitigation. A VMT reduction of 11.3% would be achieved through the implementation of Commute Trip Reduction (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.

1.8 Alternatives to the Project
Section 15126.6(a) of the CEQA Guidelines states that 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,” as well as provide an evaluation of “the comparative merits of the alternatives.” Under CEQA Guidelines Section 15126.6(a), an EIR does not need to consider alternatives that are not feasible, nor does it need to address every conceivable alternative to the project. The range of alternatives “is governed by the ‘rule of reason’ that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice” (14 CCR 15126.6[f]).

No Project/No Development Alternative (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 1 – EXECUTIVE SUMMARY
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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.

Reduced Development Intensity Alternative (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.

Refrigerated Warehouse Alternative (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.

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.

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, 1 – EXECUTIVE SUMMARY
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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.

1.9 Areas of Controversy/Issues to Be Resolved
The scope of this EIR includes the potential environmental impacts identified in the Notice of Preparation (NOP) that was available for public review from September 8, 2023, through October 9, 2023; comments received during a public scoping meeting held on September 26, 2023 at City Hall in Santee; and agency and public written comment received in response to the NOP.

A summary of these written comment letters are provided in Table 1-2. The written comments and the NOP are included as Appendix A of this EIR.

Table 1-2. Summary of Notice of Preparation Comments
Commenter Date Summary of Environmental Issues Raised
EIR Chapter/Section
Where Comment is
Addressed
State Agency
Native American
Heritage
Commission
(NAHC)
09/09/2023 ▪ Standard NAHC letter; recommendations,
consultation information, and legal
information
Cultural and Tribal
Cultural Resources
California
Department of
Transportation
(Caltrans)
09/18/2023 ▪ Standard Caltrans letter; recommends
traffic impact study, hydrology and
drainage studies, complete streets and
mobility network, land use and smart
growth, hauling/traffic control plan, noise,
glare, environmental, broadband,
mitigation, and right-of-way analyses.

Transportation
Private Organizations and Members of the Public
Lozeau Drury
LLP; Supporters
Alliance for
Environmental
Responsibility
(“SAFER”)
09/27/2023 ▪ Requests notices of CEQA documentation
and actions
n/a
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EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
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Table 1-2. Summary of Notice of Preparation Comments
Commenter Date Summary of Environmental Issues Raised
EIR Chapter/Section
Where Comment is
Addressed
Comments Received at the Scoping Meeting
Stacey LoMedico
09/26/2023
▪ Concerns about buffers near the San
Diego River Conservancy Reserve and the
nearby river.

Biological Resources
▪ Questions about nesting birds at the
Project site.

Biological Resources
▪ Visual screening around the building,
facing the river.

Aesthetics
Issues to be Resolved by Lead Agency
Section 15123(b)(3) of the CEQA Guidelines requires that an EIR contain a discussion of issues to be resolved. With respect to the proposed project, the key issues to be resolved include decisions by the City, as lead agency, as to the following:
▪ Whether this environmental document adequately describes the environmental impacts of the Project. ▪ Whether the recommended mitigation measures should be modified and/or adopted. ▪ Whether there are other mitigation measures or alternatives that should be considered for the Project besides those identified in the Draft EIR.
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2 Introduction

2.1 Purpose of the California Environmental Quality
Act Process
This Environmental Impact Report (EIR) has been prepared in accordance with the California Environmental Quality Act (CEQA) to evaluate the potential environmental effects associated with implementation of the Palisade Santee Commerce Center Project (Project). Consistent with CEQA Guidelines Section 15161, this document is a projectlevel EIR. As the lead agency for the Project, the City must complete an environmental review to determine if the Project could potentially result in significant adverse environmental effects. A detailed description of the Project is provided in Chapter 3, Project Description.

CEQA Guidelines Section 15002 states that the basic purposes of CEQA are to:
▪ Inform governmental decision makers and the public about the potential significant environmental effects of proposed activities;
▪ Identify the ways that environmental damage can be avoided or significantly reduced; and ▪ Prevent significant, avoidable damage to the environment by requiring changes in projects through the use of alternatives or mitigation measures when the governmental agency finds the changes to be feasible.

If a project will be approved involving significant environmental effects, the lead agency must also disclose to the public the reasons why a governmental agency approved the project in the manner the agency chose.

This EIR provides project-level analysis of the potential environmental effects related to implementation of the Project. The level of impact analysis in this EIR corresponds to the degree of specificity deemed appropriate in accordance with CEQA Guidelines Section 15146. This EIR addresses the potentially significant environmental impacts that could occur as a result of construction and operation of the Project. This document also identifies appropriate and feasible mitigation measures, where necessary, and includes Project alternatives that could be adopted to reduce or avoid potential significant environmental effects.

2.2 Legal Authority and Lead Agency
This EIR has been prepared in accordance with all criteria, standards, and procedures of CEQA (PRC Section 21000 et seq.), the CEQA Guidelines (14 CCR 15000 et seq.), and the rules, regulations, and procedures for implementing CEQA as adopted by the City of Santee (City).

Pursuant to CEQA Section 21067 and CEQA Guidelines Article 4 and Section 15367, the City is the lead agency under whose authority this EIR has been prepared. “Lead agency” refers to the public agency that has the principal responsibility for carrying out or approving a project. Serving as the lead agency and before taking action to approve the Project, the City has the obligation to (1) ensure that this EIR was completed in accordance with CEQA; (2) review and consider the information contained in this EIR as part of its decision-making process; (3) make a statement that this EIR reflects the City’s independent judgment; (4) ensure that all significant impacts on the environment are eliminated or substantially lessened, where feasible; and, if necessary (5) make written findings for each unavoidable significant environmental effect stating the reasons why mitigation measures or Project alternatives 2 – INTRODUCTION
EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT 15138
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identified in this EIR are infeasible and citing the specific benefits of the Project that outweigh its unavoidable adverse effects (14 CCR 15090–15093).

Pursuant to CEQA Guidelines Sections 15040 through 15043, and upon completion of the CEQA review process, the City will have the legal authority to do any of the following:
▪ Approve the Project;
▪ Require feasible changes in any or all activities involved in the Project to substantially lessen or avoid significant effects on the environment;
▪ Disapprove the Project, if necessary, to avoid one or more significant effects on the environment that would occur if the Project was approved as proposed; or
▪ Approve the Project even though the Project would cause a significant effect on the environment if the City makes a fully informed and publicly disclosed decision that (1) there is no feasible way to lessen the effect or avoid the significant effect, and (2) expected benefits from the Project will outweigh significant environmental impacts of the Project.

This EIR fulfills the CEQA environmental review requirements for the proposed Conditional Use Permit (CUP-2023- 0001), Development Review Permit (DR-2023-0002), and all other governmental discretionary and ministerial actions related to the Project.

This EIR is an informational document intended for use by City decision makers, trustee, and responsible agencies, and members of the general public in evaluating the physical environmental impacts of the Project. This EIR is the primary reference document for the formulation and implementation of a mitigation monitoring and reporting program for the Project, in compliance with Public Resources Code (PRC) Section 21081.6. Environmental impacts cannot always be mitigated to a level considered less than significant. In accordance with Section 15093(b) of the CEQA Guidelines, if a lead agency approves a project that has significant impacts that are not substantially mitigated (i.e., significant unavoidable impacts), the agency shall state in writing the specific reasons for approving the Project, based on the final CEQA documents and any other information in the public record. This is defined in Section 15093 of the CEQA Guidelines as “a statement of overriding considerations.”

2.3 Responsible and Trustee Agencies
Responsible and Trustee Agencies
PRC Section 21104 requires that all EIRs be reviewed by state responsible and trustee agencies (see also 14 CCR 15082 and 15086[a]). As defined by CEQA Guidelines Section 15381, “the term ‘Responsible Agency’ includes all public agencies other than the Lead Agency which have discretionary approval power over the project.” A trustee agency is defined in CEQA Guidelines Section 15386 as “a state agency having jurisdiction by law over natural resources affected by a project which are held in trust for the people of the State of California.” For this Project, the California Department of Fish and Wildlife is a trustee agency, because the Project has the potential to result in indirect impacts to plant and wildlife species that are managed and protected by the state.

Other Agencies from Whom Ministerial Approvals May Be Required As part of the Project, improvements at the N. Woodside Avenue/S. Woodside Avenue - SR-67 SB Off-Ramp intersection are proposed and would be subject to approval by the City and Caltrans. 2 – INTRODUCTION
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2.4 Summary of Project Analyzed in this Environmental
Impact Report
The proposed Project includes the demolition of all existing on-site structures and the construction of a 300,145 square foot industrial/warehousing building. The Project would include 290,145 square feet of warehouse space and 10,000 square feet of office space. In addition to the industrial building, the Project would include up to 42 dock-high doors, four grade-level doors, two truck courts, up to 301 passenger-vehicle parking spaces, 30- and 40- foot-wide fire access lanes along the building perimeter, landscaping, and fencing along portions of the developed perimeter with automated gates at certain driveway locations. The Project would also include associated utility, stormwater treatment, and roadway improvements. Permits and approvals required for Project implementation are listed in Chapter 3, Project Description, and described in Chapter 4, Environmental Analysis, of this Draft EIR.

2.5 Scope of Environmental Analysis

2.5.1 Notice of Preparation Scoping Process
The purpose of this EIR is to evaluate the potential environmental impacts associated with implementation of the Project. The City concluded that the Project could potentially have direct or indirect adverse effects on the environment. Accordingly, the City determined the need for preparation of an EIR for the Project. Potentially significant impacts were identified based on review of comments received in response to the Notice of Preparation (NOP) that was available for public review from September 8, 2023, through October 9, 2023 (see Appendix A) and additional research and analysis of relevant project data during preparation of this Draft EIR. A scoping meeting for this Project was held on September 26, 2023, at the Santee City Hall Council Chambers.

A summary of written comment letters received is provided in Table 2-1. No written comments were received at the scoping meeting.

Table 2-1. Summary of Notice of Preparation Comments
Commenter Date
Summary of Environmental Issues
Raised
EIR Chapter/Section
Where Comment is
Addressed
Private Organizations and Members of the Public
Stacey LoMedico September 26,
2023
▪ Location of loading docks and parking
▪ Questions regarding hours of
operation
▪ CUP due to increased height
▪ Visual screening on the north side of
the Project site
▪ Buffers of the development area and
the river
▪ Are there any known bird nesting
sites?
▪ Preparation of noise studies
▪ Will the Santee Noise Ordinance
change?
▪ Will construction be allowed on
weekends?
Chapter 3, Project
Description
Section 4.1, Aesthetics
Section 4.3, Biological
Resources
Section 4.10, Noise
Chapter 7, Alternatives
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Table 2-1. Summary of Notice of Preparation Comments
Commenter Date
Summary of Environmental Issues
Raised
EIR Chapter/Section
Where Comment is
Addressed
▪ Provided three videos from north of
the San Diego River demonstrating
existing noise levels from a
neighboring use
▪ How many project alternatives will be
studies?
Lozeau Drury September 27,
2023
▪ Request for any and all information
referring to or related to the project
N/A

2.5.2 Environmental Effects Found Not to Be Significant Pursuant to CEQA, the discussion of potential environmental impacts is focused on those impacts that could be significant or potentially significant. CEQA allows the lead agency to limit the detail of discussion of the environmental impacts that are not considered potentially significant (PRC Section 21100; 14 CCR 15126.2[a] and 15128). CEQA requires that the discussion of any significant environmental effect be limited to substantial, or potentially substantial, adverse changes in physical conditions that exist within the affected area, as defined in PRC Section 21060.5. In accordance with CEQA Guidelines Section 15143, environmental impacts dismissed in an analysis as clearly insignificant and unlikely to occur need not be discussed further in the EIR unless the lead agency subsequently receives information inconsistent with the finding.

Based on a review of comments received in response to the NOP (Appendix A) as well as additional research and analysis of relevant project data during preparation of this Draft EIR, it was determined, for reasons described in Chapter 5, Effects Found Not to Be Significant, of this EIR, that the project would not result in significant environmental impacts in the following resource areas. Thus, with the exception of the impact discussion in Chapter 5 of this EIR, these environmental resource areas are not discussed at further length in this EIR:
▪ Agricultural and Forestry Resources
▪ Geology and Soils
▪ Mineral Resources
▪ Population and Housing
▪ Recreation

2.5.3 Environmental Issues Determined to be
Potentially Significant
Pursuant to CEQA and CEQA Guidelines Section 15064, the discussion of potentially significant environmental impacts is focused in this EIR on those impacts that the lead agency has determined could be potentially significant.

A determination of the environmental impacts that would be potentially significant was made for the Project based on a review of comments received as part of the NOP scoping process and additional research and analysis of relevant information during preparation of this EIR. The following environmental issue areas were determined to be potentially significant and are addressed at further length in this EIR:
▪ Aesthetics
▪ Air Quality
▪ Biological Resources
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▪ Cultural, Tribal Cultural, and
Paleontological Resources
▪ Energy
▪ Greenhouse Gas Emissions
▪ Hazards and Hazardous Materials
▪ Hydrology and Water Quality
▪ Land Use and Planning
▪ Noise
▪ Public Services
▪ Transportation
▪ Utilities and Service Systems
▪ Wildfire

2.6 Organization of this Environmental Impact Report
This EIR contains all of the information required to be included in an EIR, as specified by the CEQA Statutes and Guidelines (PRC Section 21000 et seq.; 14 CCR 15000 et seq.). CEQA requires that an EIR contain, at a minimum, specified content. The following provides a quick reference in locating the CEQA-required sections within this document:
▪ Chapter 1: Executive Summary. The Executive Summary provides a summary of the Project and Project alternatives, including a summary of the Project and cumulative impacts, recommended mitigation measures, and the level of significance after mitigation for each environmental issue. ▪ Chapter 2: Introduction. The Introduction provides an overview of the Project and the CEQA process, and describes the purpose, scope, and components of this EIR. ▪ Chapter 3: Project Description. The Project Description provides a detailed description of the Project, including the location and Project characteristics. The intended uses of this EIR, Project background, Project objectives, and required Project approvals are also addressed. ▪ Chapter 4: Environmental Impacts and Mitigation Measures. The Environmental Impacts and Mitigation Measures chapter analyzes the environmental impacts of the Project. Impacts are organized into major environmental topic areas. Each topic area includes a description of the environmental setting, regulatory setting, significance criteria, mitigation measures, and level of significance after mitigation. The following specific environmental areas are addressed in Chapter 4:
- Section 4.1 – Aesthetics
- Section 4.2 – Air Quality
- Section 4.3 – Biological Resources
- Section 4.4 – Cultural, Tribal Cultural, and Paleontological Resources - Section 4.5 – Energy
- Section 4.6 – Greenhouse Gas Emissions
- Section 4.7 – Hazards and Hazardous Materials
- Section 4.8 – Hydrology and Water Quality
- Section 4.9 – Land Use and Planning
- Section 4.10 – Noise
- Section 4.11 – Public Services and Recreation
- Section 4.12 – Transportation
- Section 4.13 – Utilities and Service Systems
- Section 4.14 – Wildfire
▪ Chapter 5: Effects Found Not to Be Significant. The Effects Found Not to Be Significant chapter provides a summary of Project impacts that have been determined, based on review of comments received in response to the NOP and additional research and analysis of relevant project data during preparation of 2 – INTRODUCTION
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this Draft EIR, to result in less-than-significant or no impact, and therefore, further discussion is not warranted. A brief discussion of these Project impacts are provided in this chapter. ▪ Chapter 6: Other CEQA Considerations. The Other CEQA Considerations chapter provides a discussion of cumulative impacts and a summary of significant environmental impacts, including unavoidable, irreversible, and growth-inducing impacts.
▪ Chapter 7: Alternatives. The Alternatives chapter provides a comparison between the Project impacts and three Project alternatives: (1) the No Project/No Development Alternative, (2) Reduced Development Intensity Alternative, and (3) the Refrigerated Warehouse Alternative. ▪ Chapter 8: List of Preparers. The List of Preparers chapter provides a list of the organizations, persons consulted, and various individuals who contributed to the preparation of this EIR. This section also includes a list of the lead agency personnel and technical consultants used to prepare this EIR. ▪ Appendices. The technical appendices contain the NOP (including public comments) and technical studies prepared to support the analyses and conclusions in this EIR.

The Final EIR will be prepared after the public review period for this EIR has been completed. The Final EIR will include comments and recommendations received on the EIR during the public review period; a list of persons, organizations, and public agencies commenting on the EIR; written responses to significant environmental issues identified in the comments received; and any other relevant information added by the City.

2.7 Documents Incorporated by Reference
Pursuant to CEQA Guidelines Section 15150, this EIR has referenced several technical studies, analyses, and previously certified environmental documents. Information from these documents, incorporated by reference, is briefly summarized in the appropriate chapters and sections. The documents that were used to prepare this EIR include the following:
▪ City of Santee General Plan Update (2007)
▪ Santee Municipal Code (Code of Ordinances) (2023 [Updated]) ▪ County of San Diego Countywide Plan (General Plan) (2011) These reference documents, in accordance with CEQA Guidelines Section 15150(b), are available for review at the following locations:

City of Santee General Plan
https://www.cityofsanteeca.gov/services/development-services/planning-and-zoning-services/general-plan City of Santee Code of Ordinances
https://library.qcode.us/lib/santee_ca/pub/municipal_code County of San Diego Countywide Plan (General Plan)
https://www.sandiegocounty.gov/pds/generalplan.html
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2.8 Documents Prepared for the Project
The following technical studies and analyses were prepared for the Project and Project site and are incorporated into the technical appendices of this EIR:
▪ Initial Study, Notice of Preparation, and Scoping Comments, Appendix A ▪ Air Quality and Greenhouse Gas Emission Technical Report, Appendix B ▪ Biological Technical Report, Appendix C
▪ Arborist Report, Appendix D
▪ Archaeological Resources Inventory Report, Appendix E ▪ Historical Assessment, Appendix F
▪ Geotechnical Engineering Investigation, Appendix G
▪ Paleontological Resources Memorandum, Appendix H
▪ Phase I Environmental Site Assessment, Appendix I
▪ Preliminary Hydrology Study, Appendix J-1
▪ Storm Water Quality Management Plan, Appendix J-2
▪ Letter to City of Santee regarding the 100-Year Floodplain, Appendix J-3 ▪ Noise Technical Report, Appendix K
▪ Transportation Impact Study, Appendix L
▪ Water Study, Appendix M
▪ Fire Protection Plan, Appendix N
▪ AB 52 Letters and Receipts, Appendix O

2.9 Review of the Draft Environmental Impact Report
Upon completion of this Draft EIR, the City prepared and filed a Notice of Completion with the Governor’s Office of Planning and Research, State Clearinghouse to start the public review period (PRC Section 21161). Concurrent with the Notice of Completion, the City distributed a Notice of Availability in accordance with CEQA Guidelines Section 15087. The Notice of Availability was mailed to the agencies, organizations, and individuals who previously requested in writing to receive a copy. This Draft EIR was distributed to responsible and trustee agencies, other affected agencies, surrounding cities and municipalities, and all interested parties requesting a copy of this document in accordance with PRC Section 21092(b)(3). During the public review period, this Draft EIR, including the appendices, is available for review at the following locations:

In Person:

City of Santee Planning & Building Department (Building 4) City of Santee Clerk’s Office (Building 3)
10601 Magnolia Avenue
Santee, California 92071
Santee County Library
9225 Carlton Hills Boulevard, Santee, CA 92071
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Online:
https://www.cityofsanteeca.gov/business/active-projects-map Agencies, organizations, individuals, and all other interested parties not previously contacted, or who did not respond to the NOP, currently have the opportunity to comment on this Draft EIR during the public review period.

Written or email comments on this Draft EIR should be addressed to:

Sandi Sawa, Director of Planning and Building
City of Santee, Planning and Building Department
10601 Magnolia Avenue
Santee, California 92071
Phone: 619.258.4100 ext. 167
Email: [email protected]
Upon completion of the public review period, written responses to all substantive environmental comments are prepared and made available prior to the public hearing on the Project before the City of Santee City Council, at which the Project, the Final EIR, and requested entitlements are considered for approval. The comments received and the responses to those comments will be included as part of the record for consideration for the Project.

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3 Project Description
This chapter describes the objectives of the Palisade Santee Commerce Center Project (Project) and the Environmental Impact Report (EIR) and provides a detailed description of the Project characteristics. This chapter also discusses the required development approvals and discretionary actions necessary to implement the Project.

3.1 Project Location
The approximately 13.5-acre Project site is located in the southeastern part of the City of Santee (City), which is located within the East County region of San Diego County, as shown on Figure 3-1, Regional Map and Figure 3-2, Project Location. The Project site is located at 10990 N. Woodside Avenue and is bounded by the San Diego River to the north; industrial buildings to the east and west; and by industrial buildings, Wheatlands Avenue, and California State Route (SR) 67 to the south. The Project site is located in Section 23 of Township 15 South, Range 1 West, as depicted on the U.S. Geological Survey El Cajon, California 7.5-minute topographic quadrangle map.

Regional access to the proposed Project is provided via SR-67 located approximately 0.1 miles south of the Project site. Local access to the Project is provided via N. Woodside Avenue.

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

The City comprises a mix of different land use types and density. Single-family residential uses comprise the largest land use totaling approximately 2,418 acres. The other residential use types occurring throughout the City include multifamily residential (apartments and condominiums), and mobile home parks. These residential uses are primarily located near the City's highly traveled roads including Mission Gorge Road, Magnolia Avenue and Prospect Avenue. Located approximately one mile to the west of the Project, the planned 650-acre Town Center district is anticipated to be a vibrant neighborhood in the heart of Santee with new housing, dining, and indoor and outdoor amenities. The Metropolitan Transit System trolley station provides regional public transportation (City of Santee 2023). Industrial uses in the City are concentrated in the south-central region along Prospect Avenue, Magnolia Avenue and Cuyamaca Street, and north of Woodside Avenue along the San Diego River corridor, within the vicinity of the Project site (City of Santee 2003).

Existing Project Site
As shown on Figure 3-3, Project Aerial and Existing Uses, the approximately 13.5-acre Project site is developed with a drive-in theatre that includes two movie screens, two ticket booths, and a building containing restrooms and a 3 – PROJECT DESCRIPTION
15138
3-2
snack bar. The Project site boundary extends beyond the paved drive-in into the undeveloped area south of the San Diego River. The drive-in theatre has closed, but the site continues to be used for a swap meet.

Consistent with the property boundary, the Project site extends beyond the paved drive-in parking area. Beyond the paved parking area, the site includes certain vacant areas bordering the San Diego River. There are no native vegetation communities within the Project boundary. Vegetation land coverages include Developed and Ornamental. There are no aquatic resources within the Project site boundary. The northern edge of the Project site boundary is next to stands of thick vegetation occurring along a chain link fence line. This vegetation was dominated by African sumac (Searsia lancea), a non-native low-growing tree species which is known to occupy disturbed areas.

Photos of the Project site are provided in Figure 3-4, Existing Conditions.

The Assessor’s Parcel Number (APN) of the Project site is 381-070-52. The City’s General Plan and the Zoning Map designates the entire Project site as Light Industrial (IL), as shown on Figure 3-5, General Plan Land Use, and Figure 3-6, Zoning (City of Santee 2017, 2020).

Surrounding Land Uses
As shown on Figure 3-3, Project Aerial and Existing Uses, the land uses surrounding the Project site consist of a mix of industrial, manufacturing, automotive, commercial, open space, and residential uses. Specific land uses located in the immediate vicinity of the Project site include the following:
▪ North: San Diego River, with residential uses beyond
▪ East: Industrial and manufacturing uses, and Mission Park Court ▪ South: Manufacturing and commercial uses, North Woodside Avenue, and SR-67 ▪ West: Industrial and manufacturing uses, and Wheatlands Court Surrounding Circulation Network
Roadways
Regional access to the Project would be provided by SR-52 and SR-67. Local access to the Project would be provided by Riverford Road (in the community of Lakeside), Magnolia Avenue, and Mission Gorge Road-Woodside Avenue.

Both Magnolia Avenue and Mission Gorge Road-Woodside Avenue are designated truck routes within the City of Santee.

Riverford Road
Riverford Road is a north-south roadway, located in the City of Lakeside, that crosses the Santee River. Riverford Road begins north of its intersection with El Nopal Road and ends at its connection with Woodside Avenue, immediately south of SR-67. Riverford Road provides connections to Riverside Drive, N. Woodside Avenue, and Woodside Avenue. The segment of Riverford Road from Riverside Drive to Woodside Avenue is classified as a Prime Arterial and a Major Roadway. The majority of Riverford Road has Class II bike lanes and paved sidewalks on both sides of the road. The bike lanes and paved sidewalks end at the northern and southern portions of the roadway (where Riverford Road intersects with El Nopal Street and at the SR-67 underpass crossing). On-street parking is not permitted along Riverford Road and the posted speed limit is 40 miles per hour (MPH).

