SCH NO. 2021100263
Addendum to the City of Santee Housing
Element Rezone Program Implementation PEIR
Cottonwood and Park Project
AUGUST 2025
Prepared by:
605 Third Street
Encinitas, California 92024
Contact: Cindi Hoover, AICP
Prepared for:
CITY OF SANTEE
10601 Magnolia Avenue
City of Santee, California 92071
Contact: Rachael Lindebrekke, Associate Planner
Printed on 30% post-consumer recycled material.
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Table of Contents
SECTION PAGE
Acronyms and Abbreviations............................................................................................................................................. v 1 Introduction ..........................................................................................................................................................1
1.1 CEQA Requirements ...............................................................................................................................1 2 Project Description...............................................................................................................................................1
2.1 Project Location and Regional Setting..................................................................................................1
2.2 Project Overview.....................................................................................................................................1 3 Environmental Checklist......................................................................................................................................3
3.1 Aesthetics ............................................................................................................................................ 22
3.1.1 Analysis................................................................................................................................... 22
3.1.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR.............................................................................................. 25
3.2 Agriculture and Forestry Resources ................................................................................................... 25
3.2.1 Analysis................................................................................................................................... 25
3.2.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR.............................................................................................. 26
3.3 Air Quality ............................................................................................................................................. 26
3.3.1 Analysis................................................................................................................................... 26
3.3.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR............................................................................................................. 35
3.4 Biological Resources ........................................................................................................................... 35
3.4.1 Analysis................................................................................................................................... 36
3.4.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR............................................................................................................. 48
3.5 Cultural Resources and Tribal Cultural Resources............................................................................ 52
3.5.1 Analysis................................................................................................................................... 52
3.5.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR............................................................................................................. 54
3.6 Energy .................................................................................................................................................. 57
3.6.1 Analysis................................................................................................................................... 57
3.6.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR............................................................................................................. 64
3.7 Geology and Soils ................................................................................................................................ 64
3.7.1 Analysis................................................................................................................................... 65
3.7.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR............................................................................................................. 69
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3.8 Greenhouse Gas Emissions................................................................................................................ 70
3.8.1 Analysis................................................................................................................................... 70
3.8.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR............................................................................................................. 75
3.9 Hazards and Hazardous Materials ..................................................................................................... 75
3.9.1 Analysis................................................................................................................................... 75
3.9.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR............................................................................................................. 80
3.10 Hydrology and Water Quality............................................................................................................... 81
3.10.1 Analysis................................................................................................................................... 82
3.10.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR............................................................................................................. 85
3.11 Land Use and Planning ....................................................................................................................... 86
3.11.1 Analysis................................................................................................................................... 86
3.11.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR............................................................................................................. 87
3.12 Mineral Resources .............................................................................................................................. 88
3.12.1 Analysis................................................................................................................................... 88
3.12.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR............................................................................................................. 89
3.13 Noise .................................................................................................................................................... 89
3.13.1 Analysis................................................................................................................................... 89
3.13.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR............................................................................................................. 96
3.14 Population and Housing...................................................................................................................... 98
3.14.1 Analysis................................................................................................................................... 98
3.14.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR............................................................................................................. 99
3.15 Public Services and Recreation.......................................................................................................... 99
3.15.1 Analysis................................................................................................................................... 99
3.15.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR...........................................................................................................102
3.17 Transportation ...................................................................................................................................103
3.17.1 Analysis.................................................................................................................................103
3.17.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR...........................................................................................................108
3.19 Utilities and Service Systems............................................................................................................109
3.19.1 Analysis.................................................................................................................................109
3.19.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR...........................................................................................................113
3.20 Wildfire ...............................................................................................................................................113
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3.20.1 Analysis.................................................................................................................................113
3.20.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR...........................................................................................................114 4 References and Preparers..............................................................................................................................115
4.1 References Cited...............................................................................................................................115
4.2 List of Preparers ................................................................................................................................116
APPENDICES
A Cottonwood & Park Air Quality, Greenhouse Gas, and Energy Impact Study B Biological Technical Report – Cottonwood and Park Project C Phase I Environmental Site Assessment
D Preliminary Geotechnical Investigation
E Santee 3 Residential Development
F Geotechnical Investigation
G Request for a Conditional Letter of Map Revision for Santee 3 Multi-family Housing, H Storm Water Quality Management Plan (SWQMP) for Santee 3 Multifamily Housing I Drainage Study for Santee 3 Multifamily Housing
J Preliminary Engineering
K Cottonwood & Park Noise Impact Study
L Cottonwood & Park Local Transportation Analysis
FIGURES
1 Project Location ..............................................................................................................................................120 2 Rezone Site Plan.............................................................................................................................................122 3 Site Plan...........................................................................................................................................................126 4 Biological Resources.......................................................................................................................................128 TABLES
3.3.1-1 Estimated Maximum Daily Construction Criteria Air Pollutant Emissions................................................ 28
3.3.1-2 Estimated Maximum Daily Operational Criteria Air Pollutant Emissions.................................................. 29
3.4.1-1 Permanent and Temporary Impacts to Sensitive Vegetation Communities within the Project Site (Acres)....................................................................................................................................... 38
3.4.1-2 Mitigation for Permanent Impacts to Sensitive Vegetation Communities within the Project Site .......... 39
3.4.1-3 Permanent Impacts to Potential Jurisdictional Aquatic Resources within the Project Site..................... 43
3.6.1-1 Construction Equipment Fuel Consumption Estimates............................................................................. 59
3.6.1-2 Project Construction Power Cost and Electricity Usage............................................................................. 60
3.6.1-3 Construction Worker Fuel Consumption Estimates ................................................................................... 60
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3.6.1-4 Construction Vendor Fuel Consumption Estimates (MHD Trucks) ........................................................... 61
3.6.1-5 Construction Hauling Fuel Consumption Estimates (HHD Trucks) ........................................................... 61
3.6.1-6 Estimated Vehicle Operations Fuel Consumption...................................................................................... 62
3.6.1-7 Project Annual Operational Energy Demand Summary ............................................................................. 63
3.8.1-1 Estimated Annual Construction Greenhouse Gas Emissions ................................................................... 71
3.8.1-2 Opening Year Project-Related Greenhouse Gas Emissions ...................................................................... 71
3.8.1-3 Sustainable Santee Plan Consistency Analysis.......................................................................................... 73
3.13.1-1 Typical Construction Noise Levels1 of Equipment Powered by Internal Combustion Engines................ 90
3.13.1-2 Construction Noise Levels at the East Property Line................................................................................. 91
3.13.1-3 Existing/Existing + Project Scenario – Noise Levels Along Roadways (dBA Ldn) Existing Exterior Noise Levels...................................................................................................................... 91
3.13.1-4 Future Interior Noise Levels (dBA Ldn) ........................................................................................................ 93
3.13.1-5 Guideline Vibration Damage Potential Threshold Criteria......................................................................... 94
3.13.1- 6 Vibration Source Levels for Construction Equipment1 .............................................................................. 95
3.17.1-1 LOS Intersection Analysis Summary .........................................................................................................104
3.17.1-2 LOS Roadway Analysis Summary ..............................................................................................................105 15269.05 v
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Acronyms and Abbreviations
Acronym/Abbreviation Definition
AB Assembly Bill
AEP Association of Environmental Processionals
Alquist–Priolo Act Alquist–Priolo Earthquake Zoning Act ALUCP Airport Land Use Commission Plan
ASTM American Society of Testing and Materials
BMP Best Management Practice
CalEEMod California Emissions Estimator Model
CALGreen California Green Building Standards Code, Title 24, Part 11 CAPCOA California Air Pollution Control Officers Association CARB California Air Resources Board
CBC California Building Code
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
City of Santee City
City’s Housing Element City of Santee Housing Element 6th Cycle 2021-2029 CLOMR Conditional Letter of Map Revision
CO Carbon monoxide
Cortese List Government Code Section 65962.5
DIF Development Impact Fee
DOC California Department of Conservation, Division of Land Resource Protection
DPM Diesel particulate matter
EI Expansion index
EPA Environmental Protection Agency
ESA Environmental Site Assessment
FAA Federal Aviation Administration
Farmland Prime Farmland, Unique Farmland, or Farmland of Statewide Importance FEMA Federal Emergency Management Agency
FESA Federal Endangered Species Act
FMMP Farmland Mapping and Monitoring Program
GHG Greenhouse Gas
GUHSD Grossmont Union High School District
HCP Habitat Conservation Plan
Housing Rezone Program Approved Project
LDA Light duty autos
LOS Level of service
LRA Local Responsibility Area
mgd Million gallons per day
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Acronym/Abbreviation Definition
MM Mitigation measure
MRZ Mineral Resource Zone
MS4 Municipal Separate Storm Sewer System
MSCP Multiple Species Conservation Plan
MTS Metropolitan Transit System
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NCCP Natural Community Conservation Plan
NPDES National Pollutant Discharge Elimination System
OEHHA Office of Environmental Health Hazard Assessment
OPR Office of Planning and Research
PDMWD Padre Dam Municipal Water District
PEIR Programmatic Environmental Impact Report
PLF Point Loma Facility
PM Particulate matter
PPV Peak particle velocity
Project/ Proposed Project / Site
17 Cottonwood and Park Project
R-14 Medium-High Density Residential
RAQS Regional Air Quality Strategy
RHNA Regional Housing Needs Assessment
RPS Renewable Portfolio Standard
RWQCB Regional Water Quality Control Board
SANDAG San Diego Association of Governments
Santee City Council Lead Agency
SB Senate Bill
SCS Sustainable Communities Strategy
SDAB San Diego Air Basin
SDAPCD San Diego Air Pollution Control District
SDCRAA San Diego County Regional Airport Authority
SFD Santee Fire Department
SIP State Implementation Plan
SMC Santee Municipal Code
SR State Route
SSD Santee School District
SSP Sustainable Santee Plan
SWQMP Storm Water Quality Management Plan
TAC Toxic air contaminant
TDM Transportation Demand Management
TIA Traffic Impact Assessment
USACE United States Army Corps of Engineers
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Acronym/Abbreviation Definition
VMT Vehicle Miles Traveled
WEAP Worker Environmental Awareness Program
WQIP Water Quality Improvement Program
WRF Water Recycling Facility
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1 Introduction
This document is an Addendum to the City of Santee Housing Element Rezone Program Implementation Program Environmental Impact Report (Santee Housing Element Implementation PEIR) adopted in 2022 by the City of Santee (City). The Santee Housing Element Implementation PEIR and this Addendum, serve as the environmental review for the Cottonwood and Park Project (Project, proposed Project, or Site 17) as required by the California Environmental Quality Act ([CEQA] [Public Resources Code Section 21000 et seq.]) and the CEQA Guidelines (14 California Code of Regulations Sections 15000-15387). Specifically, this addendum addresses minor modifications to Site 17, a proposed multi-family residential development on 22.17 acres of land (City of Santee Assessor’s Parcel No. 381-051-18-00) designated as R-14 zone within the Santee Housing Element Implementation PEIR.
1.1 CEQA Requirements
Pursuant to CEQA Public Resources Code Section 21166 and CEQA Guidelines Section 15162, when an Environmental Impact Report (EIR) has been certified or a Negative Declaration adopted for a project, no subsequent or supplemental EIR or negative declaration shall be prepared for the project unless the lead agency determines that one or more of the following conditions are met:
▪ Substantial project changes are proposed that will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; ▪ Substantial changes would occur with respect to the circumstances under which the project is undertaken that require major revisions to the previous EIR or Negative Declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or
▪ New information of substantial importance that was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the Negative Declaration was adopted shows any of the following:
A. The project will have one or more significant effects not discussed in the previous EIR or Negative Declaration.
B. Significant effects previously examined will be substantially more severe than identified in the previous EIR.
C. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible and would substantially reduce one or more significant effects of the project, but the project proponent declines to adopt the mitigation measures or alternatives.
D. Mitigation measures or alternatives that are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponent declines to adopt the mitigation measures or alternatives.
In the event that one of these conditions would require preparation of a subsequent EIR, but “only minor additions or changes would be necessary to make the EIR adequately apply to the project in the changed situation,” a lead agency may instead issue a supplement to the EIR (14 CCR 15163(a)).
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In the alternative, where the changes or new information will result in no new impacts, or no more severe impacts than any that were disclosed in the EIR, a lead agency “shall prepare an addendum” pursuant to CEQA Guidelines Section 15164. That section states that an addendum should include a “brief explanation of the decision not to prepare a subsequent EIR pursuant to § 15162” supported by substantial evidence (14 CCR 15164(e)). The addendum need not be circulated for public review but may simply be attached to the final EIR (14 CCR 15164(c), 15164(e)).
As the lead agency for the Approved Project and the proposed Project, the City must determine whether the proposed Project creates previously undisclosed significant environmental impacts or a substantial increase in the severity of previously disclosed impacts (14 CCR 15162, 15163, 15164(a), 15088.5(a), and 15088.5(b)). As the following discussion demonstrates, it is appropriate for the City to prepare this Addendum to the Santee Housing Element Rezone Program Implementation PEIR, pursuant to CEQA Guidelines Section 15164, because there are no new impacts or substantial increase in the severity of previously disclosed impacts. 15269.05 1
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2 Project Description
2.1 Project Location and Regional Setting
The approximately 22.17-acre Project site is located in the southeastern part of the City, which is located within the East County region of San Diego County. The Project site is located between Cottonwood Avenue and Park Center Drive and is bound by the San Diego River to the south; Town Center Community Park East to the west; residential uses and Cottonwood Avenue to the east; and Park Center Drive and vacant land to the north (see Figure 1, Project Location). Regional access to the proposed Project is provided via State Route (SR) 67 located approximately 1.6 miles south of the Project site. Local access to the Project is provided via Cottonwood Avenue, Park Center Drive, and River Bluff Drive.
2.2 Project Overview
Approved Project
The City of Santee Housing Element Rezone Program Implementation PEIR (SCH 2021100263) analyzed impacts related to the implementation of Programs 9 and 10 of the City of Santee Housing Element 6th Cycle 2021-2029 (City’s Housing Element), The 6th Cycle Housing Element includes Program 9, which commits the City to evaluate candidate housing sites and rezone as appropriate to achieve adequate housing capacity. As part of this rezoning, a minimum of 25 acres must be rezoned, within 18 months of the adoption of the Housing Element (which occurred on July 14, 2021), to permit by-right (without discretionary action) multifamily development, consistent with Program 10 of the 6th Cycle Housing Element. The Housing Element Rezone Program Implementation was approved by the Santee City Council on October 12, 2022 (Approved Project). These rezone actions, including implementation of a by-right development process for housing that provides qualifying low-income units, were analyzed pursuant to the CEQA. The Santee Housing Element Implementation PEIR was certified by the Santee City Council (lead agency) on October 12, 2022.
Proposed Project
The Proposed Project is Site 17 analyzed in the Santee Housing Element Implementation PEIR located near the southwest corner of Cottonwood Avenue and Park Center Drive in the City of Santee, California (see Figure 1, Project Location and Figure 2, PEIR Rezones Sites) The Assessor’s Parcel Number is 381-051-18-00. The Project is proposing to develop 285 multifamily residential units on approximately 22.17 (gross) acres, plus off-site improvements on approximately 1.18 acres of City road right of way and land owned by the County of San Diego.
The Project would consist of 54 (2-story rowhomes), 136 (3-story interlock townhomes), and 95 (3-story rowhomes), a total of 645 parking spaces, which would include 570 garage parking spaces and 75 open parking spaces (see Figure 3, Site Plan). The total building square footage includes 237,780 ground square feet and 458,530 net square feet. The Project would include a pedestrian connection to a trail located on the southern side of the project site, pocket parks, a playground, and open space. Additionally, a 100-foot buffer from the edge of the riparian habitat associated with the San Diego River would be established within the Project site and would be managed for natural biological values as part of the City of Santee’s Preserve system. The Project would install a storm drain outfall located on County-owned property and will require an easement issued by the County. The Project’s designated zoning is Medium-High Density Residential (R-14), which allows for a density range of 14-22
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dwelling units per acre. The overall density proposed for this project is 12.86 dwelling units per acre. However, approximately 3.5 acres of the Project Site is undevelopable due to mitigation measure MM-BIO-6 and the incorporation of a 100-foot buffer, as discussed above, resulting in a buildable Project Site of 18.75 acres (gross).
Based on the buildable acreage of the Project Site, the overall density proposed for this project is 15.20 dwelling units per developable acre.
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3 Environmental Checklist
1. Project title:
Cottonwood and Park Project
2. Lead agency name and address:
City of Santee
10601 N. Magnolia Avenue
Santee, California 92071
3. Contact person and phone number:
Rachael Lindebrekke
Associate Planner
Planning and Building Department
619.258.4100 x 205
[email protected]
4. Project location:
Cottonwood Avenue & Park Center Drive
Santee, California
APN: 381-051-18-00
5. Project sponsor’s name and address:
City Ventures Homebuilding, LLC.
3121 Michelson Drive, Ste. 150
Irvine, California 92612
6. General plan designation:
TC/R-14 Town Center - Medium High Density Residential
7. Zoning:
R-14 Medium High Density Residential
8. Description of project. (Describe the whole action involved, including but not limited to later phases of the project, and any secondary, support, or off-site features necessary for its implementation. Attach additional sheets if necessary):
The Project is proposing to develop 285 multifamily residential units on approximately 22.17 (gross) acres, plus off-site improvements on approximately 1.18 acres. The Project is located near the southwest corner of Cottonwood Avenue and Park Center Drive in the City of Santee, California. The Accessors Parcel
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Number is 381-051-18-00. The Project would consist of 2-story row homes, 3-story interlock townhomes, and 3-story row homes, a total of 645 parking spaces, which would include 570 garage parking spaces and 75 open parking spaces. Additionally, the Project would include a pedestrian connection to a trail located on the southern side of the Project site, pocket parks, a playground, and open space. A 100-foot buffer from the edge of the riparian habitat associated with the San Diego River would be established within the Project site and would be managed for natural biological values as part of the City of Santee’s Preserve system. A storm drain outfall would be installed on County-owned property and will require an easement issued by the County.
9. Surrounding land uses and setting: Briefly describe the project’s surroundings:
▪ North: Vacant Land/Park Center Drive
▪ South: San Diego River
▪ East: Residential
▪ West: Town Center Community Park
10. Other public agencies whose approval is required (e.g., permits, financing approval, or participation agreement):
▪ California Department of Fish and Wildlife (CDFW) – Section 1601 Lake and Streambed Alteration Agreement for impacts to riparian habitat.
▪ County of San Diego – Easement for the placement of a storm drain outfall on County owned land. ▪ Airport Land Use Commission of San Diego County – Influence Area 1 Consistency Determination for Gillespie Field
▪ Federal Emergency Management Agency (FEMA) - Conditional Letter of Map Revision (CLOMR)
11. Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080.3.1? If so, is there a plan for consultation that includes, for example, the determination of significance of impacts to tribal cultural resources, procedures regarding confidentiality, etc.?
A response letter from the Native American Heritage Commission (NAHC) was received on March 9, 2021, indicating positive results for their search of the Sacred Lands File for the proposed Project area (Appendix D of the Santee Housing Element Implementation PEIR). The NAHC recommended that the City contact the Barona Group of the Capitan Grande and the Viejas Band of Kumeyaay Indians as well as the Kumeyaay Cultural Repatriation Committee. The NAHC also provided a list of other sources of cultural resources to contact for information regarding known and recorded sites (see Appendix D of the Santee Housing Element Implementation PEIR).
Based on the NAHC response, a tribal cultural resource is known in the vicinity of the Rezone Sites. Tribal cultural resources may include sacred lands, burial grounds, archaeological sites, and other areas of cultural significance. Pursuant to Assembly Bill (AB) 52 and Senate Bill (SB) 18, on December 3, 2021, the City notified California Native American tribes identified by the NAHC or included on the City’s list of tribes seeking notice of projects subject to CEQA review. The City received no requests for consultation regarding the Project’s potential impacts on tribal cultural resources.
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Determination (To be completed by the Lead Agency)
On the basis of this initial evaluation:
☐ No substantial changes are proposed in the project and there are no substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous approved ND or MND or certified EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects. Also, there is no “new information of substantial importance” as that term is used in CEQA Guidelines Section 15162(a)(3). Therefore, the previously adopted ND or MND or previously certified EIR adequately discusses the potential impacts of the project without modification.
☒ No substantial changes are proposed in the project and there are no substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous approved ND or MND or certified EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects. Also, there is no “new information of substantial importance” as that term is used in CEQA Guidelines Section 15162(a)(3). Therefore, the previously adopted ND, MND or previously certified EIR adequately discusses the potential impacts of the project; however, minor changes require the preparation of an ADDENDUM. ☐ Substantial changes are proposed in the project or there are substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous ND, MND or EIR due to the involvement of significant new environmental effects or a substantial increase in the severity of previously identified significant effects. Or, there is “new information of substantial importance,” as that term is used in CEQA Guidelines Section 15162(a)(3). However, all new potentially significant environmental effects or substantial increases in the severity of previously identified significant effects are clearly reduced to below a level of significance through the incorporation of mitigation measures agreed to by the project applicant.
Therefore, a SUBSEQUENT MND is required.
☐ Substantial changes are proposed in the project or there are substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous environmental document due to the involvement of significant new environmental effects or a substantial increase in the severity of previously identified significant effects. Or, there is “new information of substantial importance,” as that term is used in CEQA Guidelines Section 15162(a)(3). However, only minor changes or additions or changes would be necessary to make the previous EIR adequate for the project in the changed situation.
Therefore, a SUPPLEMENTAL EIR is required.
☐ Substantial changes are proposed in the project or there are substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous environmental document due to the involvement of significant new environmental effects or a substantial increase in the severity of previously identified significant effects. Or, there is “new information of substantial importance,” as that term is used in CEQA Guidelines Section 15162(a)(3). Therefore, a SUBSEQUENT EIR is required.
Section 15168(c) of the CEQA Guidelines provides that when the lead agency adopts a program EIR, subsequent activities in the program are examined in light of the program EIR to determine whether an additional environmental document must be prepared. Pursuant to Section 21166 of CEQA and Section 15162 of the CEQA
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Guidelines, the lead agency shall not prepare a subsequent or supplemental EIR unless the agency determines that one or more of the following conditions are met for the project:
Substantial project changes are proposed that will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;
Substantial changes would occur with respect to the circumstances under which the project is undertaken that require major revisions to the previous EIR or Negative Declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or
New information of substantial importance that was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the Negative Declaration was adopted shows any of the following:
a. The project will have one or more significant effects not discussed in the previous EIR or Negative Declaration;
b. Significant effects previously examined will be substantially more severe than identified in the previous EIR; c. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponent declines to adopt the mitigation measures or alternatives; or d. Mitigation measures or alternatives that are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponent declines to adopt the mitigation measures or alternatives.
Where none of the conditions specified in Section 15162 are present, the lead agency does not need to prepare a subsequent or supplemental EIR (CEQA Guidelines Section 15162(a)), but may prepare a negative declaration, an addendum, or no further CEQA documentation. Section 15164 of the CEQA Guidelines states that an addendum to an EIR shall be prepared “if some changes or additions are necessary, but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred.” In accordance with the CEQA Guidelines, the City has determined that an Addendum to the PEIR is the appropriate environmental document for the Project. This Addendum reviews the changes proposed by the Project and any pertinent changes to the circumstances under which the Project is undertaken that have occurred since the PEIR was certified. It also reviews any new information of substantial importance that was not known and could not have been known with exercise of reasonable diligence at the time that the PEIR was certified. It further examines whether, as a result of any changes or any new information, a subsequent or supplemental EIR may be required. This examination includes an analysis of the provisions of Section 21166 of CEQA and Section 15162 of the CEQA Guidelines and their applicability to the Project.
Signature Date
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Evaluation of Environmental Impacts
A finding of “No New Impact/No Impact” means that the potential impact was fully analyzed and/or mitigated in the prior CEQA document and no new or different impacts will result from the proposed activity.
A brief explanation is required for all answers except “No New Impact/No Impact” answers that are adequately supported by the information sources a lead agency cites in the parentheses following each question. A “No New Impact/No Impact” answer is adequately supported if the referenced information sources show that the impact simply does not apply to projects like the one involved (e.g., the project falls outside a fault rupture zone). A “No New Impact/No Impact” answer should be explained where it is based on project-specific factors as well as general standards (e.g., the project will not expose sensitive receptors to pollutants, based on a project-specific screening analysis).
A finding of “New Mitigation is Required” means that the project may have a new potentially significant impact on the environment or a substantially more severe impact than analyzed in the previously approved or certified CEQA document and that new mitigation is required to address the impact.
A finding of “New Potentially Significant Impact” means that the project may have a new potentially significant impact on the environment or a substantially more severe impact than analyzed in the previously approved or certified CEQA document that cannot be mitigated to below a level of significance or be avoided.
A finding of “Reduced Impact” means that a previously infeasible mitigation measure is now available, or a previously infeasible alternative is now available that will reduce a significant impact identified in the previously prepared environmental document.
All answers must take account of the whole action involved, including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts.
Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063(c)(3)(D). In this case, a brief discussion should identify the following:
a. Earlier Analyses Used. Identify and state where they are available for review. b. Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis. Describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the proposed action. c. Infeasible Mitigation Measures. Since the previous EIR was certified or previous ND or MND was adopted, discuss any mitigation measures or alternatives previously found not to be feasible that would in fact be feasible or that are considerably different from those previously analyzed and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measures or alternatives.
d. Changes in Circumstances. Since the previous EIR was certified or previous ND or MND was adopted, discuss any changes in the project, changes in circumstances under which the project is undertaken and/or "new information of substantial importance" that cause a change in conclusion regarding one or more effects discussed in the original document.
Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g., general plans, zoning ordinances). Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated.
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Supporting Information Sources. A source list should be attached, and other sources used or individuals contacted should be cited in the discussion.
This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies should normally address the questions from this checklist that are relevant to a project’s environmental effects in whatever format is selected.
The explanation of each issue should identify:
a. the significance criteria or threshold, if any, used to evaluate each question; b. differences between the proposed activity and the previously approved project described in the approved ND or MND or certified EIR; and
c. the previously approved mitigation measure identified, if any, to reduce the impact to less than significant.
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New Potentially
Significant Impact
New Impact
Requiring New
Mitigation
No New Impact/No
Impact Reduced Impact
I. AESTHETICS – Except as provided in Public Resources Code Section 21099, would the Project:
Issue 1: Have a substantial adverse effect on a
scenic vista?
Issue 2: Substantially damage scenic
resources, including, but not limited to,
trees, rock outcroppings, and historic
buildings within a state scenic highway?
Issue 3: 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?
Issue 4: Create a new source of substantial
light or glare which would adversely affect
day or nighttime views in the area?
II. AGRICULTURE AND FORESTRY RESOURCES – In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the Project:
Issue 1: Convert Prime Farmland, Unique
Farmland, or Farmland of Statewide
Importance (Farmland), as shown on the
maps prepared pursuant to the Farmland
Mapping and Monitoring Program of the
California Resources Agency, to nonagricultural use?
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New Potentially
Significant Impact
New Impact
Requiring New
Mitigation
No New Impact/No
Impact Reduced Impact
Issue 2: Conflict with existing zoning for
agricultural use, or a Williamson Act
contract?
Issue 3: Conflict with existing zoning for, or
cause rezoning of, forest land (as defined
in Public Resources Code Section
12220(g)), timberland (as defined by
Public Resources Code Section 4526), or
timberland zoned Timberland Production
(as defined by Government Code Section
51104(g))?
Issue 4: Result in the loss of forest land or
conversion of forest land to non-forest
use?
Issue 5: Involve other changes in the existing
environment which, due to their location or
nature, could result in conversion of
Farmland, to non-agricultural use or
conversion of forest land to non-forest
use?
III. AIR QUALITY – Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the Project:
Issue 1: Conflict with or obstruct
implementation of the applicable air
quality plan?
Issue 2: 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?
Issue 3: Expose sensitive receptors to
substantial pollutant concentrations?
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New Potentially
Significant Impact
New Impact
Requiring New
Mitigation
No New Impact/No
Impact Reduced Impact
Issue 4: Result in other emissions (such as
those leading to odors) adversely affecting
a substantial number of people?
IV. BIOLOGICAL RESOURCES – Would the Project:
Issue 1: Have a substantial adverse effect,
either directly or through habitat
modifications, on any species identified as
a candidate, sensitive, or special status
species in local or regional plans, policies,
or regulations, or by the California
Department of Fish and Wildlife or U.S.
Fish and Wildlife Service?
Issue 2: Have a substantial adverse effect on
any riparian habitat or other sensitive
natural community identified in local or
regional plans, policies, regulations, or by
the California Department of Fish and
Wildlife or U.S. Fish and Wildlife Service?
Issue 3: 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?
Issue 4: 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?
Issue 5: Conflict with any local policies or
ordinances protecting biological resources,
such as a tree preservation policy or
ordinance?
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New Potentially
Significant Impact
New Impact
Requiring New
Mitigation
No New Impact/No
Impact Reduced Impact
Issue 6: Conflict with the provisions of an
adopted Habitat Conservation Plan,
Natural Community Conservation Plan, or
other approved local, regional, or state
habitat conservation plan?
V. CULTURAL RESOURCES – Would the Project:
Issue 1: Cause a substantial adverse change
in the significance of a historical resource
pursuant to Section 15064.5?
Issues 2 and 4: Cause a substantial adverse
change in the significance of an
archaeological resource pursuant to
Section 15064.5; religious uses or tribal
cultural resources?
Issue 3: Disturb any human remains, including
those interred outside of formal
cemeteries?
VI. ENERGY – Would the Project:
Issue 1: Result in potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary consumption of
energy resources, during project
construction or operation?
Issue 2: Conflict with or obstruct a state or
local plan for renewable energy or energy
efficiency?
VII. GEOLOGY AND SOILS – Would the Project:
Issue 1: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
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New Potentially
Significant Impact
New Impact
Requiring New
Mitigation
No New Impact/No
Impact Reduced Impact
i) Rupture of a known earthquake fault,
as delineated on the most recent
Alquist-Priolo Earthquake Fault Zoning
Map issued by the State Geologist for
the area or based on other substantial
evidence of a known fault? Refer to
Division of Mines and Geology Special
Publication 42.
ii) Strong seismic ground shaking?
iii) Seismic-related ground failure,
including liquefaction?
iv) Landslides?
Issue 2: Result in substantial soil erosion or
the loss of topsoil?
Issue 3: Be located on a geologic unit or soil
that is unstable, or that would become
unstable as a result of the Project, and
potentially result in on- or off-site landslide,
lateral spreading, subsidence, liquefaction
or collapse?
Issue 4: Be located on expansive soil, as
defined in Table 18-1-B of the Uniform
Building Code (1994), creating substantial
direct or indirect risks to life or property?
Issue 5: Have soils incapable of adequately
supporting the use of septic tanks or
alternative waste water disposal systems
where sewers are not available for the
disposal of waste water?
Issue 6: Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
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New Potentially
Significant Impact
New Impact
Requiring New
Mitigation
No New Impact/No
Impact Reduced Impact
VIII. GREENHOUSE GAS EMISSIONS – Would the Project:
Issue 1: Generate greenhouse gas emissions,
either directly or indirectly, that may have a
significant impact on the environment?
Issue 2: Conflict with an applicable plan, policy
or regulation adopted for the purpose of
reducing the emissions of greenhouse
gases?
IX. HAZARDS AND HAZARDOUS MATERIALS – Would the Project:
Issue 1: Create a significant hazard to the
public or the environment through the
routine transport, use, or disposal of
hazardous materials?
Issue 2: 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?
Issue 3: Emit hazardous emissions or handle
hazardous or acutely hazardous materials,
substances, or waste within one-quarter
mile of an existing or proposed school?
Issue 4: Be located on a site that is included
on a list of hazardous materials sites
compiled pursuant to Government Code
Section 65962.5 and, as a result, would it
create a significant hazard to the public or
the environment?
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New Potentially
Significant Impact
New Impact
Requiring New
Mitigation
No New Impact/No
Impact Reduced Impact
Issue 5: For a project located within 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 result in a safety hazard or
excessive noise for people residing or
working in the Project area?
Issue 6: Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan?
Issue 7: Expose people or structures, either
directly or indirectly, to a significant risk of
loss, injury or death involving wildland
fires?
X. HYDROLOGY AND WATER QUALITY – Would the Project:
Issue 1: Violate any water quality standards or
waste discharge requirements or
otherwise substantially degrade surface or
ground water quality?
Issue 2: Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the
Project may impede sustainable
groundwater management of the basin?
Issue 3: 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;
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New Potentially
Significant Impact
New Impact
Requiring New
Mitigation
No New Impact/No
Impact Reduced Impact
ii) substantially increase the rate or
amount of surface runoff in a manner
which would result in flooding onor 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?
Issue 4: In flood hazard, tsunami, or seiche
zones, risk release of pollutants due to
Project inundation?
Issue 5: Conflict with or obstruct
implementation of a water quality control
plan or sustainable groundwater
management plan?
XI. LAND USE AND PLANNING – Would the Project:
Issue 1: Physically divide an established
community?
Issue 2: 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?
XII. MINERAL RESOURCES – Would the Project:
Issue 1: Result in the loss of availability of a
known mineral resource that would be of
value to the region and the residents of the
state?
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New Potentially
Significant Impact
New Impact
Requiring New
Mitigation
No New Impact/No
Impact Reduced Impact
Issue 2: Result in the loss of availability of a
locally important mineral resource recovery
site delineated on a local general plan,
specific plan or other land use plan?
XIII. NOISE – Would the Project result in:
Issue 1: 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?
Issue 2: Generation of excessive groundborne
vibration or groundborne noise levels?
Issue 3: 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?
XIV. POPULATION AND HOUSING – Would the Project:
Issue 1: Induce substantial unplanned
population growth in an area, either
directly (for example, by proposing new
homes and businesses) or indirectly (for
example, through extension of roads or
other infrastructure)?
Issue 2: Displace substantial numbers of
existing people or housing, necessitating
the construction of replacement
housing elsewhere?
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New Potentially
Significant Impact
New Impact
Requiring New
Mitigation
No New Impact/No
Impact Reduced Impact
XV. PUBLIC SERVICES – Would the Project:
Issue 1: Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
Fire protection?
Police protection?
Schools?
Parks?
Other public facilities?
XVI. RECREATION
Issue 1: Would the Project increase the use of
existing neighborhood and regional parks
or other recreational facilities such that
substantial physical deterioration of the
facility would occur or be accelerated?
Issue 2: Does the Project include recreational
facilities or require the construction or
expansion of recreational facilities which
might have an adverse physical effect on
the environment?
XVII. TRANSPORTATION – Would the Project:
Issue 1: Conflict with a program, plan,
ordinance, or policy addressing the
circulation system, including transit,
roadway, bicycle, and pedestrian facilities?
Issue 2: Conflict or be inconsistent with CEQA
Guidelines Section 15064.3,
subdivision (b)?
Issue 3: Substantially increase hazards due to
a geometric design feature (e.g., sharp
curves or dangerous intersections) or
incompatible uses (e.g., farm equipment)?
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New Potentially
Significant Impact
New Impact
Requiring New
Mitigation
No New Impact/No
Impact Reduced Impact
Issue 4: Result in inadequate emergency
access?
XVII. TRIBAL CULTURAL RESOURCES
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:
Issue 1: Listed or eligible for listing in the
California Register of Historical Resources,
or in a local register of historical resources
as defined in Public Resources Code
Section 5020.1(k), or
Issue 2: 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 Resources Code
Section 5024.1, the lead agency shall
consider the significance of the resource
to a California Native American tribe.
XVII. UTILITIES AND SERVICE SYSTEMS – Would the Project:
Issue 1: Require or result in the relocation or
construction of new or expanded water,
waste water treatment or storm water
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which could
cause significant environmental effects?
Issue 3: Have sufficient water supplies
available to serve the Project and
reasonably foreseeable future
development during normal, dry, and
multiple dry years?
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New Potentially
Significant Impact
New Impact
Requiring New
Mitigation
No New Impact/No
Impact Reduced Impact
Issue 3: Result in a determination by the waste
water treatment provider which serves or
may serve the Project that it has adequate
capacity to serve the Project’s projected
demand in addition to the provider’s
existing commitments?
Issue 4: 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?
Issue 5: Comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste?
XIX. WILDFIRE – If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the Project:
Issue 1: Substantially impair an adopted
emergency response plan or emergency
evacuation plan?
Issue 2: Due to slope, prevailing winds, and
other factors, exacerbate wildfire risks,
and thereby expose Project occupants to
pollutant concentrations from a wildfire or
the uncontrolled spread of a wildfire?
Issue 3: Require the installation or
maintenance of associated infrastructure
(such as roads, fuel breaks, emergency
water sources, power lines or other
utilities) that may exacerbate fire risk or
that may result in temporary or ongoing
impacts to the environment?
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New Potentially
Significant Impact
New Impact
Requiring New
Mitigation
No New Impact/No
Impact Reduced Impact
Issue 4: 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?
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3.1 Aesthetics
3.1.1 Analysis
Issue 1: Scenic Vistas
Would the Project have a substantial adverse effect on a scenic vista? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR acknowledged that certain rezone sites, including Site 17, are largely undeveloped open land located north of the San Diego River and that development within these sites could impede views to and from the river. The PEIR noted that future ministerial and discretionary development would be required to adhere to relevant portions of the Santee Municipal Code (SMC) including Chapter 13.08, et.seq., which establishes the City’s development review procedures. The PEIR further required development adjacent to the San Diego River to be subject to applicable Draft Santee MCSP Subarea Plan setback and buffer requirements. The Santee Housing Element Implementation PEIR concluded that the development of Rezone Sites would result in less-than-significant impacts on scenic vistas because the development standards would ensure consistency with General Plan policies and development regulations from the Town Center Specific Plan.
Additionally, the Development Review process consistent with SMC 13.08 would ensure that future development would not have a substantial adverse effect on scenic vistas and views.
Proposed Project Analysis
The proposed Project would substantially alter the existing visual landscape by increasing density, intensity of use, and human activity on the Project site and in the Project area. The proposed Project would incorporate open space buffers adjacent to the City of Santee’s Preserve system and the San Diego River to maintain the scenic value of these areas. As mentioned, a 100-foot buffer from the edge of the riparian habitat associated with the San Diego River would be established within the Project site. The Santee Housing Element Implementation PEIR specifically addressed the potential impacts to views to and from the San Diego River by development on rezone sites near the San Diego River. Additionally, the Project has been designed to recognize the San Diego River as a focal point by orienting buildings toward the open space, with some of the buildings oriented at an angle so additional units get visual access to the open space. The Project design incorporates open space in the form of passive uses, view parks, communal space and pedestrian trails. Impacts to scenic vistas were determined to be less than significant because development of the site would be required to comply with General Plan policies, design review procedures and adjacency requirements of the Draft Santee MSCP Subarea Plan. In addition, the Santee Housing Element Implementation PEIR concluded that development would be consistent with surrounding areas and would not affect existing views. Because the proposed Project would implement General Plan policies, design review procedures and adjacency requirements of the Draft Santee MCSP Subarea Plan, and the Project would maintain the scenic value of the area through the 100-foot buffer, the proposed Project’s impact would be the same as that envisioned for Site 17 under the Santee Housing Element Implementation PEIR. Therefore, the proposed Project would not result in any new impacts, no previously identified significant impacts would substantially increase in severity, and potential impacts to scenic vistas would remain less than significant.
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Issue 2: Scenic Resources
Would the Project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State Scenic Highway?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that the ministerial and discretionary development of Rezone Sites would not be located near a designated State Scenic Highway. The closest designated State Scenic Highway is the segment of SR-52 between Santo Road east to Mast Boulevard, which is located in the City of San Diego. Due to its distance and intervening topography, the PEIR concluded that the Rezone Sites would not be seen from this location. Further, the PEIR concluded that adherence to the requirement for development review consistent with Municipal Code Chapter 13.08 and the Town Center Specific Plan development regulations would ensure consistency with General Plan policies and applicable design and development review requirements. Application of these regulatory requirements would ensure that future development would not degrade scenic resources including but not limited to trees, rock outcroppings, and historic buildings within a State Scenic Highway. Impacts would be less than significant.
Proposed Project Analysis
The proposed Project would not substantially damage scenic resources within a State Scenic Highway. The proposed development would be within an urbanized area. Additionally, the proposed Project would be consistent with Municipal Code Chapter 13.08 which would ensure consistency with General Plan policies and applicable design and development review requirements. Because the proposed Project would implement those regulations, and the Project would not degrade scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within State Scenic Highway, the impacts would be the same as that envisioned for Site 17 under the Santee Housing Element Implementation PEIR. Therefore, the proposed Project would not result in any new impacts, no previously identified significant impacts would substantially increase in severity, and potential impacts to scenic resources would remain less than significant.
Issue 3: Visual Character or Quality
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 point). If the Project is in an urbanized area, would the Project conflict with applicable zoning and other regulations governing scenic quality?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that the ministerial and discretionary development of Rezone Sites would not substantially degrade the existing visual character or quality of public views, since the majority of the Rezone Sites are located near the outer urbanization area of the City. However, the PEIR acknowledges that residential development of Site 17 could affect the visual character and quality of views of the San Diego River. Further, the introduction of medium-density residential development on Site 17 would change the visual makeup of the Town Center and surrounding area. The PEIR concluded that adherence to regulatory requirements including Development Review consistent with municipal Code Chapter 13.08 and implementation
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of the Town Center Specific Plan development regulations would ensure that future development would not substantially degrade scenic resources. Impacts would be less than significant.
Proposed Project Analysis
The proposed Project could substantially degrade the existing visual character or quality of public views and quality of public views toward the San Diego River. While the tallest buildings would be up to 37 feet tall, open space buffers adjacent to the San Diego River would maintain the scenic value of these areas. As mentioned, a 100-foot buffer from the edge of the riparian habitat associated with the San Diego River would be established within the Project site, which would help protect the visual character and quality of the area.
Building heights would not exceed allowable building heights per the SMC. However, the Project site is designated R-14, and development of medium-high density residential at this location was considered and approved under the Town Center Specific Plan. Further, the proposed Project would undergo Development Review that would ensure the proposed Project is consistent with the General Plan policies and applicable design requirements of the Town Center Specific Plan. Thus, the proposed Project would not conflict with applicable zoning and other regulations governing scenic quality. The Project’s impacts would be the same as that envisioned for Site 17 under the Santee Housing Element Implementation PEIR. Therefore, the proposed Project would not result in any new impacts or increase the severity of impacts, and potential impacts to visual quality would remain less than significant.
Issue 4: Light or Glare
Would the Project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that the impacts from ministerial and discretionary development of the Rezone Sites would be less than significant in regard to creating a new source of substantial light or glare. The majority of the Rezone Sites are located in urbanized areas and would be required to comply with Santee Municipal Code standards related to light and glare. These standards require outdoor lighting be directed away from adjacent properties and set in a way to avoid any detriment to the surrounding area. Further, the Community Enhancement Element of the General Plan includes the standard for lighting and signage to minimize spillover of lighting through use of directional, cut-off and non-glare fixtures. All future projects must comply with regulatory requirements, such as the General Plan and undergo development review.
Therefore, the Santee Housing Element Implementation PEIR concluded that with adherence to regulatory requirements impacts related to creating a new source of substantial light or glare would be less than significant.
Proposed Project Analysis
Currently, there are no existing lighting sources on the Project site since it is undeveloped and vacant. However, the proposed Project is located within an urbanized area with existing sources of light and glare. The proposed Project is a residential development which would include exterior lighting for safety and security purposes. The project would comply with the California Green Building Standards, the City’s Municipal Code and General Plan requirements with respect to lighting. Site lighting would incorporate cutoff lenses to keep light from spilling over onto adjacent properties and to keep light sources from being visible on or directing light rays onto adjoining property as
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established in Section 13.08.070(G) of the City’s Municipal Code. Therefore, based on compliance with local requirements, the Project’s impacts would be the same as that envisioned for Site 17 under the Santee Housing Element Implementation PEIR. Therefore, the proposed Project would not result in any new impacts or increase the severity of impacts, and potential impacts to associated with light and glare would remain less than significant.
3.1.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR
No mitigation measures.
3.2 Agriculture and Forestry Resources
3.2.1 Analysis
Issues 1 through 5:
Would the Project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?
Would the Project conflict with existing zoning for agricultural use, or a Williamson Act contract? Would the Project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))? Would the Project result in the loss of forest land or conversion of forest land to non-forest use? Would the Project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use? City of Santee Housing Element Implementation PEIR Analysis The California Department of Conservation, Division of Land Resource Protection (DOC) has not identified the Rezone Sites as Prime Farmland or Unique Farmland through its Farmland Mapping and Monitoring Program (FMMP). The majority of the Rezone Sites and the surrounding area are designated as “Urban and Built-up Land,” “Other Land,” and “Grazing Land” by the DOC and are not considered a significant farmland resource under CEQA. Although a few Rezone Sites are designated as “Farmland of Local Importance”, including the Project site (Site 17), there is no recent history of agricultural use at those sites Additionally, none of the Rezone Sites are subject to a Williamson Act Contract or located on forestland within the City. The City does not possess any zoning designations for forestland, timberland, or timberland production zones. Therefore, the Santee Housing Element Implementation PEIR determined no impacts to agricultural and forestry resources would occur and included the discussion of agricultural and forestry resources in the Effects Found Not to be Significant analysis.
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Proposed Project Analysis
According to the FMMP, the proposed Project is designated “Farmland of Local Importance” and “Other Land,” however as noted above, there is no recent history of agricultural use at the proposed Project site (DOC 2022). In this case, the DOC’s designation does not recognize the fact that the site has a land use designation and zoning for residential uses and is surrounded on three sides by residential land uses. This suggests a potential use for farmland is highly unlikely to occur because of the site location. Additionally, the proposed Project site is not located on land subject to a Williamson Act Land Use Contract nor forestland or timberland. Therefore, the proposed Project would not result in any new impacts or increase the severity of impacts related to agricultural and forestry resources and no impacts associated with agricultural or forestry resources would occur.
3.2.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR
No mitigation measures required.
3.3 Air Quality
The analysis in this section was completed in compliance with the following report:
▪ Cottonwood & Park Air Quality, Greenhouse Gas, and Energy Impacts Study for City Ventures, prepared in April 30, 2025 by MD Acoustics, LLC and included as Appendix A of this Addendum.
3.3.1 Analysis
Issue 1: Consistency with Air Quality Plans
Would the Project conflict with or obstruct implementation of the applicable air quality plan? City of Santee Housing Element Implementation PEIR Analysis The San Diego Air Pollution Control District (SDAPCD) and San Diego Association of Governments (SANDAG) are responsible for developing and implementing the clean air plans for attainment and maintenance of the ambient air quality standards in the San Diego Air Basin (SDAB), specifically the 2022 Regional Air Quality Strategy (RAQS) and the 2020 Plan for Attaining the National Ambient Air Quality Standards (NAAQS) for Ozone, which is part of the State Implementation Plan (SIP).
The San Diego-specific SIP components and RAQS rely on information from the California Air Resources Board (CARB) and SANDAG, including mobile and area source emissions, as well as information regarding projected growth in both the County as a whole and the cities in the County, to project future emissions and determine the strategies necessary for the reduction of emissions through regulatory controls. CARB mobile source emission projections and SANDAG growth projections are based on population, vehicle trends, and land use plans developed by the County and the cities in the County as part of their General Plans.
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If a project proposes development that is greater than that anticipated in the local adopted plan and SANDAG’s growth projections, the project has potential to conflict with the SIP and RAQS and may contribute to a potentially significant cumulative impact on air quality.
The Santee Housing Element Implementation PEIR determined that the Rezoning Sites would conflict with or obstruct implementation of the applicable air quality plan since there would be an increase in development and in traffic generation. Overall, the development would exceed the assumptions used to develop the RAQS, therefore the PEIR concluded that the impacts would be significant and unavoidable.
Proposed Project Analysis
The City’s General Plan Land Use Map and Zoning Map designates the Project site as R-14, which allows for a density range of 14-22 dwelling units per acre (City of Santee 2017). The proposed Project would be consistent with the existing General Plan and zoning for the City of Santee as well as the land use assumed in the Santee Housing Element Implementation PEIR. Furthermore, operational emissions generated by the Project would be below the established significance thresholds for criteria pollutants as shown in Table
3.3.1-2. Therefore, the proposed Project would not result in a new or substantially more severe impact that would conflict with or obstruct implementation of the RAQS. Impacts would be less than significant.