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
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City of El Cajon
City of Santee
City of Santee Orange RR
Ä52
Ä67
El Cajon Valley
Christian School
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Reservoir
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Shadow
Hills
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Woodglen
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Walker Preserve
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Project Boundary
Regional Map
Palisade Santee Commerce Center Project
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City of Santee
Mission Gorge Rd
N
Magnolia Ave
Woodside Ave
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Rd
Mast Blvd
N Woodside Ave
Ä67
Hill Creek
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School
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San Diego River
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Reservoir
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FIGURE 3-2
Project Location
Palisade Santee Commerce Center Project
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Woodside Ave
N Woodside Ave
H
i
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reek Ln
Mission Park Ct
Wheatlands Ct
Wheatlands Rd
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Former
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Project Aerial and Existing Uses
Palisades Santee Commerce Center Project
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FIGURE 3-3
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Path: \\dudek.int\data\GISData\Projects\j1513801\MAPDOC\DOCUMENT\Draft_EIR Photo A: View looking towards the northwest corner of the Project site, from the northeast corner of the Project site Photo B: View looking towards southeast corner of the Project site, from the northwest corner of the Project site Photo C: View looking towards the southwest corner of the Project site, from the northwest corner of the Project site Photo D: View looking north towards the northeast corner of the Project site, from the southeast corner of the Project site FIGURE 3-4
Existing Conditions
Palisade Santee Commerce Center Project
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Woodside Ave
N Woodside Ave
Hartley Rd
Meadow Terrace Dr
Mission Park Ct
Wheatlands Ct
Taffy Ln
Wheat
lands Rd
Missio
n
P
a
r
k
P
l
Wheatlands Ave
Ä67
S a n D i e g o R i v e r
Walker
Preserve
Trail Project Boundary
General Plan and Land Use
General Industrial
Light Industrial
Neighborhood Commercial
Park / Open Space
Medium-High Density Residential
Low-Medium Density Residential
General Plan Land Use
Palisade Santee Commerce Center Project
SOURCE: SanGIS, Open Street Maps, City of Santee 2023
Date: 5/14/2024 - Last saved by: kholmes - Path: Z:\Projects\j1513801\MAPDOC\DOCUMENT\Draft_EIR\Draft_EIR_figures.aprx 0 100 200 n Feet
FIGURE 3-5
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EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025
Woodside Ave
N Woodside Ave
Hartley Rd
Meadow Terrace Dr
Mission Park Ct
Wheatlands Ct
Taffy Ln
Wheat
lands Rd
Missio
n
P
a
r
k
P
l
Wheatlands Ave
Ä67
S a n D i e g o R i v e r
Walker
Preserve
Trail Project Boundary
Zoning
General Industrial
Light Industrial
Neighborhood Commercial
Park / Open Space
Medium-High Density Residential
Low-Medium Density Residential
Zoning
Palisade Santee Commerce Center Project
SOURCE: SanGIS, Open Street Maps, City of Santee 2022
Date: 5/14/2024 - Last saved by: kholmes - Path: Z:\Projects\j1513801\MAPDOC\DOCUMENT\Draft_EIR\Draft_EIR_figures.aprx 0 100 200 n Feet
FIGURE 3-6
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Woodside Avenue
Woodside Avenue is an east-west roadway from Magnolia Avenue (where Mission Gorge Road ends) to Chestnut Street in Lakeside. Between Magnolia Avenue and SR-67 southbound-off ramp-Woodside Avenue intersection, Woodside Avenue is a Major Arterial, with four lanes and a center-two-way-left-turn lane (TWLTL). Class II bike lanes are provided on both sides of Woodside Avenue. The posted speed limit is 45 miles per hour.

Woodside Avenue splits into N. Woodside Avenue and Woodside Avenue east of the intersection with the SR-67 southbound off-ramp with N. Woodside Avenue paralleling SR-67 on the north side and Woodside Avenue paralleling SR-67 on the south side. N. Woodside Avenue is the segment between SR-67 southbound-off rampWoodside Avenue intersection to Riverford Road in Lakeside and is designated as a Collector Road with a TWLTL.

It is currently constructed with one lane in each direction with a center TWLTL and dedicated left-turn lanes at its intersections with Hartley Road and Wheatlands Avenue. North of Wheatland Avenue, the roadway is one lane in each direction without a TWLTL or dedicated left-turn lanes at intersections. There are Class II bike lanes on both sides of the N. Woodside Avenue. On-street parking is permitted along north side of N. Woodside Avenue. There are intermittent sidewalks along the roadway. The posted speed limit in the vicinity of the Project is 40 MPH.

Magnolia Avenue
Magnolia Avenue is a north-south roadway. It is classified as a Major Arterial north of Mission Gorge Road and Prime Arterial from Mission Gorge Road up to Prospect Avenue. On-street parking is not permitted along the roadway from Mission Gorge Road up to Prospect Avenue. There is paved sidewalk along Magnolia Avenue. The posted speed limit along the roadway is 45 miles per hour.

Transit
The San Diego Metropolitan Transit System (MTS) provides public transportation throughout Santee and northern San Diego County. The nearest MTS bus routes serving the Project are described below. ▪ Route 832 runs clockwise from Santee Town Center to northern Santee and back to Santee Town Center via Cuyamaca Street, and Magnolia Avenue. The route operates between 6:17am and 6:56pm on weekdays, with 30-minute headways, and between 8:25am and 4:45pm on weekends with 60-minute headways. The nearest bus stop is located west of the Magnolia Avenue and Mission Gorge Road – Woodside Avenue intersection, approximately 0.90 miles from the Project site. ▪ Route 833 runs from the Santee Transit Center to the El Cajon Transit Center, via Mission Gorge Road, Magnolia Avenue, and Graves Avenue. The route operates between 5:52am and 6:12pm on weekdays, with 45-minute headways, and between 8:53am and 5:10pm on weekends, with 60-minute headways. The nearest bus stop is located west of Magnolia Avenue and Mission Gorge Road – Woodside Avenue intersection, approximately 0.90 miles from the Project site. ▪ Route 834 runs in a loop, connecting the Santee Transit Center to the West Hills Parkway area, via Prospect Avenue and Carlton Oaks. The route operates only on weekdays from 6:33am to 3:30pm with 60-minuite headways. The nearest bus stop to the Project site is approximately 2 miles away.

The City of Santee is served by the Green Line Trolley (Route 530), with the sole station located at the Santee Transit Center. The Green Line connects Santee to the larger San Diego region and provides service into Downtown San Diego. The route operates from 5:00am to 1:00am with 15-minute headways on weekdays, and 30-minute

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headways on weekends. MTS ACCESS provides complementary, on-demand paratransit service to fulfill the unmet needs of residents such as seniors and persons with disabilities.

Pedestrian and Bicycle Facilities
The General Plan Circulation Element identifies the following bicycle facility classifications, as defined by Caltrans:
▪ Class I Bikeway (Bike Path) provide a completely separated right-of-way designated for the exclusive use of bicycles and pedestrians with crossflows by motor vehicles minimized. ▪ Class II Bikeway (Bike Lane) provides a striped lane designed for the exclusive or semi-exclusive use of bicycles with through travel by motor vehicles or pedestrians prohibited, but with pedestrian and motor vehicle crossflows permitted.
▪ Class III Bikeway (Bike Route) provides shared use of traffic lanes with cyclists and motor vehicles, identified by signage and street marking such as sharrows.
▪ Class IV Bikeway (Cycle Track) are separated bikeways that provide right-of-way designated exclusively for bicycle travel within the roadway and physically protected from vehicular traffic.

A Class II Bike Lane runs along Woodside Avenue; the bike lane along S. Woodside Avenue connects to bike route along Shadow Hill Road and Northcote Road, however, it does not connect to any other bicycle facility in the City.

The Planned Bicycle Network in the Mobility Element is based on Active Santee Plan (2021). It recommends Class II bike lanes along Mission Gorge Road between Riverview Parkway and Magnolia Avenue and along Magnolia Avenue between Mast Boulevard and Mission Gorge Road.

Sidewalks and pedestrian facilities are provided along one side of Woodside Avenue, and adjacent roadways within one-half mile of the Project site. While pedestrian facilities such are crosswalks are missing within the immediate Project area, the Santee Active Transportation Plan has identified this area as in need and is committed to improve the area by installing missing segments of sidewalks, adding pedestrian ramps and crosswalks, and relocating utility facilities as needed.

Environmental Baseline
The onsite drive-in theatre operations closed on December 31, 2023 and the site continues to be used as a swap meet on Saturdays and Sundays from 5 a.m. to 1 p.m. This Draft EIR does not consider the elimination of these uses in the calculation of projected Project-related operational emissions and traffic analyses (i.e., the Project’s operational emissions are not reduced to account for the elimination of these occupiable buildings); therefore, this Draft EIR provides a conservative assessment of operational impacts. Additional information is provided within the applicable environmental analysis sections in Chapter 4 of this Draft EIR.

3.3 Proposed Project
The proposed Project includes demolition and/or removal of all existing on-site structures (see Section 3.2, Environmental Setting) and the construction of a 300,145 square foot industrial/warehousing building. The individual components of the Project are discussed in further detail below.

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3.3.1 Project Components
The proposed Project includes the demolition and/or removal of all existing on-site structures (see Section 3.2, Environmental Setting) and the construction of a 300,145 square foot industrial/warehousing building. The Project would include 290,145 square feet of warehouse space and 10,000 square feet of office space. In addition to the industrial building, the Project would include up to 42 dock-high doors, four grade-level doors, two truck courts, 301 passenger-vehicle parking spaces, 30- and 40-foot-wide fire access lanes along the building perimeter, landscaping, and fencing along portions of the developed perimeter with automated gates at certain driveway locations (Figure 3-7, Conceptual Site Plan). The Project would also include associated utility, stormwater treatment, and roadway improvements. This building is designed to be used primarily to support warehousing and distribution, manufacturing, assembly, and/or research and development operations, and related office uses.

Architecture
The Project’s design employs a variety of architectural strategies to create a contemporary, unified, and high-quality business park environment. The proposed buildings would be primarily constructed with concrete tilt-up panels.

Building exteriors would feature varying textures, intrusions, and extrusions to create appropriately scaled building façades, similar to other industrial development located throughout the City and region. The building would be up to 50 feet in height and would accommodate warehousing and distribution, manufacturing, assembly, and/or research and development operations, and related office uses. The building would be painted with complementary neutral colors.

The interior truck court areas for the building would be screened and secured by metal fences or concrete screen walls with sliding metal gates across the drive aisle entrances. The fences, screen walls and gates would be approximately 8 feet tall and the gates would be painted steel rolling gates. A 2-foot gravity retaining wall would also be installed along the south boundary of the Project site, near parking areas per City regulation standards. The walls would have a vandal-free treatment and would be painted with colors complementary to the building.

Representative building elevations are provided in Figure 3-8, Representative Architectural Elevations.

Landscaping and Lighting Improvements
As depicted in Figure 3-9, Landscape Plan, landscaping is proposed for the passenger vehicle parking area, around the portions of the building visible from off-site areas, as well as the site’s frontages. Landscaping along the site’s frontages would include a mixture of trees, shrubs, and groundcover. Proposed trees include 15-gallon Italian Cypress, 36-inch box Multi-Trunk Desert Museum Palo Verde Trees, 24-inch box Holly Oaks, 24-inch box Afghan Pines, 36-inch Coast Live Oaks, 15-gallon Brisbane Box Trees, 15-gallon Austrian Willows, and 15-gallon Western Sycamore Trees. The landscaping materials along the Project frontages incorporate a layering concept to provide different height trees and border or accent shrubs and low ground covers. The landscape plan is required to comply with the City of Santee Water Efficient Landscape Ordinance, Chapter 13.36 of the zoning code.

Light spillover, trespass, and potential glare from Project lighting are regulated by Section 13.30.030(B) of the Santee Municipal Code. The code requires that all lights and illuminated signs must be designed and adjusted to reflect light away from any road or street, away from any adjoining premises, and shall be shielded or directed to not cause glare on adjacent properties or motorists. As proposed, new sources of lighting would be a mix of polemounted and wall-mounted lighting fixtures installed in parking and truck loading areas, along building exteriors, near the building office, and the site entrance off North Woodside Avenue. Light controlling devices, such as light

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
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guards, would be included where light spillage on adjacent properties could be a concern (i.e., residences and the San Diego River to the north). Project lighting would be designed consistent with the requirements of Section 13.30.030(B) of the Santee Municipal Code. The proposed photometric plan is shown in Figure 3-10.

Site Access, Circulation, and Parking Improvements
Primary vehicular site access would be provided via N. Woodside Avenue. The existing driveway that occupies the flag of the Project’s lot between N. Woodside Avenue and the main area of the Project site would be extended to loop around the entire Project site in order to allow fire lane access from all sides of the building. The width of the internal roadway is between 30 feet to 40 feet. The driveway from N. Woodside Avenue to the Project’s driveway 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. 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.

Paved passenger vehicle parking areas would surround the building, while loading docks would be located on the north and south sides of the building. The Project would provide approximately 42 loading dock-high positions and four concrete truck ramps to allow access through grade-level roll-up doors. The truck dock areas would be surrounded by concrete building walls on three sides, forming north and south truck courts. 301 passenger vehicle parking spaces would be located around the perimeter of the building. The parking ratio used to calculate on-site parking requirements is consistent with Santee Municipal Code (SMC) Section 13.24.040.B.61. The proposed Project is primarily a warehousing and distribution facility with associated office and ancillary uses. Accordingly, in conformance with SMC Chapter 13.24, one parking space is provided per 1,000 square feet of gross floor area for this land use category which encompasses all potential uses of the building including the proposed office space and any similar warehouse building uses routinely combined with warehousing such as manufacturing, assembly, and research and development. The proposed Project is consistent with the City’s parking standards.

Parking designated for electric vehicles (EV), including spaces associated with clean air vehicles will be provided per City requirement. Long-term and short-term bicycle parking2 will be provided per City’s code requirement. 1 City of Santee. https:// ecode360.com/43756953#43756953 2 Bicycles. All commercial and office areas shall provide adequate locking facilities for bicycle parking at any location convenient to the facility for which they are designated. Whenever possible, weatherproofing or facility covering should be used.

Short-Term Bicycle Parking. If the Project is anticipated to generate visitor traffic, provide permanently anchored bicycle racks within 200 feet of the visitors’ entrance, readily visible to passers-by, for five percent of visitor motorized vehicle parking capacity, with a minimum of one two-bike capacity rack.

Long-Term Bicycle Parking. For buildings with over 10 tenant-occupants, provide secure bicycle parking for five percent of motorized vehicle parking capacity, with a minimum of one space. Acceptable parking facilities shall be convenient from the street and may include:
i. Covered, lockable enclosures with permanently anchored racks for bicycles; ii. Lockable bicycle rooms with permanently anchored racks; and iii. Lockable, permanently anchored bicycle lockers.

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
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Conceptual Site Plan
Palisades Santee Commerce Center Project
FIGURE 3-7
Path:\\dudek.int\data\GISData\Projects\j1513801\MAPDOC\DOCUMENT\Draft_EIR SOURCE: Herdman, January 2024
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 
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                                         
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                                  
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               
                                    
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        
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         
                            
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 
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 
  
  
  
  
FIGURE 3-8
Path:\\dudek.int\data\GISData\Projects\j1513801\MAPDOC\DOCUMENT\Draft_EIR SOURCE: Herdman, April 2024
Representative Architectural Elevations
Palisade Santee Commerce Center Project
3 – PROJECT DESCRIPTION
15138
3-22

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EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025
Landscaping Plan
Palisades Santee Commerce Center Project
FIGURE 3-9
Path:\\dudek.int\data\GISData\Projects\j1513801\MAPDOC\DOCUMENT\Draft_EIR SOURCE: Herdman, March 2024
3 – PROJECT DESCRIPTION
15138
3-24

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EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025
0 210 420 n Feet Date: 10/9/2024 User: kholmes Path: Z:\Projects\j1513801\MAPDOC\DOCUMENT\Draft_EIR\Draft_EIR_figures.aprx SOURCE: Herdman 2024
Palisade Santee Commerce Center Project
Proposed Photometric Plan
FIGURE 3-10
3 – PROJECT DESCRIPTION
15138
3-26

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EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025
3 – PROJECT DESCRIPTION
15138
3-27
Project Access Driveway/N. Woodside Avenue Improvements The following improvement measures would be constructed by the Project to improve traffic flow near the Project site:
▪ The Project would construct a dedicated eastbound left turn lane at the Project Access Driveway/ Woodside Avenue.
▪ The Project access driveway will be designed per City specifications for commercial driveway per City of Santee standard PW-213.
▪ The Project would be responsible for constructing frontage improvements including sidewalks along the northern side of N. Woodside Avenue and a connection to the existing sidewalk along N. Woodside Avenue that lies to the west of the Project’s driveway. No sidewalk exists to the east and accordingly no new sidewalk is required to be constructed.
▪ The Project would also install a crosswalk to improve pedestrian circulation at the Project Access Driveway/N. Woodside Avenue.

Noise Barrier
The Project includes an eight-foot-tall noise barrier partially along the northern site boundary (see Figure 3-11). This noise barrier will run parallel to the east-west axis of the building and will be centered on the north truck court, with the length of the wall established by extending 45-degree angles from the building corners which form east and west corners of the truck court. A six-foot-wide break in the noise barrier would be provided to facilitate drainage; noise reduction at the drainage break would be achieved by providing a parallel wall located four-feet north of the primary noise barrier and extending approximately 17 feet beyond the east and west edges of the 6-foot drainage break.

Operational Characteristics
Although the future occupants of the proposed building are unknown at this time, the Project applicant anticipates that the building could support a number of light manufacturing and distribution uses, (e.g., warehousing and distribution, manufacturing, assembly, and/or research and development operations, and related office uses) provided that they are permitted in the Light Industrial zone. Cold storage would not be permitted in any of the proposed buildings. For purposes of evaluation in this Draft EIR, it is assumed that the building could be operational 24 hours per day, seven days per week, with exterior loading and parking areas illuminated at night. Lighting would be subject to compliance with SMC Section 13.08.070(G), which states that parking lot lighting shall be shielded, or recessed, and directed downward and away from adjoining properties. Additionally, the Project’s lighting plan is subject to approval by City staff during the plan check process.

In general, the Project’s building has been designed such that business operations would be conducted within the enclosed building, with the exception of traffic movement, passenger and truck parking, the loading and unloading of trailers within designated truck courts/loading areas, and the internal and external movement of materials around the Project site via forklifts, pallet jacks, yard hostlers, and similar equipment. Truck trailers are expected to be primarily loaded and unloaded using the dock-high door positions in the north and south truck courts. The design of the truck courts and dock-high door positions allows for material to be loaded and unloaded directly to/from the building without need for the cargo or handling equipment to traverse the truck court or outdoor parking areas. When used outdoors, the outdoor cargo handling equipment used during loading and unloading of trailers 3 City of Santee. https://www.cityofsanteeca.gov/home/showpublisheddocument/18044/637048465192800000

EIR FOR PALISADE SANTEE COMMERCE CENTER PROJECT
APRIL 2025
3 – PROJECT DESCRIPTION
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(e.g., forklifts, yard trucks, hostlers, yard goats, pallet jacks, forklifts) is expected to be a mix of diesel and nondiesel powered per contemporary industry standards. Where diesel cargo handling equipment is used, it will feature Tier 4 Interim engines or better. Additionally, the Project’s office and mezzanine space would support general office activities related to business operations. For renderings of the proposed Project, see Figure 3-12a through 3-12f.

The Project will be subject to the Santee Noise Ordinance. Section 5.04.130 of the ordinance states that it is unlawful for any person to engage in loading, unloading, opening, idling of trucks, closing or other handling of boxes, crates, containers, building materials, garbage cans, dumpsters or similar objects between the hours of 10:00 p.m. and 7:00 a.m. in such a manner as to cause a noise disturbance within or adjacent to a residential district.

Utility Improvements
Domestic Water
Domestic water service would be provided by the Padre Dam Municipal Water District. The Project would connect to the existing 12-inch diameter water main 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-inch domestic service, 2-inch 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.

Storm Drainage
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 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 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.

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 will provide energy dissipation and will prevent slope scour and erosion.

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Gas, Electric, and Telecommunication Facilities
There is currently no gas service to the Project site, and the Project does not include plans to install new gas service.

Electric service is currently provided by San Diego Gas & Electric (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.

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. Additionally, all above-ground electrical lines within the Project site would be undergrounded.

3.3.2 Project Construction
Based on information provided by the Project applicant, it is assumed that construction of the Project would commence in or around the fourth quarter of 20254 and last approximately 15 months. The analysis contained herein is based on the following assumptions (duration of phases is approximate):
▪ Demolition: October 2025 – November 2025 (1 month)
▪ Grading: November 2025 – December 2025 (1 month)
▪ Building Construction: December 2025 – September 2026 (9 months) ▪ Paving: September 2026 – December 2026 (3 months)
▪ Architectural Coating: December 2026 – January 2027 (1 month) Based on a review of the current structures located on the site, demolition activities are anticipated to generate approximately 18,381 tons of debris that would be transported to a landfill permitted to accept inert construction and demolition materials (See Appendix B, Air Quality and GHG Emissions Technical Report). Grading materials would be balanced onsite, resulting in approximately 28,304 cubic yards of cut and 28,304 cubic yards of fill (M. Hellesen, personal communication, August 21, 2023). When grading is complete, the Project site would be generally flat.

Underground utilities would be installed to maximum depth of 11 feet below grade. The underground infiltration chamber for the on-site stormwater drainage system would be installed to an approximate depth of nine feet below finished grade.

During typical Project-related construction activities, equipment is expected to operate 8 hours per day, Mondays through Saturdays, during the permitted daytime hours of 7:00 a.m. to 7:00 p.m. per Santee Municipal Code Section

5.04.090. Should construction activities need to occur at night (such as concrete pouring activities that require air temperatures to be lower than typically occur during the daytime hours), the Project applicant would be required to obtain authorization for nighttime construction activities from the Director of Engineering. 4 The air quality and greenhouse gas analyses for this Project assume a construction start date of July 2024. It is reasonable to assume the earlier start date for construction represents the worst-case scenario for criteria air pollutant and GHG emissions because equipment and vehicle emission factors for later years would be slightly less due to more stringent standards for in-use off-road equipment and heavy-duty trucks, as well as fleet turnover replacing older equipment and vehicles in later years.

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3.3.3 Project Design Features
The Project would implement the following Project Design Features (PDFs).

PDF-AQ-5: The Project shall apply only coatings that meet the requirements of San Diego Air Pollution Control District’s (SDAPCD) Rule 67.0.1, Architectural Coatings.

PDF-GHG-1: Per the Sustainable Santee Action Plan Checklist, the Project will include 450kW of solar PV based on 3 kW per 2,000 SF of building area.

PDF-GHG-3: Per the Sustainable Santee Action Plan Checklist, the Project utilizes tree planting for shade and energy efficiency such as tree planting in parking lots and streetscapes.

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

PDF-GHG-5: Per the Sustainable Santee Action Plan Checklist, proposed Project streets will include sidewalks, crosswalks, and other infrastructure that promotes non-motorized

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transportation options. The Project will include street, sidewalk, and landscape improvements.

PDF-GHG-6: Per the Sustainable Santee Action Plan Checklist, electric vehicle chargers will be installed in all new commercial developments. The Project includes 16 EVCS (EV Capable Stall with EVSE).

The Project includes 16 EVCS with EVSE.

PDF-GHG-8: Per the Sustainable Santee Action Plan Checklist, the Project will reduce waste at landfills.

The Project will include storage areas for recyclables and green waste as well as food waste.

PDF-GHG-9: The Project shall utilize high-efficiency equipment and fixtures consistent with the current California Green Building Standards Code and Title 24 of the California Code of Regulations.

PDF-GHG-11: The Project shall comply with Chapters 9.02 and 9.04 of the Santee Municipal Code that pertain to solid waste management and demolition and construction debris recycling.

PDF-NOI-1: The Project will construct an 8'-0" tall approximately 568-foot-long wall along the northern perimeter of the project site. A portion of this wall will include an overlapping wall section to allow for drainage and access. The Project will begin the installation of this wall concurrently with the commencement of rough grading and complete its installation prior to the start of precise grading.

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. 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

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vehicular ingress and egress to/from the Mission Del Magnolia community to eastbound Woodside Avenue.

3.4 Purpose and Need
The City has been identified as an area having a low job–housing ratio (i.e., an area that has more potential workers living in a community than there are jobs for them), resulting in high numbers of residents commuting out of the region for work. Santee scored lower than the County overall (City of Santee 2022). This may be due to the location of the City outside the central areas of the County, where the higher job proximity scores are located. Within the City, higher job proximity scores are located near its boundaries with El Cajon, Poway, and Scripps Ranch (City of Santee 2003). A low jobs-to-housing ratio can result in adverse environmental and economic effects on local communities. Long-distance commutes result in increased traffic and air quality and greenhouse gas emissions, and out-of-region commuters often take a share of their purchasing power with them when they make purchases away from home.

One strategy that community leaders and planners can use to provide residents with local employment is to attract development of warehousing and distribution centers, which can provide hundreds of jobs per million square feet of development. Supply chain constraints, geopolitical risks, and increased shipping traffic have created the need for additional industrial space within the San Diego region, thereby resulting in the creation of new jobs.

Additionally, low industrial vacancy rates within the Southern California region has led to high demand for flexible logistics and distribution facilities. At the close of Quarter (Q) 4 in 2023, vacancy rates within the San Diego County industrial market were 1.2% in the East County Region (Kidder Mathews 2023). These market trends are influenced by a lack of available land for the development of new facilities within the San Diego area.

As such, the Project would help meet the needs of the logistics sector while producing new jobs in an area that historically may have been considered light on jobs and heavier on housing.

3.5 Project Objectives
CEQA Guidelines Section 15124 requires an EIR to include a statement of objectives sought by the Project. The objectives assist the City in developing a reasonable range of alternatives to be evaluated in the EIR. The Project objectives also aid decision makers in preparing Findings of Fact and a Statement of Overriding Considerations, if

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necessary. The statement of objectives also include the underlying purpose of a project and describe any project benefits. Consistent with the Project’s purpose and need, the primary objectives sought by the Project are as follows:
▪ 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 SR-52 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.

3.6 Requested Approvals
The following discretionary and ministerial actions under the jurisdiction of the City and other agencies would be required. This EIR covers all state and local government, and quasi-government approvals that may be needed to implement the Project, whether or not they are explicitly listed in this section or elsewhere in this EIR (14 CCR 15124[d]).

City of Santee Discretionary Approval
Consistent with the City’s General Plan, and Municipal Code, the Project requires certain entitlements be submitted, reviewed, and approved by the City. The requested entitlements include:

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City of Santee Ministerial Approvals
▪ Permits associated with the improvements to Woodside Avenue. ▪ Any other ministerial actions required by the City including post-entitlement grading and building permits Other Agency Approvals
▪ Proposed improvements within the Caltrans right-of-way (ROW) at the N. Woodside Avenue/S. Woodside Avenue - SR-67 SB Off-Ramp intersection would be subject to approval by Caltrans. ▪ Compliance with State Water Resources Control Board (SWRCB) National Pollutant Discharge Elimination System (NPDES) Stormwater General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities.

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4 Environmental Analysis
Approach to the Environmental Analysis
This Draft Environmental Impact Report (Draft EIR) evaluates and discloses the environmental impacts associated with the Palisade Santee Commerce Center Project (Project), in accordance with the California Environmental Quality Act (CEQA) (Public Resources Code [PRC] Section 21000, et seq.) and the State CEQA Guidelines (California Code of Regulation, Title 14, Chapter 3, Section 1500, et seq.). Sections 4.1 through 4.14 of this Draft EIR present a discussion of environmental setting, regulatory setting, significance criteria, environmental impacts associated with the project, mitigation measures to reduce the level of impact, and residual level of significance (i.e., after application of mitigation, including impacts that would remain significant and unavoidable after application of all feasible mitigation measures). Issues evaluated in these sections consist of the environmental topics identified for review in the Notice of Preparation (NOP) prepared for the project (see Appendix A of this Draft EIR) and in Section 2.5.3 of this Draft EIR, Environmental Issues Determined to be Potentially Significant. Chapter 5 of this Draft EIR, Effects Found Not to be Significant, briefly describes potential environmental effects that were determined not to be significant and therefore are not discussed in further detail in the EIR, as required by Section 15128 of the CEQA Guidelines, and includes an analysis of the project’s growth inducing impacts, as required by Section 21100(b)(5) of CEQA. Chapter 6 of this Draft EIR, Other CEQA Considerations, presents an analysis of the project’s impacts considered together with other past, present, and probable future projects producing related impacts, as required by Section 15130 of the State CEQA Guidelines and includes an analysis of the project’s growth inducing impacts, as required by Section 21100(b)(5) of CEQA. Chapter 7, Alternatives, presents a reasonable range of alternatives and evaluates the environmental effects of those alternatives relative to the proposed Project, as required by Section 15126.6 of the State CEQA Guidelines.

Section 4.1 through 4.14 of this Draft EIR include the following components:
▪ Existing Conditions: Provides information describing the existing environmental conditions on the project site and in the surrounding area as appropriate, in accordance with State CEQA Guidelines Section 15125.

This setting discussion describes the conditions that existed when the NOP was posted for public review and submitted to the State Clearinghouse.
▪ Relevant Regulations, Plans, Policies, and Ordinances: Provides a discussion of existing federal, state, regional, and local regulations, plans, policies, and ordinances applicable to the Project. ▪ Thresholds of Significance: Provides criteria for determining the significance of Project impacts for each environmental issue.
▪ Impact Analysis: Provides a discussion of the characteristics of the Project that may have an impact on the environment, analyzes the nature and extent to which the Project is expected to change the existing environment, and indicates whether the Project’s impacts would meet or exceed the level of significance thresholds.

Mitigation Measures and Level of Significance After Mitigation: Mitigation measures are identified, as feasible, to avoid, minimize, rectify, reduce, or compensate for significant or potentially significant impacts, in accordance with the State CEQA Guidelines Section 15126.4. A “less-than-significant” impact is one that would not result in a substantial adverse change in the physical environment. A “potentially significant” impact or “significant” impact is one that would result in a substantial adverse change in the physical environment; both are treated the same under CEQA in terms of procedural requirements and the need to identify feasible mitigation. Significant and unavoidable impacts are identified as appropriate in accordance with State CEQA Guidelines Section 15126.2(c).
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4.1 Aesthetics
This section describes the existing visual conditions of the Santee Commerce Center Project (Project) site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures, if necessary, to reduce or avoid significant impacts related to implementation of the Project. A series of 3D visual simulations of the Project are included to aid in the description of anticipated visual change associated with proposed development of the Project site.

4.1.1 Existing Conditions
Local Context
The City of Santee (City) comprises a mix of different land use types and density. Single-family residential uses comprise the largest land use totaling approximately 2,418 acres (City of Santee 2003; Table 1-1, Existing Land Use Inventory). The other residential use types occurring throughout the City include multifamily residential (apartments and condominiums), and mobile home parks, which are primarily located near the City's highly traveled roads including Mission Gorge Road, Magnolia Avenue and Prospect Avenue. The 700-acre Town Center district forms a downtown core comprised of business parks, high-density residential and retail businesses that feed off the synergy of Santee Trolley Square shopping complex and the Metropolitan Transit System trolley station (City of Santee 2023a). Industrial uses are concentrated in the south-central portion of the City, generally along Prospect Avenue, Magnolia Avenue and Cuyamaca Street, and north of Woodside Avenue along the San Diego River corridor, within the vicinity of the Project site (City of Santee 2003).

Project Site and Surrounding Area
As shown on Figure 3-3, Project Aerial, and Existing Uses in Chapter 3, the approximately 13.43-acre Project site is currently developed with a drive-in theatre and a primarily single-story building containing restrooms, concessions, and a projection house. There are two projection screens on site. The first is located at the southeast corner of the site and is approximately 77 feet wide by 51 feet tall. The second is located at the northwest corner of the site and is approximately 100 feet wide by 65 feet tall. In addition, existing perimeter landscaping within the Project Boundary includes (among others) eucalyptus, pepper, and Italian cypress trees. See Figure 3-4, Existing Conditions. The site is accessible from North Woodside Avenue and contains two ingress lanes (transitioning to a total of four ingress lanes) and one egress lane. The ingress lanes pass two small rectangular ticket booths. The site is paved with striped parking spaces aligned in a half concentric pattern with approximately 75 percent of the spaces oriented towards the drive-in screen in the northwest corner of the site and remainder oriented towards the drive-in screen in the site’s southeast corner. Parking spaces associated with the screen in the site’s southeast corner are enclosed by a chain-link fence featuring sections of opaque, mint-colored metallic sheets. The aforementioned building is located near the center of site. The site contains some variable terrain in the northeastern corner (see Figure 3-4). The Project site boundary extends beyond the paved drive-in parking area into the undeveloped area south of the San Diego River.

The land uses surrounding the Project site consist of a mix of industrial, manufacturing, automotive, commercial, open space, and residential uses. Buildings in the immediate surrounding area are generally two- or one-story in scale, and of the industrial business park architectural style with limited ornamentation, street-facing entrances and alley accessed entrances protected by metal roll up doors. Property landscaping is typically limited to perimeter tree plantings, street-facing shrubs and other elements nearby building entrances and limited occurrence of turf

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near parkways. The San Diego River abuts the northern boundary of the Project site. The San Diego River Trail/Walker Preserve Trail is located directly on the north side of river. The Project site boundary extends slightly beyond the pavement into the undeveloped area located approximately 20 to 30 feet above the San Diego River corridor. Four vegetation communities or land cover types (i.e., non-native grassland, non-native woodland, disturbed habitat, and urban/developed land) occur within the Project site and 10 vegetation communities or land cover types occur within the 500-foot buffer surrounding the Project site. Please refer to Table 4.3-1 in Chapter 4.3, Biological Resources of this Environmental Impact Report (EIR) for a detailed description of vegetation communities in the study area.

Surrounding land uses and elements that contribute to the visual environment in the project area are described as follows:
▪ North: San Diego River, with the San Diego River Trail/Walker Preserve Trail and residential uses along Hillcreek Road beyond
▪ South: Industrial and manufacturing uses, and Wheatlands Avenue, North Woodside Avenue, and SR-67 ▪ East: Industrial and manufacturing uses, and Mission Park Court and Mission Park Place ▪ West: Manufacturing and commercial uses, and Wheatlands Court Scenic Vistas
According to the General Plan, the City’s diversity of open space resources provide numerous beneficial functions including the provision of scenic relief and vistas (City of Santee 2003). The San Diego River and adjacent floodway is included among the approximate 3,000 acres of open space lands in the City and according to the City, the orientation of the San Diego River corridor creates impressive long views within Santee and to the surrounding ridgelines and mountains (including El Capitan) (City of Santee 2003). In addition to local features, regional and local mountains and hills provide a scenic backdrop for the City as well as opportunities for distinctive scenic views and vistas. According to the City’s General Plan Community Enhancement Element, the major ridgeline and hillside systems provided by the undeveloped areas of the northern portion of the City, including the Fanita Ranch, present a substantial portion of these views and vistas. Rattlesnake Mountain and Mission Trails Regional Park also provide significant views from within Santee (City of Santee 2003).

The Project site abuts the San Diego River, and the San Diego River Trail/Walker Preserve Trail parallels the river on the north (at its closest, the trail is within 620 feet of the northern boundary of the Project site). In addition to the river floodway, the San Diego River Trail/Walker Preserve Trail offers users views to Rattlesnake Mountain (located approximately one mile to the southeast of the Project site).

Scenic Routes
According to the California Department of Transportation Scenic Highway Mapping System, the Project site is not located adjacent to, or in the vicinity of, a designated state scenic highway (Caltrans 2024a). The nearest officially designated state scenic highway is a segment of State Route (SR) 52 as it travels adjacent to Mission Trails Regional Park (approximately Santo Road in San Diego to Mast Boulevard in Santee). This segment is located approximately four miles to the west of the Project site. SR-52 (from Mast Boulevard in Santee to SR-67 in Santee) is the nearest eligible state scenic highways to the Project site, which is located approximately one mile south of the Project site (Caltrans 2024a). Due to distance and intervening terrain, the Project site is not visible from SR-52 or any other state scenic highway in San Diego County.

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Light and Glare
While limited light fixtures are installed on the project site, the drive-in is no longer operational. As such, it does not feature operable sources of artificial nighttime light. Streetlights are present along Wheatlands Court and North Woodside Avenue to the west, south, and east, and are sources of nighttime light. Other exterior artificial light sources in the immediate vicinity of the Project site include nearby industrial uses bordering the site to the south, east, and west. There are no existing sources of light or glare from the San Diego River abutting the Project site to the north, however, typical residential light sources in the residential neighborhood to the north of the Project site and San Diego River may be visible from the Project site.

4.1.2 Relevant Plans, Policies, and Ordinances
State
California Scenic Highway Program
The California State Legislature created the California Scenic Highway Program in 1963 with the intent “to protect and enhance the natural scenic beauty of California highways and adjacent corridors, through special conservation treatment.” The state laws that govern the Scenic Highway Program are Sections 260 through 263 of the Streets and Highways Code. A highway may be designated scenic based on the natural landscape visible by travelers, the scenic quality of the landscape, and the extent to which development intrudes upon the views of the highway. The Scenic Highway Program includes both officially designated scenic highways and highways that are eligible for designation. A highway may be designated as scenic based on aesthetic quality of viewable landscape, extent of views upon the natural landscape, and the degree to which development impedes these views. It is the responsibility of local jurisdictions to apply for scenic highway approval, which requires the adoption of a Corridor Protection Program (Caltrans 2024b).

Assembly Bill 98
On September 29, 2024, California Governor Gavin Newsom signed California Assembly Bill 98 (AB 98) into law.

This bill, which is part of California's ongoing efforts to regulate warehousing and trucking activity to reduce emissions and enhance community health, will increase the state's regulation of warehouses, including truck routes into warehouses. However, the bill also imposes additional costs and regulatory burdens to warehouse and truck operators in the state. AB 98 becomes effective on Jan. 1, 2026. AB 98 mandates several environmental and community health protections. The bill focuses on regulating the construction and operation of new or expanded warehouses that are 250,000 square feet or larger. Key provisions include:
▪ installation of energy-saving features such as solar panels and electric vehicle charging stations ▪ transition to zero-emission forklifts by 2030
▪ establishment of buffer zones between warehouses and sensitive areas such as homes, schools and parks ▪ establishment of truck routes that avoid residential areas It should be noted that the law does not apply to applications filed prior to September 30, 2024, which includes the proposed Project.

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California Code of Regulations
Title 24 – California Building Standards Code
Title 24, California Building Standards Code, consists of regulations to control building standards throughout the state. The following components of Title 24 include standards related to lighting:

Title 24, Part 1 – California Building Code / Title 24, Part 3 – California Electrical Code The California Building Code (Title 24, Part 1) and the California Electrical Code (Title 24, Part 3) stipulate minimum light intensities for pedestrian pathways, circulation ways, parking lots, and paths of egress.

Title 24, Part 6 – California Energy Code
The California Energy Code (CEC) (Title 24, Part 6) stipulates allowances for lighting power and provides lighting control requirements for various lighting systems, with the aim of reducing energy consumption through efficient and effective use of lighting equipment. Section 130.2 sets forth requirements for Outdoor Lighting Controls and Luminaire Cutoff requirements. All outdoor luminaires rated above 150 watts shall comply with the backlight, up light, and glare (BUG) ratings in accordance with IES TM-15-11, Addendum A, and shall be provided with a minimum of 40% dimming capability activated to full on by motion sensor or other automatic control. This requirement does not apply to streetlights for the public right of way, signs, or building facade lighting.

Section 140.7 establishes outdoor lighting power density allowances in terms of watts per area for lighting sources other than signage. The lighting allowances are provided by the Lighting Zone, as defined in Section 10-114 of the CEC. Under Section 10-114, all urban areas within California are designated as Lighting Zone 3. Additional allowances are provided for Building Entrances or Exits, Outdoor Sales Frontage, Hardscape Ornamental Lighting, Building Facade Lighting, Canopies, Outdoor Dining, and Special Security Lighting for Retail Parking and Pedestrian Hardscape.

Section 130.3 stipulates sign lighting controls with any outdoor sign that is on during both day and nighttime hours must include a minimum 65% dimming at night. Section 140.8 of the CEC sets forth lighting power density restrictions for signs.

Title 24, Part 11 – California Green Building Standards Code The California Green Building Standards Code (CALGreen) (Title 24, Part 24) is commonly referred to as the CALGreen Code. The CALGreen Code stipulates maximum allowable light levels, efficiency requirements for lighting, miscellaneous control requirements, and light trespass requirements for electric lighting and daylighting. Paragraph 5.1106.8 Light Pollution Reduction, specifies that all non-residential outdoor lighting must comply with the following:
▪ The minimum requirements in the CEC for Lighting Zones 1-4 as defined in Chapter 10 of the California Administrative Code; and
▪ BUG ratings as defined in the Illuminating Engineering Society of North America's Technical Memorandum on Luminaire Classification Systems for Outdoor Luminaires (IESNA TM-15-07); and ▪ Allowable BUG ratings not exceeding those shown in Table A5.106.8 in Section 5.106.8 of the CALGreen Code; or
▪ Comply with a local ordinance lawfully enacted pursuant to Section 101.7, whichever is more stringent.

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IESNA Recommended Practices
Illuminating Engineering Society of North American (IESNA) recommends illumination standards for a wide range of building and development types. These recommendations are widely recognized and accepted as best practices and are a consistent predictor of the type and direction of illumination for any given building type. For all areas not stipulated by the regulatory building code, municipal code, or specifically defined requirements, the IESNA standards are used as the basis for establishing the amount and direction of light for the Project.

The IESNA provides recommendations for pre-curfew and post-curfew light levels to limit light trespass. Precurfew is from dusk until 11:00 p.m. local time, when the area being illuminated is more likely to be in use. Postcurfew is from 11:00 p.m. to 7:00 a.m. local time (NLPIP 2007).

The IESNA 10th Edition Lighting Handbook defines lighting zones (LZ) relative to ambient light levels, which are used to establish a basis for outdoor lighting regulations. The existing conditions surrounding the Project site are best described as LZ 3, which has a maximum recommended light trespass limit of 8 lux (0.74 foot-candles) during pre-curfew hours and 3 lux (0.28 foot-candles) during post-curfew hours.

Local
City of Santee General Plan
Conservation Element
The purpose of the Conservation Element is to identify the community’s natural and man-made resources and to encourage their wise management in order to assure their continued availability for use, appreciation, and enjoyment. The Conservation Element includes policies and implementation measures to encourage the conservation and proper management of natural resources and open space areas in the City. The following objectives and policies from the City of Santee General Plan, Conservation Element and Community Enhancement Element pertain to aesthetics and visual quality (City of Santee 2003):

Conservation Element Objective 1.0 Protect areas of unique topography or environmental significance to the greatest extent possible.

Policy 1.1 The City shall encourage significant natural landforms to be maintained during development whenever possible.

Conservation Element Objective 10.0 Preserve significant natural resources, such as mineral deposits, biological resources, watercourses, groundwater, hills, canyons, and major rock outcroppings, as part of a Citywide open space system.

Policy 10.2 Preserve significant natural resources, such as mineral deposits, biological resources, watercourses, groundwater, hills, canyons, and major rock outcroppings, as part of a Citywide open space system.

Community Enhancement Element Objective 8.0 Improve the appearance and function of existing and planned industrial areas.

Policy 8.4 The City shall ensure that all industrial development is attractive and of high-quality design to enhance the image of the City.

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City of Santee Municipal Code
Chapter 13.14 Industrial Districts
The Project site is zoned for Light Industrial, per the City’s Zoning Code. Pursuant to Chapter 13.14 of the City’s Municipal Code, permitted uses in the Light Industrial zone include warehousing/distribution, assembly and light manufacturing, repair facilities, and business parks, including corporate offices (City of Santee 2023b,). The applicable maximum allowable building height in the Light Industrial zone is 40 feet; however, and as indicated in Table 13.14.040A, Site Dimensions and Height Limitations, of the City’s Municipal Code, proposals for development exceeding [40 feet] shall require the approval of a conditional use permit.

Chapter 13.30 General Development and Performance Standards Regarding lighting, Section 13.30.030 (B), Performance Standards (Lighting) requires adequate lighting of all public parking areas. In addition, and pursuant to Section 13.30.030(B), all lighting shall be designed and adjusted to reflect light away from any road or street, and away from any adjoining premises. Lastly, all lights and illuminated signs shall be shielded or directed so as to not cause glare on adjacent properties or to motorists.

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

Have a substantial adverse effect on a scenic vista.

Substantially damage scenic resources including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway.

In non-urbanized areas, 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 point). If the Project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

4.1.4 Impacts Analysis
A series of 3D visual simulations of the Project were prepared to aid in the description of anticipated visual change associated with proposed development of the Project site. The 3D simulations include true scale 3D models for the Project that are then rendered onto camera matched site photographs. The 3D simulations show the Project at completion and combined with the existing conditions photograph, present the visual change anticipated to occur as a result of project implementation.

Baseline images from selected representative public vantage points in the surrounding area with available views to the Project site were captured on May 16, 2024 when viewing conditions were clear and atmospheric conditions were generally sunny. Low clouds were present during the May 16 field survey at one of the three selected vantage points. The selected representative public vantage points and their proximity to the Project site are presented in

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Table 4.1, Representative Vantage Points, below. The locations of representative vantage points are shown on Figure 4.1-1, Vantage Points, and the existing condition and 3D simulations from the three vantage points are shown on Figures 4.1-2, 4.1-3, and 4.1-4.

Table 4.1-1. Selected Public Vantage Points
Number Location and Proximity to Project Site Viewer Type 1 River Trail #1 – 0.32 mile to northwest of Project Trail user 2 River Trail #2 – 0.15 mile to northeast of Project Trail user 3 Northcote Road – 0.15 mile to southeast of Project Motorist/road user In addition to the 3D simulations described above, a series of artistic renderings of the Project were prepared and are presented as Figures 3-12a through 3-12f. Renderings demonstrate the proposed bulk and scale of the building, rooftop elements, intended plantings included in the landscape plan, and address compatibility of the project within the context of the surrounding area.

A. Would the Project have a substantial adverse effect on a scenic vista? Less-than-Significant Impact The proposed Project includes demolition and/or removal of all existing on-site structures (i.e., drive-in theatre screens, restroom and snack bar building, ticket booths, and fencing) and the construction of a 300,145 square foot industrial/warehousing building. The proposed building height would be up to 50 feet.

As stated in Section 4.1.1, the open space resources within the City and adjacent areas provide opportunities for scenic vistas. Specifically, within the Project area, views to the San Diego River and adjacent floodway, and Rattlesnake Mountain, are available from public vantage points located north of the river including from the San Diego River Trail/Walker Preserve Trail and Sandy Creek Drive. At its closest point, the river trail is located approximately 610 feet north of the Project site, and Sandy Creek Drive is located approximately 1,130 feet to the northwest of the northwestern corner of the Project site. As viewed from the river trail, the San Diego River riparian corridor (specifically, dense trees and shrubs) dominates the foreground and existing features on the Project site (located south of the river) do not obstruct of interrupt existing views from the trail to the San Diego River riparian corridor or background hillsides. Figures 4.1-2 and 4.1-3 capture representative views from the river trail towards the Project site. For the same reasons, proposed development on the Project site would not obstruct or interrupt views from the river trail to the San Diego River and riparian corridor. The façades of the proposed building would be visible from segments of the trail (facades would be detectable above foreground vegetation) but the proposed building scale and mass would not result in substantial blockage of an existing scenic resource nor would it result in the significant additional interruption of views to the foreground river corridor or background hillsides. Also, as viewed from the river trail, Rattlesnake Mountain is regularly blocked from view by upland and riparian vegetation within the San Diego River floodway. Where clear views to Rattlesnake Mountain are available (such as at Vantage Points 1 and 2), building scale would not adversely affect the existing quality of the view. See Figures 4.1-2 and 4.1-3.

Similarly, the proposed building would be visible from segments of SR-67 and nearby roadways to the north including Northcote Road but the introduction of the Project would not result in substantial blockage of a scenic vista or resource. See Figure 4.1-4. Lastly and as viewed from Sandy Creek Drive, Rattlesnake Mountain is not located in line with the Project site or existing built features on the Project site. An existing view south and southeast toward Rattlesnake Mountain from Sandy Creek Drive is provided in Figure 4.1-5.

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From the river trail, the existing drive-in theatre screen in the northwest corner of the Project site is occasionally visible through gaps in tall vegetation; however, since the proposed maximum height of the industrial/warehouse building (up to 50 feet) would be less than the maximum above ground height of the closest onsite drive-in theatre screen, views through the site and toward Rattlesnake Mountain may be improved. From select river trail locations, the upper portions of the proposed industrial/warehouse building may be visible, but the majority of the building would be blocked from view by intervening riparian vegetation in the river corridor and by proposed screen trees to be planted along the site’s northern boundary. See Figure 4.1-6, Landscape Sections and River Trail View Corridors, that depicts approximate south-oriented cross-sections from the River Trail toward the northwestern corner (Section A’-A’) and northeastern corner (Section B’-B’) of the proposed building. Figures 4.1-2 through 4.1-4 also detail the partially blocked nature of views to the Project from nearby segments of the river trail and from Northcote Road.

As captured in Figures 4.1-2 through 4.1-5, the drive-in theatre screens are currently viewed as rectangular forms in a built landscape of comparably lower, rectangular industrial buildings with flat rooflines and lightly colored exteriors. Introduction of the proposed project, which would consist of similar built characteristics as nearby industrial/commercial buildings, would result in an overall more cohesive visual environment. Because construction and operation of the proposed project would not substantially obstruct, interrupt, or otherwise degrade views to Rattlesnake Mountain from either the San Diego River Trail/Walker Preserve Trail or Sandy Creek Drive, impacts to scenic vistas from these public vantage points would be less than significant.

While taller equipment including cranes used for demolition and construction activities on the Project site may be visible from Sandy Creek Drive and the San Diego River Trail/Walker Preserve Trail, the temporary presence of construction equipment in views would not have a substantial adverse effect on views to the San Diego River and adjacent floodway. Cranes and similar tall equipment would operate onsite temporarily and would be removed from the site (and public views) upon completion of activities and structures requiring their use. Further, the tall and narrow form and line of cranes located on the Project site (south of the river) and would have overall minor effects on views to the river and the river’s riparian corridor from public vantage points north of the river. Similarly and once in the operational phase, the introduction of an up to 50 foot high, industrial/warehousing building on site surrounded by existing industrial and commercial buildings of similar form, color, and scale would not obstruct, substantially interrupt, or degrade river trail or Sandy Creek Drive views to the river and adjacent floodway. Impacts would be less than significant.

B. Would the Project substantially damage scenic resources, including, but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway?
No Impact. There are no state scenic highways that occur within the vicinity of the Project site. The nearest officially designated state scenic highway, State Route (SR) 52 as it travels adjacent to Mission Trails Regional Park (approximately Santo Road in San Diego to Mast Boulevard in Santee) is located approximately four miles to the west of the Project site. SR-52 (from Mast Boulevard in Santee to SR-67 in Santee) is the nearest eligible state scenic highway to the Project site, which is located approximately one mile south of the Project site. 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. Therefore, no impacts associated with state scenic highways would occur.