Issue 2: Cumulative New Increases of Criteria Pollutants 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 (including releasing emissions which exceed quantitative threshold for ozone precursors)? City of Santee Housing Element Implementation PEIR Analysis According to the Santee Housing Element Implementation PEIR, the construction and operational emissions associated with the individual Rezone Sites would be less than the applicable thresholds for all criteria pollutants compared to the SDAPCD project-level screening levels. Therefore, project-level impacts for each individual Rezone Site would be less than significant. However, the scale and extent of construction activities associated with buildout of the Rezone Sites may result in some instances where future development would occur simultaneously and would cumulatively exceed the relevant thresholds. Therefore, cumulative constructionrelated regional air quality impacts would be potentially significant.
The City would require future developments to implement construction Best Management Practices consistent with SDAPCD rules and regulations. Additionally, the construction of future developments shall comply with California Code of Regulations, Title 12, Section 2449 and SDAPCD rules 51, 52, 54, 55, and 67. Though a sitespecific project may not exceed the SDAPCD regional significance threshold, the scale and extent of construction activities would create impacts associated with criteria air pollutants that are significant and unavoidable. The PEIR included mitigation measure MM-AQ-1 to be applied as a requirement of the City’s objective design and performance standards adopted as part of the project. The Santee Housing Element Implementation PEIR concluded for operational emissions from the project as a whole, impacts would remain significant and unavoidable even with mitigation because the significant air quality impact stems from an inconsistency between the Project and the adopted land use plan upon which the RAQS is based.
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Proposed Project Analysis
Construction
Emissions from construction of the proposed Project were estimated using California Emissions Estimator Model (CalEEMod) Version 2022.1.1.22. Default values provided by the program were used where detailed proposed Project information was not available. The Project would comply with SDAPCD Rules 52, 54, and 55 to reduce fugitive dust emissions during construction, and mitigation measure MM-AQ-1 from the PEIR would apply to this project. Construction would begin no earlier than August 2024 and would last approximately 18 months. A detailed depiction of the construction scenario assumptions—including information regarding phasing, equipment used during each phase, haul trucks, vendor trucks, and worker vehicles—is included in Appendix A. Table 3.3.1-1 shows the estimated maximum daily construction emissions associated with the proposed Project prior to implementation of MM-AQ-1 but with adherence to SDAPCD Rules 51, 52, 54, 55, 67, and 1200.
Table 3.3.1-1. Estimated Maximum Daily Construction Criteria Air Pollutant Emissions
Year VOC NOx CO SO2 PM10 PM2.5
Daily Construction Emissions (pounds/day)
2024 3.80 47.10 35.60 0.12 9.41 5.45
2025 2.74 14.70 31.90 0.04 4.20 1.33
2026 72.43 7.33 10.59 0.01 0.66 0.33
Maximum 72.43 47.10 35.60 0.12 9.41 5.45
SDAPCD Threshold 75 250 550 250 100 55
Exceeds Threshold? No No No No No No
Annual Construction Emissions (tons/year)
2024 0.14 1.26 1.43 0.00 0.26 0.11
2025 0.35 1.88 3.83 0.00 0.53 0.17
2026 1.28 0.07 0.14 0.00 0.01 0.01
Maximum 1.28 1.88 3.83 0.00 0.53 0.17
SDAPCD Threshold 13.7 40 100 40 15 10
Exceeds Threshold? No No No No No No
Source: CalEEMod Version 2022.1.1.22, Appendix A
The grading phase incorporates anticipated emissions reductions required by SDAPCD Rules 52, 54, and 55 to reduce fugitive dust.
The architectural coating phase incorporate anticipated emissions reductions required by SDAPCD Rule 67.0.1.
As shown in Table 3.3.1-1, the estimated maximum daily construction emissions would not exceed the SDAPCD thresholds of significance. Further, Table 3.3.1-1 shows more conservative results, since implementation of MMAQ-1 would further reduce emissions. Therefore, no new significant impacts would occur, and no previously identified significant air quality impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant with mitigation.
Operation
Emissions from operation of the proposed Project were also estimated using CalEEMod. The operating emissions were based on year 2026, which is the anticipated opening year for the project.
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Area Sources
Area sources include emissions from consumer products, landscape equipment and architectural coatings.
Landscape maintenance includes fuel combustion emissions from equipment such as lawn mowers, rototillers, shredders/grinders, blowers, trimmers, chain saws, and hedge trimmers, as well as air compressors, generators, and pumps. As specifics were not known about the landscaping equipment fleet, CalEEMod defaults were used to estimate emissions from landscaping equipment.
The architectural coating phase involves the greatest release of VOCs. The emissions modeling for the Project includes the use of low-VOC paint (50 grams per liter [g/L] for not flat coatings for the buildings and 100 [g/L] for parking lot striping) as required by SDAPCD Rule 67.0.1 Energy Sources
2022.1.1.22 CalEEMod defaults were utilized.
Mobile Sources
Mobile sources include emissions from the additional vehicle miles generated from the proposed Project. The vehicle trips associated with the proposed Project are based upon the trip generation rates provided by SANDAG’s Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region (SANDAG 2002). The trip generation shows a rate of 2,368 trips per day.
The program then applies the emission factors for each trip, which is provided by the EMFAC2017 model, to determine the vehicular traffic pollutant emissions. The CalEEMod default trip lengths were used in this analysis. Please see CalEEMod output comments sections in Appendix A for details.
Table 3.3.1-2 presents the proposed Project’s estimated maximum daily operational criteria air pollutant emissions. The values shown are the maximum summer or winter daily emissions (i.e., worst-case) results from CalEEMod.
Table 3.3.1-2. Estimated Maximum Daily Operational Criteria Air Pollutant Emissions Activity VOC NOx CO SO2 PM10 PM2.5
Daily Operation Emissions (pounds/day)
Area Sources1 12.70 0.30 32.80 0.00 0.03 0.02
Energy Usage2 0.11 1.86 0.79 0.01 0.15 0.15
Mobile Sources3 9.53 7.10 67.10 0.16 14.00 3.63
Total Emissions 22.34 9.26 100.69 0.17 14.18 3.80
SDAPCD Threshold 75 250 550 250 100 55
Exceeds Threshold? No No No No No No
Annual Operation Emissions (tons/year)
Area Sources1 1.96 0.03 2.95 0.00 0.00 0.00
Energy Usage2 0.02 0.34 0.14 0.00 0.03 0.03
Mobile Sources3 1.68 1.28 11.60 0.03 2.54 0.66
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Table 3.3.1-2. Estimated Maximum Daily Operational Criteria Air Pollutant Emissions Activity VOC NOx CO SO2 PM10 PM2.5
Total Emissions 3.66 1.65 14.69 0.03 2.57 0.69
SDAPCD Thresholds 13.7 40 100 40 15 10
Exceeds Threshold? No No No No No No
Source: CalEEMod Version 2022.1.1.22, Appendix A
1 Area sources consist of emissions from consumer products, architectural coatings, and landscaping equipment. 2 Energy usage consists of emissions from on-site natural gas usage. 3 Mobile sources consist of emissions from vehicles and road dust As shown in Table 3.3.1-2, emissions from the operation of the proposed Project would not exceed SDAPCD thresholds. Therefore, no new significant impacts would occur, and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant with mitigation.
Issue 3: Sensitive Receptors
Would the Project expose sensitive receptors to substantial pollutant concentrations? City of Santee Housing Element Implementation PEIR Analysis Toxic air contaminants (TACs) and fine particulate matter (PM2.5) are defined as airborne pollutants that may pose a present or potential hazard to human health and can potentially cause a wide range of health effects.
Additionally, SDAPCD identified local community risks from air pollutants which include exposure to TACs and PM2.5 concentrations. Gas stations, dry cleaners, diesel backup generators, on-road motor vehicles (e.g., trucks and cars) and off-road sources (e.g., construction equipment, ships, and trains) are common sources of TACs and PM2.5. The future development of residential uses is generally not a source of TACs. The Santee Housing Element Implementation PEIR concluded that the buildout of the Project would not result in a CO hotspot. Additionally, construction and operation of future development would not result in the exposure of sensitive receptors to TACs from construction activities, stationary sources, or mobile sources, and impacts would be less than significant.
Proposed Project Analysis
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 CARB, include children, the elderly, athletes, and people with cardiovascular and chronic respiratory diseases. As such, sensitive receptors include residences, schools, playgrounds, child-care centers, athletic facilities, long-term health-care facilities, rehabilitation centers, convalescent centers, and retirement homes. The closest sensitive receptors to the Project site are single-family residences located approximately 200 feet east of the Project site.
The greatest potential for TAC emissions during construction is diesel particulate emissions from heavy equipment operations and heavy-duty trucks and the associated health impacts to sensitive receptors. Additionally, Carbon Monoxide (CO) is a pollutant of major concern along roadways, because the majority source of CO is motor vehicles.
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Localized Carbon Monoxide Hot Spots
Traffic-congested roadways and intersections have the potential to generate localized high levels of CO. Localized areas where ambient concentrations exceed federal and/or state standards for CO are termed “CO hotspots.” The transport of CO is extremely limited, as it disperses rapidly with distance from the source. However, under certain extreme meteorological conditions, CO concentrations near a congested roadway or intersection may reach unhealthy levels, affecting sensitive receptors. Typically, high CO concentrations are associated with severely congested intersections operating at an unacceptable level of service (LOS) (LOS E or worse is unacceptable).
Projects contributing to adverse traffic impacts may result in the formation of a CO hotspot.
The SDAB is classified as a state attainment area and as a federal maintenance area for CO. Until 2003, no violations of the state standard for CO had been recorded in the SDAB since 1991, and no violations of the national standard had been recorded in the SDAB since 1989. The violations that took place in 2003 were likely the result of massive wildfires that occurred throughout the county. No violations of the state or federal CO standards have occurred since 2003.
Small-scale, localized concentrations of CO above the state and national standards have the potential to occur at intersections with stagnation points such as those that occur on major highways and heavily traveled and congested roadways. CO hot spots are a concern at congested intersections, where automobile engines burn fuel less efficiently and their exhaust contains more CO. Localized CO concentration is a direct function of motor vehicle activity at signalized intersections (e.g., idling time and traffic flow conditions), particularly during peak commute hours and meteorological conditions. The SDAB is a CO maintenance area under the federal CAA. This means that SDAB was previously a non-attainment area and is currently implementing a 10-year plan for continuing to meet and maintain air quality standards.
The SDAB is a CO maintenance area (western and central part of the SDAB only). As a screening analysis, the SCAQMD conducted CO modeling for the 2003 AQMP (Appendix V: Modeling and Attainment Demonstrations, SCAQMD 2003) for the four worst-case intersections in the SCAB: (1) Wilshire Boulevard and Veteran Avenue, (2) Sunset Boulevard and Highland Avenue, (3) La Cienega Boulevard and Century Boulevard, and (4) 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. Using CO emission factors for 2002, the peak modeled CO 1-hour concentration was estimated to be 4.6 ppm at the intersection of Wilshire Boulevard and Veteran Avenue. The 2003 AQMP also 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 ppm at the Sunset Boulevard and Highland Avenue intersection in 2002; the maximum 8-hour CO concentration was 3.4ppm at the Wilshire Boulevard and Veteran Avenue in 2002. Therefore, an intersection would need over 200,000 vehicles per day to exceed the 8-hour CO CAAQS (9.0 ppm) or 400,000 vehicles per day to exceed 1-hour CO CAAQS (20 ppm).
Accordingly, CO concentrations at congested intersections would not exceed the 8-hour CO CAAQS if projected daily traffic would generate less than 200,000 vehicles per day or the 1-hour CO CAAQS for less than 400,000 vehicles per day. The proposed Project is anticipated to generate approximately 2,368 vehicle trips per day.
Therefore, the proposed Project would not be anticipated to increase daily traffic volumes at any study intersection to more than 200,000 vehicles per day, a CO hotspot is not anticipated to occur, and associated impacts would remain less than significant. No new significant impacts would occur, and no previously identified
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significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant.
Toxic Air Contaminants
In addition to impacts from criteria pollutants, Project impacts may include emissions of pollutants identified by the state and federal government as TACs or hazardous air pollutants. 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 (immediate) and/or chronic (cumulative) non-cancer health effects. A toxic substance released into the air is considered a TAC. 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 (CARB 2024a).
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 (CARB 2023). In addition, the California Air Toxics “Hot Spots” Information and Assessment Act (AB 2588) was enacted by the legislature in 1987 to address public concern over the release of TACs into the atmosphere (CARB 2024b).
Examples of TACs 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.
Project construction would result in emissions of diesel particulate matter (DPM) from heavy construction equipment and trucks accessing the site. DPM is characterized as a TAC by the State of California.
State law has established the framework for California’s TAC identification and control program, which is generally more stringent than the federal program and aimed at TACs that are a problem in California. The state has formally identified more than 200 substances as TACs, including the federal hazardous air pollutants, and has adopted appropriate control measures for sources of these TACs. The following measures are required by state law to reduce DPM emissions:
▪ Fleet owners of mobile construction equipment are subject to the CARB Regulation for In-use Off-road Diesel Vehicles (13 CCR 2449), the purpose of which is to reduce DPM and criteria pollutant emissions from in-use (existing) off-road diesel-fueled vehicles. ▪ All commercial diesel vehicles are subject to Title 13, Section 2485 of the California Code of Regulations, limiting engine idling time. Idling of heavy-duty diesel construction equipment and trucks during loading and unloading shall be limited to five minutes; electric auxiliary power units should be used whenever possible.
TACs that would potentially be emitted during construction activities would be DPM emitted from heavy-duty construction equipment and heavy-duty trucks. Heavy-duty construction equipment and diesel trucks are subject to CARB Air Toxic Control Measures to reduce DPM emissions. The Office of Environmental Health Hazard Assessment (OEHHA) has identified carcinogenic and chronic noncarcinogenic effects from long-term exposure but has not identified health effects due to short-term exposure to diesel exhaust. According to OEHHA, health risk
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assessments should be based on a 30-year exposure duration based on typical residency period; however, such assessments should be limited to the period/duration of activities associated with the Project (OEHHA 2015).
The duration of proposed construction activities (approximately 18 months) would only constitute a small percentage of the total long-term exposure period and would not result in exposure of proximate sensitive receptors to substantial TACs. As shown in Table 3.3.1-1, the Project would result in maximums of 0.53 tons per year of PM10 and 0.17 tons per year of PM2.5, which are less than the threshold for PM10 and PM2.5 which are 15 and 10 tons per year, respectively. Furthermore, as shown in Table 3.3.1-1, maximum daily particulate matter (i.e., PM10 or PM2.5) emissions generated by construction equipment operation and haul-truck trips during construction (exhaust particulate matter or DPM), combined with fugitive dust generated by equipment operation and vehicle travel, is minimal and less than SDAPCD thresholds, which account for OEHHA guidelines. Compliance with CARB In-Use Off-Road Diesel-Fueled Fleets Regulation limits unnecessary idling to 5 minutes, requires all construction fleets to be labeled and reported to CARB, bans Tier 0 equipment, and phases out Tier 1 and 2 equipment thereby replacing fleets with cleaner equipment, and requires that fleets comply with Best Available Control Technology requirements. These regulatory measures would further ensure construction equipment generated emissions would not exceed thresholds for TAC exposure. Further, emissions during construction would not be concentrated in one area of the site but would be spread over the entirety of the site. Construction emissions would not be continuous and would cease once construction is complete. Therefore, the Project would not expose sensitive receptors to substantial quantities of TACs during construction. Impacts would be less than significant.
After proposed construction is completed, there would be no long-term source of TAC emissions during operation as TACs are typically associated with heavy-duty equipment and industrial processes. The Project would not require the extensive operation of heavy-duty diesel construction equipment, which is subject to a CARB Airborne Toxics Control Measure for in-use diesel construction equipment to reduce DPM emissions, routine use of diesel trucks, which are also subject to a CARB Airborne Toxics Control Measure, once construction is completed, or industrial processes such as chemical manufacturing. Therefore, the Project would not expose sensitive receptors to substantial quantities of TACs during operation and impacts would be less than significant.
No residual TAC emissions and corresponding health risk are anticipated after construction, and no long-term sources of TAC emissions are anticipated during operation of the Project. The Project would not include any land uses associated with generation of TAC emissions. Potential impacts associated with exposure of sensitive receptors to TACs would be less than significant.
It is expected that operation of the Project would not result in any non-permitted direct emissions (e.g., those from a point source such as diesel generators) that could be a TAC source and, as discussed previously, is anticipated to result in irregular and minimal operational activity, including diesel vehicle travel. Therefore, the Project would not result in exposure of sensitive receptors in the vicinity of the Project site to substantial TAC concentrations due to either construction or operation and impacts would be less than significant. No new significant impacts would occur, and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant.
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Issue 4: Odors
Would the Project result in other emissions (such as those leading to odors) affecting a substantial number of people?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR identified typical examples of odor-generating uses or activities including wastewater treatment plants, sanitary landfills, composting/green waste facilities, recycling facilities, petroleum refineries, chemical manufacturing plants, food-processing plants, dairies, painting/coating operations, or rendering plants agricultural uses. Additionally, the PEIR acknowledged that the City’s existing odorgenerating sources, including the Sycamore Landfill and a water reclamation plant, are located one mile or more from the Rezone Sites and therefore, would not affect substantial numbers of people.
Emissions from construction equipment would potentially generate odors from the diesel exhaust, volatile organic compounds, architectural coatings, paving activities, however these odors would be temporary and are not expected to affect a substantial number of people. Construction emissions (those leading to odors) would be less than significant. Once operational, future development would include residential and associated commercial uses that are generally not a source of objectionable odors. Therefore, the Santee Housing Element Implementation PEIR concluded that the operation of future developments would not result in odors adversely affecting a substantial number of people, and impacts would be less than significant.
Proposed Project Analysis
Odors are the form of air pollution that is most obvious to the general public and can present problems for both the source and surrounding community. The occurrence and severity of potential odor impacts depends on numerous factors: the nature, frequency, and intensity of the source; the wind speeds and direction; and the sensitivity of receiving location each contribute to the intensity of the impact. Although offensive odors seldom cause physical harm, they can be annoying, cause distress among the public, and generate citizen complaints.
SDAPCD Rule 51, commonly referred to as the public nuisance rule, prohibits emissions from any source whatsoever in such quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance to the public health or damage to property. The potential for an operation to result in odor complaints from a “considerable” number of persons in the area would be considered to be a significant, adverse odor impact.
Potential sources that may emit odors during construction activities include the application of materials such as asphalt pavement and architectural coatings. The objectionable odors that may be produced during the construction process are short-term in nature, and the odor emissions are expected cease upon the drying or hardening of the odor producing materials. Diesel exhaust and VOCs would be emitted during construction of the Project, which are objectionable to some; however, emissions would disperse rapidly from the Project site and therefore should not reach an objectionable level at the nearest sensitive receptors. Furthermore, construction emissions would not exceed SDAPCD thresholds. Due to the short-term nature and limited amounts of odor producing materials being utilized, no significant impact related to odors would occur during construction of the proposed Project.
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Land uses and operations typically associated with odor complaints include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, refineries, landfills, dairies, and fiberglass molding. The anticipated uses for the proposed residential use are not typically associated with objectionable odors. Therefore, impacts would remain less than significant. No new significant impacts would occur, and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant with mitigation.
3.3.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR
MM-AQ-1: The City shall require Project applicants to identify the measures that would be taken at the construction site to reduce construction-related criteria air pollutants such that they do not exceed the SDAPCD screening thresholds. Based on typical construction emissions, implementation of the following measures would be sufficient to reduce air pollutant emissions during construction:
▪ Requiring fugitive dust control measures that exceed SDAPCD’s Rules 52, 54, and 55, such as:
- Requiring use of non-toxic soil stabilizers to reduce wind erosion. - Applying water every four hours to active soil-disturbing activities. - Tarping and/or maintaining a minimum of 24 inches of freeboard on trucks hauling dirt, sand, soil, or other loose materials.
▪ Using construction equipment rated by the United States Environmental Protection Agency as having Tier 3 (model year 2006 or newer) emission limits, applicable for engines between 50 and 750 horsepower.
▪ Ensuring construction equipment is properly serviced and maintained to the manufacturer’s standards.
▪ Limiting nonessential idling of construction equipment to no more than five consecutive minutes.
▪ Using Super-Compliant VOC paints for coating of architectural surfaces whenever possible. A list of Super-Compliant architectural coating materials can be found on the SCAQMD’s website at: http://www.aqmd.gov/prdas/brochures/SuperCompliant_AIM.pdf.
In regard to operational emissions, measures included as part of the Sustainable Santee Plan, such as expansion of the pedestrian and bicycle networks, installation of electric vehicle charging stations, and solar photovoltaics requirements, would also reduce criteria air pollutants within the City. However, because the Project would exceed the growth projections used to develop the RAQS, no mitigation measures are available that would reduce impacts below the screening thresholds.
3.4 Biological Resources
The analysis in this section was completed in compliance with the following report:
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▪ Cottonwood and Park Biology Technical Report, prepared in June 2025 by Dudek and included as Appendix B of this Addendum.
3.4.1 Analysis
Issue 1: Sensitive Species
Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that the Rezone Sites could have the potential to substantially adverse effect special status plant and wildlife species. Potential impacts to sensitive plants and wildlife were identified on Site 17 (Project site). Additionally, mitigation would be implemented by both discretionary and by-right development projects. The following mitigations measures (MM) MM-BIO-1, MM-BIO-2, MM-BIO-4, MM-BIO-5 and MM-BIO-6 would be implemented and the direct and indirect impacts to sensitive plants and sensitive wildlife would be reduced to less than significant with mitigation incorporated.
Proposed Project Analysis
Direct and Indirect Impacts
Direct impacts to special-status plant and wildlife species could potentially result from the removal of occupied habitat through grading and other land development activities. Additionally, indirect impacts to special-status plant or wildlife species could also result from excess noise, lighting, or runoff generated during project construction. Implementation of the Santee Housing Element Implementation PEIR (City of Santee 2022) proposed MM-BIO-1 would reduce potential direct and indirect impacts special-status species to less than significant.
One special-status plant species, white rabbit-tobacco, was observed within the Project site and immediately adjacent to the Project site boundary. No other special-status plant species included in Appendix C to the Biological Technical Report for the Project (Appendix B) are expected to occur within the Project site. All white rabbit-tobacco individuals (0.20 acres; 15 individuals) would be avoided by the proposed Project with establishment of the 100-foot buffer required by MM-BIO-6.
A pair of least Bell’s vireos were observed during protocol-level breeding season surveys within the riparian habitat within the Project site, and two other least Bell’s vireo pairs were detected in the riparian habitat areas within the Project site’s 500-foot buffer. Direct impacts to least Bell’s vireo individuals are not anticipated due to the Project’s avoidance of impacts to occupied habitat through the establishment of a 100-foot buffer from the edge of the riparian habitat. However, indirect impacts to least Bell’s vireo from construction noise would be significant, and impacts would be mitigated through implementation of the Santee Housing Element Implementation PEIR MM-BIO-2, which would require noise attenuation measures for occupied habitat. Protocollevel surveys for least Bell’s vireo required by MM-BIO-2 were conducted as part of the evaluation for this Project.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
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The Santee Housing Element Implementation PEIR (City of Santee 2022) identified potential significant direct and indirect impacts to coastal California gnatcatcher (Polioptila californica californica) within the Project site.
However, there is no suitable habitat for this species within the Project site, and this species was not incidentally observed during field surveys. Therefore the Santee Housing Element Implementation PEIR MM-BIO-3 does not apply to this Project.
Direct impacts to nesting birds protected under Section 3503 of the California Fish and Game Code could occur within vegetated areas of the Project site. Project implementation of the Santee Housing Element Implementation PEIR proposed MM-BIO-4 would reduce potential direct impacts to nesting birds (including least Bell’s vireo) to a less-than-significant level through performance of a pre-construction nesting bird survey if construction occurs during the nesting season. Therefore, no new significant direct impacts to nesting birds are anticipated with Project implementation.
Three special-status wildlife species were either within the Project site (i.e., monarch and least Bell’s vireo) or immediately outside the Project site within the 500-foot buffer (i.e., yellow warbler). One monarch individual was observed passing through the Project site during the biological surveys. However, the Project site is not an established overwintering area for this species, the site does not provide any host plants (i.e., milkweed), and the site supports very limited nectar plants (i.e., the majority of the site contains non-native grasses); therefore, direct or indirect impacts to this species are not anticipated. Additionally, a total of nine special-status wildlife species have moderate potential to occur, and one special-status wildlife species has high potential to occur within the Project site or adjacent to the Project site within the San Diego River corridor due to the presence of suitable habitat for the southern California legless lizard (Anniella stebbinsi), San Diegan tigar whiptail (Aspidoscelis tigris stejnegeri), two-striped gartersnake (Thamnophis hammondii), yellow-breasted chat (Icteria virens (nesting)), pallid bat (Antrozous pallidus), Townsend’s big-eared bat (Corynorhinus townsendii), western yellow bat (Dasypterus xanthinus), western mastiff bat (Eumops perotis californicus), pocketed free-tailed bat (Nyctinomops fermorosaccus), western red bat (Lasiurus frantzii) (see Appendix D of Appendix B). Direct impacts to foraging or nesting habitat for special-status species would be reduced to less than significant with implementation of the Santee Housing Element Implementation PEIR proposed MM-BIO-5, which would require the Applicant to provide evidence in the form of a dedicated easement, proof of purchase of mitigation credits, or other method of conservation for the preservation of the suitable habitats.
The Project site does not occur within USFWS-designated critical habitat for plant or wildlife species. Therefore, no new direct impacts would occur to USFWS-designated critical habitat with Project implementation and would not result in any new or increased impacts in this regard. No new significant impacts to special status species would occur, and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant with mitigation.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
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Issue 2: Sensitive Vegetation Communities
Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined the rezones would not specifically propose vegetation removal, however, future development of the Rezone Sites could potentially directly and indirectly impact sensitive vegetation communities through grading and construction activities. The PEIR concluded that development of Site 17 could directly impact sensitive vegetation communities. Direct impacts to sensitive vegetation communities within Rezone Sites would be potentially significant and implementation of mitigation measures MMBIO-1 and MM-BIO-5 would reduce impacts to less than significant with implementation of mitigation.
Proposed Project Analysis
Direct Impacts
A total of 11.26 acres of sensitive vegetation communities would be impacted with Project implementation (Figure 4, Biological Resources). Table 3.4.1-1 summarizes the permanent and temporary direct impacts to sensitive vegetation communities within the Project site. Communities listed by the CDFW as high priority for inventory (i.e., State Rank [S] 1, 2, or 3) are considered sensitive and typically require mitigation (CDFW 2023). Southern cottonwood–willow riparian forest and arrowweed scrub both have a CDFW state ranking of S3 (CDFW 2023). Therefore, impacts to these vegetation communities would be considered significant and require mitigation. Mitigation shall include reestablishment of the permanent impact acreage at a minimum ratio of 1:1 to meet the regional MSCP (City of San Diego 1998) “no net loss” policy. Additionally, although non-native grassland (including broadleaf-dominated) is not considered sensitive by CDFW, direct impacts to non-native grassland (including broadleaf-dominated) would require mitigation to comply with regional MSCP conservation goals (City of San Diego 1998).
Table 3.4.1-1. Permanent and Temporary Impacts to Sensitive Vegetation Communities within the Project Site (Acres)
Vegetation Community
Holland/Oberbauer
Code
Perm
(acres)
Temp
(acres)1
Total
(acres)
Riparian/Bottomland Vegetation Communities
Southern Cottonwood–Willow Riparian Forest 61330 <0.01 0.01 0.01 Arrowweed Scrub 63820 2.49 0.03 2.52
Riparian/Bottomland Vegetation Communities Subtotal 2.49 0.03 2.53 Upland Vegetation Communities
Non-native Grassland 42200 6.09 0.08 6.17
Non-native Grassland (broadleaf-dominated) 42210 2.32 0.24 2.56 Upland Vegetation Communities Subtotal 8.41 0.32 8.73
Total 10.90 0.35 11.26
Note: Totals may not sum due to rounding.
N/A = not applicable; Perm = permanent direct impacts; Temp = temporary direct impacts.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
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1 All temporary direct impact areas will be restored in-place to pre-Project conditions or biologically superior conditions. In accordance with PEIR MM-BIO-5 and MM-BIO-6, a Habitat Mitigation and Monitoring Plan (HMMP) shall be prepared for the project and will include restoration of the temporary impact areas. If restoration is not feasible, all temporary impacts would be considered permanent impacts and mitigated according to the ratios provided in Table 3.4.1-2. 2 Permanent impacts to Southern Cottonwood – Willow riparian forest totals 0.004 acres.
Mitigation for the permanent loss of sensitive vegetation communities would occur through implementation of MM-BIO-5 and MM-BIO-6. Per Table 3.4.1-2, the proposed Project would require 15.89 acres of mitigation for impacts to sensitive vegetation communities within the Project site. Implementation of MM-BIO-6 would provide a portion of the arrowweed scrub mitigation requirements (approximately 2.49 acres) through the establishment of this vegetation community within the 100-foot buffer area adjacent to the San Diego River. The existing arrowweed scrub is approximately 130 feet north of the riparian edge of the San Diego River with no direct surface connection to the river or any other watercourse. This community occurs within a flat area on the western boundary of the Project site approximately 15 feet in elevation above the San Diego River. The arrowweed scrub is at least in part being fed by irrigation from the community park off-site and is completely surrounded by nonnative land covers (i.e. non-native grassland, disturbed habitat, and developed lands). Therefore, establishing a minimum of 2.49 acres of arrowweed scrub within the on-site 100-foot buffer area would provide higher value habitat than at its current location (i.e. connectivity to native habitats associated with the San Diego River, increase in species diversity, increase in aerial extent, and a reduction in edge effects) and would satisfy the “no net loss” requirement for riparian communities as would the establishment of 0.01 acres of southern cottonwood -willow riparian forest within the 100-foot buffer. Should more than 2.49 acres of arrowweed scrub establishment occur within the 100-foot buffer, acreages identified under Arrowweed Scrub options 2 through 7, as described below, would be reduced proportionally. Portions of the site that will be revegetated in compliance with MM-BIO-6 shall be designated as biological open space and incorporated into the City of Santee’s Preserve System, including recordation of an easement to ensure their protection in perpetuity. Designated biological open space easement areas will be detailed on Project building and landscape plans.
Table 3.4.1-2. Mitigation for Permanent Impacts to Sensitive Vegetation Communities within the Project Site
Vegetation Community
Holland/Oberba
uer Code
Perm Impact
Total (acres)
Mitigatio
n Ratio1
Required
Mitigation
(acres)
Riparian/Bottomland Vegetation Communities
Southern Cottonwood–Willow Riparian
Forest
61330 <0.012 3:1 0.01
Arrowweed Scrub 63820 2.49 3:1 7.47
Riparian/Bottomland Vegetation Communities Subtotal 2.49 N/A 7.48 Upland Vegetation Communities
Non-native Grassland 42200 6.09 1:1 6.09
Non-native Grassland (broadleaf-dominated) 42210 2.32 1:1 2.32 Upland Vegetation Communities Subtotal 8.41 N/A 8.41
Total 10.90 N/A 15.89
Note: Totals may not sum due to rounding.
N/A = not applicable; Perm = permanent direct impact.
1. Because the Draft Santee MSCP Subarea Plan has not yet been approved, the mitigation ratios provided are based on typical upland and wetland mitigation ratios to meet the overall Multiple Species Conservation Program (City of San Diego 1998) conservation goals.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
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2 Permanent impacts to Southern Cottonwood – Willow riparian forest totals 0.004 acres. Therefore, at a 3:1 ratio, the required mitigation totals 0.01 acres.
Implementation of the Santee Housing Element Implementation PEIR MM-BIO-5 would satisfy the remaining mitigation requirements for southern cottonwood – willow riparian forest, arrowweed scrub and non-native grassland through the following methods:
Southern Cottonwood – Willow Riparian Forest
Establishment of a minimum of 0.01 acres of southern cottonwood – willow riparian forest within the Project Site 100-foot buffer;
if option 1 is not available, option 2 would be considered Restoration of 0.01 acres of southern cottonwood – willow riparian forest within the boundary of the Draft Santee MSCP Subarea Plan San Diego River Subunit;
if option 2 is not available, option 3 would be considered Preservation of 0.01 acres of existing southern cottonwood – willow riparian forest within the boundary of the Draft Santee MSCP Subarea Plan San Diego River Subunit through a dedicated conservation easement; if option 3 is not available, option 4 would be considered In-kind creation of 0.01 acres of southern cottonwood – willow riparian forest within the boundary of the Draft Santee MSCP Subarea Plan San Diego River Subunit to be preserved in perpetuity through a dedicated conservation easement;
if option 4 is not available, option 5 would be considered In-kind creation of 0.01 acres of southern cottonwood – willow riparian forest within the boundary of the Draft Santee MSCP Subarea Plan (other subunits) to be preserved in perpetuity through a dedicated conservation easement;
if option 5 is not available, option 6 would be considered Purchase of 0.01 acres of riparian forest mitigation credits from a mitigation bank whose service area includes the Draft Santee MSCP Subarea Plan;
if option 6 is not available, option 7 would be considered Purchase of 0.01 acres of riparian forest mitigation credits from a mitigation bank whose service area is outside of the Draft Santee MSCP Subarea Plan, and within San Diego County.
Arrowweed Scrub
Establishment of a minimum of 2.49 acres of arrowweed scrub within the Project Site 100-foot buffer; And a combination of the following, in the preferred order as follows:
Restoration of up to 4.98 acres of arrowweed scrub or up-tiered restoration of mule fat scrub within the boundary of the Draft Santee MSCP Subarea Plan San Diego River Subunit; if option 2 is not available, option 3 would be considered Preservation of up to 4.98 acres of existing arrowweed scrub within the boundary of the Draft Santee MSCP Subarea Plan San Diego River Subunit through a dedicated conservation easement; if option 3 is not available, option 4 would be considered
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
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In-kind creation of up to 4.98 acres of arrowweed scrub within the boundary of the Draft Santee MSCP Subarea Plan San Diego River Subunit to be preserved in perpetuity through a dedicated conservation easement; if option 4 is not available, option 5 would be considered In-kind creation of up to 4.98 acres of arrowweed scrub within the boundary of the Draft Santee MSCP Subarea Plan (other subunits) to be preserved in perpetuity through a dedicated conservation easement; if option 5 is not available, option 6 would be considered Purchase of up to 4.98 acres of riparian forest mitigation credits from a mitigation bank whose service area includes the Draft Santee MSCP Subarea Plan;
if option 6 is not available, option 7 would be considered Purchase of up to 4.98 acres of riparian forest mitigation credits from a mitigation bank whose service area is outside of the Draft Santee MSCP Subarea Plan, and within San Diego County.
Non-Native Grassland
Purchase of 8.41 acres of non-native grassland mitigation credits from Cleveland Corridor Mitigation Bank.
Habitat Mitigation Monitoring Plan (HMMP)
The Project applicant will submit an HMMP for establishment and in-kind creation within the 100-foot San Diego River buffer and off-site mitigation areas (if acquired). The HMMP will include:
▪ goals and objectives
▪ regulatory setting
▪ site selection criterion
▪ baseline site condition information
▪ restoration design approach
▪ rationale for success
▪ implementation program (including the construction period and a 5-year maintenance and monitoring program)
▪ annual performance standards for native and non-native vegetation cover designed to assess progress toward final mitigation goals (e.g. by the end of Year 5, the establishment area is expected to achieve at least 75% absolute native vegetation cover, non-native plant cover should not exceed 10%, with perennial invasive species maintained at 0%)
▪ long-term site protection and management
The HMMP shall detail the final mitigation implementation for permanent impacts to arrowweed scrub and southern cottonwood-willow riparian forest (i.e., establishment), temporary impact areas to be restored in-place to pre-Project conditions or biologically superior conditions, and preservation areas (i.e., southern cottonwood-willow riparian forest and freshwater marsh). The HMMP will be submitted to CDFW and the City for review and approval.
Once the HMMP is approved by CDFW and the City, the Project applicant will record a conservation easement in perpetuity and enter the land into the City of Santee’s Preserve system.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
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As a condition of approval and in conformance with MM-BIO-5, prior to issuance of the first grading permit for the Project, the Project applicant will submit a biological mitigation compliance memo to the City outlining the feasibility of each method, identifying the selected approach(es) and providing verification that mitigation for impacts to arrowweed scrub, southern cottonwood – willow riparian forest, and non-native grassland has been satisfied. Mitigation of impacts through the proposed implementation strategy would reduce Project impacts to these sensitive vegetation communities to less than significant. No new significant impacts to sensitive vegetation communities would occur, and no previously identified significant impacts would substantially increase in severity.
Similar to the conclusion of the PEIR, impacts would be less than significant with mitigation.
Indirect Impacts
Project implementation has the potential to result in indirect impacts to sensitive vegetation communities occurring adjacent to the Project site.
Construction-Related: Sensitive vegetation communities may be indirectly impacted during construction of the proposed Project. Potential short-term or temporary indirect impacts to sensitive vegetation communities resulting from construction activities include inadvertent spillover impacts, including unintentional clearing, trampling, or grading outside of the Project footprint; generation of fugitive dust; changes in hydrology resulting from construction, including sedimentation and erosion; the release of chemical pollutants; and the adverse effect of invasive plant species. These potential construction-related, indirect impacts to sensitive vegetation communities would be potentially significant absent mitigation.
Implementation of the Santee Housing Element Implementation PEIR proposed MM-BIO-1 would minimize the effect of construction-related indirect impacts to sensitive vegetation communities to less than significant. . No new significant indirect impacts to sensitive vegetation communities would occur, and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant with mitigation.
Issue 3: Wetlands
Would the Project have a substantial adverse effect on wetlands as defined by Section 404 of Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that impacts to jurisdictional waters and wetlands within Rezone Sites, including the Project site would be potentially significant. The Project site is mapped in the PEIR as potentially containing “Unmapped Wetlands/ Waters and further lists the Project site as having “Previously Recorded Wetlands or Waters”. However, additional site-specific field surveys would be required to determine if there would be substantial adverse effects on wetlands as defined by Section 404 of Clean Water Act. The PEIR concluded that implementation of mitigation measure MM-BIO-6 would reduce impacts to jurisdictional waters and wetland to less than significant.
Proposed Project Analysis
According to the federal Clean Water Act, Section 404, wetlands are defined as:
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
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Those areas that are inundated or saturated by surface or ground water (hydrology) at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation (hydrophytes) typically adapted for life in saturated soil conditions (hydric soils). Wetlands generally include swamps, marshes, bogs, and similar areas.
Direct Impacts
There are no impacts within USACE or RWQCB jurisdictional aquatic resources. A total of 2.53 acres of CDFWregulated riparian habitat would be impacted by the proposed Project, as summarized in Table 3.4.1-3. Impacts to CDFW riparian habitat would be potentially significant and require mitigation. Mitigation shall include reestablishment of the permanent impact acreage at a minimum ratio of 1:1 to meet the regional MSCP (City of San Diego 1998) “no net loss” policy.
Table 3.4.1-3. Permanent Impacts to Potential Jurisdictional Aquatic Resources within the Project Site
Vegetation Community Perm (Acres)
Temp
(Acres)1
Total Impacts
(Acres
CDFW Riparian Habitat
Southern Cottonwood–Willow Riparian Forest <0.01 0.01 0.01 Arrowweed Scrub 2.49 0.03 2.52
Total 2.49 0.03 2.53
Note: Totals may not sum due to rounding.
CDFW = California Department of Fish and Wildlife; N/A = not applicable; Perm = permanent direct impacts; Temp = temporary direct impacts.
1 All temporary direct impact areas will be restored in-place to pre-Project conditions or biologically superior conditions. In accordance with PEIR MM-BIO-5 and MM-BIO-6, a Habitat Mitigation and Monitoring Plan shall be prepared for the project and will include restoration of the temporary impact areas. If restoration is not feasible, all temporary impacts should be considered permanent impacts and mitigated according to the ratios provided in Table 3.4.1-2.
All jurisdictional aquatic resources would be avoided by the proposed Project to the extent feasible. All impacts to the riparian resources within the main stem of the San Diego River would be avoided by the proposed Project, with the exception of a small impact (less than 0.01 acres of southern cottonwood-willow riparian forest) occurring from the Project’s proposed storm drain outfall (i.e., desiltation or erosion control facilities or other improvements necessary to protect the habitat). The storm drain outfall is located on County-owned property and will require an easement issued by the County. Storm basin overflow discharging into the river would not be considered an impact as the quantity and quality of the discharge is consistent with the City’s Municipal Separate Storm Sewer System (MS4) permit (see Section 3.10, Hydrology and Water Quality for more information.) Implementation of PEIR MM-BIO-6 would provide a portion of the arrowweed scrub mitigation requirements (a minimum of 2.49 acres) through the establishment of this vegetation community within the 100-foot buffer adjacent to the San Diego River. The existing arrowweed scrub is approximately 130 feet north of the riparian edge of the San Diego River with no direct surface connection to the river or any other watercourse. This community occurs within a flat area on the western boundary of the Project site approximately 15 feet in elevation above the San Diego River. The arrowweed scrub is at least in part being fed by irrigation from the community park off-site and is completely surrounded by non-native land covers (i.e. non-native grassland, disturbed habitat, and developed lands). Therefore, establishing a minimum of 2.49 acres of arrowweed scrub within the on-site
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
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100-foot buffer area would provide higher value habitat than at its current location (i.e. connectivity to native habitats associated with the San Diego River, increase in species diversity, increase in aerial extent, and a reduction in edge effects) and would satisfy the “no net loss” requirement for riparian communities as would the establishment of 0.01 acres of southern cottonwood -willow riparian forest within the 100-foot buffer. Should more than 2.49 acres of arrowweed scrub establishment occur within the 100-foot buffer, acreages identified under Arrowweed Scrub options 2 through 7, described in Section 3.4.1 (b) would be reduced proportionally.
Portions of the site that will be revegetated in compliance with MM-BIO-6 shall be designated as biological open space and incorporated into the City of Santee’s preserve system, including recordation of an easement to ensure their protection in perpetuity. Designated biological open space easement areas will be detailed on Project building and landscape plans. Implementation of the Santee Housing Element Implementation PEIR MM-BIO-5 would satisfy the remaining mitigation requirements for southern cottonwood–willow riparian forest, arrowweed scrub and non-native grassland through the methods described in Section 3.4.1 (b). An HMMP shall be prepared for the project’s on-site 100-foot buffer area and shall include the following information: details on the mitigation plan’s goals and objectives; site selection; baseline information; restoration design approach; rationale for success; the implementation program (including the construction period and the 5-year maintenance and monitoring program); annual performance standards for native and non-native vegetation cover designed to assess progress toward final mitigation goals (e.g. by the end of Year 5, the establishment area is expected to achieve at least 75% absolute native vegetation cover, non-native plant cover should not exceed 10%, with perennial invasive species maintained at 0%); and long-term site protection and management. The Project’s HMMP for the Project’s on-site 100-foot buffer area shall include the mitigation for permanent impacts to arrowweed scrub (i.e. establishment), temporary impact areas to be restored in-place to pre-Project conditions or biologically superior conditions, and preservation of existing sensitive vegetation communities within the 100-foot buffer area (i.e. southern cottonwood-willow riparian forest and freshwater marsh).
Portions of the site to be revegetated in compliance with MM-BIO-6 and shall be designated biological open space and incorporated into the City of Santee’s Preserve System, including recordation of an easement to ensure their protection in perpetuity. Designated biological open space easement areas will be detailed on Project building and landscape plans. Mitigation for the remaining loss of CDFW riparian habitat areas will occur through implementation of MM-BIO-6, which requires in-kind creation to prevent any net loss of wetland functions and values. Implementation of PEIR MM-BIO-5 would satisfy the remaining mitigation requirements for arrowweed scrub and southern cottonwood-willow riparian forest through a combination of establishment, restoration and conservation of sensitive habitats as described above in section 3.4.1 (b). The proposed Project will meet the mitigation requirements for CDFW riparian habitat in accordance with the ratios listed in Table 3.4.1-2. No new significant impacts to wetlands would occur, and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant with mitigation.
Indirect Impacts
Project implementation has the potential to result in indirect impacts to jurisdictional aquatic resources associated with the San Diego River occurring within 500 feet of the Project site.
Construction-Related: Jurisdictional aquatic resources of the United States/state may be indirectly impacted during construction. Potential short-term or temporary indirect impacts to jurisdictional aquatic resources resulting from construction activities include the generation of fugitive dust; changes in hydrology resulting from construction, including sedimentation and erosion; the release of chemical pollutants; and unintentional clearing,
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
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trampling, or grading outside of the proposed construction zone. Construction-related indirect impacts to jurisdictional aquatic resources would be potentially significant.
Implementation of the Santee Housing Element Implementation PEIR mitigation measure MM-BIO-1 would minimize construction-related indirect impacts through biological monitoring, a Worker Environmental Awareness Program that will cover the special-status resources and mitigation requirements for the Project, delineation of Project boundaries, implementation of standard dust control measures, development of a stormwater pollution prevention plan, and requiring all vehicles and equipment to be serviced in designated staging areas. No new significant impacts to sensitive vegetation communities would occur, and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant with mitigation.
Issue 4: Wildlife Corridors
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?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that impacts related to wildlife corridors would be less than significant due to the majority of the Rezone Sites being primarily located in areas where corridors would be restricted by roads and other development. The PEIR specifically noted that a portion of the Project site contains areas associated with the San Diego River and its tributaries, which are identified as a regionally significant wildlife movement corridor within the Draft Santee MSCP Subarea Plan however the PEIR stated the project site is outside of the City of Santee’s Preserve system. The proposed Project would be required to comply with State and Federal requirements to avoid wetlands and additionally implement MM-BIO-6 to ensure wetland resources are avoided or mitigated and adequate buffers are retained adjacent to the San Diego River.
Proposed Project Analysis
Direct Impacts
The Project site is not mapped as a core area or habitat linkage under the MSCP (City of San Diego 1998) and is identified in the Draft Santee MSCP Subarea Plan as an anticipated development area (City of Santee 2022). The Draft Santee MSCP Subarea Plan does not identify the Project site as an established wildlife corridor or habitat linkage. However, the Project site is currently undeveloped land adjacent to the San Diego River, and the site could potentially function as a wildlife corridor for local populations of common species. Species most likely to use this area include coyote, raccoon, striped skunk, and Virginia opossum. None of these species are special status, and they would continue to use the areas adjacent to the Project site after buildout. Impacts to aquatic resources associated with the San Diego River corridor are minimal and would be reduced to less than significant with implementation of the Santee Housing Element Implementation PEIR MM-BIO-6. Based on the Draft Santee MSCP Subarea Plan mapping available at the time of drafting this document, no portion of the Project site overlaps with the Draft Santee MSCP Subarea Plan Preserve system and a very small portion of the Project’s impact footprint would occur within the Draft Santee MSCP Subarea Plan’s San Diego River Subunit (Appendix B, Figure 1). The Project would have 0.01 acres of permanent impacts within the San Diego River Subunit; however,
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
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the Project would add the 100-foot buffer area to the City of Santee’s Preserve system through implementation of MM-BIO-6. Therefore, no new significant impacts to potential wildlife corridors would occur, and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant with mitigation.
Indirect Impacts
Project implementation has the potential to result in indirect impacts to the San Diego River corridor, which is located adjacent to the Project site and functions as a local wildlife corridor.
Construction-Related: The San Diego River wildlife corridor may be indirectly impacted during construction of the proposed Project. Potential short-term or temporary indirect impacts to biological resources within the San Diego River wildlife corridor resulting from construction activities include inadvertent spillover impacts, including unintentional clearing, trampling, or grading outside of the Project footprint; generation of fugitive dust; changes in hydrology resulting from construction, including sedimentation and erosion; the release of chemical pollutants; night-time lighting; and the adverse effects of invasive plant species. These potential construction-related, indirect impacts to the San Diego River wildlife corridor would be potentially significant absent mitigation. The Santee Housing Element Implementation PEIR identified MM-BIO-1 to reduce indirect impacts to the San Diego River corridor. No new significant impacts to potential wildlife corridors would occur, and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant with mitigation.
Issue 5: Habitat Conservation Planning
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? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that impacts related to conflicts with the Draft Santee MSCP Subarea Plan, or any other local, regional, and state habitat conservation plans would be less than significant due to implementation of MM-BIO-1 through MM-BIO-6, which would ensure that future development, such as the proposed Project, is consistent with the Draft Santee MSCP Subarea Plan. The Draft Santee MSCP Subarea Plan requires site specific field surveys be conducted to determine the presence of any sensitive biological resources, to determine the extent of any potential impacts, and to provide mitigation to reduce the impacts to below a level of significance.