Palisade Santee
Commerce Center
Vantage Point 3
Vantage Point 1
Vantage Point 2
Vantage Point
Project Boundary
0 210 420 n Feet Date: 5/31/2024 User: kholmes Path: Z:\Projects\j1513801\MAPDOC\DOCUMENT\Draft_EIR\Draft_EIR_figures.aprx Map: Map1 Layout: Figure 4.1-1 Vantage Points SOURCE: Bing Maps 2024
Palisade Santee Commerce Center Project
Vantage Points
FIGURE 4.1-1

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Vantage Point 1: River Trail Location #1
Palisades Santee Commerce Center Project
FIGURE 4.1-2 SOURCE: Clusters Creative 2024
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Existing view from eastbound segment of the River Trail towards the Project site (located 0.32 mile away) Visual Simulation of Proposed Project (west and north facades of the building visible)

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Vantage Point 2: River Trail Location #2
Palisades Santee Commerce Center Project
FIGURE 4.1-3 SOURCE: Clusters Creative 2024
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Existing view from a southbound segment the River Trail connector to Hillcreek Road towards the Project site (located 0.15 mile away)
Visual Simulation of Proposed Project (north and east (partial) facades of the building visible

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Vantage Point 3: Northcote Road
Palisades Santee Commerce Center Project
FIGURE 4.1-4 SOURCE: Clusters Creative 2024
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Existing view from southbound Northcote Road at Woodside Avenue towards the Project site (building site located 0.15 mile away)
Visual Simulation of Proposed Project (east and south (partial) facades of the building visible)

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Example View towards Rattlesnake Mountain from Sandy Creek Drive Palisades Santee Commerce Center Project
FIGURE 4.1-7
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Example View towards Rattlesnake Mountain from Sandy Creek Drive Palisades Santee Commerce Center Project
FIGURE 4.1-5 SOURCE: Google Earth 2022
View from Sandy Crek Drive towards Rattlesnake Mountain; the drive-in theatre screen in the northwest corner of the Project site is visible but blocked by intervening trees

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REFER TO

SECTION 'B-B'

REFER TO

SECTION 'A-A'
WALL
WALL
5'-0"
709'-0"

FINAL LOCATION OF

SCREEN TREES SHALL

BE COORDIANTED TO

AVOID ANY POTENTIAL

CONFLICTS WITH WALL
FOOTING, TYP.
752'-7"
6'-0"

FINAL LOCATION OF

SCREEN TREES SHALL

BE COORDIANTED TO

AVOID ANY POTENTIAL

CONFLICTS WITH WALL
FOOTING, TYP.

DATE 01/26/24
Landscape Sections and River Trail View Corridors
Palisades Santee Commerce Center Project
FIGURE 4.1-8 SOURCE: Rodarte Landscape Architecture, Inc. 2024 Path: Z:\Projects\j1513801\MAPDOC\DOCUMENT\Visual
member
the
path.

Landscape Sections and River Trail View Corridors
Palisades Santee Commerce Center Project
FIGURE 4.1-6 SOURCE: Rodarte Landscape Architecture, Inc. 2024 Path: Z:\Projects\j1513801\MAPDOC\DOCUMENT\Visual

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C. 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?
Less-than-Significant Impact. Section 20171 of the California Public Resources Code defines an “urbanized area” as “(a) an incorporated city that meets either of the following criteria: (1) Has a population of at least 100,000 persons, or (2) Has a population of less than 100,000 persons if the population of that city and not more than two contiguous incorporated cities combined equals at least 100,000 persons.” As of January 1, 2023, the California Department of Finance estimated the population of Santee to be 59,227 persons (DOF 2023). Additionally, the City of Santee is located adjacent to the City of El Cajon, which the California Department of Finance estimates to have a population of 104,619 as of January 1, 2023 (DOF 2023). Therefore, because 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. Section 21071 of the California Public Resources Code also defines an urbanized area for unincorporated areas; however, the City of Santee is an incorporated city, so this definition was not considered for this analysis.

The City’s Municipal Code includes design standards related to building height, setbacks, landscaping requirements, and other development considerations that are relevant to scenic quality. Specifically, Chapter 13, Zoning, of the City’s Municipal Code includes design standards for each zoning district, including the Light Industrial zone, which is the zoning designation for the Project site. The Light Industrial Zone has specified regulations that are outlined in Section 13.14 of the Santee Municipal Code (City of Santee 2023b). The design standards exist, in part, to regulate the uses of buildings and structures, and to encourage the most appropriate use of land. As a part of the City’s development and design review process, City staff reviews project plans to ensure compliance with applicable provisions of the Santee Municipal Code, including those provisions relating to scenic quality. Because the Project would undergo review by City Staff and with the approval of the proposed conditional use permit the proposed warehouse building’s maximum height of 50 feet would be allowable within the Light Industrial zone (Section 13.14.040 of the Santee Municipal Code). The Project would not conflict with applicable zoning and other regulations governing scenic quality. Therefore, impacts associated with scenic quality would be less than significant.

D. Would the Project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Less-than-Significant Impact. Lighting is of most concern when it may potentially spill over or trespass onto offsite properties, particularly residential buildings, sensitive biological areas such as the San Diego River corridor and the public right-of-way. Light spillover, trespass, and potential glare from project lighting are regulated by Section

13.30.030(B) of the Santee Municipal Code. The code requires that all lights and illuminated signs must be designed and adjusted to reflect light away from any road or street, away from any adjoining premises, and shall be shielded or directed to not cause glare on adjacent properties or motorists.

Project construction would be limited to the City’s allowable construction hours of 7:00 a.m. and 7:00 p.m. and is not anticipated to require night lighting. In the event that construction lighting is required, its use would be temporary and infrequent and the limited lighting sources in use would be properly shielded to avoid spillover effects.

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According to the Site Photometric Plan prepared for the Project (Herdman Architecture + Design 2024), wall mounted light fixtures (53 in total) would be installed on the exterior façades of the building. Approximately half of the wall fixtures would be mounted at a height of 25 feet above ground surface and the remaining half would be mounted at a height of 9 feet above ground surface. In addition, approximately 18 pole mounted lights would be installed throughout the site parking lot and the site driveway. The mounting height of pole lights would be 25 feet above ground surface. All lighting fixtures would be hooded and downward casting. Fixture housing would feature a cast black painted metal finish. Lamp/light sources would be white, LEDs.

Project lighting has been designed consistent with the requirements of Section 13.30.030(B) of the Santee Municipal Code. Specifically, exterior lighting on the Project site would result in the adequate lighting of parking areas, would cast light downward where most lighting would fall onto the site (offsite light trespass would be minimal). As shown on the Site Photometric Study, all measurable lighting (i.e., 0.1-foot candles or greater) would generally be contained within the site boundary. Along the site’s northern boundary with the San Diego River floodway, most measurable lighting would be contained onsite with limited occurrences of lighting (0.1-0.4 footcandles) extending north of the site’s northwestern corner (light levels in this area would be reduced to 0.0-foot candles approximately 20 feet north of the project boundary). Measurable lighting (0.1-0.5 footcandles with limited occurrences of 0.7 -0.9 footcandles immediately adjacent to the site) from onsite sources would fall onto adjacent industrial and business park uses including surface parking areas to the east and west of the Project site. However, as these uses/areas are not considered light sensitive and feature similar wall and pole mounted light sources, site lighting would not adversely affect nighttime views from these properties. Similarly, site lighting would not adversely affect nighttime views available to residences located to the north of the San Diego River as measurable lighting levels would not extend to the river trail or nearby residences. Lastly, light levels extending north of the Project site would be 0.0 footcandles or low (generally, 0.1-0.3 footcandles) and would quickly reduce in intensity with increased distance from the source and Project site.

With respect to glare potentially generated by the Project, the majority of the exterior building surfaces would consist of painted concrete (i.e., tilt-up concrete walls). To provide architectural interest and break up the overall massing of the proposed building, the design includes occasional strips of vertical windows along building exteriors and a collection of windows at building corners including at the office in the southeast corner of the building. See Figure 3-12a that depicts a rendering of the office exterior and vertical window strips along the south and east building facades. Figure 3-8 presents building elevations and demonstrates limited windows along the river-facing exterior (north elevation) of the building. As stated above, painted concrete would comprise the majority of the building exterior character and at window areas, the Project would use glass that is clear or tinted with medium to high performance anti-glare glazing. Solar panels would be installed atop the building; however, the fixed-tilt panel system would be oriented toward the south and is designed to absorb (as opposed to reflect) the majority of incoming light. The panels would be visible from some hillside residential areas to the south including near Rattlesnake Mountain; however, project-related glare visible from the residential areas is anticipated to be minimal due to distance, the general small size of the solar array system, and the orientation of the panels towards the sky.

As such, the Project would not result in a substantial amount of glare in the Project area. Therefore, impacts associated with light and glare would be less than significant.

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

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

In addition to the documents incorporated by reference (see Section 2.7 of Chapter 2 of this environmental impact report [EIR]), the following analysis is based, in part, on the following sources:
▪ Air Quality and GHG Emissions Technical Report, prepared by Dudek in March 2025 (Appendix B). ▪ Transportation Impact Study, prepared by Dudek in March 2025 (Appendix L)

4.2.1 Existing Conditions
Meteorological and Topographical Conditions
The weather of the San Diego region, as in most of Southern California, is influenced by the Pacific Ocean and its semi-permanent high-pressure systems that result in dry, warm summers and mild, occasionally wet winters. The average temperature ranges (in degrees Fahrenheit) from the mid-40s to the high 90s. Most of the region’s precipitation falls from November to April, with infrequent (approximately 10%) precipitation during the summer.

The average seasonal precipitation along the coast is approximately 10 inches; the amount increases with elevation as moist air is lifted over the mountains (WRCC 2016). This usually mild climatological pattern is interrupted infrequently by periods of extremely hot weather, winter storms, or Santa Ana winds.

The topography in the San Diego region varies greatly, from beaches on the west to mountains and desert on the east; along with local meteorology, it influences the dispersal and movement of pollutants in the basin. The mountains to the east prohibit dispersal of pollutants in that direction and help trap them in inversion layers.

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

Pollutants and Effects
Criteria Air Pollutants
Criteria air pollutants are defined as pollutants for which the federal and state governments have established ambient air quality standards, or criteria, for outdoor concentrations to protect public health. The federal and state standards have been set, with an adequate margin of safety, at levels above which concentrations could be harmful to human health and welfare. These standards are designed to protect the most sensitive persons from illness or discomfort. Pollutants of concern include O3, NO2, CO, sulfur dioxide (SO2), PM10, PM2.5, and lead. These pollutants

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are discussed in the following paragraphs.1 In California, sulfates, vinyl chloride, hydrogen sulfide, and visibilityreducing particles are also regulated as criteria air pollutants.

Ozone (O3). O3 is a strong-smelling, pale blue, reactive, toxic chemical gas consisting of three oxygen atoms. It is a secondary pollutant formed in the atmosphere by a photochemical process involving the sun’s energy and O3 precursors. These precursors are mainly NOx and VOCs. The maximum effects of precursor emissions on O3 concentrations usually occur several hours after they are emitted and many miles from the source. Meteorology and terrain play major roles in O3 formation, and ideal conditions occur during summer and early autumn on days with low wind speeds or stagnant air, warm temperatures, and cloudless skies. O3 exists in the upper atmosphere O3 layer (stratospheric O3) and at the Earth’s surface in the troposphere.2 The O3 that the U.S. Environmental Protection Agency (EPA) and the CARB regulate as a criteria air pollutant is produced close to the ground level, where people live, exercise, and breathe. Ground-level O3 is a harmful air pollutant that causes numerous adverse health effects and is thus considered “bad” O3. Stratospheric, or “good,” O3 occurs naturally in the upper atmosphere, where it reduces the amount of ultraviolet light (i.e., solar radiation) entering the Earth’s atmosphere.

Without the protection of the beneficial stratospheric O3 layer, plant and animal life would be seriously harmed.

O3 in the troposphere causes numerous adverse health effects; short-term exposures (lasting for a few hours) to O3 at levels typically observed in Southern California can result in breathing pattern changes, reduction of breathing capacity, increased susceptibility to infections, inflammation of the lung tissue, and some immunological changes (EPA 2013). These health problems are particularly acute in sensitive receptors such as the sick, the elderly, and young children.

Nitrogen Dioxide (NO2). NO2 is a brownish, highly reactive gas that is present in all urban atmospheres. The major mechanism for the formation of NO2 in the atmosphere is the oxidation of the primary air pollutant nitric oxide (NO), which is a colorless, odorless gas. NOx plays a major role, together with VOCs, in the atmospheric reactions that produce O3. NOx is formed from fuel combustion under high temperature or pressure. In addition, NOx is an important precursor to acid rain and may affect both terrestrial and aquatic ecosystems. The two major emissions sources are transportation and stationary fuel combustion sources such as electric utility and industrial boilers.

NO2 can irritate the lungs, cause bronchitis and pneumonia, and lower resistance to respiratory infections (EPA 2016).

Carbon Monoxide (CO). CO is a colorless, odorless gas formed by the incomplete combustion of hydrocarbon, or fossil fuels. CO is emitted almost exclusively from motor vehicles, power plants, refineries, industrial boilers, ships, aircraft, and trains. In urban areas, such as the Project location, automobile exhaust accounts for the majority of CO emissions.

CO is a non-reactive air pollutant that dissipates relatively quickly; therefore, ambient CO concentrations generally follow the spatial and temporal distributions of vehicular traffic. CO concentrations are influenced by local meteorological conditions—primarily wind speed, topography, and atmospheric stability. CO from motor vehicle exhaust can become locally concentrated when surface-based temperature inversions are combined with calm atmospheric conditions, which is a typical situation at dusk in urban areas from November to February. The highest levels of CO typically occur during the colder months of the year, when inversion conditions are more frequent. 1 The following descriptions of health effects for each of the criteria air pollutants associated with project construction and operations are based on the U.S. Environmental Protection Agency’s “Six Common Air Pollutants” (EPA 2023a) and the California Air Resources Board’s “Glossary of Air Pollutant Terms” (CARB 2017) published information. 2 The troposphere is the layer of the Earth’s atmosphere nearest to the surface of the Earth. The troposphere extends outward about 5 miles at the poles and about 10 miles at the equator.

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In terms of adverse health effects, CO competes with oxygen, often replacing it in the blood, reducing the blood’s ability to transport oxygen to vital organs. The results of excess CO exposure can include dizziness, fatigue, and impairment of central nervous system functions.

Sulfur Dioxide (SO2). SO2 is a colorless, pungent gas formed primarily from incomplete combustion of sulfurcontaining fossil fuels. The main sources of SO2 are coal and oil used in power plants and industries; as such, the highest levels of SO2 are generally found near large industrial complexes. In recent years, SO2 concentrations have been reduced by the increasingly stringent controls placed on stationary source emissions of SO2 and limits on the sulfur content of fuels.

SO2 is an irritant gas that attacks the throat and lungs and can cause acute respiratory symptoms and diminished ventilator function in children. When combined with particulate matter, SO2 can injure lung tissue and reduce visibility and the level of sunlight. SO2 can also yellow plant leaves and erode iron and steel.

Particulate Matter (PM). Particulate matter pollution consists of very small liquid and solid particles floating in the air, which can include smoke, soot, dust, salts, acids, and metals. Particulate matter can form when gases emitted from industries and motor vehicles undergo chemical reactions in the atmosphere. PM2.5 and PM10 represent fractions of particulate matter. Coarse particulate matter (PM10) consists of particulate matter that is 10 microns or less in diameter and is about 1/7 the thickness of a human hair. Major sources of PM10 include crushing or grinding operations; dust stirred up by vehicles traveling on roads; wood-burning stoves and fireplaces; dust from construction, landfills, and agriculture; wildfires and brush/waste burning; industrial sources; windblown dust from open lands; and atmospheric chemical and photochemical reactions. Fine particulate matter (PM2.5) consists of particulate matter that is 2.5 microns or less in diameter and is roughly 1/28 the diameter of a human hair. PM2.5 results from fuel combustion (e.g., from motor vehicles and power generation and industrial facilities), residential fireplaces, and woodstoves. In addition, PM2.5 can be formed in the atmosphere from gases such as sulfur oxides (SOx), NOx, and VOCs.

PM2.5 and PM10 pose a greater health risk than larger-size particles. When inhaled, these tiny particles can penetrate the human respiratory system’s natural defenses and damage the respiratory tract. PM2.5 and PM10 can increase the number and severity of asthma attacks, cause or aggravate bronchitis and other lung diseases, and reduce the body’s ability to fight infections. Very small particles of substances such as lead, sulfates, and nitrates can cause lung damage directly or be absorbed into the blood stream, causing damage elsewhere in the body. Additionally, these substances can transport adsorbed gases such as chlorides or ammonium into the lungs, also causing injury.

Whereas PM10 tends to collect in the upper portion of the respiratory system, PM2.5 is so tiny that it can penetrate deeper into the lungs and damage lung tissue. Suspended particulates also damage and discolor surfaces on which they settle and produce haze and reduce regional visibility.

People with influenza, people with chronic respiratory and cardiovascular diseases, and the elderly may suffer worsening illness and premature death as a result of breathing particulate matter. People with bronchitis can expect aggravated symptoms from breathing in particulate matter. Children may experience a decline in lung function due to breathing in PM10 and PM2.5 (EPA 2009).

Lead. Lead in the atmosphere occurs as particulate matter. Sources of lead include leaded gasoline; the manufacturing of batteries, paints, ink, ceramics, and ammunition; and secondary lead smelters. Prior to 1978, mobile emissions were the primary source of atmospheric lead. Between 1978 and 1987, the phaseout of leaded gasoline reduced the overall inventory of airborne lead by nearly 95%. With the phaseout of leaded gasoline,

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secondary lead smelters, battery recycling, and manufacturing facilities are becoming lead-emissions sources of greater concern.

Prolonged exposure to atmospheric lead poses a serious threat to human health. Health effects associated with exposure to lead include gastrointestinal disturbances, anemia, kidney disease, and in severe cases, neuromuscular and neurological dysfunction. Of particular concern are low-level lead exposures during infancy and childhood. Such exposures are associated with decrements in neurobehavioral performance, including IQ performance, psychomotor performance, reaction time, and growth. Children are highly susceptible to the effects of lead.

Volatile Organic Compounds (VOCs). Hydrocarbons are organic gases that are formed from hydrogen and carbon and sometimes other elements. Hydrocarbons that contribute to formation of O3 are referred to and regulated as Volatile Organic Compounds (VOCs) (also referred to as reactive organic gases). Combustion engine exhaust, oil refineries, and fossil-fueled power plants are the sources of hydrocarbons. Other sources of hydrocarbons include evaporation from petroleum fuels, solvents, dry-cleaning solutions, and paint.

The primary health effects of VOCs result from the formation of O3 and its related health effects. High levels of VOCs in the atmosphere can interfere with oxygen intake by reducing the amount of available oxygen through displacement. Carcinogenic forms of hydrocarbons, such as benzene, are considered TACs.

Non-Criteria Air Pollutants
Toxic Air Contaminants (TACs). A substance is considered toxic if it has the potential to cause adverse health effects in humans, including increasing the risk of cancer upon exposure, or acute and/or chronic noncancer health effects.

A toxic substance released into the air is considered a TAC. TACs are identified by federal and state agencies based on a review of available scientific evidence. In the State of California, TACs are identified through a two-step process that was established in 1983 under the Toxic Air Contaminant Identification and Control Act. This two-step process of risk identification and risk management and reduction was designed to protect residents from the health effects of toxic substances in the air. In addition, the California Air Toxics “Hot Spots” Information and Assessment Act, Assembly Bill (AB) 2588, was enacted by the legislature in 1987 to address public concern over the release of TACs into the atmosphere. The law requires facilities emitting toxic substances to provide local air pollution control districts with information that will allow an assessment of the air toxics problem, identification of air toxics emissions sources, location of resulting hotspots, notification of the public exposed to significant risk, and development of effective strategies to reduce potential risks to the public over 5 years.

Examples include certain aromatic and chlorinated hydrocarbons, certain metals, and asbestos. TACs are generated by a number of sources, including stationary sources such as dry cleaners, gas stations, combustion sources, and laboratories; mobile sources such as automobiles; and area sources such as landfills. Adverse health effects associated with exposure to TACs may include carcinogenic (i.e., cancer-causing) and noncarcinogenic effects. Noncarcinogenic effects typically affect one or more target organ systems and may be experienced on either short-term (acute) or long-term (chronic) exposure to a given TAC.

Diesel Particulate Matter (DPM). DPM is part of a complex mixture that makes up diesel exhaust. Diesel exhaust is composed of two phases, gas and particle, both of which contribute to health risks. More than 90% of DPM is less than 1 micrometer in diameter (about 1/70th the diameter of a human hair), and thus is a subset of PM2.5 (CARB 2022b). DPM is typically composed of carbon particles (“soot,” also called black carbon) and numerous organic compounds, including over 40 known cancer-causing organic substances. Examples of these chemicals include polycyclic aromatic hydrocarbons, benzene, formaldehyde, acetaldehyde, acrolein, and 1,3-butadiene (CARB

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2022b). CARB classified “particulate emissions from diesel-fueled engines” (i.e., DPM) as a TAC in August 1998 (17 CCR 93000). DPM is emitted from a broad range of diesel engines: on-road diesel engines of trucks, buses, and cars and off-road diesel engines including locomotives, marine vessels, and heavy-duty construction equipment, among others. Approximately 70% of all airborne cancer risk in California is associated with DPM (CARB 2000). To reduce the cancer risk associated with DPM, CARB adopted a diesel risk reduction plan in 2000 (CARB 2000). Because it is part of PM2.5, DPM also contributes to the same non-cancer health effects as PM2.5 exposure.

These effects include premature death; hospitalizations and emergency department visits for exacerbated chronic heart and lung disease, including asthma; increased respiratory symptoms; and decreased lung function in children.

Several studies suggest that exposure to DPM may also facilitate development of new allergies (CARB 2022b).

Those most vulnerable to non-cancer health effects are children whose lungs are still developing and the elderly who often have chronic health problems.

Odorous Compounds. Odors are generally regarded as an annoyance rather than a health hazard. Manifestations of a person’s reaction to odors can range from psychological (e.g., irritation, anger, or anxiety) to physiological (e.g., circulatory and respiratory effects, nausea, vomiting and headache). The ability to detect odors varies considerably among the population and overall is quite subjective. People may have different reactions to the same odor. An odor that is offensive to one person may be perfectly acceptable to another (e.g., coffee roaster). An unfamiliar odor is more easily detected and is more likely to cause complaints than a familiar one. In a phenomenon known as odor fatigue, a person can become desensitized to almost any odor, and recognition may only occur with an alteration in the intensity. The occurrence and severity of odor impacts depend on the nature, frequency, and intensity of the source; wind speed and direction; and the sensitivity of receptors.

Valley Fever. Coccidioidomycosis, more commonly known as “Valley Fever,” is an infection caused by inhalation of the spores of the Coccidioides immitis fungus, which grows in the soils of the southwestern United States. The ecologic factors that appear to be most conducive to survival and replication of the spores are high summer temperatures, mild winters, sparse rainfall, and alkaline, sandy soils.

The County is not considered a highly endemic region for Valley Fever, as the latest report from the County of San Diego Health and Human Services Agency Public Health Services indicated the County has 8.3 cases per 100,000 people (County of San Diego 2019). In the zip code area of the Project site, the case rate is reported as between

5.0-7.6 cases per 100,000 people (County of San Diego 2021).

Sensitive Receptors
Air quality varies as a direct function of the quantity of pollutants emitted into the atmosphere, the size and topography of the air basin, and the prevailing meteorological conditions. Air quality problems arise when the rate of pollutant emissions exceeds the rate of dispersion.

Some land uses are considered more sensitive to changes in air quality than others, depending on the population groups and the activities involved. People most likely to be affected by air pollution, as identified by the California Air Resources Board (CARB), include children, older adults, and people with cardiovascular and chronic respiratory diseases. According to the SDAPCD, sensitive receptors are those who are especially susceptible to adverse health effects from exposure to toxic air contaminants, such as children, the elderly, and the ill. Sensitive receptors include residences, schools (grades Kindergarten through 12), libraries, day care centers, nursing homes, retirement homes, health clinics, and hospitals within 2 kilometers of a project site (SDAPCD 2022a). The closest sensitive receptors to the Project site are single-family residences to the north of the site and north of the San Diego River and single and multifamily residential units south of the Project site and south of Highway 67.

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Local Ambient Air Quality
The Project area is located within the San Diego Air Basin (SDAB) and is subject to the SDAPCD guidelines and regulations. The SDAB is one of 15 air basins that geographically divide the State of California. The SDAB is currently classified as a federal nonattainment area for ozone (O3) and a state nonattainment area for particulate matter less than 10 microns (PM10), particulate matter less than 2.5 microns (PM2.5), and O3.

The SDAB experiences frequent temperature inversions. Subsidence inversions occur during the warmer months as descending air associated with the Pacific High Pressure Zone meets cool marine air. The boundary between the two layers of air creates a temperature inversion that traps pollutants. The other type of inversion, a radiation inversion, develops on winter nights when air near the ground cools by heat radiation and air aloft remains warm.

The shallow inversion layer formed between these two air masses also can trap pollutants. As the pollutants become more concentrated in the atmosphere, photochemical reactions occur that produce O3, which contributes to the formation of smog. Smog is a combination of smoke and other particulates, O3, hydrocarbons, oxides of nitrogen (NOx) and other chemically reactive compounds which, under certain conditions of weather and sunlight, may result in a murky brown haze that causes adverse health effects (CARB 2022a).