Proposed Project Analysis
MSCP Plan and Draft Santee MSCP Subarea Plan
The Project site is within the boundaries of the MSCP Plan (City of San Diego 1998). The Draft Santee MSCP Subarea Plan would serve as a Habitat Conservation Plan (HCP) under the MSCP Plan (City of San Diego 1998) pursuant to Section 10(a)(1)(B) of Federal Endangered Species Act (FESA) and as a Natural Community Conservation Plan (NCCP) pursuant to the California Natural Community Conservation Planning Act of 1991. The Draft Santee MSCP Subarea Plan, once finalized, will contribute to the regional MSCP for preservation, mitigation for impacts, and conservation of sensitive biological resources within San Diego County. The Draft Santee MSCP
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Subarea Plan is also intended to provide cumulative mitigation for impacts to Covered Species within the City’s jurisdiction, as long as projects are consistent with and covered by provisions of the Santee MSCP Subarea Plan, and to ensure sufficient biological resources are conserved to assist in the conservation and recovery of Covered Species under the MSCP. Although the Draft Santee MSCP Subarea Plan has not yet been approved or permitted, it is used as the guidance document for projects occurring within the City. The Proposed Project is an anticipated development area under the Draft Santee MSCP Subarea Plan (City of Santee 2022).
The portion of the San Diego River that is adjacent to the southern boundary of the project site is part of the Draft Santee MSCP Subarea Plan’s San Diego River Subunit. This portion of the San Diego River is County-owned and contributes to the overall functional east-west ecological linkage and wildlife corridor through the Subarea Plan Area but is not currently part of the City of Santee’s Preserve system. As directed by MM-BIO-6, the Project would establish a 100-foot buffer from the riparian edge to avoid any impacts to the San Diego River corridor (Figure 4).
PEIR MM-BIO1 through MM-BIO-6 would be implemented to prevent any direct or indirect impacts to specialstatus species, sensitive vegetation communities, and/or jurisdictional aquatic resources associated with the San Diego River Preserve. Furthermore, Project implementation would not significantly conflict with the provisions of the MSCP Plan or Draft Santee MSCP Subarea Plan, nor would it prevent the Draft Santee MSCP Subarea Plan from being approved or compromise continued implementation of the MSCP in San Diego County. Therefore, impacts to habitat conservation plans would be less than significant with the implementation of the ’PEIR mitigation measures.
Issue 6: Policies and Ordinances Protecting Biological Resources Would the Project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that any proposed activities would not conflict with any local policies or ordinances protecting biological resources. The Santee Housing Element Implementation PEIR would require future development to implement mitigation measures MM-BIO-1 through MM-BIO-6, in order to ensure that impacts related to biological resources are less than significant. Additionally, future development would be required to comply with the City’s Municipal Code Chapter 8.06, Chapter 11.8, Chapter 13.08 and
13.16 to ensure the protection of biological resources.
Proposed Project Analysis
City of Santee
The City’s Urban Forestry Ordinance contains tree-related policies, regulations, and generally accepted standards for planting, trimming, and removing trees on public property and public rights-of-way (Santee Municipal Code, Section 8.06 [City of Santee 2020]). The ordinance gives the City control of all trees, shrubs, and other plantings in any street, park, public right-of-way, landscape maintenance district or easement, or other City-owned property.
City staff review of development plans for the City-owned and maintained property would ensure that the proposed landscaping and maintenance requirements conform to the Urban Forestry Ordinance. The proposed Project would not require removal of any trees within the City’s purview according to Santee Municipal Code
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Section 8.06 (City of Santee 2020). Therefore, as no impacts are proposed by the Project, the Project would comply with the Urban Forestry Ordinance, and no mitigation measures are required.
Biological resources are discussed, and specific objectives and policies are presented, in the Conservation Element of the City of Santee General Plan (City of Santee 2003). The proposed Project does not conflict with any objectives or policies as presented in the Conservation Element of the Santee General Plan. No new significant impacts to local policies and ordinances would occur, and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant with mitigation.
3.4.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR
MM-BIO-1 Applications for future development, where the City has determined a potential for impacts to sensitive biological resources, shall be required to comply with the following mitigation measure. a) Prior to issuance of any construction permit or any earth-moving activities, a site-specific general biological resources survey shall be conducted to identify the presence of any sensitive biological resources, including any sensitive plant or wildlife species. A biological resources report shall be submitted to the City to document the results of the biological resources survey. The report shall include: (1) the methods used to determine the presence of sensitive biological resources; (2) vegetation mapping of all vegetation communities and/or land cover types; (3) the locations of any sensitive plant or wildlife species; (4) an evaluation of the potential for occurrence of any listed, rare, and narrow endemic species; and (5) an evaluation of the significance of any potential direct or indirect impacts from the proposed project. If suitable habitat for sensitive species is identified based on the general biological survey, then focused presence/absence surveys shall be conducted in accordance with applicable resource agency survey protocols and incorporated into the biological resources report. If potentially significant impacts to sensitive biological resources are identified, project-level grading and site plans shall incorporate project design features to avoid or minimize direct impacts on sensitive biological resources to the extent feasible, and the report shall also recommend appropriate mitigation to reduce the impacts to below a level of significance, where feasible. Mitigation measures shall be consistent with the standards contained in Section 5.3 of the 2018 Draft Santee MSCP Subarea Plan, and projects shall be required to obtain all necessary permits to ensure compliance with applicable federal, state, and local regulations, such as the federal and state Endangered Species Acts.
b) Environmentally Sensitive Areas shall be identified in the biological resources report and avoided to the maximum extent practicable. In areas near or adjacent to Environmentally Sensitive Areas (i.e., natural habitats and vegetation, wetlands, wildlife areas, wildlife corridors), the biological resources report will consider the following measures:
Avoidance of Environmentally Sensitive Areas. In areas near or adjacent to Environmentally Sensitive Areas, construction limits shall be clearly demarcated using highly visible barriers (such as silt fencing), which shall be installed under the supervision of a qualified biologist prior to the
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commencement of work. Construction personnel shall strictly limit their activities, vehicles, equipment, and construction materials to the project footprint, including designated staging areas, and routes of travel. The construction areas shall be limited to the minimal area necessary to complete the proposed project. The fencing shall remain in place until the completion of all construction activities and shall be promptly removed when construction is complete.
Biological Monitoring. A qualified biological monitor shall conduct construction monitoring of all work conducted within/adjacent to environmentally sensitive areas during all vegetation removal and ground-disturbing activities such as staging and grading, for the duration of the proposed project to ensure that practicable measures are being employed to avoid incidental disturbance of habitat outside the project footprints and to survey for sensitive wildlife species. When vegetation removal and ground-disturbing activities are not occurring, as-needed monitoring at the project sites shall occur.
Worker Environmental Awareness Program. In areas near or adjacent to Environmentally Sensitive Areas, a qualified biologist shall conduct a Worker Environmental Awareness Program (WEAP) training session for project and construction personnel prior to the commencement of work. The training shall include a description of the species of concern and their habitats, the general provisions of the Endangered Species Acts (FESA and CESA), the penalties associated with violating the provisions of the acts, the general measures that are being implemented to conserve the species of concern as they relate to the project, and the access routes to and project site boundaries.
Best Management Practices. During future project construction activities, the following best management practices (BMPs) shall be implemented:
▪ All equipment maintenance, staging, and dispensing of fuel, oil, or any other such activities shall occur in developed or designated non-sensitive upland habitat areas. The designated upland areas shall be located to prevent runoff from any spills from entering Waters of the US. ▪ A construction Storm Water Pollution Prevention Plan (SWPPP) and a soil erosion and sedimentation plan shall be developed (where requirements are met) to minimize erosion and identify specific pollution prevention measures that shall eliminate or control potential point and nonpoint pollution sources on site during and following the project construction phase. The SWPPP shall identify specific BMPs during project construction to prevent any water quality standard exceedances. In addition, the SWPPP shall contain provisions for changes to the plan such as alternative mechanisms, if necessary, during project design and/or construction to achieve the stated goals and performance standards.
▪ Trash shall be stored in closed containers so that it is not readily accessible to scavengers and shall be removed from the construction site on a daily basis. ▪ Water quality shall be visually monitored by the biological monitor to ensure that no substantial increases in turbidity occur during construction.
▪ All relevant natural resource permits and authorizations shall be obtained from appropriate agencies (i.e., USACE, RWQCB, and CDFW) prior to the initiation of construction activities.
Permit conditions contained within the permits and authorizations shall be employed throughout the duration of the project.
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▪ Hydrologic connectivity shall be maintained within drainages during the duration of construction. Brush, debris material, mud, silt, or other pollutants from construction activities shall not be placed within drainages and shall not be allowed to enter a flowing stream. ▪ Dust control measures shall be implemented by the contractor to reduce excessive dust emissions. Dust control measures shall be carried out at least two times per day on all construction days, or more during windy or dry periods, and may include wetting work areas, the use of soil binders on dirt roads, and wetting or covering stockpiles. ▪ No pets shall be allowed in, or adjacent to, the project sites. ▪ Rodenticides, herbicides, insecticides, or other chemicals that could potentially harm wildlife or native plants shall not be used near or within Environmentally Sensitive Areas within or near the roadway segments.
▪ Construction equipment shall be cleaned of mud or other debris that may contain invasive plants and/or seeds and inspected to reduce the potential of spreading noxious weeds before mobilizing to the site and before leaving the site during the course of construction. ▪ The cleaning of equipment will occur at least 300 feet from Environmentally Sensitive Area fencing.
Use of Native Plants. All project-related planting and landscaping shall not use plants listed on California Invasive Plant Council. Locally native plants shall be used near open space and native areas to the greatest extent feasible.
MM-BIO-2 Applications for future development, wherein the City has determined a potential for impacts to least Bell’s vireo, shall be required to comply with the following mitigation framework. Prior to issuance of a permit for grading or vegetation removal, USFWS protocol surveys for least Bell’s vireo shall be required should project construction occur within 300 feet of riparian habitat during the breeding season (April 10 to July 31). If least Bell’s vireo are identified during the protocol surveys, then noise attenuation measures shall be required to ensure that noise levels from construction do not exceed a 60 dB(A) hourly average per hour at the edge of the riparian habitat or to the ambient noise level if it exceeds 60 dB(A) prior to construction. Construction noise monitoring shall be required to verify that noise levels at the edge of occupied habitat are maintained below 60 dB(A) hourly average unless an analysis completed by a qualified acoustician shows that noise generated by construction activities would not exceed 60 dB(A) hourly average at the edge of occupied habitat.
MM-BIO-4 Applications for future development, where the City has determined a potential for impacts to mature trees and/or native vegetation suitable for nesting birds, shall be required to comply with the following mitigation framework. If any construction commences during the bird breeding season, a preconstruction survey for nesting birds shall occur within three days prior to construction activities by an experienced avian biologist. The survey shall occur within all suitable nesting habitat within the project impact area and a minimum 250-foot buffer (or as otherwise mandated by wildlife agencies [CDFW and USFWS]). If nesting birds are found, an avoidance area shall be established, in consultation with the wildlife agencies as appropriate, by a qualified biologist around the nest until a qualified avian biologist has determined that young have fledged
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or nesting activities have ceased. The project site shall be re-surveyed if there is a lapse in construction activities for more than 3 days.
MM-BIO-5 Prior to issuance of any grading or removal of sensitive vegetation communities, the applicant shall provide evidence to the City that replacement habitats have been preserved in accordance with the mitigation ratios in the 2018 Draft Santee MSCP Subarea Plan. The required acreages and types of replacement habitat shall be included as a note on the grading plans and the City shall require evidence of satisfaction prior to grading. Replacement habitats may be in the form of a dedicated easement, proof of purchase of mitigation credits, or other method of conservation. The applicant shall additionally implement all feasible avoidance and minimization measures to protect habitats remaining on site.
MM-BIO-6 Applications where the City has determined a potential for impacts to jurisdictional waters and wetlands, shall be required to comply with the following mitigation framework. Prior to issuance of any construction permit or any earth-moving activities, a site-specific general biological resources survey (BIO-1) shall be conducted to identify the presence of any sensitive biological resources, including any wetlands. Should any potential jurisdictional waters or wetlands be identified on site during the general biological resources survey, then a jurisdictional wetlands delineation shall be conducted following the methods outlined in the USACE’s 1987 Wetlands Delineation Manual and the Regional Supplement to the Corps of Engineers Delineation Manual for the Arid West Region. The limits of any wetland habitats on site under the sole jurisdiction of CDFW shall also be delineated, as well as any special aquatic sites that may not meet federal jurisdictional criteria but are regulated by the RWQCB. Avoidance measures based on project-level grading and site plans shall be incorporated into the project design to minimize direct impacts to jurisdictional waters consistent with federal, state, and City guidelines. Unavoidable impacts to wetlands shall be minimized to the maximum extent practicable and would be subject to alternatives and mitigation analyses consistent with U.S. Environmental Protection Agency 404(b)(1) findings and procedures under the USACE’s permit process. Unavoidable impacts would require the in-kind creation of new wetland of the same type lost, at a ratio determined by the applicable regulatory agencies that would prevent any net loss of wetland functions and values. Wetland creation on site or within the same wetland system shall be given preference over replacement off site or within a different system. The City shall also control use and development in surrounding areas of influence to wetlands with the application of buffer zones. Buffer widths shall be 50 to 200 feet from the edge of the wetland/riparian habitat, unless the applicant demonstrates that a buffer of lesser width would protect the resources of the wetland based on site-specific information related to construction and operation. Use and development within buffer areas shall be limited to minor passive recreational uses with fencing, desiltation or erosion control facilities, or other improvements deemed necessary to protect the habitat, to be located in the upper (upland) half of the buffer when feasible wetlands and buffers shall be permanently conserved or protected through the application of an open space easement or other suitable device.
Additional requirements apply for development along the San Diego River to implement Draft Santee MSCP Subarea Plan Section 5.3.4. Specifically, wherever development is proposed in or adjacent to riparian habitats along the main stem San Diego River, the riparian area and other wetlands or associated natural habitats located on the project site shall be designated as biological open space and incorporated into the preserve, including recordation of an easement
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to ensure their protection in perpetuity. In addition, a minimum 100-foot biological buffer shall be established for upland habitats, beginning at the outer edge of riparian vegetation. Within the 100-foot biological buffer, no new development shall be allowed, and the area shall be managed for natural biological values as part of the preserve system. In the event that natural habitats do not cover the 100-foot buffer area at the time of the proposed action, habitats appropriate to the location and soils shall be restored as a condition for the proposed action. In most cases, coastal sage scrub vegetation shall be the preferred habitat to restore within the biological buffer.
3.5 Cultural Resources and Tribal Cultural Resources
The analysis in this section was completed in compliance with the following report:
▪ Phase I Environmental Site Assessment for City Ventures, prepared on November 29, 2023, by Stantec Consulting Services Inc., and included as Appendix C of this Addendum.
3.5.1 Analysis
Issue 1: Historic Resources
Would the Project cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR identified historic maps and aerial photographs available online which encompass the proposed Project Site 17. Historic photos show the Project site to have been mowed periodically to maintain weed control. The earliest photograph reviewed for all Rezone Sites was from 1953. Site 17 showed vacancy with evidence of vehicle and foot traffic. In 1998, an aerial photograph of Site 17 showed that the southwest corner showed evidence of grading and in 1999 the site served as a storage yard. Overall, Site 17, showed some level of ground-disturbing activities. The Santee Housing Element determined that the Rezone Sites could result in significant impacts to historic resources and proposed mitigation measure MM-CUL-1. MMCUL-1 would verify the age of buildings and structures that could be impacted by future development and would reduce impacts associated to historical resources to be less than significant.
Proposed Project Analysis
As stated above, the proposed Project could potentially result in significant impacts due to historic resources, however the proposed Project would implement MM-CUL-1 as recommended in the Santee Housing Element Implementation PEIR. No new significant impacts to historic resources would occur, and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant with mitigation.
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Issues 2 and 4: Archaeological Resources, Religious and Sacred Uses or Tribal Cultural Resources Would the Project result in substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5; religious uses or tribal cultural resources? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR evaluated sites that were identified eligible for by-right development including Site 17 at a site-specific level, which included completion of cultural resource records search and surveys to identify the potential for archaeological resources. One historic-period archaeological site within four Rezone Sites was identified during the records search. Additionally, the records search and survey identified one prehistoric resource and one isolated artifact within a Rezone Site. However, the historic-period archaeological site was determined not eligible for listing on the CRHR, the one isolated artifact does not possess characteristics that qualify as significant under CEQA, and lastly, one prehistoric resource could potentially be significant and further testing is required to determine the significant impact. The location of potential archaeological sites is undisclosed for confidentiality per 14 California Code of Regulations Section 15120 (d); however, the City maintains a record of the survey results and is able to use these findings to determine applicability of mitigation measures.
Site 17 was identified as having a moderate potential for Register Eligible buried archaeological sites, and therefore potential direct and/or indirect impacts related to archaeological resources and/or tribal cultural resources would be potentially significant without mitigation. MM-CUL-2 and MM-CUL-3 would be implemented during the development review process and/or during future development, which would require significance evaluation of archaeological resources, mitigation for potential impacts to these resources, and a requirement for archaeological and Native American monitoring during ground disturbing activities to avoid significant impacts to unknown buried archaeological resources. Therefore, after implementation of MM-CUL-2 and MM-CUL-3, impacts related to archaeological resources and/or tribal cultural resources would be less than significant.
Proposed Project Analysis
As stated above, the Project site is identified as having a moderate potential for intact cultural deposits to exist within native soils to the depths of assumed ground disturbance. Therefore, the proposed Project site should be treated as potentially sensitive for archaeological and/or tribal cultural resources. In the event unanticipated archaeological and/or tribal cultural resources are encountered during project implementation, impacts to these resources would be potentially significant.
Thus, mitigation is required to address impacts related to the inadvertent discovery of archaeological and/or tribal cultural resources during construction. MM-CUL-2 and MM-CUL-3 would be implemented during the development review process and/or during future development, which would require significance evaluation of archaeological resources, mitigation for potential impacts to these resources, and a requirement for archaeological and Native American monitoring during ground disturbing activities to avoid significant impacts to unknown buried archaeological and/or tribal cultural resources.
No new significant impacts to archaeological, religious and sacred uses or tribal cultural resources would occur, and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant with mitigation.
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Issue 3: Human Remains
Would the Project result in disturbance of any human remains, including those interred outside of formal cemeteries? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that no known burial sites or cemeteries are located within the vicinity of the Rezone Sites, including Site 17. However, in the unlikely event that human remains are discovered, then “provisions set forth in California PRC Section 5097.98 and state Health and Safety Code Section 7050.5 would be implemented in consultation with the assigned Most Likely Descendant as identified by the NAHC. No further construction activities would be permitted until the coroner is contacted, as well as any applicable Native American tribes. The City shall be required to comply with the California Native American Graves Protection and Repatriation Act (2001), the federal Native American Graves Protection and Repatriation Act (1990), as well as AB 52 early consultation requirements. As regulations are in place to treat any inadvertent uncovering of human remains during grading, impacts to human remains would be less than significant,” (City of Santee 2022).
Proposed Project Analysis
No prehistoric or historic period burials, including those buried outside of formal cemeteries, were identified within the proposed Project site. As stated above, in the event that human remains are inadvertently encountered during ground disturbing activities, they shall be treated consistent with state and local regulations including California Health and Safety Code Section 7050.5, California Public Resources Code Section 5097.98, and the California Code of Regulations Section 15064.5(e). In accordance with these regulations, if human remains are found, the County Coroner must be immediately notified of the discovery. No further excavation or disturbance of the project site or any nearby (no less than 100 feet) area reasonably suspected to overlie adjacent remains can occur until the County Coroner has determined if the remains are potentially human in origin. If the County Coroner determines that the remains are, or are believed to be, Native American, he or she is required to notify the NAHC which would then notify those persons believed to be the most likely descendant. The most likely descendant shall determine, in consultation with the property owner, the disposition of the human remains.
Compliance with these regulations would ensure that impacts to human remains resulting from the proposed Project would remain less than significant. No new significant impacts to inadvertent discovery of human remains would occur, and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant.
3.5.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR
MM-CUL-1: Applications for future development of project areas, wherein the City Development Services Director has determined a potential for impacts to historical resources, shall be required to comply with the following mitigation framework:
a) Prior to the issuance of any permit for a future development project, the age and original structural integrity and context of any buildings/structures occurring on the project areas shall be verified. A
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staff level evaluation is required in conjunction with the development permit application to verify the age and original structural integrity of all on-site structures. b) For any building/structures in excess of 50 years of age having its original structural integrity intact, a qualified professional historian may be required to determine whether the affected building/structure is historically significant. The evaluation of historic architectural resources shall be based on criteria such as age, location, context, association with an important person or event, uniqueness, or structural integrity, as indicated in CEQA Guidelines Section 15064.5. A historical resource report shall be prepared by a Secretary of Interior’s Standard Historic Architect or Architectural Historian and submitted by the project applicant to the City and shall include the methods used to determine the presence or absence of historical resources, identify potential impacts from the proposed Project, evaluate the significance of any historical resources, and identify mitigation measures.
c) Future development at Rezone Site 20 shall be required to obtain the services of a Secretary of Interior’s Standard Historic Architect or Architectural Historian to submit a report to the City demonstrating how development adjacent to the Polo Barn would adhere to Secretary of Interior Standards for the Treatment of Historic Properties and standards and guidelines prescribed by the State Office of Historic Preservation to ensure indirect impacts are avoided. Development on Site 20 is not subject to items (a) and (b) above as the Polo Barn is already known to be a significant historical site.
MM-CUL-2: Applications for future development, wherein the City Development Services Director has determined a potential for impacts to subsurface archaeological resources, shall be required to comply with the following mitigation framework:
Prior to the issuance of any permit for future development consistent with the project and if the project has not been surveyed within the last five years, an archaeological survey shall be conducted by a qualified archaeologist to evaluate the presence of archaeological resources and the need for project impact mitigation by preservation, relocation, or other methods. The archaeological survey shall include a records search at the South Coastal Information Center branch of the California Historical Research Information System, to determine if previously recorded prehistoric or historic archaeological resources exist on the housing site. In addition, the Native American Heritage Commission should be contacted to perform a Sacred Lands File Search. An archaeological resource report detailing the results of the record search, Sacred Lands Search, and the field survey of the project area shall be submitted by the Project applicant to the City. The report shall include the methods used to determine the presence or absence of archaeological resources, identify potential impacts from the proposed Project, and evaluate the significance of any archaeological resources identified. If potentially significant impacts to an identified archaeological resource are identified, the report shall also recommend appropriate mitigation to reduce the impacts to below a level of significance, which could include avoidance as the preferred method, a data recovery program and/or construction monitoring. All information regarding site locations, Native American human remains, and associated funerary objects should be in a separate confidential addendum and not be made available for public disclosure.
Reports shall be submitted to the South Coastal Information Center upon finalization.
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MM-CUL-3: Applications for future development wherein the City Development Services Director or a sitespecific report has determined a potential for discovery of buried archaeological resources shall be required to comply with the following mitigation framework for archaeological and Native American construction monitoring:
Prior to issuance of a grading permit, the City’s Project Planner at the City must verify that the requirements for archaeological and Native American construction monitoring have been noted on the construction documents.
The applicant must provide written verification to the City Project Planner stating that a Secretary of Interior’s Standards qualified archaeologist and Native American monitor have been retained by the owner/applicant to implement construction monitoring.
The qualified archaeologist and Native American monitor shall be invited to attend the preconstruction meeting with the contractor and any subcontractors to describe the goal of construction monitoring.
Archaeological and Native American monitors shall be present during ground disturbing activities (grubbing, demolition of foundations, grading, trenching) that have the potential to unearth unknown subsurface archaeological deposits or Tribal cultural resources. If archaeological or Tribal cultural resources are discovered, both monitors may halt or divert ground-disturbing activities within 50 feet to allow for a determination of the resource’s potential significance. The qualified archaeologist shall notify the City Project Planner of the discovery. Isolates and non-significant deposits shall be minimally documented in the field.
Significant archaeological discoveries include intact features, stratified deposits, previously unknown archaeological sites, and human remains.
If a significant discovery is made, the qualified archaeologist shall prepare a data recovery plan in consultation with the Native American monitor to submit for approval by the City Project Planner.
The plan shall be implemented using professional archaeological methods. Construction grounddisturbing activities, including grubbing, grading, and trenching, would be allowed to resume after the completion of the recovery of an adequate sample and recordation of the discovery.
All cultural material collected during the monitoring and data recovery program shall be processed and curated at a San Diego facility that meets federal standards per 36 CFR Part 79 unless the tribal monitors request the collection.
If human remains are discovered, work shall halt in that area and the procedures set forth in the California Public Resources Code (Sec. 5097.98) and State Health and Safety Code (Sec. 7050.5) will be followed. The qualified archaeologist shall contact the County Coroner.
After the completion of the monitoring, an appropriate report shall be prepared by Project archaeologist. If no significant cultural resources are discovered, a brief letter to City Project Planner and South Coastal Information Center shall be prepared by the Project archaeologist. If significant cultural resources are discovered, a report with the results of the monitoring and data recovery (including the interpretation of the data within the research context) shall be prepared
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by Project archaeologist, reviewed by a Native American representative, and submitted to the City Project Planner and South Coastal information Center.
3.6 Energy
The analysis in this section was completed in compliance with the following report:
▪ Cottonwood & Park Air Quality, Greenhouse Gas, and Energy Impacts Study for City Ventures, prepared in April 30, 2025, by MD Acoustics, LLC and included as Appendix A of this Addendum.
3.6.1 Analysis
Issue 1 and 2:
Would the Project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during Project construction or operation? Would the Project conflict with or obstruct a state or local plan for renewable energy or energy efficiency? City of Santee Housing Element Implementation PEIR Analysis Construction
The Santee Housing Element Implementation PEIR concluded that there are no conditions in the Rezone Sites that would require non-standard equipment or construction practices that would increase the fuel-energy consumption above typical rates. All Rezone Sites would need to be consistent with state requirements, and all construction equipment would have to meet California Board (CARB) Tier 3 In-Use Off-Road Diesel Engine Standards. Tier 3 In-Use Off-Road Diesel Engine Standards would require that construction equipment fleets are cleaner and in the long term use less energy. Therefore, the Santee Housing Element Implementation PEIR determined that the Rezone Sites would not result in a wasteful, inefficient, or unnecessary consumption of energy resources during future development and impacts would be less than significant.
Long-term Operations
Transportation
The Santee Housing Element Implementation PEIR determined that the Rezone Sites would consume energy associated transportation uses by individuals traveling to, from, and within the Rezone Sites. The majority of the trips would rely on passenger vehicles or public transportation. In which, the passenger vehicles would be powered by gasoline, diesel or electricity. The Santee Housing Element Implementation PEIR determined that the Rezone Sites would potentially result in a reduction of vehicle miles traveled (VMT) per capita and lead the City to a citywide VMT per capita reduction. However, due to the City’s RHNA needs and planned growth, the Rezone Sites can help reduce the VMT by being located in areas with existing retail sites, which would reduce the noncommute vehicle trips. Additionally, the Santee Housing Element Implementation PEIR states that future projects shall comply with the Mobility Element Policies 9.1 through 9.5, which includes the Transportation Demand Management (TDM) strategies such as ride sharing programs, flexible work schedule programs and incentives for
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employees to use transit. Future projects would be required to comply with the Sustainable Santee Plan by promoting non-motorized transportation options, improving bicycle transit, installing electric charging stations and improving traffic flow. With the implementation of Mobility Element policies, TDM, and Sustainable Santee Plan, Rezone Sites would not a result in a wasteful, inefficient, or unnecessary consumption of energy resources during future development and impacts would be less than significant.
Electricity and Natural Gas
The Santee Housing Element Implementation PEIR determined that future development would comply with the Renewable Portfolio Standard (RPS), SB 350, SB 100, California Code of Regulations, including 2019 Energy Code, 2019 CALGreen standards, and the Sustainable Santee Plan. Therefore, compliance with the the state, federal regulations and the Sustainable Santee Plan would reduce the City’s operational energy use. Impacts associated with electricity and natural gas would not result in a wasteful, inefficient, or unnecessary consumption of energy resources during future development and impacts would be less than significant.
Energy Plans
As stated above, future development would be required to comply with CALGreen, the California Energy Code, RPS, and the Sustainable Santee Plan. Therefore, future projects would not conflict or obstruct a state or local plan for renewable energy or energy efficiency, and impacts would be less than significant.
Proposed Project Analysis
The proposed Project is included in the future development of the Rezone Sites that was the subject of the PEIR.
Additionally, the proposed Project would comply with the required state regulations and local plans, including CALGreen, the California Energy Code, RPS, and the Sustainable Santee Plan, therefore, the impacts associated with wasteful, inefficient, or unnecessary consumption of energy resources due to the construction and operation of the proposed Project would remain less than significant and no new significant impacts would occur and no previously identified significant impacts would substantially increase in severity. Calculations associated with the proposed Project’s energy consumption are provided below.
Construction
Construction Equipment Fuel Estimates
Using the CalEEMod data input, the Project’s construction phase would consume electricity and fossil fuels as a single energy demand, that is, once construction is completed their use would cease. CARB’s 2017 Emissions Factors Tables show that on average aggregate fuel consumption (gasoline and diesel fuel) would be approximately 18.5 hp-hr-gal1. As presented in Table 3.6.1-1 below, Project construction activities would consume an estimated 41,824 gallons of diesel fuel.
1 Aggregate fuel consumption rate for all equipment was estimated at 18.5 hp -hr/day (from CARB’s 2017 Emissions Factors Tables and fuel consumption rate factors as shown in Table D-21 of the Moyer Guidelines:
(https://www.arb.ca.gov/msprog/moyer/guidelines/2017gl/2017_gl_appendix_d.pdf).
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Table 3.6.1-1: Construction Equipment Fuel Consumption Estimates Phase
Number
of Days
Offroad Equipment
Type Amount
Usage
Hours
Horse
Power
Load
Factor
HP
hrs/
day
Total Fuel
Consumption
(gal diesel
fuel)1
Site
Preparation
10 Rubber Tired Dozers 3 8 367 0.4 3,523 1,904
10 Tractors/Loaders/
Backhoes 4 8 84 0.37 995 538
Grading 30 Excavators 2 8 36 0.38 219 355
30 Graders 1 8 148 0.41 485 787
30 Rubber Tired Dozers 1 8 367 0.4 1,174 1,904
30 Scrapers 2 8 84 0.4 538 872
30 Tractors/Loaders/
Backhoes
2 8 84 0.37 497 806
Building
Construction
300 Cranes 1 7 367 0.29 745 12,081
300 Forklifts 3 8 82 0.2 394 6,383
300 Generator Sets 1 8 14 0.74 83 1,344
300 Tractors/Loaders/
Backhoes
3 7 84 0.37 653 10,584
300 Welders 1 8 81 0.42 166 2,685
Paving 20 Pavers 2 8 81 0.42 544 588
20 Paving Equipment 2 8 89 0.36 513 554
20 Rollers 2 8 36 0.38 219 237
Architectural
Coating 35 Air Compressors 1 6 37 0.48 107 202
Construction Fuel Demand (gallons of diesel fuel) 41,824 Notes:
1Using Carl Moyer Guidelines Table D-21 Fuel consumption rate factors (bhp-hr/gal) for engines less than 750 hp.
Source: https://www.arb.ca.gov/msprog/moyer/guidelines/2017gl/2017_gl_appendix_d.pdf Construction Equipment Electricity Usage Estimates
Electrical service will be provided by SDG&E. Based on the 2017 National Construction Estimator, Richard Pray (2017)2, the typical power cost per 1,000 square feet of building construction per month is estimated to be $2.32. The Project plans to develop the site with 458,530 square feet of new residential structures over the course of approximately 18 months. Based on Table 3.6.1-2, the total power cost of the on-site electricity usage during the construction of the proposed Project is estimated to be approximately $19,148. As shown in Table
3.6.1-2, the total electricity usage from Project construction related activities is estimated to be approximately 348,149 kWh.
3 2 Pray, Richard. 2017 National Construction Estimator. Carlsbad: Craftsman Book Company, 2017
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Table 3.6.1-2: Project Construction Power Cost and Electricity Usage Power Cost (per 1,000 square foot of
building per month of construction)
Total Building
Size (1,000
Square Foot)
Construction
Duration
(months)
Total Project
Construction
Power Cost
$2.32 458.530 18 $19,148.21
Cost per kWh
Total Project Construction Electricity Usage
(kWh)
$0.24 348,149
Notes: Assumes the Project will be under Schedule TOU-A rate under SDG&E and, to be conservative, uses the lower anticipated cost per kWh.
Assumes the project will be under Schedule TOU-A rate under SDG&E and, to be conservative, uses the lower anticipated cost per kWh. Source:
https://www.sdge.com/sites/default/files/regulatory/3 -1-21%20Small%20Commercial%20Total%20Rates%20Table.pdf.
Source: https://www.sdge.com/sites/default/files/regulatory/3-1 21%20Small%20Commercial%20Total%20Rates%20Table.pdf Construction Worker Fuel Estimates
It is assumed that all construction worker trips are from light duty autos (LDA) along area roadways. With respect to estimated VMT, the construction worker trips would generate an estimated 1,405,452 VMT. Vehicle fuel efficiencies for construction workers were estimated in the air quality and greenhouse gas analysis using information generated using CARB’s EMFAC model (see Appendix A for details). Table 3.6.1-3 shows that an estimated 45,410.4 gallons of fuel would be consumed for construction worker trips.
Table 3.6.1-3: Construction Worker Fuel Consumption Estimates Phase
Number
of Days
Worker
Trips/Day
Trip
Length
(miles)
Vehicle
Miles
Traveled
Average
Vehicle
Fuel
Economy
(mpg)
Estimated
Fuel
Consumption
(gallons)
Site Preparation 10 17.50 12 2,100 30.95 67.9
Grading 30 20.00 12 7,200 30.95 232.6
Building Construction 300 378.00 12 1,360,800 30.95 43,967.7 Paving 20 15.00 12 3,600 30.95 116.3
Architectural Coating 35 75.60 12 31,752 30.95 1,025.9
Total Construction Worker Fuel Consumption 45,410.4
Notes: Assumptions for the worker trip length and vehicle miles traveled are consistent with CalEEMod 2022.1.1.22 defaults.
Construction Vendor/Hauling Fuel Estimates
Tables 3.6.1-4 and 3.6.1-5 show the estimated fuel consumption for vendor and hauling during building construction and architectural coating. With respect to estimated VMT, the vendor and hauling trips would generate an estimated 270,786 VMT. For the architectural coatings it is assumed that the contractors would be responsible for bringing coatings and equipment with them in their light duty vehicles. Tables 3.6.1-4 and 3.6.1-5 show that an estimated 32,363 gallons of fuel would be consumed for vendor and hauling trips.
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Table 3.6.1-4: Construction Vendor Fuel Consumption Estimates (MHD Trucks) Phase
Number
of Days
Vendor
Trips/Day
Trip
Length
(miles)
Vehicle Miles
Traveled
Average
Vehicle
Fuel
Economy
(mpg)
Estimated
Fuel
Consumption
(gallons)
Site Preparation 10 0.00 7.63 0 9.22 0
Grading 30 0.00 7.63 0 9.22 0
Building
Construction 300 85.20 7.63 195,023 9.22 21,152
Paving 20 5.00 7.63 763 9.22 83
Architectural
Coating 35 0.00 7.63 0 9.22 0
Total Vendor Fuel Consumption 21,235
Notes: Assumptions for the vendor trip length and vehicle miles traveled are consistent with CalEEMod 2022.1.1.22 defaults.
Table 3.6.1-5: Construction Hauling Fuel Consumption Estimates (HHD Trucks) Phase
Number
of Days
Hauling
Trips/Day
Trip
Length
(miles)
Vehicle Miles
Traveled
Average
Vehicle
Fuel
Economy
(mpg)
Estimated
Fuel
Consumption
(gallons)
Site Preparation 10 0 20 0 6.74 0
Grading 30 125.0 20 75,000 6.74 11,128
Building
Construction
300 0 20 0 6.74 0
Paving 20 0 20 0 6.74 0
Architectural
Coating
35 0 20 0 6.74 0
Total Construction Hauling Fuel Consumption 11,128
Notes: Assumptions for the hauling trip length and vehicle miles traveled are consistent with CalEEMod 2022.1.1.22 defaults.
Construction Energy Efficiency/Conservation Measures
Construction equipment used over the approximately 18-month construction phase would conform to CARB regulations and California emissions standards and is evidence of related fuel efficiencies. In addition, the CARB Airborne Toxic Control Measure limits idling times of construction vehicles to no more than five minutes, thereby minimizing unnecessary and wasteful consumption of fuel due to unproductive idling of construction equipment.
Furthermore, the Project has been designed in compliance with California’s Energy Efficiency Standards and 2022 CALGreen Standards.
Construction of the proposed residential development would require the typical use of energy resources. There are no unusual Project characteristics or construction processes that would require the use of equipment that would be more energy intensive than is used for comparable activities; or equipment that would not conform to current emissions standards (and related fuel efficiencies). Equipment employed in construction of the proposed
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Project would therefore not result in inefficient wasteful, or unnecessary consumption of fuel. No new or increased significant impacts associated with energy consumption during construction of the proposed Project would occur and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant.
Operation
Energy consumption in support of or related to Project operations would include transportation energy demands (energy consumed by employee and patron vehicles accessing the Project site) and facilities energy demands (energy consumed by building operations and site maintenance activities).
Transportation
The largest source of operational energy use would be vehicle operation of customers. The site is located in a suburban area just in close proximity to transit stops. Using the CalEEMod output, it is assumed that an average trip is 8.3 miles. To show a worst-case analysis, as the proposed Project is a residential project, it was assumed that vehicles would operate 365 days per year. Table 3.6.1-6 shows the worst-case estimated annual fuel consumption for all classes of vehicles from autos to heavy-heavy trucks. Table 3.6.1-6 shows that an estimated 299,263 gallons of fuel would be consumed per year for the operation of the proposed Project.
Table 3.6.1-6: Estimated Vehicle Operations Fuel Consumption Vehicle
Type
Vehicle
Mix
Number
of
Vehicles
Average
Trip
(miles)1
Daily
VMT
Average
Fuel
Economy
(mpg)
Total
Gallons
per Day
Total Annual
Fuel
Consumption
(gallons)
Light Auto Automobile 1,205.9 8.30 10,009.2 31.82 314.56 114,813 Light Truck Automobile 129.9 8.30 1,078.3 27.16 39.70 14,491 Light Truck Automobile 426.2 8.30 3,537.2 25.6 138.17 50,432 Medium
Truck
Automobile 404.1 8.30 3,353.8 20.81 161.16 58,824
Light
Heavy
Truck
2-Axle
Truck
85.9 8.30 712.6 13.81 51.60 18,833
Light
Heavy
Truck
10,000
lbs +
2-Axle
Truck
21.5 8.30 178.5 14.18 12.59 4,595
Medium
Heavy
Truck
3-Axle
Truck
26.4 8.30 219.5 9.58 22.91 8,363
Heavy
Heavy
Truck
4-Axle
Truck
68.1 8.30 565.6 7.14 79.21 28,911
Total 2,368 - 19,655 -- 819.90 --
Total Annual Fuel Consumption 299,263
Notes: ‘Per CalEEMod assumptions, the project is to generate 2,368 total net new trips. Default CalEEMod vehicle fleet mix utilized.
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1 Based on the size of the site and relative location, trips were assumed to be local rather than regional.
Trip generation generated by the proposed Project are consistent with other similar residential uses of similar scale and configuration as reflected in the traffic data. That is, the proposed Project does not propose uses or operations that would inherently result in excessive and wasteful vehicle trips, nor associated excess and wasteful vehicle energy consumption. Therefore, project transportation energy consumption would not be considered inefficient, wasteful, or otherwise unnecessary. No new or increased significant impacts associated with energy consumption due to the proposed Project’s vehicle operations fuel consumption would occur, and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant.
Electricity and Natural Gas
The annual natural gas and electricity demands were provided per the CalEEMod output and are provided in Table 3.6.1-7.
Table 3.6.1-7: Project Annual Operational Energy Demand Summary Natural Gas Demand kBTU/year
Condo/Townhouse 7,362,174
Total 7,362,174
Electricity Demand kWh/year
Condo/Townhouse 1,478,309
Enclosed Parking Structure 1,002,810
Parking Lot 111,805
Total 2,592,924
Notes: Taken from the CalEEMod 2022.1.1.22 annual output.
As shown in Table 3.6.1-7, the estimated electricity demand for the proposed Project is approximately 2,592,924 kWh per year. In 2022, the residential sector of the County of San Diego consumed approximately 7,440 million kWh of electricity.4 In addition, the estimated natural gas consumption for the proposed Project is approximately 7,362,174 kBTU per year. In 2022, the residential sector of the County of San Diego consumed approximately 280.9 million therms of gas.5 Therefore, the increase in both electricity and natural gas demand from the proposed Project is insignificant compared to the County’s 2022 demand. No new or increased significant impacts associated with energy consumption due to the proposed Project’s electricity and natural gas demand would occur, and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant.
Energy Plans
Regarding federal transportation regulations, the Project site is located in an already developed area. Access to/from the Project site is from existing roads. These roads are already in place so the Project would not interfere 4 California Energy Commission, Electricity Consumption by County. https://ecdms.energy.ca.gov/elecbycounty.aspx 5 California Energy Commission, Gas Consumption by County. http://ecdms.energy.ca.gov/gasbycounty.aspx
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with, nor otherwise obstruct intermodal transportation plans or projects that may be proposed pursuant to the ISTEA because SCAG is not planning for intermodal facilities in the Project area.
Regarding the State’s Energy Plan and compliance with Title 24 CCR energy efficiency standards, the applicant is required to comply with the California Green Building Standard Code requirements for energy efficient buildings and appliances as well as utility energy efficiency programs implemented by the SCE and Southern California Gas Company.
Regarding the State’s Renewable Energy Portfolio Standards, the Project would be required to meet or exceed the energy standards established in the California Green Building Standards Code, Title 24, Part 11 (CALGreen).
CalGreen Standards require that new buildings reduce water consumption, employ building commissioning to increase building system efficiencies, divert construction waste from landfills, and install low pollutant-emitting finish materials.
The proposed Project would result in a less than significant impact due to wasteful, inefficient, or unnecessary consumption of energy resources during construction or operation. In addition, the proposed Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. Therefore, no new or increased significant impacts would occur, and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant.
3.6.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR
No mitigation measures required.
3.7 Geology and Soils
The analysis in this section was completed in compliance with the following report:
▪ Preliminary Geotechnical Investigation Santee 3 Residential Development APN 181-151-018 Santee, California for Santee 3 Inv, LLC., prepared on February 5, 2024, by Leighton and Associates, Inc., and included as Appendix D-1 of this Addendum.
▪ Geotechnical Investigation Southwest of Cottonwood Avenue and Park Center Drive, City of Santee, San Diego, California, prepared on January 29, 2025, by Alta California Geological Inc. and included as Appendix D-2 of this Addendum.
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3.7.1 Analysis
Issues 1 and 3: Seismic Hazards and Unstable Geology
Would the Project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: (i) rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault (refer to Division of Mines and Geology Special Publication 42); (ii) strong ground shaking? (iii) seismic-related ground failure, including liquefaction; or (iv) landslides? Would the Project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the Project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
City of Santee Housing Element Implementation PEIR Analysis a) Fault Rupture, Ground Shaking, Liquefaction, and Landslide The Santee Housing Element Implementation PEIR determined that the City is not located within an Alquist-Priolo Fault Zone, and no active or potentially active faults are known to occur within or adjacent to the City. However, with the City being located in California, there is potential for periodic seismic shaking due to earthquake along remote or regional active faults. Rezone Sites could be susceptible to damage due to the seismically active nature of the region. Additionally, with an increase of development this could potentially increase the number of people or structures, exposed to ground shaking during a seismic event. Landslides generally occur within areas of previous landslide movement, or where local topographic, geological, geotechnical, and subsurface water conditions indicate potential for permanent ground displacement. Usually, soil deposits are susceptible to liquefication which is alluvial soils that can be found in the San Diego River and its deeper tributary channels, all Rezone Sites except Site 10 were identified as having potential liquefaction. However, all future development within the Rezone Sites would be required to comply with the City’s General Plan Safety Element policies, City’s Municipal Code Section 11.40.130, and the California Building Code to ensure that future development within Rezone Sites would not cause substantial adverse effects associated with fault rupture, ground shaking, liquefaction, and landslides. Through regulatory compliance, impacts would be less than significant.
City’s General Plan Safety Element policies identified below:
▪ Policy 2.1: The City should utilize existing and evolving geologic, geophysical and engineering knowledge to distinguish and delineate those areas that are particularly susceptible to damage from seismic and other geologic conditions.
▪ Policy 2.2: The City should ensure that if a project is proposed in an area identified herein as seismically and/or geologically hazardous, the proposal shall demonstrate through appropriate geologic studies and investigations that either the unfavorable conditions do not exist in the specific area in question or that they may be avoided or mitigated through proper site planning, design and construction. ▪ Policy 2.3: The City shall require that all potential geotechnical and soil hazards be fully investigated at the environmental review stage prior to project approval.
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Proposed Project Analysis
a) Fault Rupture, Ground Shaking, Liquefaction, and Landslide As mentioned above, the Alquist–Priolo Earthquake Zoning Act (Alquist–Priolo Act) requires the delineation of fault zones along active faults in California. The purpose of the Alquist–Priolo Act is to regulate development on or near active fault traces to reduce hazards associated with fault rupture. The Alquist–Priolo Earthquake Fault Zones are the regulatory zones that include surface traces of active faults. According to the California Department of Conservation, the Project site is not located in an Alquist–Priolo Earthquake Fault Zone (CDOC 2022). The nearest active fault are the Rose Canyon and Newport-Inglewood fault zones located approximately 14 miles from the Project site (Appendix D-2). Thus, the potential for surface rupture is low on the Project site.
Additionally, similar to other areas located in the seismically active Southern California region, the City is susceptible to strong ground shaking during an earthquake. However, the Project site is not located within an Alquist–Priolo Earthquake Fault Zone, and the site would not be affected by ground shaking more than any other area in this seismic region nor would the Project have any component that would induce seismic ground-shaking.
The Project would comply with the City’s Municipal Code and the latest version of the California Building Code (CBC) which would ensure that the Project would adequately resist seismic ground shaking. Additionally, the CBC includes universal standards relating to seismic load requirements. Furthermore, in addition to the Preliminary Geotechnical Reports already completed for the Project (Appendix D-1; Appendix D-2), the Project would prepare design-specific geotechnical report(s) which would provide specific design recommendations for grading plans, utility plans, and foundation plans to ensure the structural integrity of the Project in the event that seismic ground shaking is experienced at the Project site. The design-specific geotechnical report(s) would be reviewed and approved by the City’s engineers prior to approval of grading and/or building permits.
Soil liquefaction is a seismically induced form of ground failure that has been a major cause of earthquake damage in Southern California. Liquefaction is a process by which water-saturated granular soils transform from a solid to a liquid state because of a sudden shock or strain such as an earthquake. According to the Preliminary Geotechnical Report (Appendix D-1)(Leighton 2024), the proposed Project site is underlain by unconsolidated sandy materials with a groundwater table at approximately 13 feet bgs, which present a potential for liquefication (Appendix D-1). Further evaluation presented in the Geotechnical Investigation (Appendix D-2)(Alta 2025) determined that the site presents a high likelihood of lateral spreading, due to the liquefaction potential. Due to the presence of liquefication potential, lateral spreading, loss of bearing and dynamic settlement, the Geotechnical Report (Appendix D-2) recommends ground improvement beneath the proposed structures to help densify the soils and improve bearing capacity. Various methods of ground improvement may be considered for the site, including stone columns, deep soil mixing, rammed aggregate piers, and compaction grouting. The Geotechnical Report recommends preparation of a site-specific ground improvement plan. Further details can be found in Appendix D-1, Section 6.1.4 Ground Improvement (Leighton) and Appendix D-2, Section 6.2 Conclusions and Recommendations (Alta).
According to the Geotechnical Reports, landslides were not indicated at the site during the field exploration or during the review of available geologic literature, topographic maps, and stereoscopic aerial photographs.
Therefore, the potential for significant landslides or large-scale slope instability at the site is considered low.
No new impacts related to fault rupture, ground shaking, and landslides would occur. The project would be required to comply with all geotechnical recommendations included in the Project’s Geotechnical Reports. No
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previously identified significant impacts would substantially increase in severity. Therefore, impacts would remain less than significant similar to the conclusion of the PEIR.
Issue 2: Soil Erosion
Would the Project result in substantial soil erosion or the loss of topsoil? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR concluded that impacts related to substantial soil erosion or loss of topsoil would be less than significant. The Santee Housing Element Implementation PEIR determined that erosion and sedimentation would primarily be a concern during construction phases of future development as areas would be stabilized through the installation of hardscape, landscaping, or native revegetation. Additionally, future development would comply with water standards including the National Pollutant Discharge Elimination System (NPDES) Municipal Permit and Municipal Code (Title 9, Chapter 9.06 Stormwater Management and Discharge Control) requirements and regulations. These regulations require erosion and sedimentation control during construction and implementation of best management practices to avoid erosion and off-site drainage.
Therefore, adherence to applicable Municipal Code requirements, future developments would not result in substantial soil erosion or loss of topsoil, and impacts would be less than significant.
Proposed Project Analysis
As noted above, the proposed Project would comply with water standards including the NPDES Municipal Permit and Municipal Code (Title 9, Chapter 9.06 Stormwater Management and Discharge Control) requirements and regulations. Additionally, the Project will comply with the site preparation and remediation recommendations as identified in Appendix D-2. Therefore, complying with the water quality standards, including the NPDES Municipal Permit, Municipal Code (Title 9, Chapter 9.06 Stormwater Management and Discharge Control) requirements and regulations, and the Geotechnical report recommendations, the impacts associated with erosion, or the loss of topsoil would remain less than significant similar to the conclusions of the PEIR. Further, no previously identified significant impacts would substantially increase in severity.
Issue 4: Expansive Soils
Would the Project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR noted that potentially expansive soil types occur on the Rezone Sites. The PEIR concluded that impacts related to expansive soils would be less than significant because future development within Rezone Sites would be required to comply with the Municipal Code requirements including a project specific geotechnical report to ensure site-specific measures are implemented to ensure safe building construction in areas with expansive soils.
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Proposed Project Analysis
Based on the Geotechnical Reports (Appendix D-1; Appendix D-2) for the proposed Project, the Project site is anticipated to have generally very low expansion index (EI). Low expansion is considered less than 50 or less in accordance with ASTM D 4829. Thus, expansion tests were performed on samples from selected materials and those tests indicated an EI of zero. In addition, selective grading to provide low expansion material below foundations is not anticipated according to the Geotechnical Report.
In conclusion, as recommended by the Santee Housing Element Implementation PEIR, the proposed Project would comply with the City’s Municipal Code and the recommendations in the site-specific Geotechnical Report. the proposed Project would not result in direct or indirect risks to life or property due to expansive soils. Therefore, no new or increased significant impacts would occur, and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, impacts would be less than significant.
Issue 5: Septic Tanks or Alternative Wastewater Disposal Would the Project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of waste water? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that no impacts would occur due to septic tanks or alternative wastewater disposal systems, as all sites would be served by the public wastewater system.
Proposed Project Analysis
As noted above, the proposed Project would be served by City sewer service, and no new septic or alternative wastewater systems would be used. Therefore, no new or increased impacts would occur, and no previously identified significant impacts would substantially increase in severity. Similar to the conclusion of the PEIR, there would be no impacts associated with septic tanks or alternative wastewater disposal.
Issue 6: Paleontological Resources and Unique Geology
Would the Project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that grading into a geologic formation with high or moderate sensitivity has the potential to result in impacts to paleontological resources. If grading were to occur at depths sufficient to disturb a moderate to high sensitivity geologic formation with potential paleontological resources, significant impacts could occur. With the implementation of MM-GEO-1, impacts related to paleontological resources would be reduced to less than significant with mitigation. Impacts associated with unique geology would be less than significant.
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Proposed Project Analysis
All the Rezone Sites, including Site 17, are located within existing development or vacant sites with some history of disturbance. Unique geologic features have not been identified at or within any of the Rezone Sites, therefore, impacts related to unique geologic features would be less than significant. Impacts related to paleontological resources would remain less than significant with the implementation of mitigation measure GEO-1 similar to the conclusion of the PEIR, and no previously identified significant impacts would substantially increase in severity.
Further, no new or increased significant impacts would occur.
3.7.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR
MM-GEO-1: The City shall review the project application materials including the geotechnical report to determine if project grading has the potential to disturb geologic formations with the potential to contain paleontological resources. If grading depths remain within the organic and soil layers, no monitoring would be required. The City may request information from the applicant such as the depth of grading, geologic formations and paleontological sensitivity in order to determine the potential for impacts. In the event grading may disturb geologic formations with a moderate or high potential to contain paleontological resources, the following monitoring program shall be implemented prior to and during grading operations:
1. Preconstruction Personnel and Repository: Prior to the commencement of construction, a qualified project paleontologist shall be retained to oversee the mitigation program. A qualified project paleontologist is a person with a doctorate or master’s degree in paleontology or related field and who has knowledge of the County of San Diego paleontology and documented experience in professional paleontological procedures and techniques. In addition, a regional fossil repository, such as the San Diego Natural History Museum, shall be designated by the City of Santee to receive any discovered fossils.
2. Preconstruction Meeting: The project paleontologist shall attend the preconstruction meeting to consult with the grading and excavation contractors concerning excavation schedules, paleontological field techniques, and safety issues.
3. Preconstruction Training: The project paleontologist shall conduct a paleontological resource training workshop to be attended by earth excavation personnel.
4. During-Construction Monitoring: A project paleontologist or paleontological monitor shall be present during all earthwork in formations with moderate to high paleontological sensitivity. A paleontological monitor (working under the direction of the project paleontologist) shall be on site on a full-time basis during all original cutting of previously undisturbed deposits.
5. During-Construction Fossil Recovery: If fossils are discovered, the project paleontologist (or paleontological monitor) shall recover them. In most cases, fossil salvage can be completed in a short period of time. However, some fossil specimens (e.g., a bone bed or a complete large mammal skeleton) may require an extended salvage period. In these instances, the project paleontologist (or paleontological monitor) has the authority to temporarily direct, divert, or halt grading to allow recovery of fossil remains in a timely manner.
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6. Post-Construction Treatment: Fossil remains collected during monitoring and salvage shall be cleaned, repaired, sorted, and cataloged.
7. Post-Construction Curation: Prepared fossils, along with copies of all pertinent field notes, photos, and maps, shall be deposited in the designated fossil repository.
8. Post-Construction Final Report: A final summary paleontological mitigation report that outlines the results of the mitigation program shall be completed and submitted to the City of Santee within two weeks of the completion of each construction phase of the proposed Project. This report shall include discussions of the methods used, stratigraphic section(s) exposed, fossils collected, inventory lists of cataloged fossils, and significance of recovered fossils.
3.8 Greenhouse Gas Emissions
The analysis in this section was completed in compliance with the following report:
▪ Cottonwood & Park Air Quality, Greenhouse Gas, and Energy Impacts Study for City Ventures, prepared April 30, 2025 by MD Acoustics, LLC and included as Appendix A of this Addendum.
3.8.1 Analysis
Issue 1: GHG Emissions
Would the Project result in GHG emissions that may have a significant impact on the environment? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that that project would result in an increase in GHG emissions that would exceed the assumption used in development of the Sustainable Santee Plan (SSP) and would result in an increase in VMT that exceeds the 85% thresholds, resulting in a significant impact. Both ministerial and discretionary developments included in the Rezone Sites would be required to comply with the SSP through a completed Consistency Checklist. Additionally, the Rezone Sites would result in an increase in development and associated emissions that have not been accounted for in the SSP, and therefore, GHG emissions would not be adequately addressed through compliance with SSP and GHG emissions within the Rezone Sites. This impact would be significant. Future development of Rezone Sites would require implementation of mitigation measures MM-GHG-1 and MM-GHG-2 to reduce significance. Additionally, to reduce potentially significant impacts associated with VMT from future development within the Rezone Sites, mitigation measure MM-TRA-1 would require incorporation of applicable TDM measures. However, the Santee Housing Element Implementation PEIR concluded that the GHG emissions would remain significant and unavoidable because at a program level of review, it was not feasible to conclude whether site-specific impacts would be fully mitigated.
Proposed Project Analysis
Project-generated GHG emissions are presented for informational purposes and are not used in determining significance of potential GHG-related impacts. Rather, consistency with the SSP is used to analyze the
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significance of GHG emissions at the project level. The SSP is a qualified GHG emissions reduction plan in accordance with CEQA Guidelines Section 15183.5.
Construction
The greenhouse gas emissions from the proposed Project construction equipment and worker vehicles are shown in Table 3.8.1-1. The emissions are from all phases of construction. Construction-related emissions are amortized over a 30-year period in conjunction with the proposed Project’s operational emissions as recommended by Association of Environmental Processionals (AEP) and based on guidance from the SCAQMD (AEP 2016, SCAQMD 2008). The total construction emissions amortized over a period of 30 years are estimated at 46.2 metric tons of CO2e per year. Annual CalEEMod output calculations are provided in Appendix A.
Table 3.8.1-1: Estimated Annual Construction Greenhouse Gas Emissions Year
Metric Tons Per Year
Bio-CO2 NBio-CO2 Total CO2 CH4 N20 CO2e (MT)
2024 0.00 414.00 414.00 0.02 0.03 424.00
2025 0.00 920.00 920.00 0.04 0.05 938.00
2026 0.00 23.60 23.60 0.00 0.00 23.90
Total 0.00 1,357.60 1,357.60 0.06 0.08 1,385.90
Amortized Construction Emissions 46.20
Notes: MTCO2e=metric tons of carbon dioxide equivalents (includes carbon dioxide, methane, and nitrous oxide).
The emissions are averaged over 30 years.
Source: Appendix A
Operational
Operational emissions occur over the life of the Project. Table 3.8.1-2 shows the proposed Project’s operational emissions (baseline emissions without credit for any reductions from sustainable design and/or regulatory requirements) for informational purposes.
Table 3.8.1-2: Opening Year Project-Related Greenhouse Gas Emissions Category
Greenhouse Gas Emissions (Metric Tons/Year) 1
Bio-CO2
NonBioCO2 CO2 CH4 N2O R CO2e
Area Sources2 0.00 8.62 8.62 0.00 0.00 0.00 8.65
Energy Usage3 0.00 1,083.00 1,083.00 0.07 0.01 0.00 1,087.00 Mobile Sources4 0.00 2,592.00 2,592.00 0.13 0.11 3.89 2,632.00 Solid Waste5 23.60 0.00 23.60 2.36 0.00 0.00 82.70
Water6 3.99 24.40 28.39 0.41 0.01 0.00 41.60
Refrigerants 0.00 0.00 0.00 0.00 0.00 0.45 0.45
Subtotal Emissions 27.59 3,708.02 3,735.61 2.97 0.13 4.34 3,852.40 Amortized Construction Emissions7 46.20
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Table 3.8.1-2: Opening Year Project-Related Greenhouse Gas Emissions Category
Greenhouse Gas Emissions (Metric Tons/Year) 1
Bio-CO2
NonBioCO2 CO2 CH4 N2O R CO2e
Total Emissions 3,898.60
Service Population 999.00
Total Emissions per Service Population (MTCO2e/yr/SP) 3.90 2026 Interpolated Threshold (MTCO2e/yr/SP) 4.08
Exceeds threshold? No
Notes:
1 Source: CalEEMod Version 2022.1.1.22
2 Area sources consist of GHG emissions from consumer products, architectural coatings, and landscape equipment. 3 Energy usage consists of GHG emissions from electricity and natural gas usage. 4 Mobile sources consist of GHG emissions from vehicles. 5 Solid waste includes the CO2 and CH4 emissions created from the solid waste placed in landfills. 6 Water includes GHG emissions from electricity used for transport of water and processing of wastewater. 7 Construction GHG emissions based on a 30 year amortization rate.
As shown in Table 3.8.1-2, implementation of the Project would result in approximately 3,898.6 MT CO2e per year including amortized construction emissions. Complete details of the construction emissions calculations are provided in Appendix A, Air Quality and Greenhouse Gas Emissions CalEEMod Output Files, of Appendix A.
As noted previously, there is no numeric threshold appropriate to evaluate the significance of Project-generated GHG emissions. As such, the estimation of GHG emissions increase generated by the Project provided above is for informational purposes in accordance with Section 15064.4 of the State CEQA Guidelines. However, as discussed above, the Project’s compliance with the Sustainable Santee Plan is used to evaluate the significance of the Project’s GHG emissions. As detailed below, the Project is consistent with applicable plans, policies, or regulations adopted for the purpose of reducing GHG emissions. Therefore, impacts would remain less than significant similar to the conclusions of the PEIR, no new or increased significant impacts would occur, and no previously identified significant impacts would substantially increase in severity.
Issue 2: Policies, Plans, and Regulations Intended to Reduce GHG Emissions Would the Project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emission of GHGs?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that the Rezone Sites would be consistent with the goals and policies from the CARB 2017 Scoping Plan, 2021 Regional Plan/Sustainable Communities Strategy (SCS), and the SSP. However, the Santee Housing Element Implementation PEIR concluded that because the Project would result in an increase in development not accounted for in the SSP emission inventories and the Project would result in significant VMT impacts that would conflict with the 2021 Regional Plan/SCS, the Project would conflict with GHG emissions reduction plans and impacts would be significant. Therefore, impacts associated with consistency with policies, plans and regulations adopted for the purpose of reducing GHG emissions would remain significant and unavoidable after mitigation.
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Proposed Project Analysis
The proposed Project could have the potential to conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases. The proposed Project’s GHG impacts are evaluated by assessing the Project’s consistency with the applicable local GHG reduction plan and strategy.
The Office of Land Use and Climate Innovation (LCI) encourages lead agencies to make use of programmatic mitigation plans and programs from which to tier when they perform individual project analyses. The City has adopted the SSP which is a qualified GHG emissions reduction plan in accordance with CEQA Guidelines Section 15183.5. If the proposed Project complies with this plan, the proposed Project would continue to result in a less than significant impact because it would be consistent with the overarching state, regional, and local plans for GHG reduction.
A consistency analysis is provided below and describes the Project’s compliance with or exceedance of performance-based standards included in the Sustainable Santee Plan.
Sustainable Santee Plan Consistency Analysis
The focus of the SSP included promoting energy- and water-efficient buildings, smart growth and clean transit, zero waste policies, and increased local energy generation and water resources. Table 3.8.1-3 summarizes reduction strategies from the SSP and evaluates Project consistency with each strategy. The Project would be consistent with all applicable SSP reduction strategies; therefore, the Project would not conflict with the SSP.
Table 3.8.1-3 Sustainable Santee Plan Consistency Analysis Measure Project Consistency
Goal 1. Increase Energy Efficiency in Existing Residential Units
Not applicable. The project is a new
development.
Goal 2. Increase Energy Efficiency in the New Residential Units Measure 2.1. New residential construction meet or exceed California Green Building Standards Tier 2 Voluntary
Measures, such as obtaining green building ratings including LEED, Build it Green, or Energy Star Certified building certifications in scoring development and explain the
measures implemented.
Consistent. The Project will meet California
Green Building Standards Tier 2 Voluntary
Measures.
Goal 3: Increase Energy Efficiency in Existing Commercial Units Not applicable. The project is a residential
development.
Goal 4: Increase Energy Efficiency in New Commercial Units Not applicable. The project is a residential
development.
Goal 5: Decrease Energy Demand through Reducing Urban Heat Island Effect Measure 5.1. Tree Planting for Shading and Energy Efficiency Consistent. The project will comply with all City regulations regarding tree planting.
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Table 3.8.1-3 Sustainable Santee Plan Consistency Analysis Measure Project Consistency
Measure 5.2. Light-reflecting Surfaces for Energy Efficiency Consistent. While this measure is regarding commercial and municipal buildings, the
project will comply with all City regulations
regarding cool roofs for residential buildings
Goal 6. Decrease GHG Emissions through a Reduction in VMT Measure 6.1. Proposed Project streets include sidewalks, crosswalks, and other infrastructure that promotes non‐ motorized transportation options
Consistent. The project would include
sidewalks and crosswalks and would connect
to existing pedestrian networks and an existing
park.
Measure 6.2. Proposed Project installs bike paths to improve bike transit.
Consistent. The project will install the River
Trail along the southern portion of the project
site that will connect existing portions of the
River Trail west and east of the projects site
allowing for efficient bike travel in the project
vicinity.
Goal 7: Increase Use of Electric Vehicles
Measure 7.1. Install electric vehicle chargers in all new residential and commercial developments.
b. For new Multifamily Residential, install e‐chargers for 13% of total parking.
Consistent. The Project will install at least
install e‐chargers for 13% of total parking.
Goal 8. Improve Traffic Flow
Measure 8.1. Implement traffic flow improvement program.
Install smart traffic signals at intersections warranting a traffic signal, OR
Install roundabout.
Consistent. The Project will install a
roundabout at the intersection of Walker Trails
Drive and Park Center Drive. No traffic signals
will be installed as part of the Project.
Goal 9: Decrease GHG Emissions through Reducing Solid Waste Generation Measure 9.1. Reduce waste at landfills. Consistent. The Project will comply with the requirement in AB-341 to reduce waste to
landfills by 75%.
Goal 10. Decrease GHG Emissions through Increased Clean Energy Use Measure 10.1. Increase distributed energy generation within City of Santee by implementing the following applicable photovoltaic solar systems:
b. Multifamily residential to install at least 1kW per unit of PV solar systems, unless the installation is infeasible due to poor solar resources established in a solar feasibility study prepared by a qualified solar consultant submitted with an applicant’s formal project submittal to City.
Consistent. The Project will comply with the
2022 Energy Code requiring all residential
uses to include solar.
As shown in Table 3.8.1-3, the Project would comply the identified measures of the Sustainable Santee Plan.
Further, the Project would include site design elements and project design features developed to support the policy objectives of the Regional Plan and SCS. The Project is consistent with the applicable strategies of the 2017 Scoping Plan and SANDAG’s Regional Plan. A detailed consistency analysis is included in the Air Quality, Greenhouse Gas, and Energy Impact Study (Appendix A).
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Therefore, the Project will not conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases. Impacts would be less than significant with mitigation, would not result in any new or increased significant impacts, and no previously identified significant impacts would substantially increase in the severity.
3.8.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR
MM-GHG-1: For development at Rezone Sites that proceed before an update to the Sustainable Santee Plan is adopted, as detailed in MM-GHG-2, a site-specific GHG analysis is required. The site-specific GHG analysis shall (1) determine whether the project would result in GHG emissions that may have a significant impact on the environment and specifically must demonstrate how the project would reduce emissions to achieve consistency with the State Scoping Plan and applicable GHG reduction targets, and (2) the analysis must demonstrate how the project would be consistent with the Sustainable Santee Plan Consistency Checklist in addition to other applicable GHG reduction plans. The site-specific GHG analysis shall be completed to the satisfaction of the City during the permitting process. For development at Rezone Sites that proceed after the Sustainable Santee Plan is adopted as detailed in MM-GHG-2, only project consistency with the Sustainable Santee Plan Consistency Checklist is required.
MM-GHG-2: Within one year of adoption of the rezone program, the City shall prepare an update to the Sustainable Santee Plan to incorporate the additional emissions that would result from development at the rezone sites as part of the baseline inventory. The updated Sustainable Santee Plan shall determine GHG emission reduction targets consistent with the current Scoping Plan, based on the updated inventory and provide any necessary updates to the Consistency Checklist.
3.9 Hazards and Hazardous Materials
3.9.1 Analysis
Issues 1, 2, and 3: Hazardous Material—Use, Transport, Disposal; Accidental Release; and Emission near a School
Would the Project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
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? Would the Project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? City of Santee Housing Element Implementation PEIR Analysis a. Routine Use, Transport, and Disposal
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The Santee Housing Element Implementation PEIR determined that the routine use, transport, and disposal of hazardous materials would be less than significant, Rezone Sites are not located within or adjacent to an existing cleanup site. However, future developments within the Rezone Sites including the Site 17, may use, transport, and dispose hazardous materials during construction. The use, transport, and disposal of hazardous materials during construction would be temporary during the duration of construction, and future developments would be required to comply with all applicable State, regional, local regulations associated with handling and transport of hazardous materials. Therefore, with proper use and disposal of hazardous materials as required by state, regional, and local regulations, impacts related to the use, transport, and disposal of hazardous materials would be less than significant. b. Accidental Release
The Santee Housing Element Implementation PEIR determined that an accidental release could occur during the following: the routine use, transport, and disposal of hazardous materials during future development’s operation and/or through the accidental upset of hazardous material during excavation and construction.
Exposure to hazardous material could potentially occur through contact with contaminated soil or groundwater, skin contact, the inhalation of vapors or dust, or during the demolition of structures constructed prior to 1978. Therefore, the demolition of structures could potentially expose workers to asbestos containing dust. However, California law requires compliance with Cal-OSHA worker safety standards, which requires asbestos testing and abatement, this would ensure that all asbestos removal is completed properly with required safety precautions to avoid the release of hazardous materials. Additionally, risks associated with the accidental release of hazardous materials would be managed through the implementation of AB 3205, California Waste Control Law, California H&SC, California Fire Code, and RCRA regulations. Impacts related to the accidental release of hazardous material during future buildout or demolition of building at Rezone Sites would be potentially significant and would require mitigation measure MM-HAZ-1 to ensure hazardous materials are handled correctly, therefore after mitigation impacts would be less than significant. c. Emissions Near a School
The Santee Housing Element Implementation PEIR determined that none of the Rezone Sites, including Site 17, are within 0.25 mile of a school, in the case of future developments being within 0.25 mile of a school, future developments would be required to consult with and provide written notification to the school district 30 days prior to the certification of the EIR. However, none of the Rezone Sites are located within the 0.25 mile of a school, therefore, impacts related to emissions near a school would be less than significant.
Proposed Project Analysis
a. Routine Use, Transport, and Disposal
Construction of the Project would include the development of 285 multi-family residential units, associated improvements, internal roadways, water lines and electrical utilities. Site development would also include landscaping and stormwater management features. The Project site is currently vacant and no demolition of structures would be required for development of the site.
Hazardous materials that may be used during construction activities include gasoline, diesel fuel, oil, lubricants, grease, welding gases, solvents, and paints. These materials would be used and stored in
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designated construction staging areas within the boundaries of the Project site and would be transported, handled, and disposed of in accordance with all applicable federal, state, and local laws and regulations. The use of these materials for their intended purpose would not pose a significant risk to the public or environment. Hazardous wastes accumulated during Project construction will be recycled, when possible, at a licensed off-site recycling facility. Empty containers for such materials (e.g., drums and totes) may also be returned to vendors, if possible. Hazardous waste that cannot be recycled would be transported by a licensed hazardous waste hauler using a Uniform Hazardous Waste Manifest and disposed of at an appropriately permitted facility. The use of these substances is subject to applicable federal, state, and local health and safety laws and regulations that are intended to minimize health risk to the public associated with hazardous materials. With adherence to be managed through the implementation of AB 3205, California Waste Control Law, California H&SC, California Fire Code, and RCRA regulations, construction of the Project would not create a significant hazard to the public or environment during routine transport, use or disposal of hazardous materials, and impacts during construction would be less than significant and would not result in any new or increased impacts in this regard.
Additionally, residential uses are not typically associated with the transport, use, or disposal of hazardous materials. Household goods used by residential homes that contain toxic substances are usually in low concentration and small in amount. Therefore, there is no significant risk to humans or the environment from the use of such household goods. Residents are required to dispose of household hazardous waste, including pesticides, batteries, old paint, solvents, used oil, antifreeze, and other chemicals, at a Household Hazardous Waste Collection Facility. Also, as of February 2006, fluorescent lamps, batteries, and mercury thermostats can no longer be disposed in the trash. Furthermore, the transport, use, and disposal of hazardous materials are fully regulated through the implementation of AB 3205, California Waste Control Law, California H&SC, California Fire Code, and RCRA regulations. With mandatory regulatory compliance, potential hazardous material impacts associated with long-term operation of the Project would be less than significant and would not result in any new or increased impacts in this regard. b. Accidental Release
As discussed above, hazardous materials required for construction would be used following all appropriate federal, state, and local laws, rules, and regulations, thereby reducing the potential for an accidental release to the environment. Additionally, hazardous materials required during construction would not likely be stored on site in such quantities that a significant release would occur.
With adherence to applicable federal, state, and local laws, rules and regulations, construction of the Project would not create a significant hazard to the public or environment by creating a reasonably foreseeable upset or accident condition, and impacts would be less than significant.
Additionally, residential uses are not typically associated with the transport, use, or disposal of hazardous materials. Residents are required to dispose of household hazardous waste at a Household Hazardous Waste Collection Facility. In addition, operations would be required to comply with EPA, State of California, San Diego County, and/or the City regulations pertaining to household wastes. With mandatory regulatory compliance, potential hazardous materials accidental release impacts associated with long-term operation of the Project would be less than significant and would not result in any new or increased impacts in this regard. c. Emissions Near a School
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Given there are no existing or proposed schools located within 0.25 miles of the Project site. The nearest school is the Rio Seco School, a middle school located approximately 0.40 mile west of the Project site.
Therefore, the Project would not create hazardous emissions or handle hazardous materials near a school, and no new or increased impacts would occur in this regard.
Issue 4: Hazardous Material--Sites
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 it create a significant hazard to the public or the environment?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that none of the Rezone Sites are listed as hazardous materials sites pursuant to Government Code Section 65962.5 (Cortese List) and impacts related to hazardous sites would be less than significant.
Proposed Project Analysis
As stated in the Santee Housing Element Implementation PEIR, the Project site is not listed as a hazardous materials site, therefore, the proposed Project would not have any new impacts related to hazardous sites and would not result in any increase in the severity of impacts in this regard.
Issue 5: Airport Hazards
For a Project located within an ALUCP or, where such a plan has not been adopted, within two miles of a public airport or public use airport, or a project within the vicinity of a private airstrip, would the Project result in a safety hazard for people residing or working in the Project area? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that the Rezone Sites are located within Gillespie Field Influence Area 1, Gillespie Field Influence Area 2, and MCAS Miramar Influence Area 2. Rezone Site 17 is located within Gillespie Field Influence Area 1 and 2 and MCAS Miramar Influence Area 2. The ALUCP addresses four types of compatibility factors which include noise, safety, airspace protection, and overflight. After review, the Santee Housing Element Implementation PEIR determined that the Rezone Sites are not anticipated to result in a safety hazard for people working or residing in the Rezone Sites. Therefore, impacts related to airport hazards would be less than significant.
Proposed Project Analysis
As mentioned above, the proposed Project (Rezone Site 17) is located within Gillespie Field Influence Area 1 and Gillespie Field Influence Area 2, and MCAS Miramar Influence Area 2.
With specific respect to air safety issues, the Gillespie Field and MCAS Miramar ALUCPs (SDCRAA 2010 and 2011) state the following:
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▪ Influence Area 1 consists of locations where noise and safety concerns may necessitate limitations on the types of land uses actions. Specifically, Influence Area 1 encompasses locations exposed to aircraft noise levels of 60 dB CNEL or greater and areas subject to the safety zones depicted on Figure 4.7-2 in the Santee Housing Element Implementation PEIR. Sites within a designated safety zone, such as Influence Area 1, require a consistency determination with the Airport Land Use Commission (ALUC) for San Diego County. In addition, projects within Influence Area 1 must file with the Federal Aviation Administration for a Determination of No Hazard.
▪ Influence Area 2 consists of locations beyond Influence Area 1 but within the airspace and/or overflight notification areas depicted on the maps in the respective ALUCPs. Limits on the heights of structures, particularly in areas of high terrain, are the only restriction on land uses within Influence Area 2. For projects within Influence Area 2, the recordation of overflight notification documents is also required. In addition, projects within Influence Area 2 must file with the Federal Aviation Administration for a Determination of No Hazard.
The proposed Project would be located within both Influence Area 1 and Influence Area 2, approximately 1.3 miles away from Gillespie Field Airport. The ALUC for San Diego County has adopted an Airport Land Use Plan which regulates airport use and public safety. Based on the future airport noise contours provided in the compatibility plan, the Project site is not within any dB CNEL noise contour (60) for the Gillespie Field Airport. The proposed Project would not expose people residing or working on the site to excessive noise levels associated with airports (ALUC 2010). Further the FAA has issued a Determination of No Hazard for the Project which will be submitted to the ALUC for San Diego County for completion of a consistency determination. Similar to the Santee Housing Element Implementation PEIR, given the distance between the Gillespie Field Airport and the Project site, the proposed Project would not result in any new impacts related to airport safety hazards and would not result in any increase in the severity of impacts in this regard.
Issue 6: Emergency Response
Would the Project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR concluded that impacts related to emergency response plans would be less than significant. The Santee Housing Element Implementation PEIR also stated that all future developments would have to undergo reviewal and approval by the Santee Fire Department prior to issuance of building permit and impacts would be less than significant.
Proposed Project Analysis
The proposed Projectwould be consistentwith the land uses in the Santee Housing Element Implementation PEIR and prior to the issuance of building permits, the proposed Project must be reviewed and approved by the Santee Fire Department. The proposed Project has been accounted for in City planning documents for planning for emergency management in the event of a disaster. Therefore, implementation of the proposed Project would not result in any new impacts related to adopted emergency response plans or emergency evacuation plans and would not result in any increase in the severity of impacts in this regard.
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Issue 7: Wildland Fires
Would the Project expose people or structures to a significant risk of loss, injury, or death involving wildland fires, including where wildlands are adjacent to urbanized areas, within brush fire management zones, or where residences are intermixed with wildlands?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that the Rezone Site 17 is not located within a very high fire hazard severity zone and would not be required to adhere to California Fire Code Title 19, Division 1, Section 3.07(b), requiring a minimum 30-foot brush clearance around structures for fire safety. In addition, future developments would have to comply with the City’s General Plan policies 4.2 through 4.13, fire code regulations, and reviewed by the Building Official/Fire Marshal, therefore, impacts associated with risk of wildland fire would be less than significant.
Proposed Project Analysis
The proposed Project site is located within the Local Responsibility Area (LRA) and not located within a very high fire hazard severity zone area, and as such, would not expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands. Therefore, implementation of the proposed Project would not result in any new impacts and would not result in any increase in the severity of impacts in this regard.
3.9.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR
MM-HAZ-1: Applications for future development in the Rezone Sites, wherein the City has determined a potential for impacts to known and unknown hazardous materials sites, shall be required to comply with the following mitigation framework. Future projects shall be required to identify potential conditions, which require further regulatory oversight and demonstrate compliance based on the following measures prior to issuance of any permits.
A. A Phase I Environmental Site Assessment (ESA) shall be completed in accordance with American Society of Testing and Materials (ASTM) Standards. If hazardous materials are identified requiring remediation, a Phase II ESA and remediation effort shall be conducted in conformance with federal, state, and local regulations.
B. If the Phase II ESA identifies the need for remediation, then the following shall occur prior to the issuance of grading permits:
1. The applicant shall retain a qualified environmental engineer to develop a soil and/or groundwater management plan to address the notification, monitoring, sampling, testing, handling, storage, and disposal of contaminated media or substances (soil, groundwater). The qualified environmental consultant shall monitor excavations and grading activities in accordance with the plan. The plans shall be approved by the City prior to development of the site.
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2. The applicant shall submit documentation showing that contaminated soil and/or groundwater on proposed development parcels have been avoided or remediated to meet cleanup requirements established by appropriate local regulatory agencies (Regional Water Quality Control Board [RWQCB]/DTSC/DEH) based on the future planned land use of the specific area within the boundaries of the site (i.e., commercial, residential), and that the risk to human health of future occupants of these areas therefore has been reduced to below a level of significance.
3. The applicant shall obtain written authorization from the appropriate regulatory agency (RWQCB/DTSC/DEH) confirming the completion of remediation. A copy of the authorization shall be submitted to the City to confirm that all appropriate remediation has been completed and that the proposed development parcel has been cleaned up to the satisfaction of the regulatory agency. In the situation where previous contamination has occurred on a site that has a previously closed case or on a site included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5, the DEH shall be notified of the proposed land use.
4. All cleanup activities shall be performed in accordance with all applicable federal, state, and local laws and regulations, and required permits shall be secured prior to commencement of construction to the satisfaction of the City and compliance with applicable regulatory agencies such as but not limited to the City of Santee Municipal Code.
3.10 Hydrology and Water Quality
The analysis in this section was completed in compliance with the following report:
▪ Request for A Conditional Letter of Map Revision for Santee 3 Multifamily Housing, San Diego River, County of San Diego, CA, prepared January 13, 2025, by Rick Engineering Company Water Resources Division and included as Appendix E-1 of this Addendum. ▪ Priority Development Project Storm Water Quality Management Plan (SWQMP) for Santee 3 Multifamily Housing for Santee 3 Inv, LLC., prepared April 16, 2025, by Rick Engineering Company and included as Appendix E-2 of this Addendum.
▪ Drainage Study for Santee 3 Multifamily Housing Preliminary Engineering for Santee 3 Inv, LLC., prepared April 16, 2025, by Rick Engineering Company and included as Appendix E-3 of this Addendum.
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3.10.1 Analysis
Issues 1 and 5: Water Quality
Would the Project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
Would the Project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that the Rezone Sites have the potential to substantially degrade surface or groundwater quality, however, future development would be compliant to federal, state, and local regulations, including the City’s Water Quality Improvement Program (WQIP), MS4 Permit, Best Management Practice (BMP) Design Manual, National Pollutant Discharge Elimination System (NPDES) General Construction Permit, and all regulations related to water quality. Therefore, through regulatory compliance impacts related to water quality standards and waste discharge requirements would be less than significant.
Likewise, future development within the Rezone Sites would not conflict with or obstruct implementation of a water quality control plan.
Proposed Project Analysis
The Santee Housing Element Implementation PEIR assumed residential development would occur on the proposed Project site. Therefore, water supply and demand for the proposed Project has been accounted for in the Santee Housing Element Implementation PEIR. Additionally, as stated in the Drainage Study (Appendix E-3), the proposed Project would be managed via a water quality basin and modular wetland system designed pursuant the guidelines from the City’s BMP Design Manual (Appendix E-3). Thus, the Project would be compliant with all federal, state, and local regulations, including compliance with National Pollutant Discharge Elimination System permit requirements for urban runoff and stormwater discharge. BMPs for design, treatment, and monitoring for stormwater quality would be implemented as delineated in the Santee Housing Element Implementation PEIR with respect to municipal and construction permits. The proposed Project would comply with the most recent City BMP Design Manual, which would result in improved water quality discharge. The Project would also comply with the stormwater BMP requirements further detailed in the SWQMP (Appendix E-2). In compliance with all applicable rules and regulations governing water quality impacts related to water quality would remain less than significant and would not result in any increase in the severity of impacts in this regard.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05 83
AUGUST 2025
Issue 2: Groundwater
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? Would the Project substantially degrade groundwater quality or obstruct implementation of a sustainable groundwater management plan? (see groundwater portions of issue questions 1 and 5) City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR concluded that the Rezone Sites impacts would be less than significant and would not adversely affect groundwater recharge or obstruct implementation of sustainable groundwater management plan. Additionally, future developments would be required to comply with the City’s General Plan policies and regulations that prioritize infiltration and treatment of stormwater. No mitigation.
Proposed Project Analysis
As discussed in the Santee Housing Element Implementation PEIR, development of residential uses within the Rezone Sites have been planned. Therefore, the water needs of development under the Santee Housing Element Implementation PEIR and potential impacts on groundwater sources have been accounted for by the City’s Water Utilities Department. Water resources would be provided to the proposed Project site via water lines that would connect to existing City water supply for domestic and potentially recycled water lines. Therefore, the proposed Project would not result in a net deficit in aquifer volume or a lowering of the local groundwater table. In addition, impervious surfaces already support some level of development at the Project site, the drainage of the site would not be significantly altered and thus the Project would not result interfere in groundwater recharge. The proposed Project would also be required to comply with the City’s General Plan policies and regulations that prioritize infiltration and treatment of stormwater and generally require increased on-site infiltration and higher standards of water quality protection. Therefore, implementation of the proposed Project would remain less than significant and would not result in any increase in the severity of impacts in this regard.
Issue 3: Drainage Patterns/Stormwater Runoff
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 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? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR concluded that the development of the Rezone Sites has the potential to substantially alter the existing drainage pattern of the site or area and impact the existing drainage system. However, all future developments would be required to comply with federal, state, and local regulations, including the City Stormwater Ordinance aimed to reducing polluted stormwater, stormwater runoff, and avoiding overloading the City’s drainage system. Impacts associated to drainage patterns and stormwater runoff would remain less than significant and would not result in any increase in the severity of impacts in this regard.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05 84
AUGUST 2025
Proposed Project Analysis
Construction
The Project would involve earthwork and other construction activities that would disturb surface soils and temporarily leave exposed soil on the ground’s surface. Common causes of soil erosion from construction sites include stormwater, wind, and soil being tracked off site by vehicles. To help curb erosion, Project construction activities would comply with all applicable federal, state, and local regulations for erosion control. The Project would be required to comply with standard regulations, including SCAQMD Rules 402 and 403, which would reduce construction erosion impacts. Rule 402 requires that dust suppression techniques be implemented to prevent dust and soil erosion from creating a nuisance off site (SCAQMD 1976). Rule 403 requires that fugitive dust be controlled with best available control measures so that it does not remain visible in the atmosphere beyond the property line of the emissions source (SCAQMD 2005).
Since Project construction activities would disturb 1 or more acres, the Project must adhere to the provisions of the NPDES Construction General Permit. Construction activities subject to this permit include clearing, grading, and ground disturbances such as stockpiling and excavating. The NPDES Construction General Permit requires implementation of a SWPPP, which would include construction features for the Project (i.e., BMPs) designed to prevent erosion and protect the quality of stormwater runoff. Sediment-control BMPs may include stabilized construction entrances, straw wattles on earthen embankments, sediment filters on existing inlets, or the equivalent. Therefore, during construction, no new impacts would occur, and the proposed Project would not result in an increase of significant impacts or an increase in the severity of impacts associated with erosion or siltation, flooding, polluted runoff, or flood flows.
Operations
The proposed Project would add approximately 11.6 acres of impervious area in the form of building rooftops, hardscape, and parking lot. The proposed parking lot stalls will be constructed using permeable pavers to achieve the volume retention requirements on site. Stormwater on the Project site would generally drain in a southwest direction, similar to existing conditions. After leaving the Project site, runoff from Basin 100 drains into the San Diego River and ultimately flows west and discharges to the Pacific Ocean (see Appendix E-1).
According to the hydrological report (Appendix E-1), the proposed Project will not substantially alter the existing drainage pattern of the site, though the proposed Project would move all proposed structures outside the extents of the 100-year peak flow at the final outfall as compared to existing conditions.
Therefore, during operations, the proposed Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of stream or river or through the addition of impervious surfaces, in a manner which would result in erosion or siltation, flooding, polluted runoff, or flood flows. Impacts would remain less than significant and would not result in any increase in the severity of impacts in this regard.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05 85
AUGUST 2025
Issue 4: Flood Hazard/Tsunami Inundation
In flood hazard, tsunami, or seiche zones, would the Project risk release of pollutants due to project inundation? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR concluded that the future developments would be required to comply with the federal, state and local regulations to avoid or address impacts related to the development in 100-year flood zones. In addition, Rezone Site 17 is located within or partially within flood hazard areas of the San Diego River. Therefore, the future development could potentially be significant, however, with the compliance of the federal, state, local development regulations, including the City’s General Plan and Municipal Code Chapter
11.36, impacts would be less than significant.
Proposed Project Analysis
The proposed Project, Site 17, is located within Federal Emergency Management Agency (FEMA) flood zones AE and X. Flood Zone AE is a flood hazard area of the San Diego River as mentioned in the Santee Housing Element Implementation PEIR. Therefore, there is potential for riverine flooding impacts, which occurs when there is an increase in the amount of runoff conveying to the river. Riverine flooding could cause total flow and pollutant release in the river. Flood Zone X are areas of minimal flood hazard (FEMA 2020).
In support of the removal of the Project from the existing floodplain, a CLOMR has been submitted to FEMA for review. A detailed hydraulic analysis was performed using HEC-RAS to determine the new extents of floodplain and floodway for the San Diego River. The site proposes to add fill to raise the pad elevations above the water surface elevation of the San Diego River. The additional fill is the basis for requesting the CLOMR. The areas currently identified as Zone AE on the site will ultimately be removed from the Zone AE designation.
Also, riverine flooding would be managed by the proposed Project adopting all the state and local regulations, including the City’s General Plan and Municipal Code, Chapter 11.36 which establishes Flood and Damage Prevention standards.
Furthermore, the distance from Santee to the Pacific Ocean (approximately 20 miles) ensures that no people or structures would be subject to a tsunami. Therefore, implementation of the proposed Project would result in no new impacts associated with flood, tsunami, or seiche hazards and the proposed Project would remain less than significant as stated within the Santee Housing Element Implementation PEIR. In addition, the proposed Project would not result in any increase in the severity of impacts in this regard.
3.10.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR
No mitigation measures required.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05 86
AUGUST 2025
3.11 Land Use and Planning
3.11.1 Analysis
Issue 1: Physically Divide an Established Community
Would the Project physically divide an established community? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that none of the Rezone Sites would physically divide an established community as all the Rezone Sites are located in urbanized areas and served by existing infrastructure.
Proposed Project Analysis
Implementation of the proposed Project would occur on a vacant and undeveloped lot, which is surrounded by various urban land uses. Implementation of the proposed Project is consistent with the planned residential uses that currently exist or are proposed within the Rezone Sites. Development of the proposed Project does not physically divide an established community, but rather serves to accommodate the City’s assigned growth and Regional Housing Needs Assessment (RHNA). Therefore, no new impacts would occur, and the proposed Project would not result in any increase in the severity of impacts in this regard.
Issue 2: Conflicts with Plans and Policies
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 impact? City of Santee Housing Element Implementation PEIR Analysis Santee Housing Element Implementation PEIR determined that impacts associated with future development would be consistent with applicable regulations, plans, and policies, therefore impacts would be less than significant. This includes consistency with State Housing Law, San Diego Forward, MSCP, General Plan, and Municipal Code.
However, the Santee Housing Element Implementation PEIR determined that the Rezone Sites are located within Gillespie Field Influence Area 1 and Gillespie Field Influence Area 2, and MCAS Miramar Influence Area 2. Rezone Site 17 is located within Gillespie Field Influence Area 1, 2 and MCAS Miramar Influence Area 2. The ALUCP addresses four types of compatibility factors which include noise, safety, airspace protection, and overflight. After review, the Santee Housing Element Implementation PEIR determined that the Rezone Sites are not anticipated to result in a safety hazard for people working or residing in the Rezone Sites. Therefore, impacts related to airport hazards would be less than significant.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05 87
AUGUST 2025
Proposed Project Analysis
As Site 17 was included in the PEIR which implements Housing Element Programs 9 and 10, the Project would be consistent with State Housing Law and San Diego Forward. Also, only a very small portion of the Project’s impact footprint would occur within the Draft Santee MSCP Subarea Plan San Diego River Subunit. Project implementation would not significantly conflict with the provisions of the MSCP Plan or Draft Santee MSCP Subarea Plan, nor would it prevent the Draft Santee MSCP Subarea Plan from being approved or compromise continued implementation of the MSCP in San Diego County. Compliance with the MSCP is further discussed under Section 3.4.1. Further, the Project would include site design elements and project design features developed to support the policy objectives of the Regional Plan and SCS as mentioned under Section 3.8.1. The proposed Project would also adhere to goals and policies identified in the General Plan and use regulations and development standards identified in the Municipal Code. Therefore, the Project would be consistent with the applicable regulations, plans, and policies identified in the PEIR.
As mentioned above, the proposed Project (Rezone Site 17) is located within Gillespie Field Influence Area 1 and MCAS Miramar Influence Area 2. With specific respect to air safety issues, according to the Gillespie Field and MCAS Miramar ALUCPs (SDCRAA 2010 and 2011) state the following:
▪ Influence Area 1 consists of locations where noise and safety concerns may necessitate limitations on the types of land uses actions. Specifically, Review Area 1 encompasses locations exposed to aircraft noise levels of 60 dB CNEL or greater and areas subject to the safety zones depicted on Figure 4.7-2 in the Santee Housing Element Implementation PEIR.
▪ Influence Area 2 consists of locations beyond Review Area 1 but within the airspace and/or overflight notification areas depicted on the maps in the respective ALUCPs. Limits on the heights of structures, particularly in areas of high terrain, are the only restriction on land uses within Influence Area 2. For projects within Influence Area 2, the recordation of overflight notification documents is also required.
The proposed Project would be located within both Influence Area 1 and Influence Area 2, approximately 1.3 miles away from Gillespie Field Airport. The Airport Land Use Commission (ALUCP) has adopted an Airport Land Use Compatibility Plan which regulates airport use and public safety. Based on the future airport noise contours provided in the compatibility plan, the Project site is not within any noise contour (60 dB CNEL) for the Gillespie Field Airport. The proposed Project would not expose people residing or working on the site to excessive noise levels associated with airports (ALUC 2010). Further, the Project includes buildings up to 37 feet tall, which would not exceed the height limitations identified by Federal Aviation Administration (FAA) Part 77, Subpart C. In accordance with the Santee Housing Element Implementation PEIR, the proposed Project are not anticipated to result in a safety hazard for construction employees or people residing in the proposed Project, therefore, impacts related to airport hazards would remain less than significant and would not result in any increase in the severity of impacts in this regard.
3.11.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR
No mitigation measures required.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05 88
AUGUST 2025
3.12 Mineral Resources
3.12.1 Analysis
Issues 1 and 2:
Would the Project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
Would the Project result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? City of Santee Housing Element Implementation PEIR Analysis Mineral Resources are addressed in Chapter 8, Effects not to be Significant in the Santee Housing Element Implementation PEIR, which concluded projects located in Rezone Sites would not result in the loss of availability of a known mineral resource or locally important mineral resource recovery site delineate on a local general plan, specific plan, or other land use plan, and impacts would be less than significant. However, the Geological Survey classification of Mineral Resource Zones (MRZs) provides a description of the four MRZs:
▪ MRZ-1 designates areas where adequate geologic information indicates that no significant mineral deposits are present, or where it is judged that little likelihood exists for their presence. ▪ MRZ-2 designates areas underlain by mineral deposits where geologic data indicates that significant measured or indicated mineral resources are present.
▪ MRZ-3 designates areas that contain known mineral deposits, the significance of which cannot be evaluated from available data.
▪ MRZ-4 designates areas where available information is inadequate for assignment to an MRZ zone.
Under the Geological Survey classifications some Rezone Sites are designated MRZ-2 and MRZ-3, with Site 17 designated as MRZ-2. However, due to the close proximity of sensitive receptors and existing surrounding neighborhoods, mining operations would not be feasible at these sites. Impacts were determined to be less than significant.
Proposed Project Analysis
The proposed Project includes the development of multi-family units on previously vacant land. No mining activities have occurred on the Project site and the Santee Housing Element Implementation PEIR determined that mining on the site would not be feasible due to the location near sensitive receptors ; therefore, no impacts would occur related in the loss of availability of a known mineral resource or locally important mineral resource recovery site delineate on a local general plan, specific plan, or other land use plan, and impacts would remain less than significant and would not result in any new impacts or any increase in the severity of impacts in this regard.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05 89
AUGUST 2025
3.12.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR
No mitigation measures required.
3.13 Noise
The analysis in this section was completed in compliance with the following report:
▪ Cottonwood & Park Noise Impact Study for City Ventures, prepared on August 20, 2025, by MD Acoustics, LLC and included as Appendix F of this Addendum.
3.13.1 Analysis
Issue 1: Noise Standards
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?
City of Santee Housing Element Rezone Program Implementation PEIR Analysis The PEIR determined that noise impacts could be significant when comparing the existing condition and the Project site. Additionally, the PEIR stated that future traffic noise levels at the Project site are forecast to exceed 65 dBA Ldn adjacent to roadways but would not exceed 70 dBA Ldn. For stationary source noise, the PEIR determined that there would be a significant impact if future developments did not comply with the City’s Municipal Code, Title 5 – Health and Safety, Chapter 5.04 - Noise Abatement and Control. However, residential and mixed-use land uses are not anticipated to substantially increase the noise levels in the environment.
Therefore, impacts related to stationary source noise would be less than significant, and no mitigation is required.
Construction noise is temporary and future developments, including the proposed Project would have to comply with the City’s Municipal Code Section 5.04.090 which regulates noise associated with construction equipment and activities through the time-of-day restrictions (e.g., days of the week and hours of operation), and requires that notice be given when construction equipment with a manufacturer’s noise rating of 85 dBA Lmax at 50 feet will operate at a specific location for 10 consecutive workdays. However, depending on the construction equipment list, time of day, phasing, and duration, prolonged noise disturbances related to ambient noise would be potentially significant and construction noise and land use compatibility impacts are considered to be significant at this programmatic level of review, without incorporation of mitigation measures MM-NOS-1 and MM-NOS-2.
The PEIR determined impacts related to ambient noise would remain significant and unmitigated, but land use compatibility would be reduced to less than significant after mitigation (MM-NOS-1), and construction noise would be reduced to less than significant after mitigation (MM-NOS-2).