Light daytime winds, predominantly from the west, further aggravate the condition by driving air pollutants inland, toward the mountains. During the fall and winter, air quality problems are created due to carbon monoxide (CO) and NOx emissions. CO concentrations are generally higher in the morning and late evening. In the morning, CO levels are elevated due to cold temperatures and the large number of motor vehicles traveling. Higher CO levels during the late evenings are a result of stagnant atmospheric conditions trapping CO in the area. Since CO is produced almost entirely from automobiles, the highest CO concentrations in the SDAB are associated with heavy traffic. Nitrogen dioxide (NO2) levels are also generally higher during fall and winter days.

Under certain conditions, atmospheric oscillation results in the offshore transport of air from the Los Angeles region to San Diego County. This often produces high O3 concentrations, as measured at air pollutant monitoring stations within San Diego County. The transport of air pollutants from Los Angeles to San Diego has also occurred within the stable layer of the elevated subsidence inversion, where high levels of O3 are transported.

SDAB Attainment Designation
Pursuant to the 1990 CAA Amendments, EPA classifies air basins (or portions thereof) as “attainment” or “nonattainment” for each criteria air pollutant, based on whether the NAAQS have been achieved. Generally, if the recorded concentrations of a pollutant are lower than the standard, the area is classified as “attainment” for that pollutant. If an area exceeds the standard, the area is classified as “nonattainment” for that pollutant. As previously discussed, these standards are set by EPA or CARB for the maximum level of a given air pollutant that can exist in the outdoor air without unacceptable effects on human health or the public welfare. If there is not enough data available to determine whether the standard is exceeded in an area, the area is designated as “unclassified” or “unclassifiable.” The designation of “unclassifiable/attainment” means that the area meets the standard or is expected to be meet the standard despite a lack of monitoring data. Areas that achieve the standards after a nonattainment designation are redesignated as maintenance areas and must have approved maintenance plans to ensure continued attainment of the standards. The California Clean Air Act, like its federal counterpart, called for the designation of areas as “attainment” or “nonattainment,” but based on the CAAQS rather than the NAAQS.

Table 4.2-1 summarizes SDAB’s federal and state attainment designations for each of the criteria pollutants.

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Table 4.2-1. SDAB Attainment Designation
Pollutant Federal Designation State Designation
O3 (8-hour) Nonattainment Nonattainment
O3 (1-hour) Attainmenta Nonattainment
CO Attainment Attainment
PM10 Unclassifiableb Nonattainment
PM2.5 Attainment Nonattainmentc
NO2 Attainment Attainment
SO2 Attainment Attainment
Lead Attainment Attainment
Sulfates (No federal standard) Attainment
Hydrogen sulfide (No federal standard) Unclassified
Visibility-reducing particles (No federal standard) Unclassified Vinyl chloride (No federal standard) No designation
Sources: SDAPCD 2022b
Definitions: attainment = meets the standards; nonattainment = does not meet the standards; unclassified or unclassifiable = insufficient data to classify
Notes: SDAB = San Diego; O3 = ozone; CO = carbon monoxide; PM10 = coarse particulate matter; PM2.5 = fine particulate matter; NO2 = nitrogen dioxide; SO2 = sulfur dioxide.
a The federal 1-hour standard of 0.12 parts per million (ppm) was in effect from 1979 through June 15, 2005. The revoked standard is referenced here because it was employed for such a long period and because this benchmark is addressed in SIPs. b At the time of designation, if the available data does not support a designation of attainment or nonattainment, the area is designated as unclassifiable.
c CARB has not reclassified the region to attainment yet due to (1) incomplete data, and (2) the use of non-California Approved Samplers (CAS). While data collected does meet the requirements for designation of attainment with federal PM2.5 standards, the data completeness requirements for state PM2.5 standards substantially exceed federal requirements and mandates, and have historically not been feasible for most air districts to adhere to given local resources. APCD has begun replacing most regional filter-based PM2.5 monitors as they reach the end of their useful life with continuous PM2.5 air monitors to ensure collected data meets stringent completeness requirements in the future. APCD anticipates these new monitors will be approved as "CAS" monitors once CARB review the list of approved monitors, which has not been updated since 2013.

Air Quality Monitoring Data
CARB, air districts, and other agencies monitor ambient air quality at approximately 250 air quality monitoring stations across the state. Local ambient air quality is monitored by SDAPCD. SDAPCD operates a network of ambient air monitoring stations throughout the County that measure ambient concentrations of pollutants and determine whether the ambient air quality meets the CAAQS and the NAAQS. The nearest SDAPCD-operated monitoring station is the El Cajon monitoring station located at 533 First Street, El Cajon. This site was used to show the background ambient air quality for Ozone, NO2 CO, SO2, PM10, and PM2.5. The most recent background ambient air quality data and number of days exceeding the ambient air quality standards from 2020 to 2022 are presented in Table 4.2-2.

Table 4.2-2. Local Ambient Air Quality Data
Averaging
Time Unit
Agency/
Method
Ambient
Air Quality
Standard
Measured Concentration
by Year Exceedances by Year
2020 2021 2022 2020 2021 2022
Ozone (O3) – El Cajon – First Street; Floyd Smith Drive Maximum
1-hour
concentration
ppm State 0.09 0.094 0.088 0.100 0 0 1

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Table 4.2-2. Local Ambient Air Quality Data
Averaging
Time Unit
Agency/
Method
Ambient
Air Quality
Standard
Measured Concentration
by Year Exceedances by Year
2020 2021 2022 2020 2021 2022
Maximum
8-hour
concentration
ppm State 0.070 0.083 0.077 0.088 14 3 2
Federal 0.070 0.083 0.076 0.088 14 3 2
Nitrogen Dioxide (NO2) – El Cajon – First Street; Floyd Smith Drive Maximum
1-hour
concentration
ppm State 0.18 0.044 0.038 0.037 0 0 0
Federal 0.100 0.044 0.038 0.037 0 0 0
Annual
concentration
ppm State 0.030 0.008 0.006 0.008 — — --
Federal 0.053 0.008 0.006 0.008 — — --
Carbon Monoxide (CO) – El Cajon – First Street; Floyd Smith Drive Maximum
1-hour
concentration
ppm State 20 1.5 1.2 1.4 0 0 0
Federal 35 1.5 1.2 1.4 0 0 0
Maximum
8-hour
concentration
ppm State 9.0 1.4 1.1 1.1 0 0 0
Federal 9 1.4 1.1 1.1 0 0 0
Sulfur Dioxide (SO2) – El Cajon – First Street; Floyd Smith Drive Maximum
1-hour
concentration
ppm Federal 0.075 0.0017 0.0016 0.0008 0 0 0
Maximum
24-hour
concentration
ppm Federal 0.14 0.0004 0.0003 0.003 0 0 0
Annual
concentration
ppm Federal 0.030 0.00009 0.00006 0.00006 0 0 0
Coarse Particulate Matter (PM10)a – El Cajon – First Street; Floyd Smith Drive Maximum
24-hour
concentration
g/m3 State 50 55 40 44 0.0 (0) 0.0 (0) 0.0 (0)
Federal 150 55 40 44 0.0 (0) 0.0 (0) 0.0 (0)
Annual
concentration
g/m3 State 20 23 ** 23 ** * — — —
Fine Particulate Matter (PM2.5)
a – El Cajon – First Street; Floyd Smith Drive
Maximum
24-hour
concentration
g/m3 Federal 35 38.2 30.2 26.4 2.2 0 0
Annual
concentration
g/m3 State 12 11.5 10.3 * 0.0 (0) 0.0 (0) *
Federal 12.0 10.3 9.7 9.4 0.0 (0) 0.0 (0) 0.0 (0)
Sources: CARB 2023; EPA 2023.

Notes: ppm = parts per million; — = not available; g/m3 = micrograms per cubic meter Data taken from CARB iADAM (CARB 2022c) and EPA AirData (EPA 2022) represent the highest concentrations experienced over a given year.

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Daily exceedances for particulate matter are estimated days because PM10 and PM2.5 are not monitored daily. All other criteria pollutants did not exceed federal or state standards during the years shown. There is no federal standard for 1-hour O3, annual PM10, or 24-hour SO2, nor is there a state 24-hour standard for PM2.5.

Camp Pendleton monitoring station is located at 21441 West B Street, Camp Pendleton, California.

El Cajon – First Street monitoring station is located at 533 First Street, El Cajon, California.

El Cajon – Floyd Smith Drive monitoring station is located at 10537 Floyd Smith Drive, El Cajon, California. a Measurements of PM10 and PM2.5 are usually collected every 6 days and every 1 to 3 days, respectively. Number of days exceeding the standards is a mathematical estimate of the number of days concentrations would have been greater than the level of the standard had each day been monitored. The numbers in parentheses are the measured number of samples that exceeded the standard.
* There was insufficient (or no) data available to determine the value. ** Most recent data for PM10 at monitor location for annual are years 2017 and 2018.

4.2.2 Relevant Plans, Policies, and Ordinances
Federal
Criteria Air Pollutants
The federal Clean Air Act (CAA), passed in 1970 and last amended in 1990, forms the basis for the national air pollution control effort. The United States Environmental Protection Agency (EPA) is responsible for implementing most aspects of the CAA, including the setting of National Ambient Air Quality Standards (NAAQS) for major air pollutants, hazardous air pollutant (HAP) standards, approval of state attainment plans, motor vehicle emission standards, stationary source emission standards and permits, acid rain control measures, stratospheric O3 protection, and enforcement provisions.

NAAQS are established by the EPA for “criteria pollutants” under the CAA, which are O3, CO, NO2, SO2, PM10, PM2.5, and lead. The NAAQS describe acceptable air quality conditions designed to protect the health and welfare of the citizens of the nation. The CAA requires the EPA to reassess the NAAQS at least every 5 years to determine whether adopted standards are adequate to protect public health based on current scientific evidence. States with areas that exceed the NAAQS must prepare a state implementation plan (SIP) that demonstrates how those areas will attain the standards within mandated time frames.

Hazardous Air Pollutants
The 1977 CAA Amendments required the EPA to identify national emission standards for hazardous air pollutants to protect the public health and welfare. HAPs include certain volatile organic chemicals, pesticides, herbicides, and radionuclides that present a tangible hazard, based on scientific studies of exposure to humans and other mammals. Under the 1990 CAA Amendments, which expanded the control program for HAPs, 189 substances and chemical families were identified as HAPs.

State
Criteria Pollutants
The California Clean Air Act was adopted in 1988 and establishes the state’s air quality goals, planning mechanisms, regulatory strategies, and standards of progress. Under the California Clean Air Act, the task of air quality management and regulation has been legislatively granted to CARB, with subsidiary responsibilities assigned to air quality management districts and air pollution control districts at the regional and county levels. CARB is responsible for ensuring implementation of the California Clean Air Act, responding to the CAA, and regulating

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emissions from motor vehicles and consumer products. Pursuant to the authority granted to it, CARB has established California Ambient Air Quality Standards (CAAQS), which are generally more restrictive than the NAAQS.

The NAAQS and CAAQS are presented in Table 4.2-3.

Table 4.2-3. Ambient Air Quality Standards
Pollutant Averaging Time
California Standardsa National Standardsb
Concentrationc Primaryc,d Secondaryc,e
O3 1 hour 0.09 ppm (180 g/m3) — Same as
primary
standardf
8 hours 0.070 ppm (137 g/m3) 0.070 ppm (137
g/m3)
f
NO2
g 1 hour 0.18 ppm (339 g/m3) 0.100 ppm (188
g/m3)
Same as
primary
standard Annual arithmetic
mean

0.030 ppm (57 g/m3) 0.053 ppm (100
g/m3)
CO 1 hour 20 ppm (23 mg/m3) 35 ppm (40 mg/m3) None
8 hours 9.0 ppm (10 mg/m3) 9 ppm (10 mg/m3)
SO2
h 1 hour 0.25 ppm (655 g/m3) 0.075 ppm (196
g/m3)
—
3 hours — — 0.5 ppm (1,300
g/m3)
24 hours 0.04 ppm (105 g/m3) 0.14 ppm (for
certain areas)g
—
Annual — 0.030 ppm (for
certain areas)g
—
PM10i 24 hours 50 g/m3 150 g/m3 Same as
primary
standard
Annual arithmetic
mean
20 g/m3 —
PM2.5i 24 hours — 35 g/m3 Same as
primary
standard
Annual arithmetic
mean
12 g/m3 12.0 g/m3 15.0 g/m3
Leadj, k 30-day average 1.5 g/m3 — —
Calendar quarter — 1.5 g/m3 (for
certain areas)k
Same as
primary
standard Rolling 3-month
average
— 0.15 g/m3
Hydrogen
sulfide
1 hour 0.03 ppm (42 µg/m3) — —
Vinyl
chloridej
24 hours 0.01 ppm (26 µg/m3) — —
Sulfates 24- hours 25 µg/m3 — —

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Table 4.2-3. Ambient Air Quality Standards
Pollutant Averaging Time
California Standardsa National Standardsb
Concentrationc Primaryc,d Secondaryc,e
Visibility
reducing
particles
8 hour (10:00 a.m.
to 6:00 p.m. PST)
Insufficient amount to produce
an extinction coefficient of

0.23 per kilometer due to the
number of particles when the
relative humidity is less than
70%
— —
Source: CARB 2016.

Notes: O3 = ozone; ppm = parts per million by volume; g/m3 = micrograms per cubic meter; NO2 = nitrogen dioxide; CO = carbon monoxide; mg/m3= milligrams per cubic meter; SO2 = sulfur dioxide; PM10 = particulate matter with an aerodynamic diameter less than or equal to 10 microns; PM2.5 = particulate matter with an aerodynamic diameter less than or equal to 2.5 microns. a California standards for O3, CO, SO2 (1-hour and 24-hour), NO2, suspended particulate matter (PM10, PM2.5), and visibility-reducing particles are values that are not to be exceeded. All others are not to be equaled or exceeded. CAAQS are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations. b National standards (other than O3, NO2, SO2, particulate matter, and those based on annual averages or annual arithmetic mean) are not to be exceeded more than once per year. The O3 standard is attained when the fourth highest 8-hour concentration measured at each site in a year, averaged over 3 years, is equal to or less than the standard. For PM10, the 24-hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 µg/m3 is equal to or less than 1. For PM2.5, the 24-hour standard is attained when 98% of the daily concentrations, averaged over 3 years, are equal to or less than the standard.
c Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based on a reference temperature of 25°Celsius (°C) and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas.
d National Primary Standards: The levels of air quality necessary, with an adequate margin of safety, to protect the public health. e National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.
f On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 to 0.070 ppm. g To attain the national 1-hour standard, the 3-year average of the annual 98th percentile of the 1-hour daily maximum concentrations at each site must not exceed 100 parts per billion (ppb). Note that the national 1-hour standard is in units of ppb. California standards are in units of ppm. To directly compare the national 1-hour standard to the California standards, the units can be converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 ppm. h On June 2, 2010, a new 1-hour SO2 standard was established, and the existing 24-hour and annual primary standards were revoked.

To attain the national 1-hour standard, the 3-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until 1 year after an area is designated for the 2010 standard, except that in areas designated nonattainment of the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved. i On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 g/m3 to 12.0 g/m3. The existing national 24-hour PM2.5 standards (primary and secondary) were retained at 35 g/m3, as was the annual secondary standard of 15 μg/m3.

The existing 24-hour PM10 standards (primary and secondary) of 150 g/m3 were also retained. The form of the annual primary and secondary standards is the annual mean averaged over 3 years. j CARB has identified lead and vinyl chloride as TACs with no threshold level of exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants. k The national standard for lead was revised on October 15, 2008, to a rolling 3-month average. The 1978 lead standard (1.5 μg/m3 as a quarterly average) remains in effect until 1 year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.

Sulfates. Salts of sulfuric acid. Sulfates are the fully oxidized form of sulfur, which typically occur in combination with metals or hydrogen ions. Sulfates are produced from reactions of SO2 in the atmosphere and can result in respiratory impairment, as well as reduced visibility. Sulfates occur as microscopic particles (aerosols) resulting from fossil fuel and biomass combustion. They increase the acidity of the atmosphere and form acid rain.

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

Hydrogen Sulfide. Hydrogen sulfide is a colorless and flammable gas that has a characteristic odor of rotten eggs.

Sources of hydrogen sulfide include geothermal power plants, petroleum refineries, sewers, and sewage treatment plants. Exposure to hydrogen sulfide can result in nuisance odors, as well as headaches and breathing difficulties at higher concentrations.

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

Toxic Air Contaminants
The state Air Toxics Program was established in 1983 under AB 1807 (Tanner). The California TAC list identifies more than 700 pollutants, of which carcinogenic and noncarcinogenic toxicity criteria have been established for a subset of these pollutants pursuant to the California Health and Safety Code. In accordance with AB 2728, the state list includes the (federal) HAPs. The Air Toxics “Hot Spots” Information and Assessment Act of 1987 (AB 2588) seeks to identify and evaluate risk from air toxics sources; however, AB 2588 does not regulate air toxics emissions.

TAC emissions from individual facilities are quantified and prioritized. “High-priority” facilities are required to perform a health risk assessment (HRA), and if specific thresholds are exceeded, are required to communicate the results to the public in the form of notices and public meetings.

In 2000, CARB approved a comprehensive Diesel Risk Reduction Plan to reduce diesel emissions from both new and existing diesel-fueled vehicles and engines. The regulation was anticipated to result in an 80% decrease in statewide diesel health risk in 2020 compared with the diesel risk in 2000. Additional regulations apply to new trucks and diesel fuel, including the On-Road Heavy Duty Diesel Vehicle (In-Use) Regulation, the On-Road Heavy Duty (New) Vehicle Program, the In-Use Off-Road Diesel Vehicle Regulation, and the New Off-Road CompressionIgnition (Diesel) Engines and Equipment program. All of these regulations and programs have timetables by which manufacturers must comply and existing operators must upgrade their diesel powered equipment. Several Airborne Toxic Control Measures that reduce diesel emissions including In-Use Off-Road Diesel-Fueled Fleets (13 CCR § 2449 et seq.) and In-Use On-Road Diesel-Fueled Vehicles (13 CCR § 2025).

California Health and Safety Code Section 41700
This section of the Health and Safety Code states that a person shall not discharge from any source whatsoever quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or that endanger the comfort, repose, health, or safety of any of those persons or the public, or that cause, or have a natural tendency to cause, injury or damage to business or property. This section also applies to sources of objectionable odors.

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Local
San Diego Air Pollution Control District
While CARB is responsible for the regulation of mobile emission sources within the state, local air quality management districts and air pollution control districts are responsible for enforcing standards and regulating stationary sources.

The Project site is located within the SDAB and is subject to the guidelines and regulations of SDAPCD.

In San Diego County, O3 and particulate matter are the pollutants of main concern since exceedances of CAAQS for those pollutants are experienced here in most years. For this reason, the SDAB has been designated as a nonattainment area for the state PM10, PM2.5, and O3 standards. The SDAB is also a federal O3 attainment (maintenance) area for 1997 8-hour O3 standard, a O3 nonattainment area for the 2008 8-hour O3 standard, and a CO maintenance area (western and central part of the SDAB only). The Project area is in the CO maintenance area.

San Diego Association of Governments
The San Diego Association of Governments (SANDAG) is the regional planning agency for the County and serves as a forum for regional issues relating to transportation, the economy, community development, and the environment.

SANDAG serves as the federally designated metropolitan planning organization for the County. With respect to air quality planning and other regional issues, SANDAG has prepared San Diego Forward: The Regional Plan (Regional Plan) for the San Diego region (SANDAG 2015). The Regional Plan combines the big-picture vision for how the San Diego region will grow over the next 35 years with an implementation program to help make that vision a reality.

The Regional Plan, which includes the Federally mandated Regional Transportation Plan (RTP) and state required Sustainable Communities Strategy (SCS), is built on an integrated set of public policies, strategies, and investments to maintain, manage, and improve the transportation system so that it meets the diverse needs of the San Diego region through 2050.

With respect to air quality, the Regional Plan sets the policy context in which SANDAG participates and responds to the SDAPCD ’s air quality plans and builds on plan processes that are designed to meet health-based criteria pollutant standards in several ways (SANDAG 2015). First, it complements air quality plans by providing guidance and incentives for public agencies to consider best practices that support the technology-based control measures in air quality plans. Second, the Regional Plan emphasizes the need for better coordination of land use and transportation planning, which heavily influence the emissions inventory from the transportation sectors of the economy. This also minimizes land use conflicts, such as residential development near freeways, industrial areas, or other sources of air pollution.

On February 26, 2021, SANDAG’s Board of Directors adopted the final 2021 Regional Transportation Improvement Program (RTIP). The 2021 RTIP covers 5 fiscal years (FY 2021 through FY 2025) and incrementally implements the SANDAG 2019 Federal Regional Transportation Plan. The 2021 RTIP is designed to implement the region’s overall strategy for providing mobility and improving the safety, condition, and efficiency of the transportation system while reducing transportation related air pollution. The 2021 RTIP incrementally implements San Diego Forward: The 2019 Federal Regional Transportation Plan, the long-range transportation plan for the San Diego region approved by the SANDAG Board of Directors on October 25, 2019.

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Federal Attainment Plans
In December 2016, the SDAPCD adopted an update to the Eight-Hour Ozone Attainment Plan for San Diego County (2008 O3 NAAQS). The 2016 Final Eight-Hour Ozone Attainment Plan for San Diego County indicates that local controls and state programs would allow the region to reach attainment of the federal 8-hour O3 standard (1997 O3 NAAQS) by 2018 (SDAPCD 2016b). In this plan, SDAPCD relies on the Regional Air Quality Strategy (RAQS) to demonstrate how the region will comply with the federal O3 standard. The RAQS details how the region will manage and reduce O3 precursors (NOx and VOCs) by identifying measures and regulations intended to reduce these pollutants. The control measures identified in the RAQS generally focus on stationary sources; however, the emissions inventories and projections in the RAQS address all potential sources, including those under the authority of CARB and EPA. Incentive programs for reduction of emissions from heavy-duty diesel vehicles, off-road equipment, and school buses are also established in the RAQS.

Currently, the County is designated as moderate nonattainment for the 2008 O3 NAAQS and maintenance for the 1997 O3 NAAQS. As documented in the 2016 Final Eight-Hour Ozone Attainment Plan for San Diego County, the County has a likely chance of obtaining attainment due to the transition to low emission cars, stricter new source review rules, and continuing the requirement of general conformity for military growth and the San Diego International Airport. SDAPCD will also continue emission control measures including ongoing implementation of existing regulations in ozone precursor reduction to stationary and area-wide sources, subsequent inspections of facilities and sources, and the adoption of laws requiring Best Available Retrofit Control Technology for control of emissions (SDAPCD 2016b).

State Attainment Plans
The SDAPCD and SANDAG are responsible for developing and implementing the clean air plan for attainment and maintenance of the ambient air quality standards in the SDAB. The RAQS for the SDAB was initially adopted in 1991 and is updated on a triennial basis, most recently in 2020 (SDAPCD 2020). Approved by the District Board on October 14, 2020, and the California Air Resources Board on November 19, 2020, the plan was submitted by CARB on January 8, 2021 for EPA's consideration as a revision to the California State Implementation Plan (SIP) for attaining the ozone standards. The RAQS outlines SDAPCD’s plans and control measures designed to attain the state air quality standards for O3. The RAQS relies on information from CARB and SANDAG, including mobile and area source emissions, as well as information regarding projected growth in the County and the cities in the County, to forecast future emissions and then determine from that the strategies necessary for the reduction of emissions through regulatory controls. CARB mobile source emission projections and SANDAG growth projections are based on population, vehicle trends, and land use plans developed by the County and the cities in the County as part of the development of their general plans (SANDAG 2017a, 2017b).

In January 2021, CARB submitted for EPA’s consideration the revised California SIP. On July 12, 2021, the San Diego 2020 SIP was found complete by EPA. Under the Clean Air Act, the EPA has twelve months from the completeness date to take a final action on the 2020 SIP. As discussed in the 2020 RAQS, the results of modeling and Weight of Evidence analyses provide persuasive support to a conclusion that the emission control measures defined in the plan are sufficient to continue reducing ozone concentrations throughout San Diego County to the level of the 2008 ozone NAAQS by the conclusion of the 2026 ozone season, and to the level of the 2015 ozone NAAQS by the conclusion of the 2032 ozone season.

In regard to particulate matter emissions-reduction efforts, in December 2005, the SDAPCD prepared a report titled “Measures to Reduce Particulate Matter in San Diego County” to address implementation of Senate Bill (SB) 656

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in the County (SB 656 required additional controls to reduce ambient concentrations of PM10 and PM2.5) (SDAPCD 2005). In the report, SDAPCD evaluated implementation of source-control measures that would reduce particulate matter emissions associated with residential wood combustion; various construction activities including earthmoving, demolition, and grading; bulk material storage and handling; carry-out and track-out removal and cleanup methods; inactive disturbed land; disturbed open areas; unpaved parking lots/staging areas; unpaved roads; and windblown dust (SDAPCD 2005).