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05 90
AUGUST 2025
Proposed Project Analysis
Construction Noise
The Environmental Protection Agency (EPA) has compiled data regarding the noise characteristics of typical construction activities. The data are presented in Table 3.13.1-1.
Table 3.13.1-1 Typical Construction Noise Levels1 of Equipment Powered by Internal Combustion Engines
Type Noise Levels (dBA) at 50 Feet
Earth Moving
Compactors (Rollers) 73 - 76
Front Loaders 73 - 84
Backhoes 73 - 92
Tractors 75 - 95
Scrapers, Graders 78 - 92
Pavers 85 - 87
Trucks 81 - 94
Materials Handling
Concrete Mixers 72 - 87
Concrete Pumps 81 - 83
Cranes (Movable) 72 - 86
Cranes (Derrick) 85 - 87
Stationary
Pumps 68 - 71
Generators 71 - 83
Compressors 75 - 86
Impact Equipment
Saws 71 - 82
Vibrators 68 - 82
Notes:
1 Referenced Noise Levels from the Environmental Protection Agency (EPA) Construction is anticipated to occur during the permissible hours from 7:00 a.m. to 7:00 p.m. according to the City’s Municipal Code Section 5.04.090. The City’s Municipal Code also requires that construction equipment with a noise rating of 85 dBA Lmax or more at 50 feet can only operate for 10 consecutive workdays. Construction noise is considered a short-term impact and would be considered significant if construction activities are taken outside the allowable times as described in the City’s Municipal Code. Construction noise will cause a temporary or periodic increase in the ambient noise level above the existing level within the Project vicinity. Construction noise level projections are provided below in Table 3.13.1-2.
Typical operating cycles for these types of construction equipment may involve one or two minutes of full power operation followed by three to four minutes at lower power settings. Noise levels calculated at the closest sensitive receptors to the Project are listed in Table 3.13.1-2. A likely worst-case construction noise scenario assumes equipment operating as close as 80 feet and an average of 690 feet from the nearest sensitive receptor
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
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(residences to the east). The Lmax levels represent maximum levels when construction occurs adjacent to the residential receptors. Leq levels represent the energy-average construction noise level during each phase.
Table 3.13.1-2 Construction Noise Levels at the East Property Line Phase dBA Lmax dBA Leq
Site Prep 79.9 64.9
Grading 80.9 65.6
Build 79.9 63.4
Paving 85.9 64.1
Arch Coating 73.9 51.2
Notes: Const Equip from CalEEMod
As shown above, the proposed Project’s construction noise would be compliant with the City’s Municipal Code Section 5.04.090; therefore, impacts would be less than significant.
Operational Noise
Future Off-site Exterior Operational Noise
The exterior noise level off-site of the Project will be impacted by transportation-related sources and other stationary sources. The following outlines the impacts associated with exterior noise levels.
Table 3.13.1-3 Existing/Existing + Project Scenario – Noise Levels Along Roadways (dBA Ldn) Existing Exterior Noise Levels
Roadway Segment
Ldn at
50 Ft
(dBA)
Distance to Contour (Ft)
70 dBA Ldn 65 dBA Ldn 60 dBA Ldn 55 dBA Ldn
Magnolia Ave East of site 71.5 70 222 702 2,221
Mast Blvd North of site 69.3 42 134 423 1,339
Existing + Project Exterior Noise Levels
Magnolia Ave East of site 71.4 71.5 243 768 2,429
Mast Blvd North of site 69.7 47 149 471 1,491
Change in Noise Levels as a Result of the Project
Roadway1 Segment
Ldn at 50 Feet (dBA)2
Existing
Without
Project
Existing
WithProject
Change in
Noise Level
Potential
Significant
Impact
Existing
Without
Project
Magnolia Ave East of site 71.4 71.5 0.1 No
Mast Blvd North of site 69.2 69.3 0.1 No
Notes:
1 Exterior noise levels calculated at 5 feet above ground level. 2 Noise levels calculated from centerline of subject roadway.
Table 3.13.1-3 provides the Existing and Existing + Project noise conditions and shows the change in noise level because of the proposed Project. A significant impact would occur if, as a direct result of the project, noise levels would exceed the compatibility standards, or noise levels which already exceed the levels considered
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
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compatible for that use are increased by 3 dB or more. As shown in Table 3.13.1-3, there will be a small increase in traffic noise of 0.5 dBA at 50 feet from the centerline of the subject roadways and the Project would not exceed the 3 dB threshold.
Future Off-site Traffic Noise
The potential off-site noise impacts caused by the increase in vehicular traffic as a result of the Project were calculated at a distance of 50 feet. The distance to the 55, 60, 65, and 70 dBA Ldn noise contours are also provided in Table 3.13.1-3 for reference. The noise level at 50 feet is representative of approximate distances to existing multi-family homes close to the subject roadway impacted by the Project. The noise contours were calculated for the following scenarios and conditions:
▪ Existing Condition (2018 ADT): This scenario refers to the existing traffic noise condition and is included in Table 3.13.1-3.
▪ Existing + Project Condition: This scenario refers to the existing plus Project traffic noise condition and is included in Table 3.13.1-3.
Future Off-site Stationary Operational Noise
Off-site operational noise includes transformers and HVAC units. HVAC equipment is assumed to be located on the rooftops. Equipment will be at least 100 feet away from the nearest residential uses to the east. The maximum sound power level from a single unit is 72 dBA. At 100 feet away, the sound pressure level is estimated to be 31 dBA. Assuming half of all 285 units are located 100 feet away from the eastern receptor and running simultaneously, the sound level is 54 dBA Leq. If the units ran simultaneously for 24 hours, the noise level would be 60 dBA Ldn. According to the City’s Land Use Compatibility Matrix, the noise at residential properties must not exceed 65 dBA Ldn. The worst-case noise due to all of the HVAC units operating simultaneously will be 63 dBA Ldn at a residence and thus meets the City’s noise level limit for residential properties.
Per ANSI requirements for transformer noise, transformers must be no louder than 65 dBA at 6 feet.
Transformers should be placed at least 20 feet from the adjacent residential receptors or should be shielded to stay below the nighttime ambient level.
Operational noise is predicted to comply with Section 5.04 of the Santee Municipal Code. The impact would therefore be less than significant.
On-site Receptors Due to Traffic
Traffic noise from Magnolia Avenue was evaluated and compared to the City’s guidelines. Using cumulative traffic, the edge of the Project site will be up to 58 dBA Ldn. According to the Noise Element of the General Plan, residential uses are acceptable up to 65 dBA Ldn. Thus, the Project meets the 65 dBA Ldn limit for residential uses and falls within the normally acceptable level from the Noise Compatibility Matrix.
Interior Noise Levels
The future interior noise levels were calculated for the sensitive receptor locations using a typical “windows open” and “windows closed” condition. A “windows open” condition assumes 12 dBA of noise attenuation from the
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
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exterior noise level. A “windows closed” condition” assumes 20 dBA of noise attenuation from the exterior noise level. Table 3.13.1-4 lists the calculated first and second-floor interior noise levels for the closest sensitive receptors to roadways on the Project site.
Table 3.13.1-4 Future Interior Noise Levels (dBA Ldn)
Location/Roadway Noise
Source
Exterior
Façade
Study
Location
Noise
Level at
Building
Facade1
Interior
Noise
Reduction
Required to
Meet
Interior
Noise
Standard of
45 dBA Ldn
Interior Noise Level
w/ Typical
Residential
Windows (STC≥ 25)
STC Rating
for Windows
Facing
Subject
Roadway4
Window
Open2
Windows
Closed3
1st Row Units Along Eastern
Property Line/Magnolia Ave.
1st Floor 58 13 46 38 25
2nd Floor 58 13 46 38 25
Notes:
1 Noise level from worksheets in Appendix F.
2 A minimum of 12 dBA noise reduction is assumed with a "windows open" condition. 3 A minimum of 20 dBA noise reduction is assumed with a "windows closed" condition. 4 Indicates the required STC rating to meet the interior noise standard.
As shown in Table 3.13.1-4, the interior noise level will be 46 dBA Ldn with the windows open and 38 dBA Ldn with the windows closed.
To meet the City’s interior 45 dBA Ldn standard a “windows closed” condition is required. The windows and sliding glass doors will require a minimum STC rating of 25. A “windows closed” condition simply means that to achieve a 45 dBA Ldn interior noise level, the windows must be closed and does not mean the windows must be fixed.
Therefore, noise impacts would be less than significant and would not substantially increase the severity of impacts.
Issue 2: Ground-borne Noise and Vibration
Would the Project result in exposure of persons to or generation of excessive ground-borne vibration or groundborne noise levels? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that due to the unknown construction details, locations, and equipment, vibration associated with the future developments would be potentially significant; therefore, mitigation measure MM-NOS-3 would be implemented. After implementation, vibration would be less than significant.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05 94
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Proposed Project Analysis
Construction Vibration
Construction activities can produce vibration that may be felt by adjacent land uses. The construction of the proposed Project would not require the use of equipment such as impact pile drivers, which are known to generate substantial construction vibration levels. The primary vibration source during construction may be from a sonic pile driver. A sonic pile driver has a vibration impact of up to 0.734 inches per second peak particle velocity (PPV) at 25 feet.
The fundamental equation used to calculate vibration propagation through average soil conditions and distance is as follows:
PPVequipment = PPVref (25/Drec)
n
Where: PPVref = reference PPV at 25 ft.
Drec = distance from equipment to receiver in ft.
n = 1.1 (the value related to the attenuation rate through ground) The thresholds from the Caltrans Transportation and Construction Induced Vibration Guidance Manual in Table 3.13.1- 5 (below) provide general thresholds and guidelines as to the vibration damage potential from vibratory impacts.
Table 3.13.1-5 Guideline Vibration Damage Potential Threshold Criteria Structure and Condition
Maximum PPV (in/sec)
Transient Sources
Continuous/Frequent
Intermittent Sources
Extremely fragile historic buildings, ruins, ancient
monuments
0.12 0.08
Fragile buildings 0.2 0.1
Historic and some old buildings 0.5 0.25
Older residential structures 0.5 0.3
New residential structures 1.0 0.5
Modern industrial/commercial buildings 2.0 0.5
Source: Table 19, Transportation and Construction Vibration Guidance Manual, Caltrans, Sept. 2013.Note: Transient sources create a single isolated vibration event, such as blasting or drop balls. Continuous/frequent intermittent sources include impact pile drivers, pogo-stick compactors, crack-and-seat equipment, vibratory pile drivers, and vibratory compaction equipment.
Table 3.13.1-6 gives approximate vibration levels for specific construction equipment. This information provides a reasonable estimate for a wide range of soil conditions.
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Table 3.13.1- 6. Vibration Source Levels for Construction Equipment1 Equipment
Peak Particle Velocity
(inches/second) at 25
feet
Approximate Vibration
Level, LV (VdB) at 25
feet
Pile driver (impact) 1.518 (upper range) 112
0.644 (typical) 104
Pile driver (sonic) 0.734 (upper range) 105
0.17 (typical) 93
Clam shovel drop (slurry wall) 0.202 94
Hydromill 0.008 (in soil) 66
(slurry wall) 0.017 (in rock) 75
Vibratory Roller 0.21 94
Hoe Ram 0.089 87
Large bulldozer 0.089 87
Caisson drill 0.089 87
Loaded trucks 0.076 86
Jackhammer 0.035 79
Small bulldozer 0.003 58
Note:
1 Source: Transit Noise and Vibration Impact Assessment, Federal Transit Administration, September 2018.
The sonic pile driver is anticipated to be as close as 116 feet away from the nearest residential façade to the east. At a distance of 116 feet, a sonic pile driver would yield a worst-case 0.136 PPV (in/sec) which will be perceptible but below any risk of damage (0.3 in/sec PPV is the threshold of old residential structures). The construction vibration complies with MM-NOS-3 of the DPEIR, and the impact is less than significant.
Issue 3: Airport Noise
Would the Project be 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, and expose people residing or working in the area to excessive noise levels? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that the Project site is not located within the 65 dBA CNEL noise contours of any airport. Therefore, impacts would be less than significant, with no mitigation required.
Proposed Project Analysis
The Project site is located approximately 1.3 miles away from Gillespie Field Airport. The site is outside of the 60 dBA CNEL noise contour. Therefore, the impact due to aircraft noise is less than significant and would not increase the severity of impacts in this regard.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05 96
AUGUST 2025
3.13.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR
MM-NOS-1: Applications for future development, where the City has determined a potential for land use compatibility impacts related to vehicle traffic, shall be required to comply with the following mitigation measure:
Prior to the issuance of a permit to develop at the Rezone Sites, the City shall assess whether proposed noise-sensitive receivers or associated noise-sensitive exterior use areas would be subject to transportation noise levels that potentially conflict with policies established in the City’s General Plan. Based on the analysis in the Santee Housing Element Implementation PEIR, the Project site is anticipated to require the implementation of this measure. Where noise levels would potentially conflict with City policies, the City shall require preparation of a noise technical analysis by a qualified professional that demonstrates (1) noise levels would not exceed the City’s General Plan Noise Element compatibility guidelines, or (2) noise levels which already exceed the levels considered compatible for that use are not increased by 3 dB or more. In lieu of detailed analysis, the City will accept information demonstrating that noise reduction techniques have been incorporated that would reduce noise levels at exterior use areas consistent with City standards. Noise reduction techniques may include site design (including building orientation) that provides noise barriers free of gaps and obstructs the line-of-sight between the source and receiver, and has a weight of at least 2 pounds per square foot, or other noise reduction technique as applicable.
MM-NOS-2: The City shall review applications for future development to determine applicability of a Construction Noise Management Plan. An applicant may provide site-specific noise generation information demonstrating that construction activities will not exceed 75 dBA at the nearest sensitive receptor. If this site-specific information is not provided, a construction noise management plan shall be required when the construction site is located within 150 feet of a sensitive receptor.
The criterion of 150 feet is provided as a screening tool for use by the City, based on an average construction noise level of 85 dBA at 50 feet, attenuating to 75 dB at 150 feet.
Construction Noise Management Plan
Where applicable based on the criteria provided above, the City shall require preparation and implementation of a management plan that demonstrates how noise levels would be minimized to comply with the time-of-day restrictions and notification requirements of Santee Municipal Code Section 5.04.090. Noise reduction measures can include, but are not limited to, the following:
Construction equipment with a manufacturer’s noise rating of 85 dBA Lmax or greater at 50 feet may only operate at a specific location for 10 consecutive workdays. If work involving such equipment would involve more than 10 consecutive workdays, a notice must be provided to all property owners and residents within 300 feet of the site no later than 10 days before the start of construction. The notice must be approved by the City and describe the proposed Project and the expected duration of work and provide a point of contact to resolve noise complaints.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05 97
AUGUST 2025
Idling times for noise-generating equipment used in demolition, construction, site preparation, and related activities shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes.
Demolition, construction, site preparation, and related activities within 100 feet from the edge of properties with existing, occupied noise-sensitive uses shall incorporate all feasible strategies to reduce noise exposure for noise-sensitive uses, including:
a. Provide written notice to applicable noise-sensitive land uses at least two weeks prior to the start of each construction phase of the construction schedule; b. Ensure that construction equipment is properly maintained and equipped with noise control components, such as mufflers, in accordance with manufacturers’ specifications; c. Re-route construction equipment away from adjacent noise-sensitive uses; d. Locate noisy construction equipment away from surrounding noise-sensitive uses; e. Use sound aprons or temporary noise enclosures around noise-generating equipment; f. Position storage of waste materials, earth, and other supplies in a manner that will function as a noise barrier for surrounding noise-sensitive uses; g. Use the quietest practical type of equipment;
h. Use electric powered equipment instead of diesel or gasoline engine powered equipment; i. Use shrouding or shielding and intake and exhaust silencers/mufflers; and j. Other effective and feasible strategies to reduce construction noise exposure for surrounding noise-sensitive uses.
4. For construction of buildings that require the installation of piles, an alternative to installation of piles by hammering shall be used where sensitive receptors are located within 150 feet. This could include the use of augured holes for cast-in place piles, installation through vibration or hydraulic insertion, or another low noise technique.
MM-NOS-3: Applications for future development, where the City has determined a potential for vibration impacts in relation to sensitive receptors, shall be required to comply with the following mitigation measure:
Prior to the issuance of a permit to develop at the Project site, the City shall determine whether the construction process will require equipment or activities that may result in perceptible vibration in nearby structures, such as pile driving. For projects requiring pile driving during construction within 135 feet of fragile structures, such as historical resources, 100 feet of nonengineered timber and masonry buildings (e.g., most residential buildings), or within 75 feet of engineered concrete and masonry (no plaster) buildings; or a vibratory roller within 25 feet of any structure, the Project applicant shall prepare a noise and vibration analysis to assess and mitigate potential noise and vibration impacts related to these activities. These distances are based on reference vibration levels generated by pile drivers and vibratory rollers and standard vibration propagation rates as published by the Federal Transit Administration Transit Noise and Vibration Impact Assessment Manual (FTA 2018). This noise and vibration analysis shall be conducted by a qualified and experienced acoustical consultant or engineer. The vibration levels shall not exceed Federal Transit Administration architectural damage thresholds (e.g., 0.12 inches per second [in/sec] peak particle velocity [PPV] for fragile or historical resources, 0.2
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05 98
AUGUST 2025
in/sec PPV for non-engineered timber and masonry buildings, and 0.3 in/sec PPV for engineered concrete and masonry) buildings. If vibration levels would exceed these thresholds, alternative uses such as drilling piles as opposed to pile driving, and static rollers as opposed to vibratory rollers, shall be used. If necessary, construction vibration monitoring shall be conducted to ensure vibration thresholds are not exceeded.
3.14 Population and Housing
3.14.1 Analysis
Issue 1: Induce Unplanned Population Growth
Would the Project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that the Rezone Sites would potentially introduce approximately 1,945 residential units which would accommodate more than the RHNA allocation of 1,219 units.
However, this would allow flexibility for the City’s RHNA anticipated population growth. The Santee Housing Element Implementation PEIR determined that future development would not result in substantial population growth as all Rezone Sites are located within existing urbanized areas with access to services, roadways, and utilities. Additionally, future development would comply with the General Plan, payment of Development Impact Fees (DIFs) and Transportation DIFs, and adherence to the updated SANDAG 2050 Regional Growth Forecast would ensure that future developments would have less than significant impacts associated with population growth. Therefore, impacts would be less than significant, and no mitigation measures required.
Proposed Project Analysis
As noted above, the proposed Project’s population growth is already accounted for within the City’s future growth.
As therein, the Project would introduce 285 multi-family residential units in response to current economic demands. The proposed Project would be subject to payment of DIFs, which would ensure adequate services and infrastructure are available to support development. Additionally, the proposed housing would aid the City in meeting its housing provision goals set forth by the RHNA to accommodate growth by providing additional housing. The proposed Project would comply with the General Plan, payment of DIFs and Transportation DIFs, and adherence to the updated SANDAG 2050 Regional Growth Forecast would ensure that the proposed Project would have less than significant impacts associated with population. Therefore, there would be no new potential population growth. No new significant population and housing impacts would occur and the Project would not increase the severity of impacts in this regard; no additional mitigation is required.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05 99
AUGUST 2025
Issue 2: Displace People or Housing
Would the Project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR concluded that the Rezone Sites 1 through 12, 24, and 30 could potentially displace people and housing, however, the future development would propose more housing units, therefore, accommodate more people than the prior housing.
Proposed Project Analysis
As mentioned above, the proposed Project is within Rezone Site 17, which is not included in the potential site that could potentially displace people and housing. The proposed Project is located in a vacant parcel; therefore, the proposed Project would not displace existing people and/or housing. Impacts would remain less than significant and would not result in any increase in the severity of impacts in this regard.
3.14.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR
No mitigation measures required.
3.15 Public Services and Recreation
3.15.1 Analysis
Issue 1a: Fire Service
Would the Project promote growth patterns resulting in the need for and/or provision of new or physically altered fire emergency facilities in order to maintain service ratios, response times, or other performance objectives, and the construction of which could cause significant environmental impacts? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR concluded that the future discretionary and/or by-right development would not directly result in the need for additional fire facilities. However, with the additional housing units, the future developments would be required to pay the City’s Municipal Code Chapter 12.50 DIF which would be utilized by local fire protection services, to ensure the appropriate level of resources necessary to serve future development in the City. The Santee Housing Element Implementation PEIR determined impacts related to construction of fire protection facilities would be less than significant.
Proposed Project Analysis
The Santee Fire Department (SFD) provides a fire suppressions, rescue, emergency medical response, and fire prevention and education services to the City. The SFD has two fire stations, and the proposed Project would be
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
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AUGUST 2025
served primarily by Fire Station 4, located at 8950 Cottonwood Avenue, respectively. As noted above, the Santee Housing Element Implementation PEIR determined that the proposed Project would not directly result in the need for additional fire facilities as the proposed Project would pay the DIF to ensure the appropriate level of fire resources would be provided. Therefore, impacts related to fire services would remain less than significant and would not result in any increase in the severity of impacts in this regard.
Issue 1b: Police Protection
Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered police protection facilities in order to maintain service ratios, response times, or other performance objective, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR concluded that the future development would be required to comply with the City’s Municipal Code Chapter 12.50, which requires the payment of a DIF to ensure the costs of constructing adequate public facilities related to the impacts of the future developments. As stated in the Santee Housing Element Implementation PEIR, the future developments would not directly result in sufficient demand for construction of new police facilities since the future developments would pay a DIF toward anticipated facility needs and the City’s police department would be involved in the development review process. Impacts related to police facilities would remain less than significant and would not result in any increase in the severity of impacts in this regard.
Proposed Project Analysis
The City’s police protection is provided by the San Diego County Sheriff’s Department under a contractual agreement with the City. The Santee Sheriff’s substation is located at 8811 Cuyamaca Street, approximately 1.7 miles southeast from the proposed Project site. Given that the proposed Project would be increasing population and housing, the housing has been accounted for with the City’s population growth and the proposed Project would be required to pay a DIF that would go towards any anticipated police protection facility needs. Impacts would remain less than significant and would not result in any increase in the severity of impacts in this regard.
Issue 1c: Schools
Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities in order to maintain service ratios, response times, or other performance objectives, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objective for any of the public services? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that the Rezone Sites would not directly result in sufficient demand for additional new school facilities, based on the capacity at existing schools and future developments would be required to pay a SB 50 fee required by the Santee School District and Grossmont Union
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05 101
AUGUST 2025
High School District which would go towards anticipated school facility needs. Therefore, with the SB 50 fees, impacts related to the construction of schools would be less than significant.
Proposed Project Analysis
The City is primarily served by two public school districts: Santee School District and the Grossmont Union High School District (City of Santee 2022). The closest school to the proposed Project site is Rio Seco School, approximately 0.5 miles from the proposed Project site.
According to the Santee Housing Element Implementation PEIR, the Santee School District and Grossmont Union High School District were both contacted and determined the availability to accommodate the student enrolment by the Rezone Sites future developments, including the proposed Project.
Additionally, the proposed Project would be subject to SB 50, which requires the payment of mandatory impact fees to offset any impact to school facilities. In accordance with SB 50, the Project applicant would pay its fair share of school impact fees based on the number of proposed dwelling units and square footage per Government Code Section 65995(h). Specifically, Santee School District charges developer fees for residential development of $2.97 per square foot of assessable space (SSD 2022) and the Grossmont Union High School District charges developer fees for residential development of $1.20 per square foot of assessable space (GUHSD 2018). Per Government Code Section 65996, development fees authorized by SB 50 are deemed to be “full and complete school facilities mitigation.” Therefore, impacts associated with the need for new or expanded school facilities would remain less than significant and would not result in any increase in the severity of impacts in this regard.
Issue 1d: Library Services
Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered library facilities in order to maintain services ratios, response time, or other performance objective, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR concluded that future development within Rezone Sites would be less than significant and would not directly result in sufficient demand to require construction of new library facilities, since future residential developments would be subject to the City’s Municipal Code Chapter 12.50, DIF, which requires the payment of mandatory impact fees to offset any impact to library facilities.
Proposed Project Analysis
Library facilities could potentially be impacted by the proposed Project. The San Diego County services the Santee Library and would service the Project site. The Santee Library (9225 Carlton Hills Blvd #17) is located 2.3 miles southeast of the Project. With regard to libraries facilities, DIFs will be utilized by the public service agencies to ensure the appropriate level of resources necessary to serve the Project and future development within the City (City of Santee 2022). Therefore, impacts on library facilities would remain less than significant and would not result in any increase in the severity of impacts in this regard.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05 102
AUGUST 2025
Issue 1d, 2, and 3: Parks and Recreational Facilities
Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered park facilities in order to maintain service ratios, response times, or other performance objectives, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable services ratios, response times or other performance objectives for any of public services? Would the Project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? Would the Project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that the future development within the Rezone Sites would introduce a population growth which would not directly result in sufficient demand for new park and recreational facilities. Additionally, future housing development would be required to pay its share of in-lieu fees consistent with the Quimby Act and the City Municipal Code Section 12.40 which funds additional park facilities and needs within the City. The Santee Housing Element Implementation PEIR determined that impacts associated with park and recreation facilities would be less than significant.
Proposed Project Analysis
The proposed Project includes a view park located on the south overlooking the San Diego River. The view park would include a vista, an open event lawn, shade structures with picnic tables and lush planting. The proposed Project also proposes a community playground and various pocket parks with bench seating throughout the site.
In addition, as noted in the Santee Housing Element Implementation PEIR, the City currently meets its parkland goal and Rezone Sites would accommodate future population (City of Santee 2022). Therefore, the proposed Project would accommodate by including a view park, community playground and the various pocket parks throughout the site. The proposed Project would also be required to pay its share of in-lieu fees consistent with the Quimby Act, the City Municipal Code Section 12.40, and would comply with the City parkland obligations for new residential development. Thus, the proposed Project would accommodate future residents, comply with City regulations and obligations, and pay its share of in-lieu fees, therefore, impacts associated with parks and recreation facilities would remain less than significant and would not result in any increase in the severity of impacts in this regard.
3.15.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR
No mitigation measures required.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05 103
AUGUST 2025
3.17 Transportation
The analysis in this section was completed in compliance with the following report:
▪ Cottonwood & Park Local Transportation Analysis, prepared on September 2, 2025, by TJW Engineering, INC.,and included as Appendix G of this Addendum.
3.17.1 Analysis
Issue 1: Circulation System
Would the Project conflict with a plan, ordinance, or policy addressing the circulation system, including transit, roadways, bicycle, and pedestrian facilities?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that the future development within the Rezone Sites would increase ultimate development intensity on selected sites. Future development that requires a discretionary review would be subject to a site-specific environmental review that considers consistency with all applicable plans including the City’s Active Transportation Plan. Potential future development projects would not require a subsequent environmental review would be subject to a ministerial review that would include consistency with the City’s Public Works Standards such as frontage requirements, pedestrian and bicycle improvements per City’s objective design and performance standards. Future development at Rezone Sites would be consistent with Policy 2.2 within the City’s General Plan Land Use Element, which encourages the development of higher density residential developments in areas close to the multi-modal transit station (at Santee Town Center) and along major road corridors where transit and other convenience services are available and would be reviewed to not conflict with transit facilities. Therefore, the Santee Housing Element Implementation PEIR determined that impacts associated with conflict with a plan, ordinance, or policy addressing the circulation system would be less than significant.
Proposed Project Analysis
The current General Plan Land Use and Zoning of the site is Town Center Residential-14, or TCR-14. There are no proposed amendments or changes to the Land Use or Zoning compared to the PEIR.
A project specific Local Transportation Analysis was prepared by TJW Engineering, Inc. to evaluate the proposed project’s effects on the LOS on transportation facilities in the study area, including ten intersections and seven roadway segments under existing and near-term conditions without and with the Project. LOS is used for consistency with General Plan policies and can no longer be used to determine significant transportation impacts under CEQA as directed by SB 743. LOS information is provided here for informational purposes. Tables 3.17.1-1 and
3.17.1-2 summarize the results of the LOS intersection and roadway segment analysis. Under the existing conditions, existing plus project conditions, and near-term plus project conditions, the study intersections and roadways are projected to operate at acceptable LOS. The Near-Term Plus Project PM peak hour volume at the northbound leg left-turn movement of Intersection 5: Magnolia Avenue/Walker Trails Drive exceeded 300 vehicles, the threshold provided by the City of Santee. A review of the queue storage found the 95th percentile queue length during the PM peak hour exceeded the storage capacity. The addition of a second left-turn pocket
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
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was analyzed and found to provide sufficient storage space. Therefore, the Project would be consistent with the General Plan. The detailed results of the LOS Analysis are provided in Appendix G.
Table 3.17.1-1: LOS Intersection Analysis Summary
Intersection
Control
Type1
Peak
Hour
Existing
Conditions
Existing Plus
Project
Conditions
Near-term
Plus Project
Conditions
Delay2 LOS Delay2 LOS Delay2 LOS
1 Cuyamaca
Street
Mast
Boulevard
Signal AM 31.9 C 33.9 C 35.8 D
PM 30.2 C 30.3 C 33.1 C
2 Cuyamaca
Street
Riverwalk
Drive
Signal AM 17.0 B 17.1 B 17.4 B
PM 14.0 B 14.1 B 14.2 B
3 Park Center
Drive
Mast
Boulevard
Signal AM 6.1 A 8.1 A 8.3 A
PM 7.9 A 10.2 B 12.2 B
4 Magnolia
Avenue
Mast
Boulevard
Signal AM 24.6 C 25.3 C 27.7 C
PM 21.5 C 21.5 C 22.0 C
5 Magnolia
Avenue
Walker
Trails Drive
Signal AM 3.2 A 13.1 B 17.9 B
PM 2.6 A 11.3 B 14.5 B
6 Magnolia
Avenue
Mission
Gorge Road
Signal AM 20.5 C 21.0 C 21.8 C
PM 23.0 C 24.0 C 25.9 C
7 Park Center
Drive
Riverwalk
Drive
AWSC AM 8.4 A 11.2 B 11.5 B
PM 8.0 A 9.4 A 9.5 A
8 Park Center
Drive
Project
Roundabout
Roundabout AM - - 4.1 A 4.1 A
PM - - 4.3 A 4.3 A
9 Cottonwood
Avenue
Project
Driveway
#2 –
Walker
Trails Drive
TWSC AM 7.2 A 11.7 B 11.7 B
PM 7.2 A 13.0 B 13.0 B
10 Cottonwood
Avenue
Project
Driveway
#3
TWSC AM 8.3 A 8.8 A 8.8 A
PM 8.3 A 8.9 A 8.9 A
Notes:
1 AWSC = All-Way Stop Control; TWSC = Two-Way Stop Control; OWSC = One Way Stop Control. 2 Delay shown in seconds per vehicle. Per the Highway Capacity Manual 7th Edition, for intersections with one or two-way stop control, the delay and LOS for the worst individual movement is shown.
Source: Appendix G
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05 105
AUGUST 2025
Table 3.17.1-2: LOS Roadway Analysis Summary
Roadway Segment Class1 Lanes
LOS D
Capacity
Existing
ADT2 LOS
Existing
Plus
Project
ADT2 LOS
Nearterm
Plus
Project LOS
Park
Center
Drive
Mast
Boulevard to
Project
Roundabout
Parkway
TWLTL
2 13,000 2,843 A 3,083 A 3,443 A
Mast
Boulevard
Cuyamaca
Street to
Magnolia
Avenue
Major
Arterial
4 35,000 19,450 B 19,690 B 20,241 B
Magnolia
Avenue
Mast
Boulevard to
Mission
Gorge RoadWoodside
Avenue
Major
Arterial
4 35,000 25,110 C 27,150 C 28,909 C
Walker
Trails
Drive
Cottonwood
Avenue to
Magnolia
Avenue
Collector
Residential
2 6,500 537 A 2,577 B 5,287 B
Notes:
1 TWLTL = Two-Way Left-Turn Lane.
2 ADT = Average Daily Traffic
Source: Appendix G
The San Diego Metropolitan Transit System (MTS) provides public transportation near the proposed Project. MTS Bus Route 832 has three stops within one-half of a mile from the proposed Project, the first at the northeast corner of Cuyamaca Street and River Park Drive, the second on Cuyamaca Street just south of Riverwalk Drive, and third at Magnolia Avenue and Frank Lane. The City of Santee is served by the Copper Line Trolley (Route 530), with the sole station located at the Santee Transit Center. The Copper Line connects Santee to the larger San Diego region and provides service into Downtown San Diego. The route operates from 5:00am to 1:00am with 15-minute headways on weekdays, and 30-minute headways on weekends. MTS ACCESS provides complementary, on-demand paratransit service to fulfill the unmet needs of residents such as seniors and persons with disabilities.
The Santee Transit Center is located approximately 1.6 miles southwest of the proposed Project, when accessed via Riverwalk Drive and Cuyamaca Street. The proposed Project would not relocate any existing bus stops and would not require any changes to existing or future transit routes.
Currently, there are Class II bike lanes and paved sidewalks on Cuyamaca Street, Mast Boulevard, and Magnolia Avenue. The proposed Project does not involve any plans to construct any bike facilities, however, the proposed Project would provide street improvements and access to the site would be facilitated for both pedestrian and bicycle users in the area. The frontage improvements associated with proposed Project development would not conflict with any existing or planned bike or pedestrian facilities.
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
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Based on analysis provided above, the proposed Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities, and its impact to transportation plans and programs would remain less than significant and would not result in any increase in the severity of impacts in this regard.
Issue 2: Vehicle Miles Traveled
Would the Project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that the future development within the Rezone Sites, including buildout of the City’s General Plan land use and transportation network, the average resident VMT per capita of City would be reduced to 18.7 (from 20.5 under base year). While the future development within the Rezone Sites would result in a reduction in VMT per capita, the 18.7 VMT per capita represents 91.2% of the base year citywide average which exceeds the VMT significance threshold. The projected VMT per capita with the Rezone Sites would exceed the 85% significance threshold representing a significant impact. Therefore, the Santee Housing Element Implementation PEIR proposed mitigation of VMT impact of both discretionary and byright development projects by implementing MM-Impact TRA-1: VMT Reduction.
While MM-TRA-1 would minimize VMT impacts associated with future development at the Rezone Sites, impacts would not be fully mitigated because the effectiveness of VMT reducing measures is context-sensitive and would vary depending on project details, such as the location, access to transit, etc. Therefore, impacts associated with VMT or conflict with CEQA Guidelines Section 15064.3 subdivision (b) would remain significant and unavoidable.
Proposed Project Analysis
The proposed Project site was included in the VMT analysis conducted as part of the City of Santee Housing Element Update Transportation Impact Study, May 25, 2022, prepared by CRA, using the SANDAG Series 14 travel demand model with base year of 2016. As mentioned above, the analysis concluded that the VMT per capita with the Rezone Sites exceeds the 85% significance threshold resulting in a significant impact.
Additionally, the proposed Project would not screen out per VMT screening criteria included in the City of Santee VMT Analysis Guidelines (April 2022). Per City’s guidelines, the SANDAG SB 743 VMT Maps can be used for VMT analysis for projects that generate fewer than 2,400 average daily trips. As shown in Appendix G, the proposed Project would generate 2,400 daily trips with 192 AM and 240 PM peak hour trips. Per SANDAG SB 743 VMT Maps, the proposed Project is in census tract 166.15 and the SANDAG average VMT per capita of this tract is
17.8, which is 94.1% of the regional mean and is therefore above the significant threshold of 85% of the regional mean. The proposed Project would implement MM-TRA-1: VMT Reduction. Additional measures from the California Air Pollution Control Officers Association (CAPCOA) Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity, Final Draft December 2021, that would be applied at the project or community level are listed below:
▪ T-1 Increase residential density
▪ T-17 Improve street connectivity
▪ T-14 Provide electric vehicle charging infrastructure
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
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▪ T-15 Limit residential parking supply
The applicant would implement MM-TRA-1, as required by the City, which would incorporate TDM strategies to reduce project’s VMT. The following VMT reductions measures would be implemented:
▪ Provide pedestrian network improvement along project frontage ▪ Provide bicycle network improvement along project frontage ▪ Implement commute trip reduction marketing
While implementation of MM-TRA-1 would reduce VMT impacts associated with proposed Project, impacts would not be fully mitigated. Therefore, impacts associated with VMT would remain significant and unavoidable consistent with the findings of the Santee Housing Element Implementation PEIR and there would be no new or increased severity of impacts related to VMT.
Issue 3: Hazards Due to a Design Feature
Would the Project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that the future development within the Rezone Sites, may require improvements to the existing roadway network. The future development would implement the existing regulatory framework such as engineering review to ensure roads and access are configured consistent with established roadway design standards, Public Works Standards and Mobility Element Policy 3.1 (Streets and Freeway System). Therefore, the Santee Housing Element Implementation PEIR determined that impacts resulting in hazards due to a design feature or incompatible use would be less than significant.
Proposed Project Analysis
No hazardous design features such as sharp curves or dangerous intersections exist on the proposed Project or in the vicinity. The Project proposes three full access points from the construction of a new roadway through the Project site that will connect the two segments of Park Center Drive on the north and east borders of the Project site. The new segment on the east border will be changed to Walker Trails Drive. Walker Trails Drive through the project site will connect to Park Center Drive at the project north border via a new roundabout. The new roundabout will add an additional leg to the south. The third access point will be south of Walker Trails Drive at a proposed roadway ending at River Bluff Drive. The proposed Project shall construct the segment of Park Center Drive per the Mobility Element roadway classification of Parkway with a two-way left-turn lane which provides access to the proposed Project from the north and the west of the site.
On-site circulation and access to the proposed Project will be provided by an internal roadway (see Figure 3, Site Plan) that would also serve as fire lane. The width of the internal roadway is between 26 feet to 30 feet. The onsite circulation is 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.
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Therefore, the proposed Project would not increase hazards because of a roadway design feature, or incompatible uses and impact would remain less than significant and would not result in any increase in the severity of impacts in this regard.
Issue 4: Emergency Access
Would the project result in inadequate emergency access? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that access for future site-specific developments to the existing roadway network would be configured consistent with established roadway design standards that would also allow for emergency access. The City implements the Santee Emergency Operations Plan to ensure adequate emergency access, Mobility Element Policy Objective 1.0, which ensures that the existing and future transportation system is accessible, safe, reliable, efficient, integrated, convenient, well‐connected, and multimodal. In addition, Policy 3.3 states the City shall ensure that newly constructed roadways are designed to permit rapid access for emergency vehicles. The Santee Housing Element Implementation PEIR also includes adoption of objective design and performance standards that would be implemented during the review process for future ministerial development. Therefore, the Santee Housing Element Implementation PEIR determined that impacts due to inadequate emergency access would be less than significant.
Proposed Project Analysis
Vehicular and emergency access to the Project would be from Walker Trails Drive via Magnolia Avenue from the west and from Park Center Drive via Mast Boulevard from the north. A third access point will be via Cottonwood Avenue on the southern portion of the site’s east border across River Bluff Drive, ending at Chubb Lane. On-site circulation and access to the proposed Project will be provided by an internal roadway network (see Figure 3, Site Plan) that would also serve as fire lanes. All street improvements will be designed with adequate width, turning radius, and grade to facilitate access by City’s firefighting apparatus, and to provide alternative emergency ingress and egress. The site plan would be subject to plan review by the City’s Fire Department to ensure proper access for fire and emergency response is provided and required fire suppression features are included.
Therefore, the proposed Project’s impact due to inadequate emergency access would remain less than significant and would not result in any increase in the severity of impacts in this regard.
3.17.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR
Consistent with the PEIR, the following measure related to transportation would be applicable to the proposed Project:
▪ MM-TRA-1: VMT Reduction The City shall require implementation of applicable Mobility Element Policies that would support VMT reductions for individual projects. Specifically, the City shall require that future projects are compliant with Mobility Element Policies 9.1 through 9.5, which encourage the use of Transportation Demand Management (TDM) strategies, such as ride sharing programs, flexible work schedule programs, and incentives for employees to use transit. Additionally, alternative transportation modes, such as walking, cycling and public transit are encouraged to reduce peak
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hour vehicular trips, save energy, and improve air quality. Sample TDM measures that may be applied at the project-level are provided below:
▪ Increase mixed-use development
▪ Increase transit accessibility
▪ Provide pedestrian network improvement along project frontage ▪ Provide bicycle network improvement along project frontage ▪ Provide bicycle parking and bike lockers
▪ Implement subsidized or discounted transit passes
▪ Provide rider-sharing programs
▪ Implement commute trip reduction marketing
▪ Implement school pool program
▪ Implement bike-sharing or micro mobility program
▪ Provide local shuttle to connect visitors to different attractions throughout the City
3.19 Utilities and Service Systems
3.19.1 Analysis
Issue 1: Utility Infrastructure
Would the Project require or result in the relocation or construction of new or expanded water, waste water treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? City of Santee Housing Element Implementation PEIR Analysis a. Water, Wastewater, Stormwater, Electric Power, Natural Gas, and Telecommunications The Rezone Sites are located within existing developed areas with existing water utility infrastructure, wastewater utility infrastructure, stormwater infrastructure, electrical, natural gas, and telecommunication utility infrastructure. All infrastructure would require connection to existing utility infrastructure pipelines, and no major upgrades or expansions to the City is anticipated to serve the future development’s utility infrastructure. However, future developments are anticipated to require the construction of connections to existing utility infrastructure which would need to be addressed during the City review of the future development projects. While all future development shall comply with local regulations and conformance with the City General Plan, the Santee Housing Element Implementation PEIR concluded that the impacts related to utility infrastructure could be potentially significant therefore, the following mitigation measures: MM-VIS-1, MM-AQ-1, MM-BIO-1 through MM-BIO-6, MM-CUL-1 through MM-CUL-3, MM-GEO-1, MM-GEO-1, MM-GHG-1 and MM-GHG-2, MM-HAZ-11, MM-NOS-1 through MM-NOS-3, and MM-TRA-1, which would ensure that any physical impacts associated with construction of connections to existing electrical, natural gas, and telecommunications utility infrastructure would be addressed as part of the City review for each individual project. With implementation of the mitigation measures, impacts related to the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or
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telecommunications facilities, the Santee Housing Element Implementation PEIR concluded the impacts would be reduced to less than significant.
Proposed Project Analysis
a. Water
The Santee Housing Element Implementation PEIR assumed the proposed Project would occur within the Rezone Sites, therefore, the water supply and demand for the proposed Project has been accounted for in the City’s water supply. Thus, the proposed Project would not result in the relocation or construction of new or expanded water facilities and no new impacts would occur and would not result in any increase in the severity of impacts in this regard.
b. Wastewater
The San Diego Regional Water Quality Control Board (RWQCB) is responsible for enforcing the City’s Waste Discharge Requirements as established under NPDES Permit No. CA0107433. The Permit regulates treatment requirements and discharge from the San Luis Rey Wastewater Treatment Plant.
The Santee Housing Element Implementation PEIR concluded that additional wastewater generated by the Rezone Sites or future developments would not exceed wastewater treatment requirements imposed by the California Regional Water Quality Control Board. The wastewater demand and generation for the proposed Project were accounted for in the Santee Housing Element Implementation PEIR and all sites are within areas of the City that are already served by existing wastewater. In addition, the proposed Project would comply with the City’s regulations, Land Use Element Policy 3.6, and mitigation measures: MM-AQ-1, MM-BIO-1 though MM-BIO-6, MM-CUL-1 through MM-CUL-3, MM-GEO-1, MM-GHG-1 and MM-GHG-2, MM-HAZ-1, MM-NOS-1 through MM-NOS-3 and MM-TRA-1, thus no new impacts would occur and would not result in any increase in the severity of impacts in this regard.
c. Stormwater
The proposed Project is being constructed in an area of the City that is urbanized in nature and where existing storm drain infrastructure and treatment facilities already exist. Site specific storm drain improvements would be made during final construction of the proposed Project. Additionally, the proposed Project would comply with the City regulations, Land Use Element Policy 3.6, and mitigation measures: MM-AQ-1, MM-BIO-1 though MMBIO-6, MM-CUL-1 through MM-CUL-3, MM-GEO-1, MM-GHG-1 and MM-GHG-2, MM-HAZ-1, MM-NOS-1 through MM-NOS-3 and MM-TRA-1, and the City’s BMP Design Manual. Therefore, the proposed Project would remain less than significant, no new impacts to stormwater drainage would occur and would not result in any increase in the severity of impacts in this regard.
d. Electric Power, Natural Gas, and Telecommunications
The proposed Project would connect to existing utility lines providing electric power, natural gas, and telecommunication services. The proposed Project would not be anticipated to result in an increase in service demands such that the Project would exceed capacities or result in the need for new or additional service systems to be constructed. Therefore, no new impacts to electric power, natural gas, or telecommunication facilities would occur and would not result in any increase in the severity of impacts in this regard.
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Issue 2: Water Supply
Would the Project have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry and multiple dry years?
City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR determined that impacts related to water supplies within the City during normal, dry, and multiple dry years would be less than significant based on the water efficiency of multi-family development and existing regulations related to water efficiency.
Proposed Project Analysis
The Santee Housing Element Implementation PEIR assumed development would occur on the Project site.
Therefore, the water supply and demand for the proposed Project were accounted for in the Santee Housing Element Implementation PEIR. Additionally, the proposed Project would comply with any applicable and mandatory water conservation measures required by the City and state. Therefore, no new impacts would occur associated with the availability of sufficient water supply and would remain less than significant and would not result in any increase in the severity of impacts in this regard.
Issue 3: Wastewater Treatment
Would the Project result in a determination by the waste water treatment provider which serves or may serve the Project that it has adequate capacity to serve the Project’s projected demand in addition to the provider’s existing commitments?
City of Santee Housing Element Implementation PEIR Analysis The future development would generate wastewater and due to the Padre Dam Municipal Water District (PDMWD) existing facility capacity and expansion plans for the Ray Stoyer WRF, the Santee Housing Element Implementation PEIR concluded that the Rezone Sites would not result in a determination by the wastewater treatment providers it does not have adequate capacity to serve the Rezone Sites demand. However, future developments would be required to comply with local regulations and General Plan policies, therefore, impacts related to wastewater services would remain less than significant and would not result in any increase in the severity of impacts in this regard.
Proposed Project Analysis
The PDMWD collects the wastewater for the City, where the water is transported to the City’s Water Recycling Facility or to the Point Loma facility which is managed by the City of San Diego Metropolitan Wastewater System (PDMWD 2023). The PDMWD manages the wastewater collection system within its 164 mile service area to collect, treat, and dispose of wastewater delivered by the City. A wastewater collection system and interceptor sewers convey sewage to regional wastewater treatment plants, which are operated by the PDMWD and the County’s Lakeside Interceptor (PDMWD 2019).
According to the Operation and Maintenance Program, the wastewater collection systems drain from the east to the west (PDMWD 2019). There are four diversion structures between the PDMWD wastewater collection system
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and the County’s Lakeside Interceptor. Interceptor collects all of the reclaimable wastewater generated within the City (PDMWD 2019). Sewage from the City is treated at two locations— the City’s Ray Stoyer Water Recycling Facility (WRF) and the Point Loma Facility (PLF). The PLF has a design flow capacity of 240 million gallons per day (mgd) and treats approximately 175 mgd, and the WRF has a design flow capacity of 2 mgd and treats on average 2 mgd (City of San Diego 2023, PDMWD 2023). Therefore, the PDMWD would have the adequate capacity to treat the estimated flows from the proposed Project and no new impacts would occur and would not result in any increase in the severity of impacts in this regard.
Issues 4 and 5: Solid Waste
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? Would the Project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
City of Santee Housing Element Implementation PEIR Analysis Future development would be required to comply with state and local regulations related to solid waste requirements. In addition to the General Plan policies. Following regulations and policies, impacts related to solid waste would be less than significant.
Proposed Project Analysis
Waste Management Inc. provides solid waste collection and disposal within the City. Waste would likely be hauled to the Sycamore Landfill. The Sycamore Landfill has a permitted throughput of 5,000 tons/day and is expected to remain open for another 18 years. The increase of waste generated by the Project during operations would represent approximately 0.004% of the total daily capacity of permitted at the landfill.
Once the Sycamore Landfill reaches capacity, additional landfills and strategies would be identified, so that disposal needs continue to be met. Further, there are landfills within the County with up to 35 years of remaining life. For example, the Las Pulgas Landfill is expected to remain open another 35 years (CalRecycle 2023). As such, in the event of the closure of the Sycamore Landfill, other landfills in the region would be able to accommodate solid waste from the Project, and regional planning efforts would ensure continued landfill capacity in the foreseeable future. Therefore, the Project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. Impacts during operation would remain less than significant and would not result in any increase in the severity of impacts in this regard.
As discussed, solid waste from the Project would be transported to the Sycamore Landfill. This facility is regulated under federal, state, and local laws. Additionally, the City of Santee is required to comply with the solid waste reduction and diversion requirements set forth in AB 939, AB 341, AB 1327, and AB 1826. Per AB 341, businesses that generate 4 cubic yards or more of organic waste per week are required to arrange for organic waste recycling services. In addition, as preciously described, waste diversion and reduction during Project construction and operations would be completed in accordance with CALGreen standards and City diversion standards. As a result, the Project would comply with federal, state, and local management and reduction
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statutes and regulations related to solid waste and impacts would remain less than significant and would not result in any increase in the severity of impacts in this regard.
3.19.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR
No mitigation measures required.
3.20 Wildfire
3.20.1 Analysis
Issue 1: Emergency Response Plans
Would the Project substantially impair an adopted emergency response plan or emergency evacuation plan? Issue 2: Wildfire
Would the Project, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose Project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire? Issue 3: Infrastructure
Would the Project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? Issue 4: Flooding or landslide
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? City of Santee Housing Element Implementation PEIR Analysis The Santee Housing Element Implementation PEIR concluded that impacts related to emergency response plans would be less than significant. The Santee Housing Element Implementation PEIR also stated that all future developments would have to undergo reviewal and approval by the Santee Fire Department prior to issuance of building permit and impacts would be less than significant. The Santee Housing Element Implementation PEIR also determined that the Rezone Site 17 is not located within a very high fire hazard severity zone and would not be required to adhere to California Fire Code Title 19, Division 1, Section 3.07(b), requiring a minimum 30-foot brush clearance around structures for fire safety. In addition, future developments would have to comply with the City’s General Plan policies 4.2 through 4.13, fire code regulations, California Building Code, and reviewed by the Building Official/Fire Marshal, therefore, impacts associated with risk of wildland fire would be less than significant, no mitigation required.
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Proposed Project Analysis
The proposed Project site is not located within or adjacent to a High Fire Hazard Severity Zone or within a State Responsibility Area (CALFIRE 2024). As such, the proposed Project would not expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands. Therefore, the proposed Project would not result in impacts to wildfire, including impacts to adopted emergency response plans or emergency evacuation plans, pollutant concentrations from a wildfire, exacerbation of fire risk or that may result in temporary or ongoing impacts to the environment, or exacerbate fire risk or that may result in temporary or ongoing impacts to the environment.
No new impacts would occur and would not result in any increase in the severity of impacts in this regard.
3.20.2 Applicable Mitigation Measures from the Santee Housing Element Implementation PEIR
No mitigation measures required.
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4 References and Preparers
4.1 References Cited
AEP (Association of Environmental Professionals) 2016. Final White Paper – Beyond 2020 and Newhall. https://califaep.org/docs/AEP-2016_Final_White_Paper.pdf.
California Air Resources Board (CARB). 2023. “What is the Air Toxics Program?” Accessed September 2023. https://ww2.arb.ca.gov/resources/documents/what-air-toxics-program.
CARB. 2024a. Health and Air Pollution. https://ww2.arb.ca.gov/resources/health-airpollution#:~:text=CARB%20has%20set%20standards%20for,toxics%20is%20730%20per%20million.
CARB. 2024b. Overview of the Air Toxics "Hot Spots" Information and Assessment Act. https://ww2.arb.ca.gov/overview-air-toxics-hot-spots-information-and-assessment-act CALFIRE. 2024. Fire Hazard Severity Zones. Accessed April 2024. https://experience.arcgis.com/experience/03beab8511814e79a0e4eabf0d3e7247/.
CalRecycle. 2019. SWIS Facility/Site Summary Sycamore Landfill (37-AA-0023). Accessed April 2024. https://www2.calrecycle.ca.gov/SolidWaste/Site/Summary/2871.
CalRecycle. 2023. SWIS Facility/Site Summary Las Pulgas Landfill (37-AA-0903). Accessed April 2024. https://www2.calrecycle.ca.gov/SolidWaste/Site/Summary/2901.
CDFW (California Department of Fish and Wildlife). 2023. “California Natural Community List.” Sacramento, California: CDFW, Vegetation Classification and Mapping Program. June 1, 2023. Accessed July 2023. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=153398&inline.
City of San Diego. 1998. Final MSCP Plan. Multiple Species Conservation Program. Prepared by MSCP Policy Committee and MSCP Working Group. San Diego, California: MSCP Policy Committee and MSCP Working Group. August 1998. Accessed June 10, 2024. http://www.sandiegocounty.gov/content/ dam/sdc/pds/mscp/docs/SCMSCP/FinalMSCPProgramPlan.pdf.
City of Santee. 2007. General Plan Land Use Map. Accessed April 2024. https://www.cityofsanteeca.gov/home/showpublisheddocument/8547/636362228959170000.
City of Santee. 2020. Santee Municipal Code. Urban Forestry Ordinance. Accessed June 10. 2024. https://ecode360.com/43750246#43750246.
City of Santee. 2022. City of Santee Housing Element Rezone Program Implementation. Accessed April 2024. https://ceqanet.opr.ca.gov/2021100263/2.
City of San Diego. 2023. Point Loma Wastewater Treatment Plant. Accessed April 2024. https://www.sandiego.gov/public-utilities/customer-service/water-wastewater-facilities/point-loma.
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DOC (California Department of Conservation). 2022. California Important Farmland Finder. Accessed on April 2024. https://maps.conservation.ca.gov/dlrp/ciff/.
FEMA (Federal Emergency Management Agency). 2020. Flood Zones. https://www.fema.gov/about/ glossary/flood-zones
GUHSD (Grossmont Union High School District). 2018. Pay Fees. https://www.guhsd.net/Departments/BusinessServices/Facilities-and-Construction/Building-Fees/Pay-Fees/index.html.
PDMWD (Padre Dam Municipal Water District). 2019. Sewer System Management Plan. Updated April 2019.
Accessed April 2024. https://www.padredam.org/DocumentCenter/View/3555/SSMP-April-2019.
PDMWD (Padre Dam Municipal Water District). 2023. Water Recycling Facility. Accessed April 2024. https://www.padredam.org/130/Water-Recycling-Facility#:~:text=Relocated%20to%20its%20present% 20site%20north%20of%20Santeenitrogen%20and%20phosphorous%20without%20the%20use%20of%2 0chemicals.
SCAQMD (South Coast Air Quality Management District). 1976. Rule 402, Nuisance. Adopted May 7, 1976. http://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule-402.pdf.
SCAQMD. 2005. Rule 403, Fugitive Dust. Adopted May 7, 1976; last amended June 3, 2005. http://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule-403.pdf.
SCAQMD. 2008. Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans. https://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significancethresholds/ghgboardsynopsis.pdf?sfvrsn=2.
San Diego County Regional Airport Authority (SDCRAA). 2010. Gillespie Field Airport Land Use Compatibility Plan.
Microsoft Word - SEE ALUCP Cover_Jan 10.doc
SSD (Santee School District). 2022. Developer Fees. Accessed April 2024. https://www.santeesd.net/district/ department/business_services/facilities_maintenance_operations/developer_fees.
4.2 List of Preparers
City of Santee (Lead Agency)
Sandi Sawa, AICP, Director of Planning & Building/City Planner Marni Borg, Principal Environmental Planner
Rachael Lindebrekke, Associate Planner
Michael Coyne, AICP, Former Principal Planner
Dudek (Environmental Consultant)
Carey Fernandes, Principal in Charge
Cindi Hoover, AICP, Environmental Planner
Elysa Briens, Environmental Planner
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Jennifer Reed, Air Resources Manager
Nicholas Lorenzen, Air Resources Specialist
Ames Noll, Air Resources Specialist
Sabita Tewani, AICP, PTP, Transportation Planner
Jim Cowan, INCE Bd.Cert., Lead Acoustician
Danielle Mullen, Biologist
Brock Ortega, Biologist
Addendum Contributors
Addendum contributors prepared technical reports that have been included in the Addendum.
MD Acoustics, LLC (Air Quality, Greenhouse Gas, and Energy Impact Report and Noise Impact Report)
Tyler Klassen, EIT
Rachel Edelman
Drew Gibson
Stantec (Phase I Environmental Site Assessment)
Kyle D. Emerson, C.E.G., Managing Principal
Alicia Jansen, Senior Scientist
Jennifer Alvarado, Associate Scientist
Leighton and Associates, INC. (Preliminary Geotechnical Investigation) Todd Schmitz, CEG 2510, Senior Project Geologist
Nicholas Tracy, GE 3058, Associate Engineer
Robert Stroh, CEG 2099, Principal Engineering Geologist Alta California Geotechnical Inc. (Geotechnical Investigation) Scott A. Gray, RGE 2857
Frank J. Echenique, CEG 2134
Logan A. Marquette, Civil Engineering Associate
Youssef F. Hijazi, Engineering Geology Associate
Rick Engineering Company (Preliminary Hydraulic Study, Drainage Study, and SWQMP) Water Resources Department
TJW Engineering, INC. (Traffic Impact Analysis)
Thomas Wheat PE, TE, President, Civil Engineer and Traffic Engineer David Chew, PTP, Transportation Planner
Tiffan Chang, EIT, Assistant Transportation Planner
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Travis Yokota, Assistant Transportation Planner
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FIGURE 3-1b
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17RORGANICS W.H. RECYCLE TRASH 52.0' 10.0' MIN.
INTERIOR SIDE SETBACK 10.0' MIN. FRONT YARD SETBACK B12-TH2 B1010 B17-TH2 B910 B18-TH2 B910 B25-TH2 B710 B37-TH3 B620 B30-TH3 B720 B29-TH2 B710 B24-TH2 B610 B10-TH1 B600 B9-TH1 B600 B21-TH2 B1011 B1-TH1 B300 B36-TH3 B1020 B35-TH3 B920 B34-TH3 B520 B42-TH3 B620
COTTONWOOD AVE
PARK CENTER DR TOWN CENTER COMMUNITY PARK N.A.P. TOWN CENTER COMMUNITY PARK PARKING LOT N.A.P. RIPARIAN BUFFER AREA ±173,668 SF TRAIL CONNECTION AMENITY SPACE ±9,007 SF
72.0' TO ROW 10.0' FRONT YARD SETBACK
9.0' 26.0' PROJECT ENTRY
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30.0' DRIVE PLAYGROUND ±10,050 SF 42.0' ROW 20.9' 30.0' DRIVE 40.3' 22.0' 30.0' DRIVE 36.0' 34.0' DRIVE 31.0' 26.0' DRIVE 31.0' 26.0' DRIVE 31.0' 26.0' DRIVE 31.0'
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INTERIOR SIDE SETBACK 10.0' MIN. INTERIOR SIDE SETBACK 101.2' TO NEAREST HOUSE B2-TH1 B300 B3-TH1 B300 B4-TH1 B300 B5-TH1 B300 B6-TH1 B300 B7-TH1 B300 B8-TH1 B300 30.0' DRIVE 36.0' 30.0' DRIVE 36.0' 22.0' B33-TH3 B520 B11-TH1 B600 B23-TH2 B610 B22-TH2 B1110 B19-TH2 B1110 B16-TH2 B1110 B13-TH2 B1110 B14-TH2 B1011 B20-TH1 B400 B15-TH1 B400 B26-TH1 B400 B28-TH2 B1010 B27-TH2 B44-TH3 B810 B421 B43-TH3 B421 B31-TH3 B1020 B32-TH3 B520 B40-TH3 B520 12.9'
30.0' DRIVE
46.8' 26.0' DRIVE 26.0' DRIVE 31.0' 30.0' DRIVE 36.4' 30.0' DRIVE 36.0' 44.0' 26.0' DRIVE
32.0' 30.0' DRIVE 26.0' DRIVE 32.0' 26.0' DRIVE 38.1' 30.0' DRIVE 38.3' 30.0' DRIVE 26.0' 24.1' 23.5' 21.8' B41-TH3 B621 16.9' 22.0' 22.0' 19.0' 19.0' 30.0' DRIVE 36.0' 30.0' DRIVE
25.7' 32.0'
26.0' 53.1' 35.8' 35.6' 53.7' 20.2' 20.0' 22.3' DETENTION BASIN ±39,126 SF P P P P P P P P P P P P P P P P P P P P P PP P PPP PPPPPP PPPP PP P P P P P 9.0' P
30.0' DRIVE
25.8' GREENCOURT ±3,730 SF GREENCOURT ±7,681 SF
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14.5' GREEN- COURT ±5,688 SF GREEN- COURT ±6,470 SF 36.0' 30.0' DRIVE
30.0' DRIVE 26.0' DRIVE
8.0' 8.0' GREEN- COURT ±3,705 SF GREEN- COURT ±2,604 SF P P P P CENTRAL VIEW PARK ±4,274 SF GREENCOURT ±4,735 SF FLOOD PLAIN FLOOD PLAIN SAN DIEGO RIVER SAN DIEGO RIVER WALKER TRAILS DR PP GREENCOURT ±4,730 SF PP PP P P PP PP PP PP PP P PP P P P P P B39-TH3 B720 B38-TH3 B620 Architecture + Planning 17911 Von Karman Ave, Suite 200 Irvine, CA 92614 949.851.2133 ktgy.com "PARKVUE" (SANTEE 3) SANTEE, CA # 2023-0148 City Ventures 3121 Michelson Drive, Suite 150 Irvine, CA 92612 Plot Date: 06.12.2025 1st Submittal Date: 2.2.2024 Revised 1st Submittal Date: 5.17.2024 2nd Submittal Date: 01.30.2025 3rd Submittal Date: 04.30.2025 4th Submittal Date: 06.13.2025 A0.10 ARCHITECTURAL SITE PLAN 0 80 160 Scale: 1" = 80'-0" 40 UNIT ENTRY ALEGEND PLAN 1 - 17 DU PLAN 2 - 9 DU PLAN 3 - 28 DU TH #1 - VERANDA AT PARKVUE 2-STORY ROWHOMES PLAN 1 - 16 DU PLAN 2 - 8 DU TH #2: LOGGIA AT PARKVUE 3-STORY INTERLOCK TOWNHOMES PLAN 1 - 8 DU PLAN 2 - 49 DU PLAN 3 - 11 DU TH #3 - TERRACE AT PARKVUE 3-STORY ROWHOMES PLAN 4 - 19 DU PLAN 5 - 8 DU NOTES: 1. INDIVIDUAL TRASH PICK-UP FOR ALL PRODUCT TYPES 2. ALL AC CONDENSERS ARE TO BE ROOF MOUNTED. PLAN 3 - 58 DU PLAN 4 - 54 DU ACCESSIBLE UNIT RIPARIAN AREA TRAIL EASEMENT CURRENT FLOOD PLAIN AIRPORT SAFETY ZONE 6
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05
AUGUST 2025
INTENTIONALLY LEFT BLANK
125
ADDENDUM TO THE SANTEE HOUSING ELEMENT IMPLEMENTATION PEIR / COTTONWOOD AND PARK
PROJECT
15269.05
AUGUST 2025
INTENTIONALLY LEFT BLANK
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Appendix A
Cottonwood & Park Air Quality, Greenhouse Gas, and
Energy Impact Study
Cottonwood & Park
Air Quality, Greenhouse Gas, and Energy Impact
Study
City of Santee, CA
Prepared for:
Michael You
City Ventures
3121 Michelson Drive, Suite 150
Irvine, CA 92555
Prepared by:
MD Acoustics, LLC
Tyler Klassen, EIT
1197 Los Angeles Ave, Ste C-256
Simi Valley, CA 93065
Date: 4/30/2025
Cottonwood & Park
Air Quality, Greenhouse Gas, and Energy Impact Study
City of Santee, CA TABLE OF CONTENTS
MD Acoustics, LLC ii
JN: 01632410_Report
TABLE OF CONTENTS
1.0 Introduction ..........................................................................................................................1
1.1 Purpose of Analysis and Study Objectives 1
1.2 Project Summary 1
1.2.1 Site Location 1
1.2.2 Project Description 1
1.2.3 Sensitive Receptors 1
1.3 Executive Summary of Findings and Mitigation Measures 2
2.0 Regulatory Framework and Background.................................................................................6
2.1 Air Quality Regulatory Setting 6
2.1.1 National and State 6
2.1.2 Local 8
2.2 Greenhouse Gas Regulatory Setting 11
2.2.1 International 11
2.2.2 National 11
2.2.3 California 13
2.2.4 Local 20
3.0 Setting.................................................................................................................................22
3.1 Existing Physical Setting 22
3.1.1 Local Climate and Meteorology 22
3.1.2 Local Air Quality 23
3.1.3 Attainment Status 25
3.2 Greenhouse Gases 26
4.0 Modeling Parameters and Assumptions...............................................................................29
4.1 Construction 29
4.2 Operations 30
5.0 Thresholds of Significance....................................................................................................31
5.1 Air Quality Thresholds of Significance 31
5.1.1 CEQA Guidelines for Air Quality 31
5.1.2 Regional Significance Thresholds 31
5.2 Greenhouse Gas Thresholds of Significance 32
5.2.1 CEQA Guidelines for Greenhouse Gas 32
5.3 Toxic Air Contaminants 34
6.0 Air Quality Emissions Impact................................................................................................36
6.1 Construction Air Quality Emissions Impact 36
6.1.1 Temporary Construction Emissions 36
6.1.2 Construction-Related Toxic Air Contaminant Impact 36
6.2 Operational Air Quality Emissions Impact 37
6.2.1 Operational Emissions 37
6.3 CO Hot Spot Emissions 38
Cottonwood & Park
Air Quality, Greenhouse Gas, and Energy Impact Study
City of Santee, CA TABLE OF CONTENTS
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6.4 Odors 39
6.5 Cumulative Regional Air Quality Impacts 39
6.6 Air Quality Compliance 40
7.0 Greenhouse Gas Impact Analysis..........................................................................................41
7.1 Construction Greenhouse Gas Emissions Impact 41
7.2 Operational Greenhouse Gas Emissions Impact 41
7.3 Greenhouse Gas Plan Consistency 42
8.0 Energy Analysis....................................................................................................................50
8.1 Construction Energy Demand 50
8.1.1 Construction Equipment Electricity Usage Estimates 50
8.1.2 Construction Equipment Fuel Estimates 51
8.1.3 Construction Worker Fuel Estimates 52
8.1.4 Construction Vendor/Hauling Fuel Estimates 52
8.1.5 Construction Energy Efficiency/Conservation Measures 53
8.2 Operational Energy Demand 54
8.2.1 Transportation Fuel Consumption 54
8.2.2 Facility Energy Demands (Electricity and Natural Gas) 55
8.3 Renewable Energy and Energy Efficiency Plan Consistency 55
9.0 References...........................................................................................................................57 Cottonwood & Park
Air Quality, Greenhouse Gas, and Energy Impact Study
City of Santee, CA TABLE OF CONTENTS
MD Acoustics, LLC iv
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LIST OF APPENDICES
Appendix A:
CalEEMod Output
Appendix B:
EMFAC2017 Output
LIST OF EXHIBITS
Exhibit A ...........................................................................................................................................4 Location Map 4
Exhibit B ...........................................................................................................................................5 Site Plan 5
LIST OF TABLES
Table 1: Land Use Summary........................................................................................................................ 1 Table 2: Ambient Air Quality Standards ..................................................................................................... 6 Table 3: Meteorological Summary............................................................................................................ 23 Table 4: Local Area Air Quality Levels....................................................................................................... 24 Table 5: San Diego County Air Basin Attainment Status........................................................................... 25 Table 6: Description of Greenhouse Gases............................................................................................... 27 Table 7: SDAPCD Air Quality Significance Thresholds............................................................................... 32 Table 8: Estimated Maximum Daily Construction Criteria Air Pollutant Emissions ................................. 36 Table 9: Estimated Maximum Daily Operational Criteria Air Pollutant Emissions................................... 37 Table 10: Estimated Annual Construction Greenhouse Gas Emissions.................................................... 41 Table 11: Opening Year Project-Related Greenhouse Gas Emissions...................................................... 41 Table 12: Project Consistency with San Diego Forward: The Regional Plan1........................................... 43 Table 13: Project Consistency with CARB Scoping Plan Policies and Measures1..................................... 46 Table 14: Sustainable Santee Plan Consistency Analysis.......................................................................... 48 Table 15: Project Construction Power Cost and Electricity Usage ........................................................... 50 Table 16: Construction Equipment Fuel Consumption Estimates............................................................ 51 Table 17: Construction Worker Fuel Consumption Estimates ................................................................. 52 Table 18: Construction Vendor Fuel Consumption Estimates (MHD Trucks)1......................................... 53 Cottonwood & Park
Air Quality, Greenhouse Gas, and Energy Impact Study
City of Santee, CA TABLE OF CONTENTS
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Table 19: Construction Hauling Fuel Consumption Estimates (HHD Trucks)1.......................................... 53 Table 20: Estimated Vehicle Operations Fuel Consumption1................................................................... 54 Table 21: Project Unmitigated Annual Operational Energy Demand Summary1..................................... 55 Cottonwood & Park
Air Quality, Greenhouse Gas, and Energy Impact Study
City of Santee, CA TABLE OF CONTENTS
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GLOSSARY OF TERMS
CAAQS California Ambient Air Quality Standards
CARB California Air Resources Board
CEQA California Environmental Quality Act
CFCs Chlorofluorocarbons
CH4 Methane
CNG Compressed natural gas
CO Carbon monoxide
CO2 Carbon dioxide
CO2e Carbon dioxide equivalent
DPM Diesel particulate matter
GHG Greenhouse gas
HFCs Hydrofluorocarbons
MTCO2e Metric tons of carbon dioxide equivalent
MMTCO2e Million metric tons of carbon dioxide equivalent NAAQS National Ambient Air Quality Standards
NOx Nitrogen Oxides
NO2 Nitrogen dioxide
N2O Nitrous oxide
O3 Ozone
PFCs Perfluorocarbons
PM Particle matter
PM10 Particles that are less than 10 micrometers in diameter PM2.5 Particles that are less than 2.5 micrometers in diameter PMI Point of maximum impact
PPM Parts per million
PPB Parts per billion
RAQS San Diego Regional Air Quality Strategy
RTIP Regional Transportation Improvement Plan
RTP Regional Transportation Plan
SDAB San Diego Air Basin
SDAPCD San Diego Air Pollution Control District
SF6 Sulfur hexafluoride
SIP State Implementation Plan
SOx Sulfur Oxides
SRA Source/Receptor Area
TAC Toxic air contaminants
VOC Volatile organic compounds
WRCC Western Regional Climate Center
Cottonwood & Park
Air Quality, Greenhouse Gas, and Energy Impact Study
City of Santee, CA Introduction
1 1.0 Introduction
1.1 Purpose of Analysis and Study Objectives
This air quality, greenhouse gas (GHG), and health risk analysis was prepared to evaluate whether the estimated criteria pollutants and GHG emissions generated from the project would cause a significant impact to the air resources in the project area. This assessment was conducted within the context of the California Environmental Quality Act (CEQA, California Public Resources Code Sections 21000, et seq.).
The assessment is consistent with the methodology and emission factors endorsed by San Diego Air Pollution control district (SDAPCD), California Air Resource Board (CARB), and the United States Environmental Protection Agency (US EPA).
1.2 Project Summary
1.2.1 Site Location
The project site is located near the southwest corner of Cottonwood Avenue and Park Center Drive in the City of Santee, California (APN 381-051-18), as shown in Exhibit A. The site is located within the Town Center Specific Plan. Land uses surrounding the site include residential to the north, northeast, and east, public/open space to the west, and flood/open space to the south.
1.2.2 Project Description
The project proposes to develop 285 multi-family units on approximately 22.17 acres. There will be 570 garage parking spaces and 76 open parking spaces. The site plan used for this project, provided by City Ventures, is shown in Exhibit B.
Construction activities within the Project area will consist of site preparation, on-site grading, building, paving, and architectural coating. Table 1 summarizes the land use description for the Project Site.
Table 1: Land Use Summary
Land Use Unit Amount Size Metric1
Condo/Townhouse 285 Dwelling Units
Enclosed Parking Structure 570 Spaces
Parking Lot 76 Spaces
1.2.3 Sensitive Receptors
Sensitive receptors are considered land uses or other types of population groups that are more sensitive to air pollution than others due to their exposure. As identified by the California Air Resources Board (CARB), sensitive population groups include children, the elderly, the acutely and chronically ill, and those with cardio-respiratory diseases. For CEQA purposes, a sensitive receptor would be a location Cottonwood & Park
Air Quality, Greenhouse Gas, and Energy Impact Study
City of Santee, CA Introduction
2 where a sensitive individual could remain for 24-hours or longer, such as residencies, hospitals, and schools (etc).
The closest existing sensitive receptors (to the site area) are the single-family residential land uses located approximately 75 feet east of the project site.
1.3 Executive Summary of Findings and Mitigation Measures The following is a summary of the analysis results:
Construction-Source Emissions
Project construction-source emissions would not exceed the SDAPCD’s significance thresholds for criteria pollutants.
Project construction-source emissions would not conflict with the San Diego Regional Air Quality Strategy (RAQS). As discussed herein, the project will comply with all applicable SDAPCD constructionsource emission reduction rules and guidelines. Project construction source emissions would not cause or substantively contribute to violation of the California Ambient Air Quality Standards (CAAQS) or National Ambient Air Quality Standards (NAAQS).
Established requirements addressing construction equipment operations, and construction material use, storage, and disposal requirements act to minimize odor impacts that may result from construction activities. Moreover, construction-source odor emissions would be temporary, short-term, and intermittent in nature and would not result in persistent impacts that would affect substantial numbers of people. Potential construction-source odor impacts are therefore considered less-than-significant.
Operational-Source Emissions
Operational-sourced emissions would not exceed the SDAPCD’s significance thresholds; therefore, impacts during project operation would be less than significant. Project-related traffic will not cause or result in CO concentrations exceeding applicable state and/or federal standards (CO “hotspots). Project operational-source emissions would therefore not adversely affect sensitive receptors within the vicinity of the project.
The project operational-source emissions will not exceed the City of SDAPCD’s significance thresholds and will not conflict with the RAQS. The project does not propose any such uses or activities that would result in potentially significant operational-source odor impacts. Potential operational-source odor impacts are therefore considered less-than significant. The project greenhouse gas emissions would be less than the Tier 4 screening level threshold and would not conflict with the goals of SB-32, the CARB Scoping Plan, the City of Santee Climate Action Plan; or the SANDAG Regional Plan; therefore, the project would not generate significant GHG emissions and would not conflict with an applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases. Impacts are considered to be less than significant.
Cottonwood & Park
Air Quality, Greenhouse Gas, and Energy Impact Study
City of Santee, CA Introduction
3 Mitigation Measures
A. Construction Measures
Adherence to SDAPCD Rules 52, 54, and 55 is required.
No construction mitigation required.
B. Operational Measures to Reduce Emissions
No operational mitigation required.
Exhibit A
Location Map
4 Introduction
Cottonwood & Park
Air Quality, Greenhouse Gas, and Energy Impact Study
City of Santee, CA
Site
Exhibit B
Site Plan
Introduction
Cottonwood & Park
Air Quality, Greenhouse Gas, and Energy Impact Study
City of Santee, CA
5 Cottonwood & Park
Air Quality, Greenhouse Gas, and Energy Impact Study
City of Santee, CA Regulatory Framework and Background
6 2.0 Regulatory Framework and Background
2.1 Air Quality Regulatory Setting
Air pollutants are regulated at the national, state, and air basin level; each agency has a different level of regulatory responsibility. The United States Environmental Protection Agency (EPA) regulates at the national level. The California Air Resources Board (ARB) regulates at the state level. The San Diego Air Pollution Control District (SDAPCD) regulates at the air basin level.
2.1.1 National and State
The EPA is responsible for global, international, and interstate air pollution issues and policies. The EPA sets national vehicle and stationary source emission standards, oversees approval of all State Implementation Plans, provides research and guidance for air pollution programs, and sets National Air Quality Standards, also known as federal standards. There are six common air pollutants, called criteria pollutants, which were identified from the provisions of the Clean Air Act of 1970. • Ozone
• Nitrogen Dioxide
• Lead
• Particulate Matter (PM10 and PM2.5)
• Carbon Monoxide
• Particulate Matter
• Sulfur Dioxide
The federal standards were set to protect public health, including that of sensitive individuals; thus, the standards continue to change as more medical research is available regarding the health effects of the criteria pollutants. Primary federal standards are the levels of air quality necessary, with an adequate margin of safety, to project the public health.
A State Implementation Plan is a document prepared by each state describing existing air quality conditions and measures that will be followed to attain and maintain federal standards. The State Implementation Plan for the State of California is administered by the ARB, which has overall responsibility for statewide air quality maintenance and air pollution prevention. California’s State Implementation Plan incorporates individual federal attainment plans for regional air districts—air district prepares their federal attainment plan, which sent to ARB to be approved and incorporated into the California State Implementation Plan. Federal attainment plans include the technical foundation for understanding air quality (e.g., emission inventories and air quality monitoring), control measures and strategies, and enforcement mechanisms. See http://www.arb.ca.gov/research/aaqs/aaqs.htm for additional information on criteria pollutants and air quality standards.
The federal and state ambient air quality standards are summarized in Table 2 and can also be found at http://www.arb.ca.gov/research/aaqs/aaqs2.pdf.
Table 2: Ambient Air Quality Standards
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7 Pollutant Averaging Time
California Standards1 National Standards2
Concentrations3 Method4 Primary3,5 Secondary3,6 Method7 Ozone (O3)
1-Hour 0.09 ppm Ultraviolet
Photometry
- - Same as
Primary
Standard
Ultraviolet
8-Hour 0.070 ppm 0.070 ppm (147 μg/m Photometry 3)
Respirable
Particulate Matter
(PM10)8
24-Hour 50 μg/m3
Gravimetric or Beta
Attenuation
150 μ/m3 Same as
Primary
Standard
Inertial Separation
and Gravimetric
Analysis Annual Arithmetic Mean 20 μg/m3
- -
Fine Particulate
Matter (PM2.5)8
24-Hour - - - - 35 μg/m3
Same as
Primary
Standard
Inertial Separation
and Gravimetric
Analysis Annual Arithmetic Mean 12 μg/m3
Gravimetric or Beta
Attenuation 12 μg/m3 15 μg/m3
Carbon Monoxide
(CO)
1-Hour 20 ppm (23 μg/m3)
Non-Dispersive
Infrared Photometry
(NDIR)
35 ppm (40 μg/m3) - -
Non-Dispersive
Infrared
Photometry (NDIR)
8-Hour 9.0 ppm (10 μg/m3) 9 ppm (10 μg/m3) - -
8-Hour
(Lake Tahoe) 6 ppm (7 μg/m3
) - - - -
Nitrogen Dioxide
(NO2)
9 1-Hour 0.18 ppm (339 μg/m3)
Gas Phase
Chemiluminescence
100 ppb (188 μg/m3) - -
Gas Phase
Annual Arithmetic Mean 0.030 ppm (357 μg/m Chemiluminescence 3) 0.053 ppm (100 μg/m3) Same as
Primary
Standard
Sulfur Dioxide
(SO2)
10 1-Hour 0.25 ppm (655 μg/m3)
Ultraviolet
Fluorescence
75 ppb (196 μg/m3) - -
Ultraviolet
Fluorescence;
Spectrophotometry
(Pararosaniline
Method)
3-Hour - - - -
0.5 ppm
(1300 mg/m3)
24-Hour 0.04 ppm (105 μg/m3)
0.14 ppm
(for certain areas)10 - -
Annual Arithmetic Mean - -
0.130ppm
(for certain areas)10 - -
Lead11,12
30 Day Average 1.5 μg/m3
Atomic Absorption
- -
Calendar Qrtr - -
1.5 μg/m3
(for certain areas)12 Same as
Primary
Standard
High Volume
Sampler and
Atomic Absorption Rolling 3-Month
Average - - 0.15 μg/m3
Visibility Reducing
Particles13 8-Hour See footnote 13
Beta Attenuation and
Transmittance
through Filter Tape No
National
Standards
Sulfates 24-Hour 25 μg/m3Ion Chromatography
Hydrogen Sulfide 1-Hour 0.03 ppm (42 μg/m3)
Ultraviolet
Fluorescence
Vinyl Chloride11 24-Hour 0.01 ppm (26 μg/m3) Gas Chromatography Notes:
1. California standards for ozone, carbon monoxide (except 8-hour Lake Tahoe), sulfur dioxide (1 and 24 hour), nitrogen dioxide, and particulate matter (PM10, PM2.5, and visibility reducing particles), are values that are not to be exceeded. All others are not to be equaled or exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations.
2. National standards (other than ozone, particulate matter, and those based on annual arithmetic mean) are not to be exceeded more than once a year.
The ozone standard is attained when the fourth highest 8-hour concentration measured at each site in a year, averaged over three years, is equal to or less than the standard. For PM10, the 24 hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 μg/m3is equal to or less than one. For PM2.5, the 24 hour standard is attained when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard. Contact the U.S. EPA for further clarification and current national policies.
3. Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas.
4. Any equivalent measurement method which can be shown to the satisfaction of the ARB to give equivalent results at or near the level of the air quality standard may be used.
5. National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public health.
6. National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.
7. Reference method as described by the U.S. EPA. An “equivalent method” of measurement may be used but must have a “consistent relationship to the reference method” and must be approved by the U.S. EPA.
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8 8. On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 μg/m3to 12.0 μg/m3. The existing national 24-hour PM2.5 standards (primary and secondary) were retained at 35 μg/m3, as was the annual secondary standard of 15 μg/m3. The existing 24-hour PM10 standards (primary and secondary) of 150 μg/m3 also were retained. The form of the annual primary and secondary standards is the annual mean, averaged over 3 years.
9. To attain the 1-hour national standard, the 3-year average of the annual 98th percentile of the 1-hour daily maximum concentrations at each site must not exceed 100 ppb. Note that the national 1-hour standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm). To directly compare the national 1-hour standard to the California standards the units can be converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 ppm.
10. On June 2, 2010, a new 1-hour SO2 standard was established and the existing 24-hour and annual primary standards were revoked. To attain the 1- hour national standard, the 3-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until one year after an area is designated for the 2010 standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved.
Note that the 1-hour national standard is in units of parts per billion (ppb). California standards are in units of parts per million (ppm). To directly compare the 1-hour national standard to the California standard the units can be converted to ppm. In this case, the national standard of 75 ppb is identical to 0.075 ppm.
11. The ARB has identified lead and vinyl chloride as 'toxic air contaminants' with no threshold level of exposure for adverse health effects determined.
These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants.
12. The national standard for lead was revised on October 15, 2008 to a rolling 3-month average. The 1978 lead standard (1.5 μg/m3 as a quarterly average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.
13. In 1989, the ARB converted both the general statewide 10-mile visibility standard and the Lake Tahoe 30-mile visibility standard to instrumental equivalents, which are "extinction of 0.23 per kilometer" and "extinction of 0.07 per kilometer" for the statewide and Lake Tahoe Air Basin standards, respectively.
Several pollutants listed in Table 2 are not addressed in this analysis. Analysis of lead is not included in this report because the project is not anticipated to emit lead. Visibility-reducing particles are not explicitly addressed in this analysis because particulate matter is addressed. The project is not expected to generate or be exposed to vinyl chloride because proposed project uses do not utilize the chemical processes that create this pollutant and there are no such uses in the project vicinity. The proposed project is not expected to cause exposure to hydrogen sulfide because it would not generate hydrogen sulfide in any substantial quantity.
2.1.2 Local
San Diego Air Pollution Control District
In San Diego, the APCD is responsible for enforcing the rules and regulations protecting air quality. The San Diego Regional Air Quality Strategy (RAQS) was developed pursuant to California Clean Air Act (CCAA) requirements. The RAQS was initially adopted in 1991, and is updated on a triennial basis (most recently in 2009). The RAQS identifies feasible emission control measures to provide progress in San Diego County toward attaining the State ozone standard. The pollutants addressed in the RAQS are VOCs and NOX, precursors to the photochemical formation of ozone (the primary component of smog).
The RAQS relies on information from CARB and San Diego Association of Governments (SANDAG), including mobile and area source emissions, as well as information regarding projected growth 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 Cottonwood & Park
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9 SANDAG growth projections are based on population and vehicle trends and land use plans developed by the cities and the County as part of the development of the individual General Plans.
In December 2016, the SDAPCD adopted an update to the Eight-Hour Ozone Attainment Plan for San Diego County which indicates that local controls and state programs would allow the region to reach attainment of the federal 8-hour O3 standard by 2018 (SDAPCD 2016). In this plan, SDAPCD relies on the 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 contaminants. 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 the EPA. Incentive programs for reduction of emissions from heavy-duty diesel vehicles, off-road equipment, and school buses are also established in the RAQS.
SDAPCD Rules and Regulations
The following rules and regulations apply to all sources in the jurisdiction of SDAPCD, and would apply to the project.
• SDAPCD Regulation IV: Prohibitions; Rule 50: Visible Emissions. Prohibits discharge into the atmosphere from any single source of emissions whatsoever any air contaminant for a period or periods aggregating more than 3 minutes in any period of 60 consecutive minutes that is darker in shade than that designated as Number 1 on the Ringelmann Chart, as published by the United States Bureau of Mines, or of such opacity as to obscure an observer’s view to a degree greater than does smoke of a shade designated as Number 1 on the Ringelmann Chart. • SDAPCD 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 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 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 Regulation XII: Toxic Air Contaminates; Rule 1200: Toxic Air Contaminants – New Source Review. Requires new or modified stationary source units with the potential to emit TACs above rule threshold levels to either demonstrate that they will not increase the maximum incremental cancer risk above 1 in 1 million at every receptor location, or demonstrate that toxics best available control technology (T-BACT) will be employed if maximum incremental cancer risk is equal to or less than 10 in 1 million, or demonstrate compliance with SDAPCD’s protocol for Cottonwood & Park
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10 those sources with an increase in maximum incremental cancer risk at any receptor location of greater than 10 in 1 million but less than 100 in 1 million. • SDAPCD Regulation XII: Toxic Air Contaminates; Rule 1210: Toxic Air Contaminant Public Health Risks – Public Notification and Risk Reduction. Requires each stationary source that is required to prepare a public risk assessment to provide written public notice of risks at or above the following levels: maximum incremental cancer risks equal to or greater than 10 in 1 million, or cancer burden equal to or greater than 1.0, or total acute non-cancer health hazard index equal to or greater than 1.0, or total chronic non-cancer health hazard index equal to or greater than
1.0. San Diego Association of Governments
SANDAG is the regional planning agency for San Diego County and serves as a forum for regional issues relating to transportation, the economy, community development, and the environment. 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, including its 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. In regard to air quality, the Regional Plan sets the policy context in which SANDAG participates and responds to the air district’s air quality plans and builds off the air district’s air quality plan processes that are designed to meet health-based criteria pollutant standards in several ways (SANDAG 2015). On September 23, 2016, SANDAG’s Board of Directors adopted the final 2016 Regional Transportation Improvement Program (RTIP). The 2016 RTIP is a multi-year program of projects for major transportation projects in the San Diego region. Transportation projects supported through federal, state, and TransNet (the San Diego transportation sales tax program) funds must be included in an approved RTIP. The 2016 RTIP covers five fiscal years and incrementally implements the Regional Plan (SANDAG 2016). The 2021 Regional Plan was adopted on December 10, 2021, and includes plans for multimodal roads, expanded transit, and improvements to the transportation system technology (SANDAG 2021).
On October 28, 2011, SANDAG adopted the 2050 Regional Transportation Plan (RPT) and Sustainable Communities Strategy (SCS), which meets the CARB emission reduction requirements. The 2050 RTP is a long-range visioning plan that builds upon and expands land use and transportation strategies established over several planning cycles to increase mobility options and achieve a more sustainable growth pattern. The plan outlines more than $214 billion in transportation system investments through 2050. The RTP is supported by a combination of transportation and land use strategies that help the region achieve state greenhouse gas emission reduction goals and federal Clean Air Act requirements, preserve open space areas, improve public health and roadway safety, support our vital goods movement industry and utilize resources more efficiently.
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11 2.2 Greenhouse Gas Regulatory Setting
2.2.1 International
Many countries around the globe have made an effort to reduce GHGs since climate change is a global issue.
Intergovernmental Panel on Climate Change. In 1988, the United Nations and the World Meteorological Organization established the Intergovernmental Panel on Climate Change to assess the scientific, technical and socio-economic information relevant to understanding the scientific basis of risk of humaninduced climate change, its potential impacts, and options for adaptation and mitigation.
United Nations. The United States participates in the United Nations Framework Convention on Climate Change (UNFCCC) (signed on March 21, 1994). Under the Convention, governments gather and share information on greenhouse gas emissions, national policies, and best practices; launch national strategies for addressing greenhouse gas emissions and adapting to expected impacts, including the provision of financial and technological support to developing countries; and cooperate in preparing for adaptation to the impacts of climate change.
The 2014 UN Climate Change Conference in Lima Peru provided a unique opportunity to engage all countries to assess how developed countries are implementing actions to reduce emissions.
Kyoto Protocol. The Kyoto Protocol is a treaty made under the UNFCCC and was the first international agreement to regulate GHG emissions. It has been estimated that if the commitments outlined in the Kyoto Protocol are met, global GHG emissions could be reduced by an estimated 5 percent from 1990 levels during the first commitment period of 2008 – 2012 (UNFCCC 1997). On December 8, 2012, the Doha Amendment to the Kyoto Protocol was adopted. The amendment includes: New commitments for Annex I Parties to the Kyoto Protocol who agreed to take on commitments in a second commitment period from 2013 – 2020; a revised list of greenhouse gases (GHG) to be reported on by Parties in the second commitment period; and Amendments to several articles of the Kyoto Protocol which specifically referenced issues pertaining to the first commitment period and which needed to be updated for the second commitment period.
2.2.2 National
Greenhouse Gas Endangerment. On December 2, 2009, the EPA announced that GHGs threaten the public health and welfare of the American people. The EPA also states that GHG emissions from on-road vehicles contribute to that threat. The decision was based on Massachusetts v. EPA (Supreme Court Case 05-1120) which argued that GHGs are air pollutants covered by the Clean Air Act and that the EPA has authority to regulate those emissions.
Clean Vehicles. Congress first passed the Corporate Average Fuel Economy law in 1975 to increase the fuel economy of cars and light duty trucks. The law has become more stringent over time. On May 19, 2009, President Obama put in motion a new national policy to increase fuel economy for all new cars and trucks sold in the United States. On April 1, 2010, the EPA and the Department of Transportation’s Cottonwood & Park
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12 National Highway Safety Administration announced a joint final rule establishing a national program that would reduce greenhouse gas emissions and improve fuel economy for new cars and trucks sold in the United States.
The first phase of the national program would apply to passenger cars, light-duty trucks, and mediumduty passenger vehicles, covering model years 2012 through 2016. They require these vehicles to meet an estimated combined average emissions level of 250 grams of carbon dioxide per mile, equivalent to
35.5 miles per gallon if the automobile industry were to meet this carbon dioxide level solely through fuel economy improvements. Together, these standards would cut carbon dioxide emissions by an estimated 960 million metric tons and 1.8 billion barrels of oil over the lifetime of the vehicles sold under the program (model years 2012-2016). The second phase of the national program would involve proposing new fuel economy and greenhouse gas standards for model years 2017 – 2025 by September 1, 2011.
On October 25, 2010, the EPA and the U.S. Department of Transportation proposed the first national standards to reduce greenhouse gas emissions and improve fuel efficiency of heavy-duty trucks and buses. For combination tractors, the agencies are proposing engine and vehicle standards that begin in the 2014 model year and achieve up to a 20 percent reduction in carbon dioxide emissions and fuel consumption by the 2018 model year. For heavy-duty pickup trucks and vans, the agencies are proposing separate gasoline and diesel truck standards, which phase in starting in the 2014 model year and achieve up to a 10 percent reduction for gasoline vehicles and 15 percent reduction for diesel vehicles by 2018 model year (12 and 17 percent respectively if accounting for air conditioning leakage). Lastly, for vocational vehicles, the agencies are proposing engine and vehicle standards starting in the 2014 model year which would achieve up to a 10 percent reduction in fuel consumption and carbon dioxide emissions by 2018 model year.
Issued by NHTSA and EPA in March 2020 (published on April 30, 2020 and effective after June 29, 2020), the Safer Affordable Fuel-Efficient Vehicles Rule would maintain the CAFE and CO2 standards applicable in model year 2020 for model years 2021 through 2026. The estimated CAFE and CO2 standards for model year 2020 are 43.7 mpg and 204 grams of CO2 per mile for passenger cars and 31.3 mpg and 284 grams of CO2 per mile for light trucks, projecting an overall industry average of 37 mpg, as compared to
46.7 mpg under the standards issued in 2012. This Rule also excludes CO2- equivalent emission improvements associated with air conditioning refrigerants and leakage (and, optionally, offsets for nitrous oxide and methane emissions) after model year 2020.1 Mandatory Reporting of Greenhouse Gases. On January 1, 2010, the EPA started requiring large emitters of heat-trapping emissions to begin collecting GHG data under a new reporting system. Under 1 National Highway Traffic Safety Administration (NHTSA) and U.S. Environmental Protection Agency (USEPA), 2018. Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules, The Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021–2026 Passenger Cars and Light Trucks 2018. Available at: https://www.gpo.gov/fdsys/pkg/FR-2018-08-24/pdf/2018-16820.pdf.
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13 the rule, suppliers of fossil fuels or industrial greenhouse gases, manufacturers of vehicles and engines, and facilities that emit 25,000 metric tons or more per year of greenhouse gas emissions are required to submit annual reports to the EPA.
Climate Adaption Plan. The EPA Plan identifies priority actions the Agency will take to incorporate considerations of climate change into its programs, policies, rules and operations to ensure they are effective under future climatic conditions. The following link provides more information on the EPA Plan:
https://www.epa.gov/arc-x/planning-climate-change-adaptation
2.2.3 California
California Code of Regulations (CCR) Title 24, Part 6. CCR Title 24, Part 6: California’s Energy Efficiency Standards for Residential and Nonresidential Buildings (Title 24) were first established in 1978 in response to a legislative mandate to reduce California’s energy consumption. The standards are updated periodically to allow consideration and possible incorporation of new energy efficiency technologies and methods. Although it was not originally intended to reduce GHG emissions, electricity production by fossil fuels results in GHG emissions and energy efficient buildings require less electricity. Therefore, increased energy efficiency results in decreased GHG emissions.
The Energy Commission adopted 2008 Standards on April 23, 2008 and Building Standards Commission approved them for publication on September 11, 2008. These updates became effective on August 1, 2009. 2013 and 2016 standards have been approved and became effective July 1, 2014 and January 1, 2016, respectively. 2019 standards were published July 1, 2019 and became effective January 1, 2020.
California Code of Regulations (CCR) Title 24, Part 11. All buildings for which an application for a building permit is submitted on or after January 1, 2020 must follow the 2019 standards.. Energy efficient buildings require less electricity; therefore, increased energy efficiency reduces fossil fuel consumption and decreases greenhouse gas emissions. The following links provide more information on Title 24, Part 11:
https://www.dgs.ca.gov/BSC/Codes
https://www.energy.ca.gov/sites/default/files/2020-03/Title_24_2019_Building_Standards_FAQ_ada.pdf California Green Building Standards. On January 12, 2010, the State Building Standards Commission unanimously adopted updates to the California Green Building Standards Code, which went into effect on January 1, 2011. The Housing and Community Development (HCD) updated CALGreen through the 2015 Triennial Code Adoption Cycle, during the 2016 to 2017 fiscal year. During the 2019-2020 fiscal year, the Department of Housing and Community Development (HCD) updated CALGreen through the 2019 Triennial Code Adoption Cycle.
The Code is a comprehensive and uniform regulatory code for all residential, commercial and school buildings. CCR Title 24, Part 11: California Green Building Standards (Title 24) became effective in 2001 in response to continued efforts to reduce GHG emissions associated with energy consumption. CCR Title 24, Part 11 now require that new buildings reduce water consumption, employ building commissioning to increase building system efficiencies, divert construction waste from landfills, and Cottonwood & Park
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14 install low pollutant-emitting finish materials. One focus of CCR Title 24, Part 11 is water conservation measures, which reduce GHG emissions by reducing electrical consumption associated with pumping and treating water. CCR Title 24, Part 11 has approximately 52 nonresidential mandatory measures and an additional 130 provisions for optional use. Some key mandatory measures for commercial occupancies include specified parking for clean air vehicles, a 20 percent reduction of potable water use within buildings, a 50 percent construction waste diversion from landfills, use of building finish materials that emit low levels of volatile organic compounds, and commissioning for new, nonresidential buildings over 10,000 square feet.