SDAPCD Rules and Regulations
As stated previously, SDAPCD is responsible for planning, implementing, and enforcing federal and state ambient standards in the SDAB. The following rules and regulations apply to all sources in the jurisdiction of SDAPCD:
▪ SDAPCD Regulation IV: Prohibitions; Rule 50: Visible Emissions. Prohibits any activity causing air contaminant emissions darker than 20% opacity for more than an aggregate of 3 minutes in any consecutive 60-minute time period. In addition, Rule 50 prohibits any diesel pile-driving hammer activity causing air contaminant emissions for a period or periods aggregating more than 4 minutes during the driving of a single pile (SDAPCD 1997).
▪ SDAPCD Regulation IV: Prohibitions; Rule 51: Nuisance. Prohibits the discharge, from any source, of such quantities of air contaminants or other materials that cause or have a tendency to cause injury, detriment, nuisance, annoyance to people and/or the public, or damage to any business or property (SDAPCD 1976). ▪ SDAPCD Regulation IV: Prohibitions; Rule 55: Fugitive Dust. Regulates fugitive dust emissions from any commercial construction or demolition activity capable of generating fugitive dust emissions, including active operations, open storage piles, and inactive disturbed areas, as well as track-out and carry-out onto paved roads beyond a project site (SDAPCD 2009b).
▪ SDAPCD Regulation IV: Prohibitions; Rule 67.0.1: Architectural Coatings. Requires manufacturers, distributors, and end users of architectural and industrial maintenance coatings to reduce VOC emissions from the use of these coatings, primarily by placing limits on the VOC content of various coating categories (SDAPCD 2015).

Santee General Plan
The City of Santee General Plan serves as a long-term policy guide for physical, economic, and environmental growth. It is a statement of the community's vision for ultimate growth. State law requires that every city prepare and adopt a comprehensive long-range plan to serve as a guide for the development of the community. City actions, such as those relating to land use allocations, annexations, zoning, subdivision and design review, redevelopment and capital improvements must be consistent with the General Plan. Applicable General Plan objectives and policies related to improving air quality include the following:

Mobility Element
Streets and Freeway System Objective 2.0 Transportation network, consisting of local roads, collectors, arterials, freeways and transit services, in a manner that promotes the health and mobility of Santee residents and that meets future circulation needs, provides access to all sectors of the City, and supports established and planned land uses.

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Policy 2.9 The City should work with the region to develop traffic and congestion management programs to improve commute times and improve air quality.

Transportation Demand Management Objective 9.0 Increased use of alternative modes of travel to reduce peak hour vehicular trips, save energy, and improve air quality.

Policy 9.1 The City shall encourage and provide for Ride Sharing, Park ‘n Ride, and other similar commuter programs that eliminate vehicles from freeways and arterials.

Policy 9.2 The City should encourage businesses to provide flexible work schedules for employees.

Policy 9.3 The City should encourage employers to offer shared commute programs and/or incentives for employees to use transit.

Policy 9.4 The City should encourage the use of alternative transportation modes, such as walking, cycling and public transit. The City should maintain and implement the policies and recommendations of the Bicycle Master Plan and Safe Routes to School Plan to improve safe bicycle and pedestrian access to major destinations.

Policy 9.5 The City should improve safety of walking and biking environment around schools to reduce school-related vehicle trips.

City of Santee Active Santee Plan, January 2021
Objective 8.0 Increased use of alternative modes of travel to schools to reduce peak hour vehicular trips, save energy, and improve air quality around schools.

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

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

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

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

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

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sustainability goals and policies that encourage sustainable development and aim to conserve and reduce the consumption of resources, such as energy and water, among others.

4.2.3 Thresholds of Significance
The significance criteria used to evaluate the Project impacts to air quality are based on CEQA Guidelines Appendix G.

According to CEQA Guidelines Appendix G, a significant impact related to air quality would occur if the Project would:

Conflict with or obstruct implementation of the applicable air quality plan.

Result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is non-attainment under an applicable federal or state ambient air quality standard.

Expose sensitive receptors to substantial pollutant concentrations.

Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

As part of its air quality permitting process, the SDAPCD has established thresholds in Rule 20.2 requiring the preparation of Air Quality Impact Assessments for permitted stationary sources. The SDAPCD sets forth quantitative emission thresholds below which a stationary source would not have a significant impact on ambient air quality.

Project-related air quality impacts estimated in this environmental analysis would be considered significant if any of the applicable significance thresholds presented in Table 4.2-4 are exceeded.

For CEQA purposes, these screening criteria can be used as numeric methods to demonstrate that the Project’s total emissions would or would not result in a significant impact to air quality.

Table 4.2-4. SDAPCD Air Quality Significance Thresholds Construction Emissions
Pollutant Total Emissions (Pounds per Day)
Coarse particulate matter (PM10) 100
Fine particulate matter (PM2.5) 55
Oxides of nitrogen (NOx) 250
Sulfur oxides (SOx) 250
Carbon monoxide (CO) 550
Volatile organic compounds (VOCs) 75*
Operational Emissions
Pollutant
Total Emissions
Pounds per
Hour
Pounds per
Day Tons per Year
Coarse particulate matter (PM10) — 100 15
Fine particulate matter (PM2.5) — 55 10
Oxides of nitrogen (NOx) 25 250 40
Sulfur oxides (SOx) 25 250 40
Carbon monoxide (CO) 100 550 100
Lead and lead compounds — 3.2 0.6
Volatile organic compounds (VOCs) — 75* 13.7
Source: SDAPCD 2016a.

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Notes: SDAPCD = San Diego Air Pollution Control District. * VOC threshold based on the threshold of significance for VOCs from the South Coast Air Quality Management District (SCAQMD) for the Coachella Valley as stated in the San Diego County Guidelines for Determining Significance.

The thresholds listed in Table 4.2-4 represent screening-level thresholds that can be used to evaluate whether Project-related emissions would cause a significant impact on air quality. Emissions below the screening-level thresholds would not cause a significant impact. In the event that emissions exceed these thresholds, modeling would be required to demonstrate that the Project’s total air quality impacts result in ground-level concentrations that are below the CAAQS and NAAQS, including appropriate background levels. For non-attainment pollutants, if emissions exceed the thresholds shown in Table 4.2-4, the Project could have the potential to result in a cumulatively considerable net increase in these pollutants and thus could have a significant impact on the ambient air quality.

SDAPCD Rule 51 (Public Nuisance) prohibits emission of any material that causes nuisance to a considerable number of persons or endangers the comfort, health, or safety of any person (SDAPCD 1976). A project that proposes a use that would produce objectionable odors would be deemed to have a significant odor impact if it would affect a considerable number of off-site receptors.

Methodology
Construction Emissions
Emissions from the construction phase of Project components were estimated using the California Emissions Estimator Model (CalEEMod) Version 2022.1.1.19. Per preliminary project details, it is assumed that construction of the Project would begin in June 20243 and would last approximately 15 months.

Table 4.2-5 provides the construction timeline, potential phasing, construction equipment mix, and vehicle trips assumed for estimating Project-generated construction emissions. The construction schedule has been developed based on available information provided by the Project applicant, typical construction practices, and CalEEMod default assumptions. Construction phasing is intended to represent a schedule of anticipated activities for use in estimating potential Project-generated construction emissions.

Table 4.2-5. Construction Scenario Assumptions
Construction
Phase
(Duration)
Vehicle Trips Equipment
Average
Daily
Worker
Trips
Average
Daily
Vendor
Truck
Trips
Total
Haul
Truck
Trips Equipment Type Quantity
Usage
Hours
Demolition 16 4 184 Concrete/Industrial Saws 1 8
Excavators 3 8
Rubber Tired Dozers 2 8
3 At the time this Air Quality and Greenhouse Gas modelling was initiated, the analysis assumed a construction start date of July 2023. While past, it represented the earliest date construction could have been initiated. It is assumed that the earliest start date for construction represents the worst-case scenario for criteria air pollutant and GHG emissions because equipment and vehicle emission factors for later years would be slightly less due to more stringent standards for in-use off-road equipment and heavyduty trucks, as well as fleet turnover replacing older equipment and vehicles in later years. Therefore, the conclusions of the analysis are more conservative than analyses prepared for later years.

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Table 4.2-5. Construction Scenario Assumptions
Construction
Phase
(Duration)
Vehicle Trips Equipment
Average
Daily
Worker
Trips
Average
Daily
Vendor
Truck
Trips
Total
Haul
Truck
Trips Equipment Type Quantity
Usage
Hours
Asphalt Crusher (Other
Construction Equipment)
1 8
Grading 20 4 0 Excavators 2 8
Graders 1 8
Rubber Tired Dozers 1 8
Scrapers 2 8
Tractors/Loaders/
Backhoes
2 8
Building
Construction
126 50 0 Cranes 1 7
Forklifts 3 8
Generator Sets 1 8
Tractors/Loaders/
Backhoes
3 7
Welders 1 8
Paving 16 0 0 Pavers 2 8
Paving Equipment 2 8
Rollers 2 8
Architectural Coating 26 0 0 Air Compressors 1 6
Note: See Appendix B of this EIR for additional details.

The equipment mix assumptions were based on CalEEMod default assumptions based on proposed land use, and is meant to represent a reasonably conservative estimate of construction activity. During the demolition phase of construction, asphalt crushing was modeled as other construction equipment for engine emissions and fugitive particulate emissions were estimated through EPA emission factors outside of CalEEMod and provide in the Appendix.

For the analysis, it is generally assumed that heavy construction equipment would be operating at the site for approximately 8 hours per day, 5 days per week. Default assumptions provided in CalEEMod were used to determine worker trips and vendor truck trips for each potential construction phase. The default CalEEMod trip distance for construction vehicles was assumed, which was a one-way distance of 11.97 miles for worker trips, 7.63 miles for vendor truck trips, and 20 miles for haul truck trips.

Implementation of the Project would generate criteria air pollutant emissions from entrained dust, off-road equipment, vehicle emissions, architectural coatings, and asphalt pavement application. Based on project specific information, grading materials would be balanced onsite. Entrained dust results from the exposure of earth surfaces to wind from the direct disturbance and movement of soil, resulting in PM10 and PM2.5 emissions. Construction of Project components would be subject to SDAPCD Rule 55 – Fugitive Dust Control. Compliance with Rule 55 would limit fugitive dust (PM10 and PM2.5) that may be generated during grading and construction activities. Standard construction practices that would be employed to reduce fugitive dust emissions include watering of the active sites two times per day, depending on weather conditions.

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Internal combustion engines used by construction equipment, vendor trucks (i.e., delivery trucks), haul trucks, and worker vehicles would result in emissions of VOCs, NOx, CO, PM10, and PM2.5. The application of architectural coatings, such as exterior application/interior paint and other finishes, and application of asphalt pavement would also produce VOC emissions; however, the contractor is required to procure architectural coatings from a supplier in compliance with the requirements of SDAPCD Rule 67.0.1 for Architectural Coatings.

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

Operational Emissions
Emissions from the operational phase of the Project were estimated using CalEEMod for operational year 2025.

Area Sources
CalEEMod was used to estimate operational emissions from area sources, including emissions from consumer product use, architectural coatings, and landscape maintenance equipment. Emissions associated with natural gas usage in space heating and water heating are calculated in the building energy use module of CalEEMod, as described in the following text.

Consumer products are chemically formulated products used by household and institutional consumers, including detergents; cleaning compounds; polishes; floor finishes; cosmetics; personal care products; home, lawn, and garden products; disinfectants; sanitizers; aerosol paints; and automotive specialty products. Other paint products, furniture coatings, or architectural coatings are not considered consumer products (CAPCOA 2021). Consumer product VOC emissions were estimated in CalEEMod based on the floor area of buildings and default factor of pounds of VOC per building square foot per day. The CalEEMod default values for consumer products were assumed.

VOC off-gassing emissions result from evaporation of solvents contained in surface coatings, such as in paints and primers used during building maintenance. CalEEMod calculates the VOC evaporative emissions from the application of surface coatings based on the VOC emission factor, the building square footage, the assumed fraction of surface area, and the reapplication rate. The VOC emissions factor is based on the VOC content of the surface coatings, and SDAPCD Rule 67.0.1, Architectural Coatings, governs the VOC content for interior and exterior coatings. CalEEMod default values were assumed, including the surface area to be painted, the VOC content of architectural coatings, and the reapplication rate of 10% of area per year.

Landscape maintenance includes fuel combustion emissions from equipment such as lawn mowers, rototillers, shredders/grinders, blowers, trimmers, chainsaws, and hedge trimmers. The emissions associated with landscape equipment use were estimated based on CalEEMod default values for emission factors (grams per square foot of building space per day) and number of summer days (when landscape maintenance would generally be performed) and winter days.

Mobile Sources
The Project would generate criteria pollutantemissions from mobile sources (vehicular traffic) as a result of the employee passenger vehicles (workers) and truck traffic associated with the operation of the warehouse.

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Emissions from the mobile sources during operation of the Project were estimated in CalEEMod. The maximum daily trip rates, taken from the Project transportation analysis, were 1,011 primary trips per day, which were assumed 7 days per week. The passenger vehicle trip lengths were assumed to be CalEEMod default trip length of 11 miles for commercial-work trips (i.e., trips made by someone who is employed by the warehouse land use) and assumed to be 100% of primary trips. The light-duty, medium-heavy-duty, and heavy-duty truck trip lengths were based on the 40 miles and assumed to be 100% of primary trips. Vehicle emissions occur during startup, operation (running), and idling, as well as from evaporative losses when the engines are resting. The emissions factors for trucks and passenger vehicles were determined using CalEEMod.

To identify an appropriate trip length assumption for heavy-duty truck trips, a project-specific EMFAC-based estimate was performed. EMFAC data and the distance to the Otay Mesa Port of Entry was examined. EMFAC data was queried for San Diego County for operational year 2025 for light-heavy duty (LHDT1 and LHDT2), medium heavy duty (MHDT), and heavy-heavy duty trucks (HHDT) for total vehicle miles traveled (VMT) and number of vehicle trips.

Based on the EMFAC data it is estimated that MHDTs average 3.6 miles per trip and HHDTs average 8.21 miles per trip in San Diego County. LHDT1 and LHDT2s have a shorter EMFAC trip distance compared to MHDT. Therefore, as a conservative assumption, LHDT1 and LHDT2 were assumed to have the same trip distance as MHDTs. The estimated trip distance from the Otay Mesa Port of Entry to the Project was estimated to be 37 miles. Based on the EIR’s transportation analysis, HHDT make up 62.6% of the total truck trips for the Project and LHDT1, LHDT2, and MHDTs make up 37.4% of truck trips. Conservatively assuming all HHDTs originate from the Otay Mesa Port of Entry, then 50% of HHDT truck arrival trips are assumed to be from a distance of 37 miles. The other 50% making up the HHDT departure from the Project are assumed to have trip distance equal to the average EMFAC San Diego County trip distance of 8.21 miles. To determine an average total truck distance for use in CalEEMod, HHDT trips were averaged with the other 37.4% of the trucks (and LHDT1, LHDT2, and MHDTs) to determine an overall weighted average truck trip distance equal to 32 miles. See Table 4.2-6 for calculation details.

Table 4.2-6. Operational Truck Trip Distance
Vehicle
Percent of
Trucks Trips
(%)1
EMFAC Data Trip Distance
EMFAC Truck
Classification County-wide VMT
County-wide
Vehicle Trips VMT per Trip
2-4 Axle
Trucks
(Arriving and
Departing)

37.4 LHDT1, LHDT2,
and MHDT
755,3392 209,6902 3.60
5+ Axle
Trucks
(Arriving from
Port)

31.3 (50% of
total HHDT
Trips4)
HHDT N/A N/A 373
5+ Axle
Trucks
(Departing)

31.3 (50% of
total HHDT
Trips4)
HHDT 1,900,421 231,587 8,21
Weighted Average (All Truck Trips) 14.74
Notes:
1 Based on project traffic impact analysis, Appendix L of this EIR. 2 LHDT1, LHDT2, and MHDT conservatively based on EMFAC VMT and Trip data for MHDT. 3 Based on the distance from the project site to the Otay Mesa Port of Entry. 4 Percent of truck trips represents arrival and departure trips, therefore 50% of trips (arrival) conservatively assumed to originate at the Otay Mesa Port of Entry. 50% of trips assumed to depart the project facility and estimated truck trip distance is based on EMFAC county-wide average HHDT truck VMT per trip.

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Project truck idling would be limited to 5 minutes in accordance with CARB’s adopted Airborne Toxic Control Measure; however, for HRA modeling purposes, it was conservatively assumed that the trucks would idle for a total of 15 minutes: 5 minutes at the entrance, 5 minutes at the loading dock, and 5 minutes at the exit of the Project site.

Energy Source Emissions
As represented in CalEEMod, energy sources include emissions associated with building electricity and natural gas usage. Electricity use would contribute indirectly to criteria air pollutant emissions; however, the emissions from electricity use are only quantified for greenhouse gas emissions in CalEEMod, since criteria pollutant emissions would occur at the site of power plants, which are not on the Project site. However, natural gas combustion would occur at the Project site itself, in association with equipment that uses natural gas. The emissions associated with natural gas use were calculated using CalEEMod default parameters, which assume compliance with the 2019 Title 24 Building Energy Efficiency Standards and represents a conservative analysis compared to the 2022 standards.

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

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

Construction Health Risk Analysis
An HRA was performed to assess the impact of construction on sensitive receptors proximate to the Project site.

This report includes an HRA associated with emissions from construction of the proposed Project based on the methodologies prescribed in the Office of Environmental Health Hazard Assessment (OEHHA) document, Air Toxics Hot Spots Program Risk Assessment Guidelines – Guidance Manual for Preparation of Health Risk Assessments (OEHHA Guidelines) (OEHHA 2015). To implement the OEHHA Guidelines based on proposed project information, the SDAPCD has developed a three-tiered approach where each successive tier is progressively more refined, with fewer conservative assumptions. The SDAPCD document, Supplemental Guidelines for Submission of Air Toxics “Hot Spots” Program Health Risk Assessments (SDAPCD 2022a), provides guidance with which to perform HRAs within the SDAB.

Health effects from carcinogenic air toxics are usually described in terms of cancer risk. The SDAPCD recommends a carcinogenic (cancer) risk threshold of 10 in one million. Additionally, some TACs increase non-cancer health risk due to long-term (chronic) exposures. The Chronic Hazard Index is the sum of the individual substance chronic hazard indices for all TACs affecting the same target organ system. The SDAPCD recommends a Chronic Hazard Index significance threshold of one (project increment). The exhaust from diesel engines is a complex mixture of gases, vapors, and particles, many of which are known human carcinogens. DPM has established cancer risk factors and relative exposure values for long-term chronic health hazard impacts. No short-term, acute relative exposure level has been established for DPM; therefore, acute impacts of DPM are not addressed in this

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assessment. The HRA for the Project evaluated the risk to existing off-site residents from diesel emissions from exhaust from on-site construction equipment and diesel haul and vendor trucks.

The dispersion modeling of DPM was performed using the American Meteorological Society/EPA Regulatory Model (AERMOD), which is the model SDAPCD requires for atmospheric dispersion of emissions. AERMOD is a steadystate Gaussian plume model that incorporates air dispersion based on planetary boundary layer turbulence structure and scaling concepts, including treatment of surface and elevated sources, building downwash, and simple and complex terrain (EPA 2021). For the Project, AERMOD was run with all sources emitting unit emissions (one gram per second) to obtain the “Χ/Q” values. Χ/Q is a dispersion factor that is the average effluent concentration normalized by source strength and is used as a way to simplify the representation of emissions from many sources. The Χ/Q values of ground-level concentrations were determined for construction emissions using AERMOD and the maximum concentrations determined for the one-hour and period-averaging periods. Principal parameters of this modeling are presented in Table 4.2-7.

Table 4.2-7. AERMOD Principal Parameters
Parameter Details
Meteorological Data The latest three-year meteorological data (2019–2021) for the Lexington Elementary School Station were obtained from SDAPCD as the recommended meteorological station and input to AERMOD.

Terrain
Characteristics
The elevation of the modeled site is about 100 meters above sea level. Digital elevation model files were imported into AERMOD so that complex terrain features were evaluated as appropriate.

Elevation Data Digital elevation data were imported into AERMOD, and elevations were assigned to the emission sources and receptors. Digital elevation data were obtained through AERMOD View in the U.S. Geological Survey’s National Elevation Dataset format with a 10-meter resolution.

Emission Sources
and Release
Parameters
Air dispersion modeling of DPM from construction equipment was conducted using emissions estimated using CalEEMod, assuming emissions would occur eight hours per day, five days per week. Vendor and hauling trips were modified to account only for emissions occurring within 1,000 ft of the Project site. The Project area was modeled as a series of adjacent line-volume sources.

Source Release
Characterizations
The source release height was assumed to be 3.4 meters with plume height and width of 6.8 and 8.6 meters per volume source.

Notes: AERMOD = American Meteorological Society/EPA Regulatory Model; SDAPCD = San Diego Air Pollution Control District; DPM = diesel particulate matter; CalEEMod = California Emissions Estimator Model.

See Appendix B of this EIR for additional information.

Dispersion model plot files from AERMOD were then imported into CARB’s Hotspots Analysis Reporting Program (HARP) Version 2 (Version 22118) to determine health risk, which requires peak one-hour emission rates and annual emission rates for all pollutants for each modeling source. For the residential health risk, the HRA assumes exposure would start in the third trimester of pregnancy for a duration of 15 months.

Operational Health Risk Assessment
CARB’s Air Quality and Land Use Handbook: A Community Health Perspective encourages consideration of the health impacts of distribution centers that accommodate more than 100 trucks per day on sensitive receptors sited within 1,000 feet from the source in the land use decision-making process (CARB 2005). For the operational health risk, the operation year 2025 was assumed consistent with completion of Project construction. Emissions from the operation of the Project include truck trips, and truck idling emissions and emissions from the routing maintenance

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of the onsite emergency fire-water pump engine. For risk assessment purposes, PM10 in diesel exhaust is considered DPM, originating mainly from trucks traveling on site and off site and truck idling located at the loading docks. Truck travel and idling emission rates were obtained from CARB’s EMFAC2021. Emission factors representing the vehicle mix and emissions for 2025 were used to estimate emissions associated with operation of the Project. Truck idling would be limited to 5 minutes in accordance with CARB’s adopted Airborne Toxic Control Measure; however, truck idling was conservatively assumed to idle for 15 minutes.4 Therefore, the analysis conservatively overestimates DPM emissions from idling. All deliveries would occur Monday through Sunday.

Conservatively, a 2025 EMFAC2021 run was conducted and a constant 2025 emission factor data set was used for the entire duration of the analysis (i.e., 30 years). Use of the 2025 emission factors would overstate potential impacts since this approach does not include reductions in emissions due to fleet turnover or cleaner technology with lower emissions. The truck travel DPM emissions were calculated by applying the exhaust PM10 emission factor from EMFAC2021 and the total truck trip number over the length of the distance traveled. In addition, the on-site truck idling exhaust emissions were calculated by applying the idle exhaust PM10 emission factor from EMFAC2021 and total truck trip over the total idling time (i.e., 15 minutes).

The dispersion modeling was performed to estimate emissions at proximate receptors using AERMOD (Version

13.0.0). The truck traffic was modeled as a line of adjacent volume sources with a trip distribution consistent with the traffic analysis including 90 percent (%) truck trips to and from Highway 52 to the Project site via Highway 67 and 10% of truck trips traveling to and from north of the Project site via Highway 67. Truck idling was modeled as line volume sources.

As previously described, health effects from carcinogenic air toxics are usually described in terms of cancer risk.

The SDAPCD recommends a carcinogenic (cancer) risk threshold of 10 in one million. Some TACs increase noncancer health risk due to long-term (chronic) exposures. A hazard index less than one (1.0) means that adverse health effects are not expected. Within this analysis, noncarcinogenic exposures of less than 1.0 are considered less than significant. The exhaust from diesel engines is a complex mixture of gases, vapors, and particles, many of which are known human carcinogens. DPM has established cancer risk factors and relative exposure values for long-term chronic health hazard impacts. No short-term, acute relative exposure values are established and regulated and are therefore not addressed in this assessment.

Dudek evaluated the Project’s potential cancer and noncancer health impacts using exposure periods appropriate to evaluate long-term emission increases (third trimester of pregnancy to 30 years). Emissions dispersion of DPM was modeled using AERMOD, then cancer risk and noncancer health impacts subsequently using the CARB HARP2 (ADMRT, Version 22118). The health risk results were then compared to SDAPCD thresholds to assess Project significance. Principal parameters of this modeling are presented in Table 4.2-8.

Table 4.2-8. Operational Health Risk Assessment American Meteorological Society/U.S. Environmental Protection Agency Regulatory Model Operational Principal Parameters
Parameter Details
Meteorological
Data
The latest three-year meteorological data (2019–2021) for the Lexington Elementary School Station were obtained from SDAPCD as the recommended meteorological station and input to AERMOD.
4 Although the Project is required to comply with CARB’s idling limit of 5 minutes, on-site idling emissions was estimated for 15 minutes of truck idling, which would take into account on-site idling while the trucks are waiting to pull up to the loading dock, idling at the loading dock, and idling during check-in and check-out.

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Table 4.2-8. Operational Health Risk Assessment American Meteorological Society/U.S. Environmental Protection Agency Regulatory Model Operational Principal Parameters
Parameter Details
Terrain
Characteristics
The elevation of the modeled site is about 100 meters above sea level. Digital elevation model files were imported into AERMOD so that complex terrain features were evaluated as appropriate. Digital elevation data were imported into AERMOD, and elevations were assigned to the emission sources and receptors. Digital elevation data were obtained through AERMOD View in the U.S. Geological Survey’s National Elevation Dataset format with a 10-meter resolution.

Emission Sources
and Release
Parameters
Air dispersion modeling of off-site and on-site truck travel and were conducted using emissions generated using EMFAC2021. Truck idling equipment emissions were estimated using EMFAC2021.