The 2019 CalGreen Code includes the following changes and/or additional regulations:
Single-family homes built with the 2019 standards will use about 7 percent less energy due to energy efficiency measures versus those built under the 2016 standards. Once rooftop solar electricity generation is factored in, homes built under the 2019 standards will use about 53 percent less energy than those under the 2016 standards. Nonresidential buildings will use about 30 percent less energy due mainly to lighting upgrades2.
HCD modified the best management practices for stormwater pollution prevention adding Section
5.106.2 for projects that disturb one or more acres of land. This section requires projects that disturb one acre or more of land or less than one acre of land but are part of a larger common plan of development or sale must comply with the post-construction requirement detailed in the applicable National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities issued by the State Water Resources Control Board. The NPDES permits require post-construction runoff (post-project hydrology) to match the preconstruction runoff pre-project hydrology) with installation of post-construction stormwater management measures.
HCD added sections 5.106.4.1.3 and 5.106.4.1.5 in regards to bicycle parking. Section 5.106.4.1.3 requires new buildings with tenant spaces that have 10 or more tenant-occupants, provide secure bicycle parking for 5 percent of the tenant-occupant vehicular parking spaces with a minimum of one bicycle parking facility. In addition, Section 5.106.4.1.5 states that acceptable bicycle parking facility for Sections 5.106.4.1.2 through 5.106.4.1.4 shall be convenient from the street and shall meeting one of the following: (1) covered, lockable enclosures with permanently anchored racks for bicycles; (2) lockable bicycle rooms with permanently anchored racks; or (3) lockable, permanently anchored bicycle lockers.
HCD amended section 5.106.5.3.5 allowing future charging spaces to qualify as designated parking for clean air vehicles.
2 https://ww2.energy.ca.gov/title24/2019standards/documents/2018_Title_24_2019_Building_Standards_FAQ.pdf Cottonwood & Park
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15 HCD updated section 5.303.3.3 in regards to showerhead flow rates. This update reduced the flow rate to 1.8 GPM.
HCD amended section 5.304.1 for outdoor potable water use in landscape areas and repealed sections
5.304.2 and 5.304.3. The update requires nonresidential developments to comply with a local water efficient landscape ordinance or the current California Department of Water Resource’s’ Model Water Efficient Landscape Ordinance (MWELO), whichever is more stringent. Some updates were also made in regards to the outdoor potable water use in landscape areas for public schools and community colleges.
HCD updated Section 5.504.5.3 in regards to the use of MERV filters in mechanically ventilated buildings.
This update changed the filter use from MERV 8 to MERV 13.
The California Green Building Standards Code does not prevent a local jurisdiction from adopting a more stringent code as state law provides methods for local enhancements. The Code recognizes that many jurisdictions have developed existing construction and demolition ordinances, and defers to them as the ruling guidance provided they provide a minimum 50-percent diversion requirement. The code also provides exemptions for areas not served by construction and demolition recycling infrastructure. State building code provides the minimum standard that buildings need to meet in order to be certified for occupancy. Enforcement is generally through the local building official. The following link provides more on CalGreen Building Standards:
http://www.bsc.ca.gov/Home/CALGreen.aspx
Executive Order S-3-05. California Governor issued Executive Order S-3-05, GHG Emission, in June 2005, which established the following targets:
• By 2010, California shall reduce greenhouse gas emissions to 2000 levels; • By 2020, California shall reduce greenhouse gas emissions to 1990 levels. • By 2050, California shall reduce greenhouse gas emissions to 80 percent below 1990 levels.
The executive order directed the secretary of the California Environmental Protection Agency (CalEPA) to coordinate a multi-agency effort to reduce GHG emissions to the target levels. To comply with the Executive Order, the secretary of CalEPA created the California Climate Action Team (CAT), made up of members from various state agencies and commissions. The team released its first report in March 2006. The report proposed to achieve the targets by building on the voluntary actions of businesses, local governments, and communities and through State incentive and regulatory programs.
Executive Order S-01-07. Executive Order S-1-07 was issued in 2007 and proclaims that the transportation sector is the main source of GHG emissions in the State, since it generates more than 40 percent of the State’s GHG emissions. It establishes a goal to reduce the carbon intensity of transportation fuels sold in the State by at least ten percent by 2020. This Order also directs CARB to determine whether this Low Carbon Fuel Standard (LCFS) could be adopted as a discrete early-action measure as part of the effort to meet the mandates in AB 32.
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16 On April 23, 2009 CARB approved the proposed regulation to implement the low carbon fuel standard and began implementation on January 1, 2011. The low carbon fuel standard is anticipated to reduce GHG emissions by about 16 MMT per year by 2020. CARB approved some amendments to the LCFS in December 2011, which were implemented on January 1, 2013. In September 2015, the Board approved the re-adoption of the LCFS, which became effective on January 1, 2016, to address procedural deficiencies in the way the original regulation was adopted. In 2018, the Board approved amendments to the regulation, which included strengthening and smoothing the carbon intensity benchmarks through 2030 in-line with California's 2030 GHG emission reduction target enacted through SB 32, adding new crediting opportunities to promote zero emission vehicle adoption, alternative jet fuel, carbon capture and sequestration, and advanced technologies to achieve deep decarbonization in the transportation sector.
The LCFS is designed to encourage the use of cleaner low-carbon transportation fuels in California, encourage the production of those fuels, and therefore, reduce GHG emissions and decrease petroleum dependence in the transportation sector. Separate standards are established for gasoline and diesel fuels and the alternative fuels that can replace each. The standards are “back-loaded”, with more reductions required in the last five years, than the first five years. This schedule allows for the development of advanced fuels that are lower in carbon than today’s fuels and the market penetration of plug-in hybrid electric vehicles, battery electric vehicles, fuel cell vehicles, and flexible fuel vehicles. It is anticipated that compliance with the low carbon fuel standard will be based on a combination of both lower carbon fuels and more efficient vehicles.
Reformulated gasoline mixed with corn-derived ethanol at ten percent by volume and low sulfur diesel fuel represent the baseline fuels. Lower carbon fuels may be ethanol, biodiesel, renewable diesel, or blends of these fuels with gasoline or diesel as appropriate. Compressed natural gas and liquefied natural gas also may be low carbon fuels. Hydrogen and electricity, when used in fuel cells or electric vehicles are also considered as low carbon fuels for the low carbon fuel standard.
SB 97. Senate Bill 97 (SB 97) was adopted August 2007 and acknowledges that climate change is a prominent environmental issue that requires analysis under CEQA. SB 97 directed the Governor’s Office of Planning and Research (OPR), which is part of the State Resource Agency, to prepare, develop, and transmit to CARB guidelines for the feasible mitigation of GHG emissions or the effects of GHG emissions, as required by CEQA, by July 1, 2009. The Resources Agency was required to certify and adopt those guidelines by January 1, 2010.
Pursuant to the requirements of SB 97 as stated above, on December 30, 2009 the Natural Resources Agency adopted amendments to the state CEQA guidelines that address GHG emissions. The CEQA Guidelines Amendments changed 14 sections of the CEQA Guidelines and incorporate GHG language throughout the Guidelines. However, no GHG emissions thresholds of significance are provided and no specific mitigation measures are identified. The GHG emission reduction amendments went into effect on March 18, 2010 and are summarized below:
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17 • Climate action plans and other greenhouse gas reduction plans can be used to determine whether a project has significant impacts, based upon its compliance with the plan. • Local governments are encouraged to quantify the greenhouse gas emissions of proposed projects, noting that they have the freedom to select the models and methodologies that best meet their needs and circumstances. The section also recommends consideration of several qualitative factors that may be used in the determination of significance, such as the extent to which the given project complies with state, regional, or local GHG reduction plans and policies. OPR does not set or dictate specific thresholds of significance. Consistent with existing CEQA Guidelines, OPR encourages local governments to develop and publish their own thresholds of significance for GHG impacts assessment.
• When creating their own thresholds of significance, local governments may consider the thresholds of significance adopted or recommended by other public agencies, or recommended by experts. • New amendments include guidelines for determining methods to mitigate the effects of greenhouse gas emissions in Appendix F of the CEQA Guidelines.
• OPR is clear to state that “to qualify as mitigation, specific measures from an existing plan must be identified and incorporated into the project; general compliance with a plan, by itself, is not mitigation.”
• OPR’s emphasizes the advantages of analyzing GHG impacts on an institutional, programmatic level.
OPR therefore approves tiering of environmental analyses and highlights some benefits of such an approach.
• Environmental impact reports (EIRs) must specifically consider a project's energy use and energy efficiency potential.
AB 32. The California State Legislature enacted AB 32, the California Global Warming Solutions Act of 2006. AB 32 requires that greenhouse gases emitted in California be reduced to 1990 levels by the year 2020. “Greenhouse gases” as defined under AB 32 include carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. ARB is the state agency charged with monitoring and regulating sources of greenhouse gases. AB 32 states the following:
Global warming poses a serious threat to the economic well-being, public health, natural resources, and the environment of California. The potential adverse impacts of global warming include the exacerbation of air quality problems, a reduction in the quality and supply of water to the state from the Sierra snowpack, a rise in sea levels resulting in the displacement of thousands of coastal businesses and residences, damage to marine ecosystems and the natural environment, and an increase in the incidences of infectious diseases, asthma, and other human health-related problems.
The ARB Board approved the 1990 greenhouse gas emissions level of 427 million metric tons of carbon dioxide equivalent (MMTCO2e) on December 6, 2007 (California Air Resources Board 2007). Therefore, emissions generated in California in 2020 are required to be equal to or less than 427 MMTCO2e.
Emissions in 2020 in a “business as usual” scenario are estimated to be 596 MMTCO2e.
Under AB 32, the ARB published its Final Expanded List of Early Action Measures to Reduce Greenhouse Gas Emissions in California. Discrete early action measures are currently underway or are enforceable Cottonwood & Park
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18 by January 1, 2010. The ARB has 44 early action measures that apply to the transportation, commercial, forestry, agriculture, cement, oil and gas, fire suppression, fuels, education, energy efficiency, electricity, and waste sectors. Of these early action measures, nine are considered discrete early action measures, as they are regulatory and enforceable by January 1, 2010. The ARB estimates that the 44 recommendations are expected to result in reductions of at least 42 MMTCO2e by 2020, representing approximately 25 percent of the 2020 target.
The ARB’s Climate Change Scoping Plan (Scoping Plan) initially contained measures designed to reduce the State’s emissions to 1990 levels by the year 2020 with a further goal of 40 percent below 2020 levels by 2030 established in 2017 (California Air Resources Board 2017). The 2020 goal was achieved in 2016.
The Scoping Plan identifies recommended measures for multiple greenhouse gas emission sectors and the associated emission reductions needed to achieve the year 2020 emissions target—each sector has a different emission reduction target. Most of the measures target the transportation and electricity sectors. As stated in the Scoping Plan, the key elements of the strategy for achieving the 2030 greenhouse gas target include:
• Expanding and strengthening existing energy efficiency programs as well as building and appliance standards;
• Achieving a statewide renewables energy mix of 33 percent; • Developing a California cap-and-trade program that links with other Western Climate Initiative partner programs to create a regional market system;
• Establishing targets for transportation-related greenhouse gas emissions for regions throughout California and pursuing policies and incentives to achieve those targets; • Adopting and implementing measures pursuant to existing State laws and policies, Including California’s clean car standards, goods movement measures, and the Low Carbon Fuel Standard; and • Creating targeted fees, including a public goods charge on water use, fees on high global warming potential gases, and a fee to fund the administrative costs of the State’s long-term commitment to AB 32 implementation.
In addition, the Scoping Plan differentiates between “capped” and “uncapped” strategies. “Capped” strategies are subject to the proposed cap-and-trade program. The Scoping Plan states that the inclusion of these emissions within the cap-and trade program will help ensure that the year 2020 emission targets are met despite some degree of uncertainty in the emission reduction estimates for any individual measure. Implementation of the capped strategies is calculated to achieve a sufficient amount of reductions by 2020 to achieve the emission target contained in AB 32. “Uncapped” strategies that will not be subject to the cap-and-trade emissions caps and requirements are provided as a margin of safety by accounting for additional greenhouse gas emission reductions.4 SB 375. Senate Bill 375 (SB 375) was adopted September 2008 and aligns regional transportation planning efforts, regional GHG emission reduction targets, and land use and housing allocation. SB 375 requires Metropolitan Planning Organizations (MPO) to adopt a sustainable communities strategy (SCS) or alternate planning strategy (APS) that will prescribe land use allocation in that MPOs Regional Cottonwood & Park
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19 Transportation Plan (RTP). CARB, in consultation with each MPO, will provide each affected region with reduction targets for GHGs emitted by passenger cars and light trucks in the region for the years 2020 and 2035. These reduction targets will be updated every eight years but can be updated every four years if advancements in emissions technologies affect the reduction strategies to achieve the targets. CARB is also charged with reviewing each MPO’s sustainable communities strategy or alternate planning strategy for consistency with its assigned targets.
The proposed project is located within the San Diego Association of Government (SANDAG), which has authority to develop the SCS or APS. For the SANDAG region, the targets set by CARB are at 15 percent below 2005 per capita GHG emissions levels by 2020 and 19 percent below 2005 per capita GHG emissions levels by 2035. On October 28, 2011, SANDAG adopted the 2050 Regional Transportation Plan (RPT) and Sustainable Communities Strategy (SCS), which meets the CARB emission reduction requirements.
The 2050 RTP is a long-range visioning plan that builds upon and expands land use and transportation strategies established over several planning cycles to increase mobility options and achieve a more sustainable growth pattern. The plan outlines more than $214 billion in transportation system investments through 2050. The RTP is supported by a combination of transportation and land use strategies that help the region achieve state greenhouse gas emission reduction goals and federal Clean Air Act requirements, preserve open space areas, improve public health and roadway safety, support our vital goods movement industry and utilize resources more efficiently.
City and County land use policies, including General Plans, are not required to be consistent with the RTP and associated SCS or APS. However, new provisions of CEQA would incentivize, through streamlining and other provisions, qualified projects that are consistent with an approved SCS or APS and categorized as “transit priority projects.”
Assembly Bill 939, Assembly Bill 341, and Senate Bill 1374. Assembly Bill 939 (AB 939) requires that each jurisdiction in California to divert at least 50 percent of its waste away from landfills, whether through waste reduction, recycling or other means. AB 341 requires at least 75 percent of generated waste be source reduced, recycled, or composted by the year 2020. Senate Bill 1374 (SB 1374) requires the California Integrated Waste Management Board to adopt a model ordinance by March 1, 2004 suitable for adoption by any local agency to require 50 to 75 percent diversion of construction and demolition of waste materials from landfills.
Executive Order S-13-08. Executive Order S-13-08 indicates that “climate change in California during the next century is expected to shift precipitation patterns, accelerate sea level rise and increase temperatures, thereby posing a serious threat to California’s economy, to the health and welfare of its population and to its natural resources.” Pursuant to the requirements in the order, the 2009 California Climate Adaptation Strategy (California Natural Resource Agency 2009) was adopted, which is the “… first statewide, multi-sector, region-specific, and information-based climate change in California, identifying and exploring strategies to adapt to climate change, and specifying a direction for future research.
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20 Executive Order B-30-15. Executive Order B-30-15, establishing a new interim statewide greenhouse gas emission reduction target to reduce greenhouse gas emissions to 40 percent below 1990 levels by 2030, was signed by Governor Brown in April 2015.
Executive Order B-29-15. Executive Order B-29-15, mandates a statewide 25% reduction in potable water usage and was signed into law on April 1, 2015.
Executive Order B-37-16. Executive Order B-37-16, continuing the State’s adopted water reduction, was signed into law on May 9, 2016. The water reduction builds off the mandatory 25% reduction called for in EO B-29-15.
Executive Order N-79-20. Executive Order N-79-20 was signed into law on September 23, 2020 and mandates 100 percent of in-state sales of new passenger cars and trucks be zero-emission by 2035; 100 percent of medium- and heavy-duty vehicles in the state be zero-emission vehicles by 2045 for all operations where feasible and by 2035 for drayage trucks; and to transition to 100 percent zero-emission off-road vehicles and equipment by 2035 where feasible.
Renewables Portfolio Standard (RPS) Program. California's RPS program was established in 2002 by Senate Bill (SB) 1078 with the initial requirement that 20% of electricity retail sales must be served by renewable resources by 2017. The program was accelerated in 2015 with SB 350 which mandated a 50% RPS by 2030. SB 350 includes interim annual RPS targets with three-year compliance periods and requires 65% of RPS procurement to be derived from long-term contracts of 10 or more years. In 2018, SB 100 was signed into law, which again increases the RPS to 60% by 2030 and requires all the state's electricity to come from carbon-free resources by 2045 (CPUC 2021).
San Diego Gas & Electric procured 42 percent of its power from renewable resources, which is above the State’s statutory and Commission’s RPS program requirements (SDG&E 2021).
2.2.4 Local
City of Santee
Sustainable Santee Plan (Climate Action Plan)
In 2019, the City of Santee adopted the Sustainable Santee Plan (SSP). The plan inventoried existing CO2 emissions from available data, projected emissions growth to 2035, and evaluated a wide range of CO2 reduction measures. Overall, the SSP would reduce the City's communitywide GHG emissions 40 percent below 2005 emissions by 2030, and 49 percent below 2005 emissions by 2035. In addition, in compliance with the California Air Resources Board 2017 Scoping Plan Update, the SSP would reduce communitywide emissions below 3.8 MT CO2e per capita by 2030. The SSP describes the baseline GHG emissions produced in the City and projects GHG emissions that could be expected if the SSP is not implemented. The SSP contains communitywide reductions measures applicable to existing and new development, as well as municipal reduction measures, demonstrating compliance with State reduction targets. It also includes adaption measures, an emissions tracking tool, an annual reporting process, Cottonwood & Park
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21 inventory updates, and continued refinement of target setting to keep pace with the long-term State goal found in Executive Order B-55-18 of carbon neutrality by 2045.
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22 3.0 Setting
3.1 Existing Physical Setting
The project site is located in the City of Santee, which is in the San Diego Air Basin (SDAB). The boundaries of the SDAB are contiguous with the political boundaries of San Diego County. The County of San Diego is bounded on the north by Orange and Riverside Counties, on the east by Imperial County, on the west by the Pacific Ocean, and on the south by the Mexican State of Baja California.
3.1.1 Local Climate and Meteorology
The San Diego Air Basin climate is largely dominated by the semi-permanent high-pressure system over the Pacific Ocean, which creates a pattern of late-night and early-morning low clouds, hazy afternoon sunshine, daytime onshore breezes, and little temperature variation year round. The San Diego area is classified as having a Mediterranean climate, with warm, dry summers and mild, wet winters.
Temperature and precipitation can vary widely within the SDAB, where average annual precipitation ranges from approximately 10 inches in the coastal and inland areas to over 30 inches in the mountains (County of San Diego, 2007). In general, more mild annual temperatures are experienced in the maritime and coastal areas, whereas the interior and desert areas experience warmer summers and cooler winters. The project site is located approximately 2.8 miles inland from the coast.
The high-pressure system drives the prevailing winds in the SDAB. The winds tend to blow onshore in the daytime and offshore at night. In the summer, an inversion layer is created over the coastal areas and increases the O3 levels. During winter, San Diego often experiences a shallow inversion layer which tends to increase carbon monoxide and PM2.5 concentration levels due to the increased use of residential wood burning. The SDAB is often impacted by Santa Ana winds during the fall months. These winds blow the air basin’s pollutants out to sea; however, a weak Santa Ana can transport air pollution from the South Coast Air Basin and greatly increase the San Diego O3 concentrations. (SDAPCD 2017) The temperature and precipitation levels for the City of San Diego are in Table 3. Table 3 shows that August and September are typically the warmest months and December and January are typically the coolest months. Rainfall in the project area varies considerably in both time and space. Almost all the annual rainfall comes from the fringes of mid-latitude storms from late November to early April, with summers being almost completely dry.
<Table 3, next page>
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23 Table 3: Meteorological Summary
Month
Temperature (˚F) Average Precipitation
Average High Average Low (inches)
January 64.8 48.1 2.00
February 65.2 49.7 1.98
March 65.9 51.9 1.63
April 67.4 54.7 0.78
May 68.6 58.1 0.21
June 70.9 60.8 0.05
July 74.8 64.4 0.02
August 76.3 65.7 0.06
September 75.7 63.9 0.17
October 72.9 59.3 0.51
November 69.9 52.9 0.97
December 65.8 48.7 1.77
Annual Average 69.9 56.5 10.1
Notes:
1 Source: https://wrcc.dri.edu/cgi-bin/cliMAIN.pl?ca7740
3.1.2 Local Air Quality
The San Diego APCD operates and maintains ten monitoring stations located throughout the region. The purpose of these stations is to measure concentrations of the criteria pollutants and determine whether the ambient air quality meets the NAAQS and the CAAQS. The nearest air monitoring station to the project site is the Camp Pendleton Monitoring Station (Camp Pendleton Station). The C Camp Pendleton Station is located approximately 13 miles southwest of the project site at 21441 W B Street. Table 4 presents the monitored pollutant levels within the vicinity. However, it should be noted that due to the air monitoring station distance from the project site, recorded air pollution levels at the air monitoring station reflect with varying degrees of accuracy, local air quality conditions at the project site. <Table 4, next page>
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24 Table 4: Local Area Air Quality Levels
Year
Pollutant (Standard)2 2020 2021 2022
Ozone:
Maximum 1-Hour Concentration (ppm) 2020 2021 2022
Days > CAAQS (0.09 ppm)
Maximum 8-Hour Concentration (ppm) 0.094 0.074 0.076
Days > NAAQS (0.07 ppm) 0 0 0
Days > CAAQS (0.070 ppm) 0.074 0.059 0.067
Carbon Monoxide: 3 0 0
Maximum 8-Hour Concentration (ppm) 3 0 0
Days > NAAQS (9 ppm)
Nitrogen Dioxide: * * *
Maximum 1-Hour Concentration (ppm) * * *
Days > NAAQS (0.25 ppm)
Sulfur Dioxide: 0.058 0.059 0.050
Maximum 1-Hour Concentration (ppm) 0 0 0
Days > CAAQS (0.25 ppm)
Inhalable Particulates (PM10): * * *
Maximum 24-Hour Concentration (ug/m3) * * *
Days > NAAQS (150 ug/m3)
Days > CAAQS (50 ug/m3) * * *
Annual Average (ug/m3) * * *
Annual > NAAQS (50 ug/m3) * * *
Annual > CAAQS (20 ug/m3) * * *
Ultra-Fine Particulates (PM2.5): * * *
Maximum 24-Hour Concentration (ug/m3) * * *
Days > NAAQS (35 ug/m3)
Annual Average (ug/m3) * * 18.0
Annual > NAAQS (15 ug/m3) * * 0
Annual > CAAQS (12 ug/m3) 9.5 * *
1. Source: obtained from https://www.arb.ca.gov/adam/topfour/topfour1.php 2 CAAQS = California Ambient Air Quality Standard; NAAQS = National Ambient Air Quality Standard; ppm = parts per million * No data and/or insufficient data available.
The monitoring data presented in Table 4 shows that ozone and particulate matter (PM10 and PM2.5) are the air pollutants of primary concern in the project area, which are detailed below.
Ozone
During the 2020 to 2022 monitoring period, the State 1-hour concentration standard for ozone was not exceeded at the Camp Pendleton Station. The State and Federal 8-hour ozone standards have both been exceeded for three days in 2020 over the past three years at the Camp Pendleton Station.
Carbon Monoxide
CO is another important pollutant that is due mainly to motor vehicles. The Camp Pendleton Station did not record an exceedance of the state or federal 1-hour or 8-hour CO standards for the last three years.
Nitrogen Dioxide
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25 The Camp Pendleton Station did not record an exceedance of the State or Federal NO2 standards for the last three years.
Sulfur Dioxide
The Camp Pendleton Station did not record an exceedance of the State SO2 standards for the last three years.
Particulate Matter
The Camp Pendleton Station did not record an exceedance of the State or Federal PM10 or PM2.5 standards for the last three years.
According to the EPA, some people are much more sensitive than others to breathing fine particles (PM10 and PM2.5). People with influenza, chronic respiratory and cardiovascular diseases, and the elderly may suffer worsening illness and premature death due to breathing these fine particles. People with bronchitis can expect aggravated symptoms from breathing in fine particles. Children may experience decline in lung function due to breathing in PM10 and PM2.5. Other groups considered sensitive are smokers and people who cannot breathe well through their noses. Exercising athletes are also considered sensitive, because many breathe through their mouths during exercise.
3.1.3 Attainment Status
The EPA and the ARB designate air basins where ambient air quality standards are exceeded as “nonattainment” areas. If standards are met, the area is designated as an “attainment” area. If there is inadequate or inconclusive data to make a definitive attainment designation, they are considered “unclassified.” National nonattainment areas are further designated as marginal, moderate, serious, severe, or extreme as a function of deviation from standards. Each standard has a different definition, or ‘form’ of what constitutes attainment, based on specific air quality statistics. For example, the Federal 8-hour CO standard is not to be exceeded more than once per year; therefore, an area is in attainment of the CO standard if no more than one 8-hour ambient air monitoring values exceeds the threshold per year. In contrast, the federal annual PM2.5 standard is met if the three-year average of the annual average PM2.5 concentration is less than or equal to the standard.
The criteria pollutants of primary concern that are considered in this analysis are O3, NO2, CO, SO2, PM10, and PM2.5. Although there are no ambient standards for VOCs or NOx, they are important as precursors to O3. The portion of the SDAB where the project site is located is designated by the EPA as a nonattainment area for the 8-hour NAAQS for O3. The SDAB is designated in attainment for all other criteria pollutants under the NAAQS with the exception of PM10, which was determined to be unclassifiable. The SDAB is currently designated nonattainment for O3 and particulate matter, PM10 and PM2.5, under the CAAQS. It is designated attainment for the CAAQS for CO, NO2, SO2, lead, and sulfate Table 5 lists the attainment status for the criteria pollutants in the basin.
Table 5: San Diego County Air Basin Attainment Status
Pollutant Federal Designation State Designation
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26 O3 (1 hour) Attainment1 Nonattainment
O3 (8-hour) Nonattainment Nonattainment
CO Attainment Attainment
PM10 Unclassifiable2 Nonattainment
PM2.5 Attainment Nonattainment
NO2 Attainment Attainment
SO2 Attainment Attainment
Lead Attainment Attainment
Sulfates (No federal standard) Attainment
Hydrogen Sulfide (No federal standard) Unclassified
Visibility-reducing particulates (No federal standard) Unclassified Notes:
Sources:https://www.sandiegocounty.gov/content/sdc/apcd/en/air-quality-planning/attainment-status.html 1 The federal 1-hour standard of 0.12 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 State Implementation Plans. 2 At the time of designation, if the available data do not support a designation of attainment or nonattainment, the area is designated as unclassifiable.
3.2 Greenhouse Gases
Constituent gases of the Earth’s atmosphere, called atmospheric greenhouse gases (GHG), play a critical role in the Earth’s radiation amount by trapping infrared radiation emitted from the Earth’s surface, which otherwise would have escaped to space. Prominent greenhouse gases contributing to this process include carbon dioxide (CO2), methane (CH4), ozone, water vapor, nitrous oxide (N2O), and chlorofluorocarbons (CFCs). This phenomenon, known as the Greenhouse Effect, is responsible for maintaining a habitable climate. Anthropogenic (caused or produced by humans) emissions of these greenhouse gases in excess of natural ambient concentrations are responsible for the enhancement of the Greenhouse Effect and have led to a trend of unnatural warming of the Earth’s natural climate, known as global warming or climate change. Emissions of gases that induce global warming are attributable to human activities associated with industrial/manufacturing, agriculture, utilities, transportation, and residential land uses. Transportation is responsible for 41 percent of the State’s greenhouse gas emissions, followed by electricity generation. Emissions of CO2 and nitrous oxide (NO2) are byproducts of fossil fuel combustion. Methane, a potent greenhouse gas, results from off-gassing associated with agricultural practices and landfills. Sinks of CO2, where CO2 is stored outside of the atmosphere, include uptake by vegetation and dissolution into the ocean. Table 6 provides a description of each of the greenhouse gases and their global warming potential.
Additional information is available: https://www.arb.ca.gov/cc/inventory/data/data.htm Cottonwood & Park
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27 <Table 6 on next page>
Table 6: Description of Greenhouse Gases
Greenhouse Gas Description and Physical Properties Sources Nitrous oxide
Nitrous oxide (N20),also known as laughing gas is a
colorless gas. It has a lifetime of 114 years. Its global warming potential is 298.
Microbial processes in soil and water,
fuel combustion, and industrial
processes. In addition to agricultural
sources, some industrial processes
(nylon production, nitric acid
production) also emit N20.
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28 Methane
Methane (CH4) is a flammable gas and is the main
component of natural gas. It has a lifetime of 12 years.
Its global warming potential is 25.
A natural source of CH4 is from the
decay of organic matter. Methane is
extracted from geological deposits
(natural gas fields). Other sources are
from the decay of organic material in
landfills, fermentation of manure, and
cattle farming.
Carbon dioxide
Carbon dioxide (CO2) is an odorless, colorless, natural greenhouse gas. Carbon dioxide’s global warming
potential is 1. The concentration in 2005 was 379 parts per million (ppm), which is an increase of about 1.4
ppm per year since 1960.
Natural sources include decomposition
of dead organic matter; respiration of
bacteria, plants, animals, and fungus;
evaporation from oceans; and volcanic
outgassing. Anthropogenic sources are
from burning coal, oil, natural gas, and
wood.
Chlorofluorocarbons
CFCs are nontoxic, nonflammable, insoluble, and
chemically unreactive in the troposphere (the level of
air at the earth’s surface). They are gases formed
synthetically by replacing all hydrogen atoms in
methane or methane with chlorine and/or fluorine
atoms. Global warming potentials range from 3,800 to
8,100.
Chlorofluorocarbons were synthesized
in 1928 for use as refrigerants, aerosol
propellants, and cleaning solvents. They
destroy stratospheric ozone, therefore
their production was stopped as
required by the Montreal Protocol.
Hydrofluorocarbons
Hydrofluorocarbons (HFCs) are a group of greenhouse
gases containing carbon, chlorine, and at least one
hydrogen atom. Global warming potentials range from
140 to 11,700.
Hydrofluorocarbons are synthetic
manmade chemicals used as a
substitute for chlorofluorocarbons in
applications such as automobile air
conditioners and refrigerants.
Perfluorocarbons
Perfluorocarbons (PFCs) have stable molecular
structures and only break down by ultraviolet rays
about 60 kilometers above the Earth's surface. They
have a lifetime 10,000 to 50,000 years. They have a
global warming potential range of 6,200 to 9,500.
Two main sources of perfluorocarbons
are primary aluminum production and
semiconductor manufacturing.
Sulfur
hexafluoride
Sulfur hexafluoride (SF6) is an inorganic, odorless,
colorless, and nontoxic, nonflammable gas. It has a
lifetime of 3,200 years. It has a high global warming
potential, 23,900.
This gas is manmade and used for
insulation in electric power
transmission equipment, in the
magnesium industry, in semiconductor
manufacturing, and as a tracer gas for
leak detection.
Notes:
1. Sources: Intergovernmental Panel on Climate Change 2014a and Intergovernmental Panel on Climate Change 2014b. https://www.ipcc.ch/publications_and_data/ar4/wg1/en/ch2s2-10-2.html Cottonwood & Park
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29 4.0 Modeling Parameters and Assumptions
4.1 Construction
Typical emission rates from construction activities were obtained from CalEEMod Version 2022.1.1.22 The CalEEMod program uses the EMFAC2017 computer program to calculate the emission rates specific for the southwestern portion of San Diego County for construction-related employee vehicle trips and the OFFROAD2011 computer program to calculate emission rates for heavy truck operations.
EMFAC2017 and OFFROAD2011 are computer programs generated by CARB that calculates composite emission rates for vehicles. Emission rates are reported by the program in grams per trip and grams per mile or grams per running hour. Using CalEEMod, the peak daily air pollutant emissions were calculated and presented below. These emissions represent the highest level of emissions for each of the construction phases in terms of air pollutant emissions.
The analysis assesses the emissions associated with the construction of the proposed project as indicated in Table 1. Using CalEEMod default timelines for construction phases and the proposed operational date, the proposed project was modeled as beginning construction no earlier than August 2024 and lasting 18 months. The phases of the construction activities which have been analyzed below are: 1) site preparation, 2) grading, 3) building, 4) paving, and 5) architectural coating. CalEEMod default construction equipment counts were used as a basis. Additional hauling trips were added to account for asphalt delivery during paving and were based on a conservative assumption of 65 square feet of coverage per cubic yard of asphalt and 16 cubic yards of asphalt per hauling trip.3It should also be noted the scenario in the current model was based on a previous site plan with 358 units with 716 garage spaces and 126 open spaces, making this a conservative analysis compared to the current site plan of 285 units with 570 garage spaces and 76 open spaces. For details on construction modeling and construction equipment for each phase, please see Appendix A.
The project would be required to comply with SDAPCD Rules 52, 54, and 55 which identify measures to reduce fugitive dust and are required to be implemented at all construction sites located within the SDAB. The requirements to reduce fugitive dust in compliance with SDAPCD Rules 52, 54, and 55 were included in CalEEMod for the grading phase of construction.
The architectural coating phase involves the greatest release of VOCs. The emissions modeling for the project includes the use of low-VOC paint (50 grams per liter [g/L] for not flat coatings for the buildings and 100 [g/L] for parking lot striping) as required by SDAPCD Rule 67.0.1.4 3 Reeves Construction Company. Material Calculator. https://www.reevescc.com/asphalt-calculator/. 4 Rule 67.0.1. Architectural Coatings. Table 2. February 10, 2021. https://www.sdapcd.org/content/dam/sdapcd/documents/rules/rule-archive/2021/Rule-67.0.1.pdf.
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30 4.2 Operations
Operational or long-term emissions occur over the life of the Project. Both mobile and area sources generate operational emissions. Area source emissions arise from consumer product usage, heaters that consume natural gas, gasoline-powered landscape equipment, and architectural coatings (painting).
Mobile source emissions from motor vehicles are the largest single long-term source of air pollutants from the operation of the Project. Small amounts of emissions would also occur from area sources such as the consumption of natural gas for heating, hearths, and consumer product usage. The operational emissions were estimated using the latest version of CalEEMod.
Mobile Sources
Mobile sources include emissions from the additional vehicle miles generated from the proposed project. The vehicle trips associated with the proposed project are based upon the trip generation rates provided by SANDAG’s (Not So) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region (SANDAG 2002). The trip generation shows a rate of 2,368 trips per day.
The program then applies the emission factors for each trip which is provided by the EMFAC2017 model to determine the vehicular traffic pollutant emissions. The CalEEMod default trip lengths were used in this analysis. Please see CalEEMod output comments sections in Appendix A for details.
Area Sources
Area sources include emissions from consumer products, landscape equipment and architectural coatings. Landscape maintenance includes fuel combustion emissions from equipment such as lawn mowers, rototillers, shredders/grinders, blowers, trimmers, chain saws, and hedge trimmers, as well as air compressors, generators, and pumps. As specifics were not known about the landscaping equipment fleet, CalEEMod defaults were used to estimate emissions from landscaping equipment.
The architectural coating phase involves the greatest release of VOCs. The emissions modeling for the project includes the use of low-VOC paint (50 grams per liter [g/L] for not flat coatings for the buildings and 100 [g/L] for parking lot striping) as required by SDAPCD Rule 67.0.1.
Energy Usage
2022.1.1.22 CalEEMod defaults were utilized.
Solid Waste Sources
Solid waste sources include emissions from disposal of solid waste into landfills.
Energy Usage
2022.1.1.22 CalEEMod defaults were utilized. CalEEMod outputs can be found in Appendix A.
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31 5.0 Thresholds of Significance
5.1 Air Quality Thresholds of Significance
5.1.1 CEQA Guidelines for Air Quality
The CEQA Guidelines define a significant effect on the environment as “a substantial, or potentially substantial, adverse change in the environment.” To determine if a project would have a significant impact on air quality, the type, level, and impact of emissions generated by the project must be evaluated.
The following air quality significance thresholds are contained in Appendix G of the CEQA Guidelines. A significant impact would occur if the project would:
a) Conflict with or obstruct implementation of the applicable air quality plan; b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable national or state ambient air quality standard; c) Expose sensitive receptors to substantial pollutant concentrations; or d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.
While the final determination of whether a project is significant is within the purview of the Lead Agency pursuant to Section 15064(b) of the CEQA Guidelines, SDAPCD recommends that its quantitative air pollution thresholds be used to determine the significance of project emissions. If the Lead Agency finds that the project has the potential to exceed these air pollution thresholds, the project should be considered to have significant air quality impacts.
5.1.2 Regional Significance Thresholds
The SDAPCD has established thresholds in Rule 20.2 for new or modified stationary sources. The County’s Guidelines for Determining Significance and Report Format and Content Requirements include screening level thresholds for all County related Air Quality Impact Assessments (AQIA) and for determining CEQA air quality impacts.5 These daily screening thresholds for construction and operations are shown in Table 7 below.
5 https://www.sandiegocounty.gov/content/dam/sdc/pds/ProjectPlanning/docs/AQ-Guidelines.pdf Cottonwood & Park
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32 Table 7: SDAPCD Air Quality Significance Thresholds
Pollutant Total Emissions
Pounds per Hour Pounds Per Day Tons Per Year
VOCs - 100 15
NOx - 55 10*
CO 25 250 40
SOx 25 250 40
PM10 100 550 100
PM2.5 - 3.2 0.6
Lead*- 75** 13.7** *
Notes:
Source: San Diego County. March 2007. County of San Diego Guidelines for Determining Significance and Report Format and Content Requirements: Air Quality. http://www.sandiegocounty.gov/content/dam/sdc/pds/ProjectPlanning/docs/AQ-Guidelines.pdf. *EPA “Proposed Rule to Implement the Fine Particle National Ambient Air Quality Standards” published September 8, 2005. Also used by the SCAQMD.
** Threshold for VOCs based on the threshold of significance for VOCs from the South Coast Air Quality Management District for the Coachella Valley. *** 13.7 Tons Per Year threshold based on 75 lbs/day multiplied by 365 days/year and divided by 2000 lbs/ton.
The thresholds listed above, and in Table 7, represent screening-level thresholds that can be used to evaluate whether project-related emissions could cause a significant impact on air quality. Emissions below the screening-level thresholds would not cause a significant impact. For nonattainment pollutants, if emissions exceed the thresholds shown in Table 7, 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.
With respect to odors, SDAPCD Rule 51 (Public Nuisance) prohibits emission of any material that causes nuisance to a considerable number of persons or endangers the comfort, health, or safety of any person.
A project that 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.
5.2 Greenhouse Gas Thresholds of Significance
5.2.1 CEQA Guidelines for Greenhouse Gas
CEQA Guidelines define a significant effect on the environment as “a substantial, or potentially substantial, adverse change in the environment.” To determine if a project would have a significant impact on greenhouse gases, the type, level, and impact of emissions generated by the project must be evaluated.
The following greenhouse gas significance thresholds are contained in Appendix G of the CEQA Guidelines, which were amendments adopted into the Guidelines on March 18, 2010, pursuant to SB 97. A significant impact would occur if the project would:
(a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; or
(b) Conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases.
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33 However, despite this, currently neither the CEQA statutes, OPR guidelines, nor the draft proposed changes to the CEQA Guidelines prescribe thresholds of significance or a particular methodology for performing an impact analysis; as with most environmental topics, significance criteria are left to the judgment and discretion of the Lead Agency.
No GHG emission thresholds have been adopted by the City for land development projects. The San Diego Air Pollution Control District (SDAPCD) is considered the most appropriate agency with special knowledge in the subject area as the City is located within the SDAPCD jurisdiction. However, the SDAPCD has not issued guidance for assessing GHG impacts from land use development projects. Thus, in the absence of a threshold of significance for GHG emissions for the SDAPCD, as has been done with previous projects in the City, the project is evaluated based on the recommendation from the next closest air district, the South Coast AQMD.
This analysis follows guidance from the South Coast AQMD’s Interim CEQA GHG Significance Thresholds (SCAQMD 2008). South Coast AQMD’s thresholds are a tiered approach; projects may be determined to be less than significant under each tier or require further analysis under subsequent tiers. As identified in the Working Group meeting in September 2010, the five tiers are:
• Tier 1 consists of evaluating whether or not the project qualifies for any applicable exemption under CEQA.
• Tier 2 consists of determining whether or not the project is consistent with a greenhouse gas reduction plan. If a project is consistent with a qualifying local greenhouse gas reduction plan, it does not have significant greenhouse gas emissions.
• Tier 3 consists of screening values, which the lead agency can choose but must be consistent. A project’s construction emissions are averaged over 30 years and are added to a project’s operational emissions. If a project’s emissions are under one of the following screening thresholds, then the project is less than significant:
- All land use types: 3,000 MTCO2e per year
- Based on land use types: residential is 3,500 MTCO2e per year; commercial is 1,400 MTCO2e per year; mixed use is 3,000 MTCO2e per year; and industrial is 10,000 MTCO2e • Tier 4 has the following options:
- Option 1: Reduce emissions from business as usual by a certain percentage; this percentage is currently undefined
- Option 2: Early implementation of applicable AB 32 Scoping Plan measures - Option 3: Year 2020 target for service populations (SP), which includes residents and employees: 4.8 MTCO2e/SP/year for projects and 6.6 MTCO2e/SP/year for plans; - Option 3, 2035 target: 3.0 MTCO2e/SP/year for projects and 4.1 MTCO2e/SP/year for plans
• Tier 5 involves mitigation offsets to achieve target significance threshold.
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34 Tier 1 and Tier 2 thresholds are based on planning consistency. This approach, which is referred to in the CEQA Guidelines as “tiering,” allows agencies to rely on programmatic analysis of GHG emissions to determine that subsequent development consistent with the regional plan would result in incremental GHG emissions contribution that represent a less than significant contribution to cumulative effects.
Tier 3 significance screening levels from SCAQMD guidance are based on the concept of establishing a 90 percent GHG emission market capture rate. A 90 percent emission capture rate means that 90 percent of total emissions from new development projects would be subject to CEQA analysis and mitigation.
The market capture rate of 90 percent was developed to capture a substantial fraction of GHG emissions from new development projects while excluding small projects that will in aggregate contribute a relatively small fraction of the cumulative statewide GHG emissions. This market capture rate approach is based on guidance from the CAPCOA report CEQA & Climate Change, dated January 2008 (CAPCOA 2008). Following rationale presented in the CAPCOA Guidance, the aggregate emissions from all projects with individual annual emissions that are equal to or less than the identified screening levels for 90 percent market capture rate would not impede achievement of the statewide GHG emissions reduction targets.
Tier 4 and Tier 5 interim thresholds are intended to demonstrate project consistency with the AB 32 goal of achieving 1990 emission levels by 2020 and the SB 32 goal of reducing GHG emissions to 40 percent below 1990 levels by 2030.
Therefore, this analysis utilizes SCAQMD’s Tier 4 interpolated threshold of 4.08 MTCO2e/SP/year for all land use types and then, per SCAQMD’s Tier 2 thresholds, assessed in compliance with applicable plans, policies, regulations, and requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions. As a land use development project, the most directly applicable adopted regulatory plan to reduce GHG emissions is the SANDAG’s Regional Plan, which is designed to achieve regional GHG reductions from the land use and transportation sectors as required by SB 375 and the state’s long-term climate goals. This analysis also considers consistency with regulations and requirements adopted by the Scoping Plan and the City’s CAP. Furthermore, the OPR has noted that lead agencies should make a good-faith effort to calculate or estimate GHG emissions from a project.6 Therefore, the GHG emissions have also been quantified below, consistent with OPR guidelines.
As recommended by the Association of Environmental Professionals in the 2016 Final White Paper, construction-related emissions are amortized over a 30-year period in conjunction with the proposed project’s operational emissions (AEP 2016).
5.3 Toxic Air Contaminants
Non criteria pollutants such as Hazardous Air Pollutants (HAPs) or Toxic Air Contaminants (TACs) are also regulated by the SDAPCD. Rule 1200 (Toxic Air Contaminants - New Source Review) adopted on 6 OPR Technical Advisory, page 5.
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35 June 12, 1996, requires evaluation of potential health risks for any new, relocated, or modified emission unit which may increase emissions of one or more toxic air contaminants. The rule requires that projects that could potentially increase cancer risk to between 1 and 10 in one million need to implement toxics best available control technology (T-BACT) or impose the most effective emission limitation, emission control device or control technique to reduce the cancer risk. At no time shall the project increase the cancer risk to over 10 in one million or a health hazard index (chronic and acute) greater than one.
Projects creating cancer risks less than one in one million are not required to implement T-BACT technology.
Therefore, the threshold for toxic air contaminants (TACs) is a maximum incremental cancer risk of 10 per million and a non-cancer (acute and chronic) hazard index of 1.0 or greater. An exceedance to these values would be considered a significant impact.
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36 6.0 Air Quality Emissions Impact
6.1 Construction Air Quality Emissions Impact
The latest version of CalEEMod was used to estimate the construction emissions. The emissions incorporate adherence to SDAPCD Rules 51, 52, 54, 55, 67, and 1200 (as identified in Section 4.1 above).
Adherence to these rules are not considered mitigation measures as the project by default is required to incorporate these rules during construction.
6.1.1 Temporary Construction Emissions
The construction emissions for the project would not exceed the SDAPCD’s screening level thresholds during project construction, as demonstrated in Table 8, and therefore would be considered less than significant. Construction modeling parameters and assumptions can be found in Section 4.1.
Table 8: Estimated Maximum Daily Construction Criteria Air Pollutant Emissions Pollutant Emissions1
Activity VOC NOx CO SO2 PM10 PM2.5
Daily Construction Emissions (pounds/day)
2024 3.80 47.10 35.60 0.12 9.41 5.45
2025 2.74 14.70 31.90 0.04 4.20 1.33
2026 72.43 7.33 10.59 0.01 0.66 0.33
Maximum 72.43 47.10 35.60 0.12 9.41 5.45
SDAPCD Screening Threshold 75 250 550 250 100 55
Exceeds Threshold? No No No No N0 No
Annual Construction Emissions (tons/year)
2024 0.14 1.26 1.43 0.00 0.26 0.11
2025 0.35 1.88 3.83 0.00 0.53 0.17
2026 1.28 0.07 0.14 0.00 0.01 0.01
Maximum 1.28 1.88 3.83 0.00 0.53 0.17
SDAPCD Screening Threshold 13.7 40 100 40 15 10
Exceeds Threshold? No No No No N0 No
Notes:
Source: CalEEMod Version 2022.1.1.22
1 Grading phases incorporate anticipated emissions reductions required by SDAPCD Rules 52, 54, and 55 to reduce fugitive dust. The architectural coating phases incorporate anticipated emissions reductions required by SDAPCD Rule 67.
6.1.2 Construction-Related Toxic Air Contaminant Impact The greatest potential for toxic air contaminant emissions would be related to diesel particulate emissions associated with heavy equipment operations during construction of the proposed project. The Office of Environmental Health Hazard Assessment (OEHHA) has issued the Air Toxic Hot Spots Program Risk Assessment Guidelines and Guidance Manual for the Preparation of Health Risk Assessments, February 2015 to provide a description of the algorithms, recommended exposure variates, cancer and noncancer health values, and the air modeling protocols needed to perform a health risk assessment (HRA) under the Air Toxics Hot Spots Information and Assessment Act of 1987. Hazard identification includes identifying all substances that are evaluated for cancer risk and/or noncancer acute, 8-hour, Cottonwood & Park
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37 and chronic health impacts. In addition, identifying any multi-pathway substances that present a cancer risk or chronic noncancer hazard via non-inhalation routes of exposure.
CARB In-Use Off-Road Diesel-Fueled Fleets Regulation limits unnecessary idling to 5 minutes, requires all construction fleets to be labeled and reported to CARB, bans Tier 0 equipment, and phases out Tier 1 and 2 equipment thereby replacing fleets with cleaner equipment, and requires that fleets comply with Best Available Control Technology requirements.
The SDAPCD recommends a 30-year period for analyzing health risks from TAC emissions. Given the construction schedule of 18 months and the relatively limited number of heavy-duty construction equipment, the proposed Project would not result in a long-term substantial source of toxic air containment emissions and corresponding individual cancer risk. Furthermore, construction-based particulate matter (PM) emissions (including diesel exhaust emissions) do not exceed any regional thresholds. Therefore, no significant short-term toxic air contaminant impacts would occur during construction of the proposed Project.
6.2 Operational Air Quality Emissions Impact
6.2.1 Operational Emissions
The operations-related criteria air quality impacts created by the proposed project have been analyzed through the use of CalEEMod model. The operating emissions were based on year 2026, which is the anticipated opening year for the project. The summer and winter emissions created by the proposed project’s long-term operations were calculated and the highest emissions from either summer or winter are summarized in Table 9. Emissions were modeled according to the parameters and assumptions established in Section 4.2.