Source Release
Characterizations
Off-site and on-site truck travel were modeled as a line of adjacent volume sources, with a release height of 3.4 meters, a plume height of 6.8 meters, and a plume width of 13.4 meters. The truck idling emissions were modeled as a line of adjacent volume sources with a plume height of 8 meters, plume width of 8.6 meters, and release height of 4 meters.

Emergency Fire-Water Pump Engine was modeled as a point source exiting the warehouse roof, with stack height of 55 feet and stack diameter of 8 inches.

Source: See Appendix B of this EIR.

Note: AERMOD = American Meteorological Society/Environmental Protection Agency Regulatory Model Combined Construction and Operational Health Risk Assessment While the SDAPCD does not specifically recommend a combined construction and operational HRA, the analysis is provided for informational purposes. The combined HRA analysis adds each common receptor impacts of construction and operation together to form a combined impact. The operational health risk analysis begins after construction HRA at approximately 15 months and concludes at a combined 30 years.

4.2.4 Impacts Analysis
A. Would the Project conflict with or obstruct implementation of the applicable air quality plan? Less-than-Significant Impact. As stated in Section 4.2.2, Local, SDAPCD and SANDAG are responsible for developing and implementing the clean air plans for attainment and maintenance of the NAAQS and CAAQS in the SDAB; specifically, the SIP and RAQS.5 The federal O3 maintenance plan, which is part of the SIP, was adopted in 2016. The SIP includes a demonstration that current strategies and tactics will maintain acceptable air quality in the SDAB based on the NAAQS. The RAQS was initially adopted in 1991 and is updated every 3 years. The RAQS outlines SDAPCD’s plans and control measures designed to attain the CAAQS for O3. The SIP and RAQS rely on information from CARB and SANDAG, including mobile and area source emissions, as well as information regarding projected growth in San Diego County and the cities in the County, to project future emissions and then determine from that the strategies necessary for the reduction of emissions through regulatory controls. CARB mobile source emission projections and SANDAG growth projections are based on population, vehicle trends, and land use plans developed by San Diego County and the cities in the County as part of the development of their general plans. 5 For the purpose of this discussion, the relevant federal air quality plan is the O3 maintenance plan (SDAPCD 2016b). The RAQS is the applicable plan for purposes of state air quality planning. Both plans reflect growth projections in the SDAB.

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The most recent update, the 2022 Regional Air Quality Strategy, was finalized in 2023. The 2022 RAQS contains strategies to continue directly reducing emissions of ozone precursors in San Diego County. As a co-benefit of these strategies, the 2022 RAQS is assisting in the reduction of particulate matter and greenhouse gases. Consistent with the District’s recent reorganization pursuant to Assembly Bill (AB) 423 (Gloria, 2019), the 2022 RAQS also proposes to expand the District’s involvement as a regional agency within our regulatory authority, by including commitments to support research and innovation opportunities, developing new partnerships with public and private entities, convening more opportunities for engagement and education with stakeholders, and integrating environmental justice and equity into all District actions.

If a project that proposes development that is greater than that anticipated in the local plan and SANDAG’s growth projections, the project might be in conflict with the SIP and RAQS and may contribute to a potentially significant cumulative impact on air quality. The City of Santee General Plan identifies the site as Light Industrial. The existing land use designation and zoning allows for a wide range of industrial uses, including warehouse, storage and distribution facilities. The Project is consistent with the underlying land use and zoning for the Project.

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 increased development beyond those contemplated by SANDAG. Because the proposed land uses and associated vehicle trips are anticipated in local air quality plans, the Project would be consistent at a regional level with the underlying growth forecasts in the RAQS. Accordingly, the Project would not conflict with and would not obstruct implementation of applicable local and regional air quality plans; impacts would be less than significant.

B. Would the Project result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is non-attainment under an applicable federal or state ambient air quality standard? Air pollution is largely a cumulative impact. The nonattainment status of regional pollutants is a result of past and present development, and SDAPCD develops and implements plans for future attainment of the NAAQS and CAAQS.

Based on these considerations, project-level thresholds of significance for criteria pollutants are relevant in the determination of whether the project’s individual emissions would have a cumulatively significant impact on air quality.

Construction
Less-than-Significant Impact. Construction of the Project would result in the temporary addition of pollutants to the local airshed caused by on-site sources (i.e., off-road construction equipment, soil disturbance, and VOC offgassing) and off-site sources (vendor and haul truck trips, and worker vehicle trips). Construction emissions can vary substantially day to day, depending on the level of activity, the specific type of operation, and for dust, the prevailing weather conditions.

Criteria air pollutant emissions associated with construction activities were quantified using CalEEMod Default values provided by the program were used where detailed Project information was not available. A detailed description of the construction schedule—including information regarding phasing, equipment used during each phase, haul trucks, vendor trucks, and worker vehicles—is included in Section 4.2.3, Methodology, above.

Development of the Project would generate air pollutant emissions from entrained dust, off-road equipment, vehicle emissions, asphalt pavement application, and architectural coatings. Fugitive dust would be limited through compliance with SDAPCD Rule 55, which requires the restriction of visible emissions of fugitive dust beyond the

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property line through watering exposed areas of the Project site at least 2 times per day and limiting vehicle travel to ten miles per hour on unpaved roads.

Table 4.2-9 shows the estimated maximum unmitigated daily construction emissions associated with the conceptual construction phases of the Project. Complete details of the emissions calculations are provided in Appendix A, Air Quality and Greenhouse Gas Emissions CalEEMod Output Files, of Appendix B to this Draft EIR.

Table 4.2-9. Estimated Maximum Daily Construction Criteria Air Pollutant Emissions Construction Year
VOC NOx CO SOx PM10 PM2.5
Pounds per Day
2024 1.26 31.60 36.40 0.12 16.35 3.24
2025 58.80 11.40 21.60 0.03 1.52 0.46
Maximum 58.80 31.60 36.40 0.12 16.35 3.24
SDAPCD threshold 75 250 550 250 100 55
Threshold exceeded? No No No No No No
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse particulate matter; PM2.5 = fine particulate matter; SDAPCD = San Diego Air Pollution Control District.

See Appendix B of this EIR for complete results.

The values shown are the maximum summer or winter daily emissions results from CalEEMod.

As shown in Table 4.2-9, daily construction emissions for the Project would not exceed SDAPCD’s significance thresholds for any criteria air pollutant. Therefore, the Project would have a less than significant impact related to emissions of criteria air pollutant emissions during construction.

Operations
Less-than-Significant Impact. Operation of the Project would generate VOC, NOx, CO, SOx, PM10, and PM2.5 emissions from mobile sources (vehicle trips), cargo handling equipment, area sources (consumer products, landscape maintenance equipment), routine maintenance of the emergency fire-water pump engine and energy sources. As discussed in Section 4.2.3, Methodology, pollutant emissions associated with long-term operations were quantified using CalEEMod and include warehouse land use. Future tenants/users are not yet known, nevertheless, the SDAPCD has the air permitting authority for any stationary sources that may be identified by future tenants. The Project includes an onsite fire-water pump engine and associated emissions were estimated with CalEEMod. Project-generated mobile source emissions were estimated in CalEEMod based on project-specific trip rates. CalEEMod default values were used to estimate emissions from the Project area and energy sources. The Project includes project design features (PDFs) (see Section 3.3.3 of this Draft EIR) that require the cargo handling equipment including forklifts (forklifts and pallet jacks) and yard tractors for facility operation to be Tier 4 Interim engines or better.

Table 4.2-10 presents the unmitigated maximum daily emissions associated with the operation of the Project in 2025 after all phases of construction have been completed. Complete details of the emissions calculations are provided in Appendix A, Air Quality and Greenhouse Gas Emissions CalEEMod Output Files, of Appendix B, Air Quality and Greenhouse Gas Emissions Technical Report, of this EIR. Emissions represent maximum of summer and winter for each source regardless of season. “Summer” emissions are representative of the conditions that may occur during the O3 season (May 1 to October 31), and “winter” emissions are representative of the conditions that may occur during the balance of the year (November 1 to April 30).

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Table 4.2-10. Estimated Maximum Daily Operational Criteria Air Pollutant Emissions Source
VOC NOx CO SOx PM10 PM2.5
Pounds per Day
Area 8.99 0.11 13.1 <0.005 0.02 0.02
Energy 0.07 1.18 0.99 0.01 0.09 0.09
Mobile 2.25 18.0 25.90 0.17 8.58 2.38
Stationary (Fire-water pump
engine)

0.82 2.29 2.09 <0.005 0.12 0.12
Off-Road (Cargo Handling) 0.86 23.00 39.60 0.05 0.11 0.11 Total 12.99 44.58 81.68 0.23 8.92 2.72
SDAPCD threshold 75 250 550 250 100 55
Threshold exceeded? No No No No No No
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse particulate matter; PM2.5 = fine particulate matter; SDAPCD = San Diego Air Pollution Control District. <0.01 = reported value is less than 0.01.

See Appendix A for complete results.

The values shown are the maximum summer or winter daily emissions results from CalEEMod.

As shown in Table 4.2-10, daily operational emissions for the Project would not exceed SDAPCD’s significance thresholds for any criteria air pollutant. Therefore, operation of the Project would not result in a net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard; impacts due to Project operation would be less than significant.

C. Would the Project expose sensitive receptors to substantial pollutant concentrations? Carbon Monoxide Hotspots
Less than Significant Impact. Regionally, project-related travel will add to regional trip generation and increase the vehicle miles traveled within the SDAB. Locally, project traffic will be added to the City’s roadway system. If such traffic occurs during periods of poor atmospheric ventilation, consists of a large number of vehicles “cold-started” and operating at pollution-inefficient speeds, and operates on roadways already crowded with non-project traffic, there is a potential for the formation of microscale CO “hotspots” in the area immediately around points of congested traffic. Because of continued improvement in mobile emissions at a rate faster than the rate of vehicle growth and/or congestion, the potential for CO hotspots in the basin is steadily decreasing.

Projects contributing to adverse traffic impacts at high congested intersections may result in the formation of CO hotspots. To determine whether the Project would not cause or contribute to a violation of the CO standard, a screening evaluation of the potential for CO hotspots was conducted. The County’s CO hotspot screening guidance (County of San Diego 2007) was followed to determine whether the Project would require a site-specific hotspot analysis. Per guidance, any project that would place receptors within 500 feet of a signalized intersection operating at or below LOS E (peak-hour trips exceeding 3,000 trips) must conduct a “hotspot” analysis for CO. Likewise, projects that will cause road intersections to operate at or below a LOS E (i.e., with intersection peak-hour trips exceeding 3,000) will also have to conduct a CO “hotspot” analysis. As presented in the Transportation Impact Study (Appendix L), the following intersections were analyzed:

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Roadway Segments:
▪ Magnolia Avenue, south of Mission Gorge - Woodside Avenue ▪ Woodside Avenue, between Magnolia Avenue and Woodside Avenue ▪ Woodside Avenue, between Woodside Avenue to Project Driveway Intersections:
▪ Magnolia Avenue/SR-52 EB Off-Ramps
▪ Magnolia Avenue/SR-52 WB On-Ramp - SR-67 SB On-Ramp
▪ Magnolia Avenue - Mission Gorge Road/Woodside Avenue
▪ Woodside Avenue/S. Woodside Avenue - SR-67 SB Off-Ramp ▪ Hartley Road/Woodside Avenue
▪ Wheatlands Avenue/Woodside Avenue
▪ Project Access Driveway/Woodside Avenue
As presented in the Transportation Impact Study (Appendix L of this Draft EIR), all study area roadway segments and intersections would continue to operate at satisfactory levels of service (LOS D or better) under Near Term plus Project conditions with the exception of the Magnolia Avenue - Mission Gorge Road/Woodside Avenue intersection and the Woodside Avenue/S. Woodside Avenue - SR-67 SB Off-Ramp intersection. However, for the Magnolia Avenue - Mission Gorge Road/Woodside Avenue intersection the proposed project would not increase the delay by more than 2 seconds and therefore, not exceed the City’s criteria for project specific traffic effect under Horizon Year plus Project conditions. No improvements are required, and as such, no impacts are expected for the formation of adverse CO hotspots.

As presented in the Transportation Impact Study (Appendix I) the proposed project would result in a traffic effect at the N. Woodside Avenue/S. Woodside Avenue - SR-67 SB Off-Ramp intersection, under Existing plus Project, Near Term plus Project conditions, and Horizon Year plus Project conditions, The project would construct a missing segment of sidewalk along N. Woodside Avenue near the N. Woodside Avenue/Woodside Avenue - SR-67 SB OffRamp 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-of-way 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. Although this improvement would not reduce delay or improve LOS at the Woodside Avenue/S. Woodside Avenue - SR-67 SB Off-Ramp intersection, it would improve non-vehicular circulation and pavement conditions along Woodside Avenue and would be considered an acceptable improvement by the City in lieu of improving delay or LOS at the intersection.

In addition, at the time that the South Coast Air Quality Management District (SCAQMD) Handbook (SCAQMD 1993) was published, the South Coast Air Basis (SCAB) was designated nonattainment under the CAAQS and NAAQS for CO. In 2007, the SCAQMD was designated in attainment for CO under both the CAAQS and NAAQS as a result of the steady decline in CO concentrations in the SCAB due to turnover of older vehicles, introduction of cleaner fuels,

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and implementation of control technology on industrial facilities. The SCAQMD conducted CO modeling for the 2003 AQMP6 (SCAQMD 2003b) for the four worst-case intersections in the SCAB:

Wilshire Boulevard and Veteran Avenue
Sunset Boulevard and Highland Avenue
La Cienega Boulevard and Century Boulevard
Long Beach Boulevard and Imperial Highway
At the time the 2003 AQMP was prepared, the intersection of Wilshire Boulevard and Veteran Avenue was the most congested intersection in Los Angeles County, with an average daily traffic volume of about 100,000 vehicles per day. The 2003 AQMP projected 8-hour CO concentrations at these four intersections for 1997 and from 2002 through 2005. From years 2002 through 2005, the maximum 8-hour CO concentration was 3.8 parts per million at the Sunset Boulevard and Highland Avenue intersection in 2002 and the maximum 8-hour CO concentration was

3.4 parts per million at the Wilshire Boulevard and Veteran Avenue in 2002.

Accordingly, CO concentrations at congested intersections would not exceed the 1-hour or 8-hour CO CAAQS unless projected daily traffic would be at least over 100,000 vehicles per day. While the project is not located in the SCAB, similar localized ambient impacts can be expected near intersections regardless of location. The Project estimated horizon year plus Project intersection volumes results in 27,100 and 26,620 daily total vehicles for AM and PM conditions, see Appendix A. Because the project is not anticipated to increase daily traffic volumes at N. Woodside Avenue/S. Woodside Avenue - SR-67 SB Off-Ramp intersection more than 100,000 vehicles per day, a CO hotspot is not anticipated to occur.

Therefore, the Project would not generate traffic that would contribute to potential adverse traffic impacts that may result in the formation of CO hotspots and no hotspot analysis is required. Based on these considerations, the Project would not expose sensitive receptors to substantial CO concentrations; impacts based on CO exposure would be less than significant.

Toxic Air Contaminants
Construction Health Risk
Less-than-Significant Impact. In addition to impacts from criteria pollutants, project impacts may include emissions of pollutants identified by the state and federal government as TACs or HAPs. The greatest potential for TAC emissions during construction would be DPM emissions from heavy equipment operations and heavy-duty trucks, and the associated health impacts to sensitive receptors. Construction of the Project would occur over a period of approximately 15 months. The closest sensitive receptors to the Project site are single-family residences to the north of the site and north of the San Diego River and single and multifamily residential units south of the Project site and south of Highway 67. As such, a construction health risk analysis was performed for the Project as discussed below.

Table 4.2-11 summarizes the results of the HRA for Project construction, and detailed results are provided in Appendix B of Appendix B, Health Risk Assessment Output Files.
6 SCAQMD’s CO hotspot modeling guidance has not changed since 2003.

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Table 4.2-11. Construction Activity Health Risk Assessment Results - Unmitigated Impact Parameter Units
Project
Impact
CEQA
Threshold Level of Significance
Offsite
Cancer Risk Per Million 1.39 10.0 Less than Significant Chronic Hazard Index
– Residential
Not Applicable 0.0012 1.0 Less than Significant
Source: Appendix B of this EIR
Notes: CEQA = California Environmental Quality Act; HIC = Chronic Hazard Index.

The results of the HRA demonstrate that the TAC exposure from construction diesel exhaust emissions would result in a cancer risk on site of less than the 10 in 1 million threshold, as well as Chronic Hazard Index less than 1.0.

Therefore, TAC emissions from construction of the Project would not expose sensitive receptors to substantial pollutant concentrations and would result in a less than significant impact.

Operational Health Risk
Less-than-Significant Impact. As discussed in Section 4.2.3, an HRA was performed to estimate the Maximum Individual Cancer Risk and Chronic Hazard Index for residential receptors associated with Project operations.

Results of the operational HRA are presented in Table 4.2-12.

Table 4.2-12. Operational Health Risk Assessment Results - Unmitigated Impact Parameter Units
Impact
Level
CEQA
Threshold
Level of
Significance
Maximum Individual Cancer Risk –
Residential
Per Million 3.80 10 Less than
Significant
Chronic Hazard Index – Residential Index Value 0.00146 1.0 Less than Significant.

Source: Appendix B of this EIR.

Notes: CEQA = California Environmental Quality Act
As shown in Table 4.2-12, the DPM emissions from operation of the Project would result in a Residential Maximum Individual Cancer Risk of 3.80 in 1 million and a Residential Chronic Hazard Index of 0.00146.

The results of the HRA demonstrate that the TAC exposure from operational diesel exhaust emissions would result in cancer risk less than the 10 in 1 million threshold and Chronic Hazard Index less than 1. Therefore, operation of the Project would not expose sensitive receptors to substantial pollutant concentrations; impacts would be less than significant.

Combined Construction and Operational Health Risk
Less-than-Significant Impact. As discussed, a combined construction and operational HRA was performed to estimate the Maximum Individual Cancer Risk and Chronic Hazard Index for residential receptors associated with the Project. Results of the combined HRA are presented in Table 4.2-13.

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Table 4.2-13. Combined Construction and Operational Health Risk Assessment Results - Unmitigated
Impact Parameter Units
Impact
Level
CEQA
Threshold
Level of
Significance
Maximum Individual Cancer Risk –
Residential
Per Million 5.14 10 Less than
Significant
Chronic Hazard Index – Residential Index Value 0.0027 1.0 Less than Significant.

Source: Appendix B of this EIR.

Notes: CEQA = California Environmental Quality Act
As shown in Table 4.2-13, the DPM emissions from the combined construction and operation of the Project would result in a Residential Maximum Individual Cancer Risk of in 5.14 million and a Residential Chronic Hazard Index of 0.0027.

The results of the combined construction and operational HRA demonstrate that the TAC exposure from diesel exhaust emissions would result in cancer risk less than the 10 in 1 million threshold and Chronic Hazard Index less than 1. Therefore, the Project would not expose sensitive receptors to substantial pollutant concentrations; impacts would be less than significant.

Health Effects of Criteria Air Pollutants
Less-than-Significant Impact. As demonstrated, construction and operation of the Project would not result in emissions that exceed SDAPCD’s emission thresholds for any criteria air pollutants. The SDAPCD thresholds are based on SDAB compliance with the NAAQS and CAAQS which are protective of public health; therefore, no adverse effects to human health would result from the Project. The following provides a general discussion of criteria air pollutants and their health effects.

Some VOCs would be associated with motor vehicles and construction equipment, while others are associated with architectural coatings and asphalt off-gassing, the emissions of which would not result in exceedances of SDAPCD’s thresholds. SDAPCD Rule 67.0.1 restricts the VOC content of coatings for both construction and operational applications.

VOCs and NOx are precursors to O3, for which the SDAB is designated as nonattainment with respect to certain NAAQS and CAAQS standards (the SDAB is designated by EPA as an attainment area for the 1-hour O3 NAAQS standard and 1997 8-hour NAAQS standard). The health effects associated with O3, as discussed in Section 2.1.4, Criteria Air Pollutants, are generally associated with reduced lung function. The contribution of VOCs and NOx to regional ambient O3 concentrations is the result of complex photochemistry, with increases in O3 concentrations in the SDAB due to precursor emissions found downwind from the source location. However, the potential for exacerbating excessive O3 concentrations would also depend on the time of year that the VOC emissions would occur because exceedances of the O3 NAAQS and CAAQS tend to occur between April and October, when solar radiation is highest. The effect of a single project’s emissions of O3 precursors is speculative due to the lack of quantitative methods to assess this impact. VOC and NOx emissions associated with Project construction would only negligibly contribute to regional O3 concentrations and the associated health impacts. Accordingly, the Project would not expose sensitive receptors to substantial concentrations of VOCs and NOx; health impacts would be less than significant.

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Health effects associated with CO include chest pain in patients with heart disease, headache, light-headedness, and reduced mental alertness (CARB 2019). CO tends to be a localized impact associated with congested intersections. CO hotspots were discussed previously as a less than significant impact. Thus, the proposed Project’s CO emissions would not contribute to the health effects associated with this pollutant. Health impacts would be less than significant.

Construction of the Project would not exceed thresholds for PM10 or PM2.5 and would not contribute to exceedances of the NAAQS and CAAQS for particulate matter. As noted above, PM10 or PM2.5 emissions during both construction and operation of the Project would be less than the applicable SDAPCD threshold. Accordingly, the Project would not expose sensitive receptors to substantial concentrations of PM10 or PM2.5; health impacts would be less than significant.

Nitrogen oxides (NOx) is a term used to describe the sum of nitric oxide (NO), nitrogen dioxide (NO2), and other oxides of nitrogen. As such, NO2 is a constituent of NOx. Construction of the Project would not contribute to exceedances of the NAAQS and CAAQS for NO2 since NOx emissions would be less than the applicable SDAPCD threshold. As discussed above, the SDAPCD thresholds are based on SDAB compliance with the NAAQS and CAAQS, which are protective of public health; therefore, no adverse effects to human health would result from emissions below threshold. As described in Section 4.2.1, NO2 health impacts are associated with respiratory irritation, which may be experienced by nearby receptors during the periods of heaviest use of off-road construction equipment.

However, these operations would be relatively short term, and the off-road construction equipment would be operating on various portions of the site and would not be concentrated in one portion of the site at any one time.

Accordingly, the Project would not expose sensitive receptors to substantial pollutant concentrations of NO2; impacts would be less than significant.

D. Would the Project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Construction
Less than Significant Impact. The State of California Health and Safety Code, Division 26, Part 4, Chapter 3, Section 41700 SDAPCD Rule 51, and the City’s Municipal Code prohibit emissions from any source whatsoever in such quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance to the public health or damage to property. Projects required to obtain permits from SDAPCD are evaluated by SDAPCD staff for potential odor nuisance, and conditions may be applied (or control equipment required) where necessary to prevent occurrence of public nuisance. Odors would be generated from vehicles and/or equipment exhaust emissions during construction of the Project. Odors produced during construction would be attributable to concentrations of unburned hydrocarbons from tailpipes of construction equipment and architectural coatings. Such odors are temporary and for the types of construction activities anticipated for Project components, would generally occur at magnitudes that would not affect substantial numbers of people. In addition, there are no adjacent sensitive receptors to the Project site, the closest sensitive receptors are approximately 0.15 mile north and south of the Project site. Therefore, construction of the Project would not result in odors that would adversely affect a substantial number of people, and impacts associated with odors during construction would be less than significant.

Operation
Less-than-Significant Impact. 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. A project that proposes a use that would produce objectionable odors would be deemed to have a significant odor impact if

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it would affect a considerable number of off-site receptors. Odor issues are very subjective by the nature of odors themselves because their measurements are difficult to quantify. As a result, this guideline is qualitative, and will focus on the existing and potential surrounding uses and location of sensitive receptors.

Due to the subjective nature of odor impacts, the number of variables that can influence the potential for an odor impact, and the variety of odor sources, there are no quantitative or formulaic methodologies to determine if potential odors would have a significant impact. Examples of land uses and industrial operations that are commonly associated with odor complaints include agricultural uses, wastewater treatment plants, food processing facilities, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding facilities. In addition to the odor source, the distance between the sensitive receptor(s) and the odor source, as well as the local meteorological conditions, are considerations in the potential for a project to frequently expose the public to objectionable odors.

Although localized air quality impacts are focused on potential impacts to sensitive receptors, such as residences and schools, other land uses where people may congregate (e.g., workplaces) or uses with the intent to attract people (e.g., restaurants and visitor-serving accommodations) should also be considered in the evaluation of potential odor nuisance impacts. 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. Therefore, operation of the Project would not result in odors that would adversely affect a substantial number of people, impacts related to odors during operation would be less than significant.

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

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4.3 Biological Resources
This section describes the existing biological resources 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 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 source:
▪ Biological Technical Report (BTR), prepared by Dudek in May 2024 (Appendix C)

4.3.1 Existing Conditions
The approximately 13.5-acre Project site is in the southeastern part of the City of Santee and is currently a developed parking lot with a two-screen drive-in theatre and a building containing restrooms and a snack bar. The Project site boundary extends slightly beyond the pavement into the undeveloped area located approximately 20 to 30 feet above the San Diego River corridor. The following sections describe the existing biological resources within the Project site and potentially occurring within adjacent areas associated with the San Diego River (i.e., 500- foot surrounding buffer).

4.3.1.1 Vegetation Communities and Land Covers
Vegetation community classifications within the Project site follow Holland (1986), as revised by Oberbauer et al. (2008). Based on species composition and general physiognomy, four vegetation communities or land cover types occur within the Project site and 10 vegetation communities or land cover types occur within the 500-foot buffer surrounding the Project site. Acreages for each vegetation community or land cover type are provided in Table 4.3-1, below, and their spatial distributions are shown in Figure 4.3-1, Biological Resources. Descriptions of each vegetation community and land cover type are included in Section 4.1 of Appendix C of this Draft EIR.

Table 4.3-1. Vegetation Communities and Land Covers within the Project Site and 500-Foot Buffer
Vegetation Community/Land Cover Type
Holland/Oberbauer
Code
500-Foot
Buffer (Acres)
Project Site
(Acres)
Riparian/Bottomland Vegetation Communities
Coastal and Valley Freshwater Marsh 52410 1.52 0
Southern Arroyo Willow Riparian Forest 61320 5.69 0
Southern Cottonwood–Willow Riparian Forest 61330 0.56 0 Southern Willow Scrub 63320 2.02 0
Open Water 64140 8.09 0
Riparian/Bottomland Vegetation Communities Subtotal 17.88 0 Upland Vegetation Communities
Diegan Coastal Sage Scrub 32500 1.04 0
Non-Native Communities and Land Cover Types
Non-Native Grassland 42200 0.95 0.27

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Table 4.3-1. Vegetation Communities and Land Covers within the Project Site and 500-Foot Buffer
Vegetation Community/Land Cover Type
Holland/Oberbauer
Code
500-Foot
Buffer (Acres)
Project Site
(Acres)
Non-Native Woodland 79000 0.62 0.51
Disturbed Habitat 11300 0.48 0.02
Urban/Developed 12000 53.39 12.70
Non-Native Communities and Land Cover Types Subtotal 55.45 13.49 Total 74.37 13.49
Note: Totals may not sum due to rounding.

4.3.1.2 Plants and Wildlife Observed
A total of 19 species of native or naturalized plants, 2 native (11%) and 17 non-native (89%), were recorded on the site (see Appendix B of Appendix C of this Draft EIR). The majority of these plant species are ornamental trees planted in association with the current development on site. Due to the lack of habitat (i.e., site is currently a parking lot), very few wildlife species were observed within the Project site (i.e., eight bird species and one mammal species).

A total of 42 wildlife species common to San Diego County were observed within the surrounding area during surveys. Appendix B of Appendix C of this Draft EIR lists all wildlife species observed within the Project site and the 500-foot surrounding buffer.

4.3.1.3 Special-Status Plants
Special-status plant species include those listed, or candidates for listing, as threatened or endangered by the U.S.

Fish and Wildlife Service (USFWS) and California Department of Fish and Wildlife (CDFW), and species identified as rare by the California Native Plant Society (particularly California Rare Plant Rank [CRPR] 1A, presumed extinct in California; CRPR 1B, rare, threatened, or endangered throughout its range; and CRPR 2, rare or endangered in California, more common elsewhere). BTR Appendix C provides a table of all special-status plant species whose geographic ranges fall within the general vicinity of the Project site. Special-status species’ potential to occur within the Project site were evaluated based on known species distribution, species-specific habitat preferences, and Dudek biologists’ knowledge of regional biological resources. Each special-status species was assigned a rating of “not expected,” “low,” “moderate,” or “high” potential to occur within the Project site based on relative location to known occurrences, vegetation community, soil, and elevation.

No special-status plant species were observed within the Project site during surveys, and due to lack of habitat, none are expected to occur. There is moderate potential for special-status plant species to occur off site within suitable habitat areas in the 500-foot buffer surrounding the Project site within the San Diego River corridor. 0#
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least Bell's vireo (Vireo bellii pusillus)
0# yellow-breasted chat (Icteria virens)
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Vegetation Communities and Land Covers
Coastal and Valley Freshwater Marsh
Diegan Coastal Sage Scrub
Non-Native Grassland
Non-Native Woodland
Southern Arroyo Willow Riparian Forest
Southern Cottonwood-Willow Riparian
Forest
Southern Willow Scrub
Disturbed Habitat
Open Water
Urban/Developed
Biological Resources
Palisades Santee Commerce Center Project
SOURCE: SanGIS, Open Street Maps
Date: 5/9/2024 - Last saved by: kholmes - Path: Z:\Projects\j1513801\MAPDOC\DOCUMENT\BTR\BTR_figures.aprx 0 100 200 n Feet
Figure 4.3-1 Figure 4.3-1
Biological Resources
Palisade Santee Commerce Center Project

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INTENTIONALLY LEFT BLANK

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4.3.1.4 Special-Status Wildlife
Special-status wildlife species include those listed, or candidates for listing, as threatened or endangered by USFWS and CDFW, those designated as Species of Special Concern by CDFW, and those designated as sensitive by USFWS.

BTR Appendix D provides a table of all special-status wildlife species whose geographic ranges fall within the general vicinity of the Project site. Special-status species’ potential to occur within the Project site were evaluated based on known species distribution, species-specific habitat preferences, and Dudek biologists’ knowledge of regional biological resources. Each special-status species was assigned a rating of “not expected,” “low,” “moderate,” or “high” potential to occur within the Project site based on relative location to known occurrences, vegetation community, soil, and elevation.

No special-status wildlife species were observed within the Project site during surveys, and due to lack of habitat, none are expected to occur. However, three special-status wildlife species—least Bell’s vireo (Vireo bellii pusillus), yellow-breasted chat (Icteria virens), and yellow warbler (Setophaga petechia)—were observed off site within the Project site’s 500-foot buffer that overlaps the riparian habitat associated with the San Diego River. Three nesting pairs of least Bell’s vireo were detected within the riparian habitat; one pair occurred on the southern side of the San Diego River and two pairs occurred on the northern side. One pair of yellow breasted chat was detected, and both were active across much of the habitat. A number of yellow warblers were detected, and much of the riparian habitat was used by them.

Additionally, coastal California gnatcatcher (Polioptila californica californica) was observed outside the 500-foot buffer (more than 700 feet north of the Project site) in coastal scrub habitat during the riparian bird surveys.

However, there is minimal suitable habitat for this species within the 500-foot buffer area. The coastal sage scrub occurring within the 500-foot buffer is small (i.e., approximately 1 acre), disturbed, on steep slopes, and likely not used for nesting by this species.

4.3.1.5 Jurisdictional Resources
No jurisdictional aquatic resources were observed within the Project site during the jurisdictional aquatic resource assessment. The northern edge of the Project site is adjacent to stands of thick vegetation occurring along a chainlink fence line that lines the parking lot. This vegetation was dominated by African sumac (Searsia lancea), a nonnative low-growing tree species that is known to occupy disturbed areas. African sumac would not be considered a jurisdictional wetland or riparian vegetation subject to aquatic resources regulation. In addition, the edge of the Project site occurs at least 20 to 30 feet in elevation higher than and approximately 70 to 100 feet south of the riparian (willow forest) and wetland (freshwater marsh) vegetation communities associated with the San Diego River. These wetland areas occur outside of the Project site. A strip of disturbed habitat separates the San Diego River and the upland communities adjacent to the Project site; multiple encampments created by people experiencing homelessness were observed in this area. Two culverts were observed during the jurisdictional aquatic resource assessment that appear to transport flows from the Project site boundary northward toward the San Diego River; however, no channels or aquatic resources have developed around the culvert structures. Other culverts could exist but are likely obscured by vegetation growth and erosion.

4.3.1.6 Wildlife Corridors and Habitat Linkages
Wildlife corridors are linear features that connect large patches of natural open space and provide avenues for the migration of animals. Wildlife corridors contribute to population viability by ensuring continual exchange of genes

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between populations, providing access to adjacent habitat areas for foraging and mating, and providing routes for recolonization of habitat after local extirpation or ecological catastrophes (e.g., fires).

Habitat linkages are small patches that join larger blocks of habitat and help reduce the adverse effects of habitat fragmentation. Habitat linkages provide a potential route for gene flow and long-term dispersal of plants and animals and may also serve as primary habitat for smaller animals, such as reptiles and amphibians. Habitat linkages may be continuous habitat or discrete habitat islands that function as steppingstones for dispersal.

The San Diego Multiple Species Conservation Program (MSCP) Plan (City of San Diego 1998) defines core and linkage areas as those maintaining ecosystem function and processes, including large animal movement. Each core area is connected to other core areas or to habitat areas outside of the MSCP study area either through common boundaries or through linkages. Core areas have multiple connections to help ensure that the balance in the ecosystem will be maintained.

The Project site is currently developed as a parking lot and drive-in theater and is not mapped as a core area or habitat linkage under the MSCP (City of San Diego 1998). Therefore, the Project site does not function as a wildlife corridor or habitat linkage. However, the Project site is adjacent to the San Diego River, which could potentially function as a wildlife corridor for local populations of common species. Larger species, like mule deer (Odocoileus hemionus) and mountain lion (Puma concolor), are not expected to use this highly urbanized vicinity of the river corridor due to the amount of adjacent commercial and industrial uses, large presence of human encampments, and general lack of connectivity to larger core areas of suitable habitat. It is unlikely that bobcat would use this area for the same reasons. Species most likely to use this area include coyote (Canis latrans), raccoon (Procyon lotor), striped skunk (Mephitis mephitis), and Virginia opossum (Didelphis virginiana).

4.3.2 Relevant Plans, Policies, and Ordinances
Federal
Federal Endangered Species Act
The federal Endangered Species Act (FESA) of 1973 (16 USC 1531 et seq.), as amended, is administered by USFWS for most plant and animal species, and by the National Oceanic and Atmospheric Administration National Marine Fisheries Service for certain marine species. This legislation is intended to provide a means to conserve the ecosystems upon which endangered and threatened species depend, and provide programs for the conservation of those species, thus preventing the extinction of plants and wildlife. FESA defines an endangered species as “any species that is in danger of extinction throughout all or a significant portion of its range.” A threatened species is defined as “any species that is likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range.” Under FESA, it is unlawful to “take” any listed species; “take” is defined as, “harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct.” FESA allows for the issuance of incidental take permits for listed species under Section 7, which is generally available for projects that also require other federal agency permits or other approvals, and under Section 10, which provides for the approval of habitat conservation plans on private property without any other federal agency involvement.

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Migratory Bird Treaty Act
The Migratory Bird Treaty Act prohibits the intentional and unintentional take of any migratory bird or any part, nest, or eggs of any such bird. Under the Migratory Bird Treaty Act, “take” is defined as pursuing, hunting, shooting, capturing, collecting, or killing, or attempting to do so (16 USC 703 et seq.). Currently, the Migratory Birds office considers nests that support eggs, nestlings, or juveniles to be active. Additionally, Executive Order 13186, Responsibilities of Federal Agencies to Protect Migratory Birds, requires that any project with federal involvement address impacts of federal actions on migratory birds with the purpose of promoting conservation of migratory bird populations (66 FR 3853–3856). Executive Order 13186 requires federal agencies to work with USFWS to develop a memorandum of understanding. USFWS reviews actions that might affect these species.

Clean Water Act
The Clean Water Act (CWA) provides guidance for the restoration and maintenance of the chemical, physical, and biological integrity of the nation’s waters. Section 401 requires a project operator for a federal license or permit that allows activities resulting in a discharge to waters of the United States to obtain state certification, thereby ensuring that the discharge will comply with provisions of the CWA. The Regional Water Quality Control Boards (RWQCBs) administer the certification program in California. Section 402 establishes a permitting system for the discharge of any pollutant (except dredged or fill material) into waters of the United States. Section 404 establishes a permit program administered by the U.S. Army Corps of Engineers (USACE) that regulates the discharge of dredged or fill material into waters of the United States, including wetlands. USACE implementing regulations are found in the Code of Federal Regulations (CFR) at 33 CFR Parts 320 to 332. Guidelines for implementation are referred to as the Section 404(b)(1) Guidelines, which were developed by the U.S. Environmental Protection Agency in conjunction with USACE (40 CFR 230). The guidelines allow the discharge of dredged or fill material into the aquatic system only if there is no practicable alternative that would have less adverse impacts.

Wetlands and Other Waters of the United States
Based on a recent court case ordering vacation of the Navigable Waters Protection Rule, USACE and the U.S.

Environmental Protection Agency have halted implementation of the rule and are interpreting waters of the United States consistent with the pre-2015 regulatory regime until further notice. Per 33 CFR 328.3(a), waters of the United States are defined as follows:

All waters which are currently used, or were used in the past, or may be susceptible to use in interstate or foreign commerce, including all waters which are subject to the ebb and flow of the tide; All interstate waters including interstate wetlands;
All other waters such as intrastate lakes, rivers, streams (including intermittent streams), mudflats, sandflats, wetlands, sloughs, prairie potholes, wet meadows, playa lakes, or natural ponds, the use, degradation or destruction of which could affect interstate or foreign commerce including any such waters:
a. Which are or could be used by interstate or foreign travelers for recreational or other purposes; or b. From which fish or shellfish are or could be taken and sold in interstate or foreign commerce; or c. Which are used or could be used for industrial purposes by industries in interstate commerce; All impoundments of waters otherwise defined as waters of the United States under this definition; Tributaries of waters identified in paragraphs (a)(1) through (4) of this section; The territorial seas;

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Wetlands adjacent to waters (other than waters that are themselves wetlands) identified in paragraphs (a)(1) through (6) of this section; and
Waste treatment systems, including treatment ponds or lagoons designed to meet the requirements of CWA (other than cooling ponds as defined in 40 CFR 423.11(m) which also meet the criteria of this definition) are not waters of the United States.

The USACE/U.S. Environmental Protection Agency Rapanos Guidance states that USACE will regulate traditional navigable waters and adjacent wetlands, and relatively permanent waters tributary to traditional navigable waters and adjacent wetlands. Non-relatively permanent waters (those exhibiting less than 3 months of continuous surface flows) and their adjacent wetlands would be regulated if there is a significant nexus from the site to traditional navigable waters.

The State Water Resources Control Board has authority over wetlands through Section 401 of the CWA, as well as the Porter–Cologne Water Quality Control Act (Porter–Cologne Act), California Code of Regulations Section 3831(k), and California Wetlands Conservation Policy. The CWA requires that an applicant for a Section 404 permit (to discharge dredge or fill material into waters of the United States) first obtain certification from the appropriate state agency stating that the fill is consistent with the state’s water quality standards and criteria. In California, the authority to either grant certification or waive the requirement for permits is delegated by the State Water Resources Control Board to the nine RWQCBs. A request for certification is submitted to the RWQCB at the same time that an application is filed with USACE.

State
California Endangered Species Act
The California Endangered Species Act (CESA) (California Fish and Game Code Sections 2050–2068) provides protection for and prohibits the take of plant, fish, and wildlife species listed by the State of California. Unlike FESA, under CESA, state-listed plants have the same degree of protection as wildlife, but insects and other invertebrates may not be listed. Take is defined similarly to FESA and is prohibited for both listed and candidate species. Take authorization may be obtained by a project applicant from CDFW under CESA Section 2081, which allows take of a listed species for educational, scientific, or management purposes. In this case, developers consult with CDFW to develop a set of measures and standards for managing the listed species, including full mitigation for impacts, funding of implementation, and monitoring of mitigation measures.

California Fish and Game Code
Fully Protected Species
Sections 3511, 4700, 5050, and 5515 of the California Fish and Game Code outline protection for fully protected species of mammals, birds, reptiles, amphibians, and fish. Species that are fully protected by these sections may not be taken or possessed at any time. CDFW cannot issue permits or licenses that authorize the “take” of any fully protected species, except under certain circumstances, such as scientific research and live capture and relocation of such species pursuant to a permit for the protection of livestock. On July 10, 2023, Senate Bill 147 was signed into law and amends the California Fish and Game Code to allow a 10-year permitting mechanism for a defined set of projects within the renewable energy, transportation, and water infrastructure sectors. Furthermore, it is the responsibility of the CDFW to maintain viable populations of all native species. Toward that end, CDFW has

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designated certain vertebrate species as Species of Special Concern, because declining population levels, limited ranges, and/or continuing threats have made them vulnerable to extinction.

Sections 1600–1616
CDFW jurisdiction includes ephemeral, intermittent, and perennial watercourses (including dry washes) and lakes characterized by the presence of (1) definable bed and banks and (2) existing fish or wildlife resources. CDFW takes jurisdiction to the top of bank of the stream, or the limit of the adjacent riparian vegetation, which may include oak woodlands in canyon bottoms. Historical court cases have further extended CDFW jurisdiction to include watercourses that seemingly disappear but reemerge elsewhere. Under the CDFW definition, a watercourse need not exhibit evidence of an ordinary high-water mark to be claimed as jurisdictional. CDFW does not have jurisdiction over ocean or shoreline resources.

Under California Fish and Game Code Sections 1600–1616, CDFW has the authority to regulate work that will substantially divert or obstruct the natural flow of, or substantially change or use any material from, the bed, channel, or bank of any river, stream, or lake. CDFW also has the authority to regulate work that will deposit or dispose of debris, waste, or other material containing crumbled, flaked, or ground pavement where it may pass into any river, stream, or lake. This regulation takes the form of a requirement for a Lake or Streambed Alteration Agreement and is applicable to all projects. Applications to CDFW must include a complete certified California Environmental Quality Act (CEQA) document.

California Native Plant Protection Act
The Native Plant Protection Act of 1977 (see Section 1900 et seq. of the California Fish and Game Code) directed CDFW to carry out the Legislature’s intent to “preserve, protect and enhance rare and endangered plants in this State.” The Native Plant Protection Act gave the California Fish and Game Commission the power to designate native plants as “endangered” or “rare” and protect endangered and rare plants from take. CESA expanded on the original Native Plant Protection Act and enhanced legal protection for plants, but the Native Plant Protection Act remains part of the California Fish and Game Code. To align with federal regulations, CESA created the categories of “threatened” and “endangered” species. It converted all “rare” animals into the act as threatened species but did not do so for rare plants. Thus, there are three listing categories for plants in California: rare, threatened, and endangered. Because rare plants are not included in CESA, mitigation measures for impacts to rare plants are specified in a formal agreement between CDFW and the project proponent.

Nesting Birds
Section 3503 of the California Fish and Game Code states that it is unlawful to take, possess, or needlessly destroy the nests or eggs of any bird, except as otherwise provided by this code or any regulation made pursuant thereto.

Section 3503.5 protects all birds of prey (raptors) and their eggs and nests. Section 3511 states that fully protected birds or parts thereof may not be taken or possessed at any time. Section 3513 states that it is unlawful to take or possess any migratory non-game bird as designated in the Migratory Bird Treaty Act.

California Environmental Quality Act
CEQA requires identification of a project’s potentially significant impacts on biological resources and ways that such impacts can be avoided, minimized, or mitigated. CEQA also provides guidelines and thresholds for use by lead agencies for evaluating the significance of proposed impacts.

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The State of California CEQA Guidelines (CEQA Guidelines) Section 15380(b)(1) defines endangered animals or plants as species or subspecies whose “survival and reproduction in the wild are in immediate jeopardy from one or more causes, including loss of habitat, change in habitat, overexploitation, predation, competition, disease, or other factors.” A rare animal or plant is defined in Section 15380(b)(2) as a species that, although not presently threatened with extinction, exists “in such small numbers throughout all or a significant portion of its range that it may become endangered if its environment worsens; or … [t]he species is likely to become endangered within the foreseeable future throughout all or a significant portion of its range and may be considered ‘threatened’ as that term is used in the federal Endangered Species Act.” Additionally, an animal or plant may be presumed to be endangered, rare, or threatened if it meets the criteria for listing, as defined further in CEQA Guidelines Section 15380(c).

CDFW has developed a list of “Special Species” as “a general term that refers to all of the taxa the California Natural Diversity Database is interested in tracking, regardless of their legal or protection status.” This is a broader list than those species that are protected under FESA, CESA, and other California Fish and Game Code provisions, and includes lists developed by other organizations, including, for example, the Audubon Watch List Species. Guidance documents prepared by other agencies, including the U.S. Bureau of Land Management’s Sensitive Species and USFWS Birds of Special Concern, are also included on this CDFW Special Species list. Additionally, CDFW has concluded that plant species listed as CRPR 1 and 2 by the California Native Plant Society, and potentially some CRPR 3 plants, are covered by CEQA Guidelines Section 15380.

Section IV, Appendix G (Environmental Checklist Form), of the CEQA Guidelines requires an evaluation of impacts to “any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by CDFW or USFWS.”
Porter–Cologne Water Quality Control Act
Pursuant to provisions of the Porter–Cologne Act, the RWQCBs regulate discharging waste, or proposing to discharge waste, within any region that could affect a water of the state (California Water Code, Section 13260[a]).

The State Water Resources Control Board defines a waters of the state as “any surface water or groundwater, including saline waters, within the boundaries of the state” (California Water Code, Section 13050[e]). All waters of the United States are waters of the state. Waters of the state include wetlands, and the State Water Resources Control Board definition of wetlands includes the following:

Natural wetlands.

Wetlands created by modification of a surface water of the state.

Artificial wetlands that meet any of the following criteria:
a. Approved by an agency as compensatory mitigation for impacts to other waters of the state, except where the approving agency explicitly identifies the mitigation as being of limited duration.
b. Specifically identified in a water quality control plan as a wetland or other water of the state.
c. Resulted from historic human activity, is not subject to ongoing operation and maintenance, and has become a relatively permanent part of the natural landscape. d. Greater than or equal to 1 acre in size unless the artificial wetland was constructed and is currently used and maintained, primarily for one or more of the following purposes:

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industrial or municipal wastewater treatment or disposal; settling of sediment; detention, retention, infiltration, or treatment of stormwater runoff and other pollutants or runoff subject to regulation under a municipal, construction, or industrial permitting program; treatment of surface waters; agricultural crop irrigation or stock watering; fire suppression; industrial processing or cooling water; active surface mining – even if the site is managed for interim wetlands functions and values; log storage; treatment, storage, or distribution of recycled water; maximizing groundwater recharge (this does not include wetlands that have incidental groundwater recharge benefits); or fields flooded for rice growing.

Wetlands that may not meet all of USACE’s wetland delineation criteria are considered wetland waters of the state if, “under normal circumstances, (1) the area has continuous or recurrent saturation of the upper substrate caused by groundwater, or shallow surface water, or both; (2) the duration of such saturation is sufficient to cause anaerobic conditions in the upper substrate; and (3) the area’s vegetation is dominated by hydrophytes or the area lacks vegetation” (SWRCB 2021). Additionally, aquatic resources that USACE determines to not be waters of the United States because they lack a significant nexus to a traditional navigable water or are above the ordinary highwater mark limit of federal jurisdiction may also be considered waters of the state. If a CWA Section 404 permit is not required for a project, the RWQCB may still require a permit (waste discharge requirements) for impacts to waters of the state under the Porter–Cologne Act.

Local
Multiple Species Conservation Program Plan
The Project site is within the boundaries of the San Diego MSCP Plan (City of San Diego 1998). The MSCP Plan is a multijurisdictional habitat conservation planning program that involves USFWS, CDFW, the County of San Diego, the Cities of San Diego and Chula Vista, and other local jurisdictions and special districts. Local jurisdictions and special districts implement the MSCP Plan for their respective portions through subarea plans. The combination of the MSCP Plan and subarea plans serve as a Habitat Conservation Plan (HCP) pursuant to FESA Section 10(a)(1)(B), and as a Natural Community Conservation Plan (NCCP) pursuant to the California Natural Community Conservation Planning Act of 1991 (City of San Diego 1998).

The MSCP Plan study area encompasses 582,243 acres within the southwestern portion of San Diego County. As stated in the MSCP Plan, an objective of the MSCP is to conserve a connected system of biologically viable habitat lands in a manner that maximizes the protection of sensitive species and precludes the need for future listings of species as threatened or endangered. The MSCP Plan identifies a Multi-Habitat Planning Area (MHPA), which is the area within which the permanent MSCP Preserve is assembled and managed for its biological resources. The MHPA is defined in many areas by mapped boundaries in figures in the MSCP Plan and is also defined by quantitative targets for conservation of vegetation communities and goals and criteria for Preserve design. The MSCP Plan targets 171,917 acres within the MHPA for conservation (City of San Diego 1998).

A total of 85 plant and animal species are “covered” by the MSCP Plan. The MSCP Plan Final EIR/Environmental Impact Statement (City of San Diego 1997) identifies “Vegetation Community Conservation Target Areas” for conservation by subarea (Attachment B of the MSCP Plan [City of San Diego 1998]). A total of 2,067 acres is expected to be conserved within the Santee Subarea MHPA. With approval of each subarea plan and corresponding implementing agreement, each participating local jurisdiction receives permits and/or authorization to directly impact or take MSCP Covered Species. The Covered Species include species listed as endangered or threatened

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by FESA and/or CESA, as well as unlisted species. Table 3-5 in the MSCP Plan provides a list of the MSCP Covered Species, and includes specific conditions required for take authorizations (City of San Diego 1998).

Draft Santee MSCP Subarea Plan
The City of Santee has been preparing its subarea plan since the original approval of the San Diego MSCP Plan and is currently in the process of completing the 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. The current Draft Santee MSCP Subarea Plan seeks coverage for up to 23 species, and relies on a combination of hardline conservation areas, criteria-based upland standards areas, San Diego River conservation opportunities areas, and City-owned preserve lands to protect species and habitat (City of Santee 2023). Coverage for species is dependent on a number of factors, including multijurisdictional participation, adequate building of the Preserve system, adequate protection of certain populations, permanent management funding, and other factors.

Santee City CouncilAugust 27, 2025

Santee City Council
August 27, 2025