Table 9: Estimated Maximum Daily Operational Criteria Air Pollutant Emissions Activity
Pollutant Emissions1
VOC NOx CO SO2 PM10 PM2.5
Daily Operation Emissions (pounds/day)
Area Sources2 12.70 0.30 32.80 0.00 0.03 0.02
Energy Usage3 0.11 1.86 0.79 0.01 0.15 0.15
Mobile Sources4 9.53 7.10 67.10 0.16 14.00 3.63
Total Emissions 22.34 9.26 100.69 0.17 14.18 3.80
SDAPCD Thresholds 75 250 550 250 100 55
Exceeds Threshold? No No No No No No
Annual Operation Emissions (tons/year)
Area Sources2 1.96 0.03 2.95 0.00 0.00 0.00
Energy Usage3 0.02 0.34 0.14 0.00 0.03 0.03
Mobile Sources4 1.68 1.28 11.60 0.03 2.54 0.66
Total Emissions 3.66 1.65 14.69 0.03 2.57 0.69
SDAPCD Thresholds 13.7 40 100 40 15 10
Exceeds Threshold? No No No No N0 No
1 Source: CalEEMod Version 2022.1.1.22
2 Area sources consist of emissions from consumer products, architectural coatings, and landscaping equipment.
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38 3 Energy usage consists of emissions from on-site natural gas usage. 4 Mobile sources consist of emissions from vehicles and road dust.
The data in Table 9 shows that emissions from the operation of the proposed project does not exceed SDAPCD thresholds. Therefore, the impact is considered less than significant.
6.3 CO Hot Spot Emissions
CO is the pollutant of major concern along roadways because the most notable source of CO is motor vehicles. For this reason, CO concentrations are usually indicative of the local air quality generated by a roadway network and are used as an indicator of potential local air quality impacts. Local air quality impacts can be assessed by comparing future without and with project CO levels to the State and Federal CO standards.
The SDAB is classified as a state attainment area and as a federal maintenance area for CO. Until 2003, no violations of the state standard for CO had been recorded in the SDAB since 1991, and no violations of the national standard had been recorded in the SDAB since 1989. The violations that took place in 2003 were likely the result of massive wildfires that occurred throughout the county. No violations of the state or federal CO standards have occurred since 2003.
Small-scale, localized concentrations of CO above the state and national standards have the potential to occur at intersections with stagnation points such as those that occur on major highways and heavily traveled and congested roadways. Localized high concentrations of CO are referred to as “CO hot spots” and are a concern at congested intersections, where automobile engines burn fuel less efficiently and their exhaust contains more CO.
Localized CO concentration is a direct function of motor vehicle activity at signalized intersections (e.g., idling time and traffic flow conditions), particularly during peak commute hours and meteorological conditions. The SDAB is a CO maintenance area under the federal CAA. This means that SDAB was previously a non-attainment area and is currently implementing a 10-year plan for continuing to meet and maintain air quality standards.
The SDAB is a CO maintenance area (western and central part of the SDAB only). As a screening analysis, the SCAQMD conducted CO modeling for the 2003 AQMP (Appendix V: Modeling and Attainment Demonstrations, SCAQMD 2003) for the four worst-case intersections in the SCAB: (1) Wilshire Boulevard and Veteran Avenue, (2) Sunset Boulevard and Highland Avenue, (3) La Cienega Boulevard and Century Boulevard, and (4) 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. Using CO emission factors for 2002, the peak modeled CO 1-hour concentration was estimated to be 4.6 ppm at the intersection of Wilshire Boulevard and Veteran Avenue. The 2003 AQMP also 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 ppm at the Sunset Boulevard and Highland Avenue intersection in 2002; the maximum 8-hour CO concentration was 3.4 ppm at the Wilshire Boulevard and Veteran Avenue in 2002. Therefore, an intersection would need over Cottonwood & Park
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39 200,000 vehicles per day to exceed the 8-hour CO CAAQS (9.0 ppm) or 400,000 vehicles per day to exceed 1-hour CO CAAQS (20 ppm).
Accordingly, CO concentrations at congested intersections would not exceed the 8-hour CO CAAQS if projected daily traffic would generate less than 200,000 vehicles per day or the 1-hour CO CAAQS for less than 400,000 vehicles per day. The proposed project is anticipated to generate approximately 2,368 vehicle trips per day. Therefore, the proposed project would not be anticipated to increase daily traffic volumes at any study intersection to more than 200,000 vehicles per day, a CO hotspot is not anticipated to occur and associated impacts would be less than significant.
6.4 Odors
SDAPCD Rule 51, commonly referred to as the public nuisance rule, prohibits emissions from any source whatsoever in such quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance to the public health or damage to property. The potential for an operation to result in odor complaints from a “considerable” number of persons in the area would be considered to be a significant, adverse odor impact.
Potential sources that may emit odors during construction activities include the application of materials such as asphalt pavement. The objectionable odors that may be produced during the construction process are of short-term in nature and the odor emissions are expected cease upon the drying or hardening of the odor producing materials. Diesel exhaust and VOCs would be emitted during construction of the project, which are objectionable to some; however, emissions would disperse rapidly from the project site and therefore should not reach an objectionable level at the nearest sensitive receptors. Furthermore, construction emissions would not exceed SDAPCD thresholds. Due to the shortterm nature and limited amounts of odor producing materials being utilized, no significant impact related to odors would occur during construction of the proposed project.
Land uses and operations typically associated with odor complains include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, refineries, landfills, dairies, and fiberglass molding. The anticipated uses for the proposed residential use are not typically associated with objectionable odors. Therefore, no significant impact related to odors would occur during the on-going operations of the proposed project.
6.5 Cumulative Regional Air Quality Impacts
Cumulative projects include local development as well as general growth within the project area.
However, as with most development, the greatest source of emissions is from mobile sources, which travel well out of the local area. Therefore, from an air quality standpoint, the cumulative analysis would extend beyond any local projects and when wind patterns are considered, would cover an even larger area. Accordingly, the cumulative analysis for the project’s air quality must be generic by nature.
The project area is out of attainment for O3 for federal standards and O3, PM10, and PM2.5 for state standards. Construction and operation of cumulative projects will further degrade the local air quality, as well as the air quality of the SDAB. As discussed previously, the construction related emissions will be Cottonwood & Park
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40 below the SDAPCD significance levels utilized by the City and would not result in significant impacts to air quality. Construction will be short-term and consistent with the size and scale of the project.
Construction of the project will potentially be conducted at the same time and in the same general vicinity as other major construction projects; however, in accordance with the SDAPCD methodology, projects that do not exceed the SDAPCD criteria or can be mitigated to less than criteria levels are not significant and do not add to the overall cumulative impact. The project does not exceed any of the thresholds of significance and therefore is not considered to contribute to a significant cumulative impact on air quality.
Furthermore, the project will not contribute to any cumulative odor impacts through compliance with SDAPCD Rule 51 which prohibits emissions from a project that would cause injury, detriment, nuisance, or annoyance to the public health or damage to property, as discussed in Section 6.4.
As stated earlier, the RAQS relies on SANDAG growth projections based on population, vehicle trends, and land use plans developed by the cities and by the county as part of the development of their general plans. It is assumed that a project which conforms to the General Plan, and does not have emissions exceeding operational thresholds discussed in Section 5.1, will not create a cumulatively considerable net increase to ozone since the emissions were accounted for in the RAQS. The project site has a land use designation of Residential according to the City of Santee Town Center Specific Plan. Therefore, the project would be consistent with the existing general plan and zoning for the City of Santee; therefore, the project would be considered consistent with the RAQS. Furthermore, operational emissions generated by the project would be below the established significance thresholds for criteria pollutants as shown in Table 9, and the project’s operational emissions would not result in a cumulatively considerable contribution to the region’s poor air quality. Cumulative air quality impacts would, therefore, be less than significant.
6.6 Air Quality Compliance
The California Environmental Quality Act (CEQA) requires a discussion of any inconsistencies between a proposed project and applicable General Plans and Regional Plans (CEQA Guidelines Section 15125). The regional plan that applies to the proposed project includes the RAQS. Therefore, this section discusses any potential inconsistencies of the proposed project with the RAQS.
The purpose of this discussion is to set forth the issues regarding consistency with the assumptions and objectives of the RAQS and discuss whether the proposed project would interfere with the region’s ability to comply with Federal and State air quality standards. If the decision-makers determine that the proposed project is inconsistent, the lead agency may consider project modifications or inclusion of mitigation to eliminate the inconsistency.
The RAQS relies on information from CARB and SANDAG, including projected growth in the County, mobile, area, and all other source emissions in order to project future emissions and determine strategies necessary for the reduction of stationary source emissions. Those projects that propose development that is consistent with the City’s General Plan are; therefore, consistent with the RAQS.
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41 7.0 Greenhouse Gas Impact Analysis
7.1 Construction Greenhouse Gas Emissions Impact
The greenhouse gas emissions from project construction equipment and worker vehicles are shown in Table 10. The emissions are from all phases of construction. Construction-related emissions are amortized over a 30-year period in conjunction with the proposed project’s operational emissions as recommended by Association of Environmental Processionals (AEP 2016).
The total construction emissions amortized over a period of 30 years are estimated at 46.2 metric tons of CO2e per year. Annual CalEEMod output calculations are provided in Appendix A.
Table 10: Estimated Annual Construction Greenhouse Gas Emissions Year
Metric Tons Per Year
Bio-CO2 NBio-CO2 Total CO2 CH4 N20 CO2e (MT)
2024 0.00 414.00 414.00 0.02 0.03 424.00
2025 0.00 920.00 920.00 0.04 0.05 938.00
2026 0.00 23.60 23.60 0.00 0.00 23.90
Total 0.00 1357.60 1357.60 0.06 0.08 1385.90
Amortized Construction Emissions 46.20
Notes:
1. MTCO2e=metric tons of carbon dioxide equivalents (includes carbon dioxide, methane and nitrous oxide).
2. The emissions are averaged over 30 years.
* CalEEMod output (Appendix A)
7.2 Operational Greenhouse Gas Emissions Impact
Operational emissions occur over the life of the project. Table 11 shows that the total for the proposed project’s emissions (baseline emissions without credit for any reductions from sustainable design and/or regulatory requirements) would be 3,852.4 metric tons of CO2e per year or 3.90 metric tons of CO2e per year per Service Population. Therefore, as the total emissions for the proposed project would not exceed the SCAQMD draft Tier 4 interpolated 2026 threshold of 4.08 MT of CO2e per year, impacts are considered to be less than significant.
Table 11: Opening Year Project-Related Greenhouse Gas Emissions Category
Greenhouse Gas Emissions (Metric Tons/Year)1
Bio-CO2 NonBio-CO2 CO2 CH4 N2O R CO2e
Area Sources2 0.00 8.62 8.62 0.00 0.00 0.00 8.65
Energy Usage3 0.00 1,083.00 1,083.00 0.07 0.01 0.00 1,087.00 Mobile Sources4 0.00 2,592.00 2,592.00 0.13 0.11 3.89 2,632.00 Solid Waste5 23.60 0.00 23.60 2.36 0.00 0.00 82.70
Water6 3.99 24.40 28.39 0.41 0.01 0.00 41.60
Refrigerants 0.00 0.00 0.00 0.00 0.00 0.45 0.45
Subtotal Emissions 27.59 3,708.02 3,735.61 2.97 0.13 4.34 3,852.40 Amortized Construction Emissions 46.20
Total Emissions 3,898.60
Service Population 999.00
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42 Total Emissions per Service Population (MTCO2e/yr/SP) 3.90 2026 Interpolated Threshold (MTCO2e/yr/SP) 4.08
Exceeds Threshold? No
Notes:
1 Source: CalEEMod Version 2022.1.1.22
2 Area sources consist of GHG emissions from consumer products, architectural coatings, and landscape equipment. 3 Energy usage consists of GHG emissions from electricity and natural gas usage. 4 Mobile sources consist of GHG emissions from vehicles. 5 Solid waste includes the CO2 and CH4 emissions created from the solid waste placed in landfills. 6 Water includes GHG emissions from electricity used for transport of water and processing of wastewater. 7 Construction GHG emissions based on a 30 year amortization rate.
7.3 Greenhouse Gas Plan Consistency
The proposed project could have the potential to conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases. The project’s GHG impacts are evaluated by assessing the project’s consistency with applicable statewide, regional, and local GHG reduction plans and strategies.
The Office of Planning and Research (OPR) encourages lead agencies to make use of programmatic mitigation plans and programs from which to tier when they perform individual project analyses. The City has adopted the City of Santee CAP which encourages and requires applicable projects to implement energy efficiency measures. In addition, the California Climate Action Team (CAT) Report provides recommendations for specific emission reduction strategies for reducing GHG emissions and reaching the targets established in AB 32 and Executive Order S-3-05. On a statewide level, the 2008 Climate Change Scoping Plan provides measures to achieve AB 32 targets. On a regional level, the SANDAG’s Regional Plan contains measures to achieve VMT reductions required under SB 375. Thus, if the project complies with these plans, policies, regulations, and requirements, the project would result in a less than significant impact because it would be consistent with the overarching state, regional, and local plans for GHG reduction.
A consistency analysis is provided below and describes the project’s compliance with or exceedance of performance-based standards included in the regulations outlined in the applicable portions of the 2008 and 2017 Climate Change Scoping Plan, and SANDAG’s Regional Plan.
Consistency with SANDAG’s San Diego Forward: the Regional Plan Regarding consistency with SANDAG’s Regional Plan, the proposed project would include site design elements and project design features developed to support the policy objectives of the RTP and SB 375.
Table 12 illustrates the proposed project’s consistency with all applicable goals and policies of the Regional Plan (SANDAG 2021).
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43 Table 12: Project Consistency with San Diego Forward: The Regional Plan1 Category Policy Objective or Strategy Consistency Analysis The Regional Plan - Policy Objectives
Mobility Choices
Provide safe, secure, healthy, affordable,
and convenient travel choices between
the places where people live, work, and
play.
Consistent. The proposed project is
be located near bus routes and
within a quarter mile of a YMCA.
Mobility Choices
Take advantage of new technologies to
make the transportation system more
efficient and environmentally friendly.
Not applicable. The proposed
project would not impair
SANDAG’s ability to employ new
technologies to make travel more
reliable and convenient.
Habitat and Open Space
Preservation
Focus growth in areas that are already
urbanized, allowing the region to set aside
and restore more open space in our less
developed areas.
Consistent. The proposed project is
surrounded by existing commercial
and residential development and
would be located close to major
urban centers.
Habitat and Open Space
Preservation
Protect and restore our region’s urban
canyons, coastlines, beaches, and water
resources.
Not Applicable. The proposed
project would not impair the
ability of SANDAG to protect and
restore urban canyons, coastlines,
beaches, and water resources.
Furthermore, the proposed project
is located in an already developed
area.
Regional Economic Prosperity
Invest in transportation projects that
provide access for all communities to a
variety of jobs with competitive wages.
Not Applicable. The proposed
project would not impair the
ability of SANDAG to invest in
transportation projects available to
all members of the Community.
Regional Economic Prosperity
Build infrastructure that makes the
movement of freight in our community
more efficient and environmentally
friendly.
Not Applicable. The proposed
project would not impair the
ability of SANDAG to make the
movement of freight in the
community more efficient and
environmentally friendly.
Partnerships/Collaboration
Collaborate with Native American tribes,
Mexico, military bases, neighboring
counties, infrastructure providers, the
private sector, and local communities to
design a transportation system that
connects to the mega‐region and national
network, works for everyone, and fosters
a high quality of life for all.
Not Applicable. The proposed
project would not impair the
ability of SANDAG to provide
transportation choices to better
connect the San Diego region with
Mexico, neighboring counties, and
tribal nations.
Partnerships/Collaboration
As we plan for our region, recognize the
vital economic, environmental, cultural,
and community linkages between the San
Diego region and Baja California.
Not Applicable. The proposed
project would not impair the
ability of SANDAG to provide
transportation choices to better
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44 connect the San Diego region with
Mexico.
Healthy and Complete Communities Create great places for everyone to live, work, and play.
Consistent. The proposed project is
a residential project with a current
land use designation of residential
according to the City of Santee
Town Center Specific Plan. The
proposed project is be located
near bus routes and within a
quarter mile of a YMCA.
Healthy and Complete Communities
Connect communities through a variety of
transportation choices that promote
healthy lifestyles, including walking and
biking.
Consistent. The proposed project is
a residential project located near
bus routes. The project site is also
surrounded by existing commercial
and residential uses.
Environmental Stewardship
Make transportation investments that
result in cleaner air, environmental
protection, conservation, efficiency, and
sustainable living.
Consistent. The proposed project is
a residential project located near
bus routes and a YMCA.
Environmental Stewardship Support energy programs that promote sustainability.
Consistent. The proposed project
would be in compliance with the
current building standards.
Sustainable Communities Strategy - Strategies
Strategy Number 1
Focus housing and job growth in urbanized
areas where there is existing and planned
transportation infrastructure, including
transit.
Consistent. The proposed project
would be located close to major
urban centers as it is located near
bus routes and is surrounded by
existing commercial and
residential development.
Strategy Number 2
Protect the environment and help ensure
the success of smart growth land use
policies by preserving sensitive habitat,
open space, cultural resources, and
farmland.
Consistent. The proposed project
would be located close to major
urban centers as it is located near
bus routes and is surrounded by
existing commercial and
residential development.
Strategy Number 3
Invest in a transportation network that
gives people transportation choices and
reduces greenhouse gas emissions.
Consistent. The proposed project is
a residential project located near
bus routes.
Strategy Number 4 Address the housing needs of all economic segments of the population.
Not Applicable. The proposed
project would not impair the
ability of SANDAG to address
housing needs of all economic
segments of the population.
Strategy Number 5 Implement the Regional Plan through
incentives and collaboration.
Not Applicable. The proposed
project would not impair the
ability of SANDAG to implement
the Regional Transportation Plan
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45 through incentives and
collaborations.
Notes:
MTS = San Diego Metropolitan Transit System; SANDAG = San Diego Association of Governments. 1 Source: SANDAG, 2021.
As shown in Table 12, the proposed project is consistent with all applicable Regional Plan Policy Objectives or Strategies. Impacts would be less than significant.
CARB Scoping Plan Consistency
The ARB Board approved a Climate Change Scoping Plan in December 2008. The Scoping Plan outlines the State’s strategy to achieve the 2020 greenhouse gas emissions limit. The Scoping Plan “proposes a comprehensive set of actions designed to reduce overall greenhouse gas emissions in California, improve our environment, reduce our dependence on oil, diversify our energy sources, save energy, create new jobs, and enhance public health” (California Air Resources Board 2008). The measures in the Scoping Plan have been in place since 2012.
In November 2017, CARB release the 2017 Scoping Plan. This Scoping Plan incorporates, coordinates, and leverages many existing and ongoing efforts and identifies new policies and actions to accomplish the State’s climate goals, and includes a description of a suite of specific actions to meet the State’s 2030 GHG limit. In addition, Chapter 4 provides a broader description of the many actions and proposals being explored across the sectors, including the natural resources sector, to achieve the State’s mid and longterm climate goals.
Guided by legislative direction, the actions identified in the 2017 Scoping Plan reduce overall GHG emissions in California and deliver policy signals that will continue to drive investment and certainty in a low carbon economy. The 2017 Scoping Plan builds upon the successful framework established by the Initial Scoping Plan and First Update, while identifying new, technologically feasible, and cost-effective strategies to ensure that California meets its GHG reduction targets in a way that promotes and rewards innovation, continues to foster economic growth, and delivers improvements to the environment and public health, including in disadvantaged communities. The Plan includes policies to require direct GHG reductions at some of the State’s largest stationary sources and mobile sources. These policies include the use of lower GHG fuels, efficiency regulations, and the Cap-and Trade Program, which constrains and reduces emissions at covered sources.
As the latest, 2017 Scoping Plan builds upon previous versions, project consistency with applicable strategies of both the 2008 and 2017 Plan are assessed in Table 13. As shown in Table 13, the project is consistent with the applicable strategies and would result in a less than significant impact.
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46 Table 13: Project Consistency with CARB Scoping Plan Policies and Measures1 2008 Scoping Plan Measures to Reduce Greenhouse Gas
Emissions Project Compliance with Measure
California Light-Duty Vehicle Greenhouse Gas Standards – Implement adopted standards and planned second phase of the program. Align zero-emission vehicle, alternative and renewable fuel and vehicle technology programs with long-term climate change goals.
Consistent. These are CARB enforced standards;
vehicles that access the project that are
required to comply with the standards will
comply with the strategy.
Energy Efficiency – Maximize energy efficiency building and appliance standards; pursue additional efficiency including new technologies, policy, and implementation mechanisms. Pursue comparable investment in energy efficiency from all retail providers of electricity in California.
Consistent. The project will be compliant with
the current Title 24 standards.
Low Carbon Fuel Standard – Develop and adopt the Low Carbon Fuel Standard.
Consistent. These are CARB enforced standards;
vehicles that access the project that are
required to comply with the standards will
comply with the strategy.
Vehicle Efficiency Measures – Implement light-duty vehicle efficiency measures.
Consistent. These are CARB enforced standards;
vehicles that access the project that are
required to comply with the standards will
comply with the strategy.
Medium/Heavy-Duty Vehicles – Adopt medium and heavy-duty vehicle efficiency measures.
Consistent. These are CARB enforced standards;
vehicles that access the project that are
required to comply with the standards will
comply with the strategy.
Green Building Strategy – Expand the use of green building practices to reduce the carbon footprint of California’s new and existing inventory of buildings.
Consistent. The California Green Building
Standards Code (proposed Part 11, Title 24) was
adopted as part of the California Building
Standards Code in the CCR. Part 11 establishes
voluntary standards, that are mandatory in the
2022 edition of the Code, on planning and
design for sustainable site development, energy
efficiency (in excess of the California Energy
Code requirements), water conservation,
material conservation, and internal air
contaminants. The project will be subject to
these mandatory standards.
High Global Warming Potential Gases – Adopt measures to reduce high global warming potential gases.
Consistent. CARB identified five measures that
reduce HFC emissions from vehicular and
commercial refrigeration systems; vehicles that
access the project that are required to comply
with the measures will comply with the
strategy.
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47 Recycling and Waste – Reduce methane emissions at landfills.
Increase waste diversion, composting, and commercial recycling.
Move toward zero-waste.
Consistent. The state is currently developing a
regulation to reduce methane emissions from
municipal solid waste landfills. The project will
be required to comply with City programs, such
as any City recycling and waste reduction
programs, which comply, with the 75 percent
reduction required by 2020 per AB 341.
Water – Continue efficiency programs and use cleaner energy sources to move and treat water.
Consistent. The project will comply with all
applicable City ordinances and CAL Green
requirements.
2017 Scoping Plan Recommended Actions to Reduce
Greenhouse Gas Emissions
Project Compliance with Recommended Action
Implement Mobile Source Strategy: Further increase GHG
stringency on all light-duty vehicles beyond existing Advanced Clean Car regulations.
Consistent. These are CARB enforced standards;
vehicles that access the project that are
required to comply with the standards will
comply with the strategy.
Implement Mobile Source Strategy: At least 1.5 million zero emission and plug-in hybrid light-duty electric vehicles by 2025 and at least 4.2 million zero emission and plug-in hybrid light-duty electric vehicles by 2030.
Consistent. These are CARB enforced standards;
vehicles that access the project that are
required to comply with the standards will
comply with the strategy.
Implement Mobile Source Strategy: Innovative Clean Transit:
Transition to a suite of to-be-determined innovative clean transit options. Assumed 20 percent of new urban buses purchased beginning in 2018 will be zero emission buses with the
penetration of zero-emission technology ramped up to 100 percent of new sales in 2030. Also, new natural gas buses, starting in 2018, and diesel buses, starting in 2020, meet the optional heavy-duty low-NOX standard.
Consistent. These are CARB enforced standards;
vehicles that access the project that are
required to comply with the standards will
comply with the strategy.
Implement Mobile Source Strategy: Last Mile Delivery: New regulation that would result in the use of low NOX or cleaner engines and the deployment of increasing numbers of zeroemission trucks primarily for class 3-7 last mile delivery trucks in California. This measure assumes ZEVs comprise 2.5 percent of new Class 3–7 truck sales in local fleets starting in 2020, increasing to 10 percent in 2025 and remaining flat through 2030.
Consistent. These are CARB enforced standards;
vehicles that access the project that are
required to comply with the standards will
comply with the strategy.
Implement SB 350 by 2030: Establish annual targets for statewide energy efficiency savings and demand reduction that will achieve a cumulative doubling of statewide energy efficiency savings in electricity and natural gas end uses by 2030.
Consistent. The project will be compliant with
the current Title 24 standards.
By 2019, develop regulations and programs to support organic waste landfill reduction goals in the SLCP and SB 1383.
Consistent. The project will be required to
comply with City programs, such as any City
recycling and waste reduction programs, which
comply, with the 75 percent reduction required
by 2020 per AB 341.
Notes:
1 Source: CARB Scoping Plan (2008 and 2017)
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48 Sustainable Santee Plan Consistency Analysis
The focus of the SSP included promoting energy- and water-efficient buildings, smart growth and clean transit, zero waste policies, and increased local energy generation and water resources. Table 14 summarizes reduction strategies from the SSP and evaluates project consistency with each strategy. The project would be consistent with all applicable SSP reduction strategies; therefore, the project would not conflict with the SSP.
Table 14: Sustainable Santee Plan Consistency Analysis
Measure Project Consistency
Goal 1. Increase Energy Efficiency in Existing Residential Units Not applicable. The project is a new development.
Goal 2. Increase Energy Efficiency in the New Residential Units Measure 2.1. New residential construction meet or exceed California Green Building Standards Tier 2 Voluntary Measures, such as obtaining green building ratings including LEED, Build it Green, or Energy Star Certified building certifications in scoring development and explain the measures implemented.
Consistent. The project will meet California
Green Building Standards Tier 2 Voluntary
Measures.
Goal 3: Increase Energy Efficiency in Existing Commercial Units Not applicable. The project is a residential development.
Goal 4: Increase Energy Efficiency in New Commercial Units Not applicable. The project is a residential development.
Goal 5: Decrease Energy Demand through Reducing Urban Heat Island Effect Measure 5.1. Tree Planting for Shading and Energy Efficiency Consistent. The project will comply with all City regulations regarding tree planting.
Measure 5.2. Light-reflecting Surfaces for Energy Efficiency Consistent. While this measure is regarding
commercial and municipal buildings, the
project will comply with all City regulations
regarding cool roofs for residential
buildings.
Goal 6. Decrease GHG Emissions through a Reduction in VMT Measure 6.1. Proposed project streets include sidewalks, crosswalks, and other infrastructure that promotes non‐motorized transportation options Consistent. The project would include
sidewalks and crosswalks and would
connect to existing pedestrian networks
and an existing park.
Measure 6.2. Proposed project installs bike paths to improve bike transit.
Consistent. The project will install the River
Trail along the southern portion of the
project site that will connect existing
portions of the River Trail west and east of
the projects site allowing for efficient bike
travel in the project vicinity.
Goal 7: Increase Use of Electric Vehicles
Measure 7.1. Install electric vehicle chargers in all new residential and commercial developments.
b. For new Multifamily Residential, install e‐chargers for 13 percent of total parking.
Consistent. The project will install at least
install e‐chargers for 13 percent of total
parking.
Goal 8. Improve Traffic Flow
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49 Measure 8.1. Implement traffic flow improvement program. a. Install smart traffic signals at intersections warranting a traffic signal, OR
b. Install roundabout.
Not applicable. The project will not require
the installation of traffic signals or
roundabouts.
Goal 9: Decrease GHG Emissions through Reducing Solid Waste Generation Measure 9.1. Reduce waste at landfills.
Consistent. The project will comply with the
requirement in AB-341 to reduce waste to
landfills by 75%.
Goal 10. Decrease GHG Emissions through Increased Clean Energy Use Measure 10.1. Increase distributed energy generation within City of Santee by implementing the following applicable photovoltaic solar systems:
b. Multifamily residential to install at least 1kW per unit of PV solar systems, unless the installation is infeasible due to poor solar resources established in a solar feasibility study prepared by a qualified solar consultant submitted with an applicant’s formal project submittal to City.
Consistent. The project will comply with the
2022 Energy Code requiring all residential
uses to include solar.
Therefore, the project will not conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases. Impacts are considered to be less than significant.
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50 8.0 Energy Analysis
Information from the CalEEMod 2022.1.1.22 Daily and Annual Outputs contained in the air quality and greenhouse gas analyses above was utilized for this analysis. The CalEEMod outputs detail project related construction equipment, transportation energy demands, and facility energy demands.
8.1 Construction Energy Demand
8.1.1 Construction Equipment Electricity Usage Estimates Electrical service will be provided by SDG&E. Based on the 2017 National Construction Estimator, Richard Pray (2017)7, the typical power cost per 1,000 square feet of building construction per month is estimated to be $2.32. The project plans to develop the site with 458,530 square feet of new residential structures over the course of approximately 18 months. Based on Table 15, the total power cost of the on-site electricity usage during the construction of the proposed project is estimated to be approximately $19,148.21. As shown in Table 15, the total electricity usage from Project construction related activities is estimated to be approximately 348,149 kWh.8 Table 15: Project Construction Power Cost and Electricity Usage Power Cost (per 1,000 square
foot of building per month of
construction)
Total Building
Size (1,000
Square Foot)1
Construction
Duration
(months)
Total Project
Construction
Power Cost
$2.32 458.530 18 $19,148.21
Cost per kWh
Total Project Construction
Electricity Usage (kWh)
$0.24 348,149
*Assumes the project will be under Schedule TOU-A rate under SDG&E and, to be conservative, uses the lower anticipated cost per kWh. Source: https://www.sdge.com/sites/default/files/regulatory/3-1- 21%20Small%20Commercial%20Total%20Rates%20Table.pdf
7 Pray, Richard. 2017 National Construction Estimator. Carlsbad: Craftsman Book Company, 2017. 8 Assumes the project will be under Schedule TOU-A rate under SDG&E and, to be conservative, uses the lower anticipated cost per kWh. Source: https://www.sdge.com/sites/default/files/regulatory/3 -1-21%20Small%20Commercial%20Total%20Rates%20Table.pdf Cottonwood & Park
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51 8.1.2 Construction Equipment Fuel Estimates
Using the CalEEMod data input, the project’s construction phase would consume electricity and fossil fuels as a single energy demand, that is, once construction is completed their use would cease. CARB’s 2017 Emissions Factors Tables show that on average aggregate fuel consumption (gasoline and diesel fuel) would be approximately 18.5 hp-hr-gal.9 As presented in Table 16 below, project construction activities would consume an estimated 41,824 gallons of diesel fuel.
Table 16: Construction Equipment Fuel Consumption Estimates Phase
Number
of Days Offroad Equipment Type Amount
Usage
Hours
Horse
Power
Load
Factor
HP
hrs/
day
Total Fuel
Consumption
(gal diesel
fuel)1
Site
Preparation
10 Rubber Tired Dozers 3 8 367 0.4 3,523 1,904
10 Tractors/Loaders/Backhoes 4 8 84 0.37 995 538
Grading
30 Excavators 2 8 36 0.38 219 355
30 Graders 1 8 148 0.41 485 787
30 Rubber Tired Dozers 1 8 367 0.4 1,174 1,904
30 Scrapers 2 8 84 0.4 538 872
30 Tractors/Loaders/Backhoes 2 8 84 0.37 497 806
Building
Construction
300 Cranes 1 7 367 0.29 745 12,081
300 Forklifts 3 8 82 0.2 394 6,383
300 Generator Sets 1 8 14 0.74 83 1,344
300 Tractors/Loaders/Backhoes 3 7 84 0.37 653 10,584
300 Welders 1 8 46 0.45 166 2,685
Paving
20 Pavers 2 8 81 0.42 544 588
20 Paving Equipment 2 8 89 0.36 513 554
20 Rollers 2 8 36 0.38 219 237
Architectural
Coating 35 Air Compressors 1 6 37 0.48 107 202
CONSTRUCTION FUEL DEMAND (gallons of diesel fuel) 41,824 Notes:
1Using Carl Moyer Guidelines Table D-21 Fuel consumption rate factors (bhp-hr/gal) for engines less than 750 hp. (Source: https://www.arb.ca.gov/msprog/moyer/guidelines/2017gl/2017_gl_appendix_d.pdf) 9 Aggregate fuel consumption rate for all equipment was estimated at 18.5 hp -hr/day (from CARB’s 2017 Emissions Factors Tables and fuel consumption rate factors as shown in Table D-21 of the Moyer Guidelines:
(https://www.arb.ca.gov/msprog/moyer/guidelines/2017gl/2017_gl_appendix_d.pdf).
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52 8.1.3 Construction Worker Fuel Estimates
It is assumed that all construction worker trips are from light duty autos (LDA) along area roadways. With respect to estimated VMT, the construction worker trips would generate an estimated 1,405,452 VMT.
Vehicle fuel efficiencies for construction workers were estimated in the air quality and greenhouse gas analysis using information generated using CARB’s EMFAC model (see Appendix C for details). Table 17 shows that an estimated 45,410.4 gallons of fuel would be consumed for construction worker trips.
Table 17: Construction Worker Fuel Consumption Estimates Phase
Number of
Days
Worker
Trips/Day
Trip Length
(miles)
Vehicle
Miles
Traveled
Average
Vehicle Fuel
Economy
(mpg)
Estimated Fuel
Consumption
(gallons)
Site Preparation 10 17.50 12 2,100 30.95 67.9
Grading 30 20.00 12 7,200 30.95 232.6
Building Construction 300 378.00 12 1,360,800 30.95 43,967.7 Paving 20 15.00 12 3,600 30.95 116.3
Architectural Coating 35 75.60 12 31,752 30.95 1,025.9
Total Construction Worker Fuel Consumption 45,410.4
Notes:
1Assumptions for the worker trip length and vehicle miles traveled are consistent with CalEEMod 2022.1.1.22 defaults.
8.1.4 Construction Vendor/Hauling Fuel Estimates
Tables 18 and 19 show the estimated fuel consumption for vendor and hauling during building construction and architectural coating. With respect to estimated VMT, the vendor and hauling trips would generate an estimated 270,786 VMT. For the architectural coatings it is assumed that the contractors would be responsible for bringing coatings and equipment with them in their light duty vehicles.10 Tables 18 and 19 show that an estimated 32,362 gallons of fuel would be consumed for vendor and hauling trips.
<Tables 18 and 19, next page>
10 Vendors delivering construction material or hauling debris from the site during grading would use medium to heavy duty vehicl es with an average fuel consumption of 9.22 mpg for medium heavy -duty trucks and 6.74 mpg for heavy heavy-duty trucks (see Appendix B for details).
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53 Table 18: Construction Vendor Fuel Consumption Estimates (MHD Trucks)1 Phase
Number of
Days
Vendor
Trips/Day
Trip Length
(miles)
Vehicle
Miles
Traveled
Average
Vehicle Fuel
Economy
(mpg)
Estimated Fuel
Consumption
(gallons)
Site Preparation 10 0.00 7.63 0 9.22 0
Grading 30 0.00 7.63 0 9.22 0
Building Construction 300 85.20 7.63 195,023 9.22 21,152 Paving 20 5.00 7.63 763 9.22 83
Architectural Coating 35 0.00 7.63 0 9.22 0
Total Vendor Fuel Consumption 21,235
Notes:
1 Assumptions for the vendor trip length and vehicle miles traveled are consistent with CalEEMod 2022.1.1.22 defaults.
Table 19: Construction Hauling Fuel Consumption Estimates (HHD Trucks)1 Phase
Number of
Days
Hauling
Trips/Day
Trip Length
(miles)
Vehicle
Miles
Traveled
Average
Vehicle Fuel
Economy
(mpg)
Estimated Fuel
Consumption
(gallons)
Site Preparation 10 0 20 0 6.74 0
Grading 30 125.0 20 75,000 6.74 11,128
Building Construction 300 0 20 0 6.74 0
Paving 20 0 20 0 6.74 0
Architectural Coating 35 0 20 0 6.74 0
Total Construction Hauling Fuel Consumption 11,128
Notes:
1Assumptions for the hauling trip length and vehicle miles traveled are consistent with CalEEMod 2022.1.1.22 defaults.
8.1.5 Construction Energy Efficiency/Conservation Measures Construction equipment used over the approximately 18-month construction phase would conform to CARB regulations and California emissions standards and is evidence of related fuel efficiencies. In addition, the CARB Airborne Toxic Control Measure limits idling times of construction vehicles to no more than five minutes, thereby minimizing unnecessary and wasteful consumption of fuel due to unproductive idling of construction equipment. Furthermore, the project has been designed in compliance with California’s Energy Efficiency Standards and 2022 CALGreen Standards.
Construction of the proposed residential development would require the typical use of energy resources.
There are no unusual project characteristics or construction processes that would require the use of equipment that would be more energy intensive than is used for comparable activities; or equipment that would not conform to current emissions standards (and related fuel efficiencies). Equipment Cottonwood & Park
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54 employed in construction of the project would therefore not result in inefficient wasteful, or unnecessary consumption of fuel.
8.2 Operational Energy Demand
Energy consumption in support of or related to project operations would include transportation energy demands (energy consumed by employee and patron vehicles accessing the project site) and facilities energy demands (energy consumed by building operations and site maintenance activities).
8.2.1 Transportation Fuel Consumption
The largest source of operational energy use would be vehicle operation of customers. The site is located in a suburban area just in close proximity to transit stops. Using the CalEEMod output, it is assumed that an average trip is 8.3 miles. To show a worst-case analysis, as the proposed project is a residential project, it was assumed that vehicles would operate 365 days per year. Table 20 shows the worst-case estimated annual fuel consumption for all classes of vehicles from autos to heavy-heavy trucks.11 Table 20 shows that an estimated 299,263 gallons of fuel would be consumed per year for the operation of the proposed project.
Table 20: Estimated Vehicle Operations Fuel Consumption1 Vehicle Type Vehicle Mix
Number
of
Vehicles
Average
Trip
(miles)2
Daily
VMT
Average
Fuel
Economy
(mpg)
Total
Gallons
per Day
Total Annual
Fuel
Consumption
(gallons)
Light Auto Automobile 1,205.9 8.30 10,009.2 31.82 314.56 114,813 Light Truck Automobile 129.9 8.30 1,078.3 27.16 39.70 14,491 Light Truck Automobile 426.2 8.30 3,537.2 25.6 138.17 50,432 Medium Truck Automobile 404.1 8.30 3,353.8 20.81 161.16 58,824 Light Heavy Truck 2-Axle Truck 85.9 8.30 712.6 13.81 51.60 18,833 Light Heavy Truck 10,000 lbs + 2-Axle Truck 21.5 8.30 178.5 14.18 12.59 4,595 Medium Heavy Truck 3-Axle Truck 26.4 8.30 219.5 9.58 22.91 8,363 Heavy Heavy Truck 4-Axle Truck 68.1 8.30 565.6 7.14 79.21 28,911 Total 2,368 - 19,655 -- 819.90 --
Total Annual Fuel Consumption 299,263
Notes:
'1 Per CalEEMod assumptions, the project is to generate 2,368 total net new trips. Default CalEEMod vehicle fleet mix utilized. 2 Based on the size of the site and relative location, trips were assumed to be local rather than regional.
Trip generation generated by the proposed project are consistent with other similar residential uses of similar scale and configuration as reflected in the traffic data. That is, the proposed project does not propose uses or operations that would inherently result in excessive and wasteful vehicle trips, nor 11 Average fuel economy based on aggregate mileage calculated in EMFAC 2017 for opening year (2023). See Appendix B for EMFAC output.
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55 associated excess and wasteful vehicle energy consumption. Therefore, project transportation energy consumption would not be considered inefficient, wasteful, or otherwise unnecessary.
8.2.2 Facility Energy Demands (Electricity and Natural Gas) The annual natural gas and electricity demands were provided per the CalEEMod output and are provided in Table 21.
Table 21: Project Annual Operational Energy Demand Summary1 Natural Gas Demand kBTU/year
Condo/Townhouse 7,362,174
Total 7,362,174
Electricity Demand kWh/year
Condo/Townhouse 1,478,309
Enclosed Parking Structure 1,002,810
Parking Lot 111,805
Total 2,592,924
Notes:
1Taken from the CalEEMod 2022.1.1.22 annual output.
As shown in Table 21, the estimated electricity demand for the proposed project is approximately 2,592,924 kWh per year. In 2022, the residential sector of the County of San Diego consumed approximately 7,440 million kWh of electricity.12 In addition, the estimated natural gas consumption for the proposed project is approximately 7,362,174 kBTU per year. In 2022, the residential sector of the County of San Diego consumed approximately 280.9 million therms of gas.13 Therefore, the increase in both electricity and natural gas demand from the proposed project is insignificant compared to the County’s 2022 demand.
8.3 Renewable Energy and Energy Efficiency Plan Consistency Regarding federal transportation regulations, the project site is located in an already developed area.
Access to/from the project site is from existing roads. These roads are already in place so the project would not interfere with, nor otherwise obstruct intermodal transportation plans or projects that may be proposed pursuant to the ISTEA because SCAG is not planning for intermodal facilities in the project area.
Regarding the State’s Energy Plan and compliance with Title 24 CCR energy efficiency standards, the applicant is required to comply with the California Green Building Standard Code requirements for 12 California Energy Commission, Electricity Consumption by County. https://ecdms.energy.ca.gov/elecbycounty.aspx 13 California Energy Commission, Gas Consumption by County. http://ecdms.energy.ca.gov/gasbycounty.aspx Cottonwood & Park
Air Quality, Greenhouse Gas, and Energy Impact Study
City of Santee, CA Energy Analysis
56 energy efficient buildings and appliances as well as utility energy efficiency programs implemented by the SCE and Southern California Gas Company.
Regarding the State’s Renewable Energy Portfolio Standards, the project would be required to meet or exceed the energy standards established in the California Green Building Standards Code, Title 24, Part 11 (CALGreen). CalGreen Standards require that new buildings reduce water consumption, employ building commissioning to increase building system efficiencies, divert construction waste from landfills, and install low pollutant-emitting finish materials.
Cottonwood & Park
Air Quality, Greenhouse Gas, and Energy Impact Study
City of Santee, CA References
57 9.0 References
The following references were used in the preparing this analysis.
Association of Environmental Professionals (AEP)
2016 Final White Paper – Beyond 2020 and Newhall. October 18.
California Air Pollution Control Officers Association
2009 Health Risk Assessments for Proposed Land Use Projects California Air Resources Board
2005 Air Quality and Land Use Handbook: A Community Health Perspective. April. 2008 Resolution 08-43
2008 Recommended Approaches for Setting Interim Significance Thresholds for Greenhouse Gases under the California Environmental Quality Act
2008 ARB Recommended Interim Risk Management Policy for Inhalation-Based Residential Cancer Risk – Frequently Asked Questions
2008 Climate Change Scoping Plan, a framework for change. 2011 Supplement to the AB 32 Scoping Plan Functional Equivalent Document 2013 Revised Emission Factors for Gasoline Marketing Operations at California Gasoline Dispensing Facilities
2014 First Update to the Climate Change Scoping Plan, Building on the Framework Pursuant to AB32, the California Global Warming Solutions Act of 2006. May. 2017 The 2017 Climate Change Scoping Plan, The Strategy for Achieving California’s 2030 Greenhouse Gas Target, Draft. October 27, 2017.
2021 Historical Air Quality, Top 4 Summary
City of Vista
2012 Vista General Plan. Adopted February 28.
2021 City of Vista Climate Action Plan. October.
Cottonwood & Park
Air Quality, Greenhouse Gas, and Energy Impact Study
City of Santee, CA References
58 Governor’s Office of Planning and Research
2008 CEQA and Climate: Addressing Climate Change Through California Environmental Quality Act (CEQA) Review
2009 CEQA Guideline Sections to be Added or Amended
Intergovernmental Panel on Climate Change (IPCC)
2014 Fifth Assessment Report (AR5), Climate Change 2014: Synthesis Report.
Office of Environmental Health Hazard Assessment
2015 Air Toxics Hot Spots Program Risk Assessment Guidelines South Coast Air Quality Management District (SCAQMD)
20008 Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold.
October 2008.
2009 Greenhouse Gas CEQA Significance Threshold Stakeholder Working Group 14. November 19, 2009.
2019 South Coast AQMD Air Quality Significance Thresholds. April.
San Diego County
2007 County of San Diego Guidelines for Determining Significance and Report Format and Content Requirements: Air Quality. March 19.
2018 County of San Diego Guidelines for Determining Significance Climate change. January 2018.
San Diego Association of Governments (SANDAG)
2015 SANDAG Data Surfer. http://datasurfer.sandag.org/
2016 2016 Regional Transportation Improvement Program
2021 2021 Regional Plan. https://sdforward.com/mobility-planning/2021-regional-plan.
San Diego Air Pollution Control District
2017 Annual Air Quality Monitoring Network Plan 2016. June 30. 2020 ”Attainment Status” https://www.sandiegocounty.gov/content/sdc/apcd/en/air-qualityplanning/attainment-status.html Appendix A:
CalEEMod Output
Cottonwood & Park Multifamily Detailed Report, 3/22/2024 1 / 47
Cottonwood & Park Multifamily Detailed Report
Table of Contents
1. Basic Project Information
1.1. Basic Project Information
1.2. Land Use Types
1.3. User-Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds
2.2. Construction Emissions by Year, Unmitigated
2.4. Operations Emissions Compared Against Thresholds
2.5. Operations Emissions by Sector, Unmitigated
3. Construction Emissions Details
3.1. Site Preparation (2024) - Unmitigated
3.3. Grading (2024) - Unmitigated
3.5. Building Construction (2024) - Unmitigated
3.7. Building Construction (2025) - Unmitigated
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3.9. Paving (2025) - Unmitigated
3.11. Paving (2026) - Unmitigated
3.13. Architectural Coating (2026) - Unmitigated
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
4.3. Area Emissions by Source
4.3.1. Unmitigated
4.4. Water Emissions by Land Use
4.4.1. Unmitigated
4.5. Waste Emissions by Land Use
4.5.1. Unmitigated
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
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4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
5. Activity Data
5.1. Construction Schedule
5.2. Off-Road Equipment
5.2.1. Unmitigated
5.3. Construction Vehicles
5.3.1. Unmitigated
5.4. Vehicles
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5.4.1. Construction Vehicle Control Strategies
5.5. Architectural Coatings
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
5.6.2. Construction Earthmoving Control Strategies
5.7. Construction Paving
5.8. Construction Electricity Consumption and Emissions Factors
5.9. Operational Mobile Sources
5.9.1. Unmitigated
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.2. Architectural Coatings
5.10.3. Landscape Equipment
5.11. Operational Energy Consumption
5.11.1. Unmitigated
5.12. Operational Water and Wastewater Consumption
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5.12.1. Unmitigated
5.13. Operational Waste Generation
5.13.1. Unmitigated
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
5.16.2. Process Boilers
5.17. User Defined
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
5.18.2. Sequestration
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5.18.2.1. Unmitigated
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
6.2. Initial Climate Risk Scores
6.3. Adjusted Climate Risk Scores
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores
7.2. Healthy Places Index Scores
7.3. Overall Health & Equity Scores
7.4. Health & Equity Measures
7.5. Evaluation Scorecard
7.6. Health & Equity Custom Measures
8. User Changes to Default Data
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1. Basic Project Information
1.1. Basic Project Information
Data Field Value
Project Name Cottonwood & Park Multifamily
Construction Start Date 8/1/2024
Operational Year 2026
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 2.60
Precipitation (days) 7.60
Location 32.84843378293502, -116.97522873221708
County San Diego
City Santee
Air District San Diego County APCD
Air Basin San Diego
TAZ 6529
EDFZ 12
Electric Utility San Diego Gas & Electric
Gas Utility San Diego Gas & Electric
App Version 2022.1.1.22
1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
Cottonwood & Park Multifamily Detailed Report, 3/22/2024 8 / 47
Condo/Townhouse 358 Dwelling Unit 10.4 379,480 0.00 — 999 — Enclosed Parking
Structure
716 Space 6.44 286,400 0.00 — — —
Parking Lot 123 Space 2.93 0.00 73,440 — — —
1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 3.80 46.7 35.6 0.12 1.61 7.81 9.41 1.50 3.97 5.45 — 15,961 15,961 0.77 1.53 20.5 16,456 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 72.4 47.1 35.5 0.12 1.61 6.10 7.71 1.50 2.10 3.60 — 15,953 15,953 0.77 1.53 0.53 16,428 Average
Daily
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 7.02 10.3 21.0 0.03 0.33 2.59 2.92 0.30 0.62 0.93 — 5,556 5,556 0.26 0.32 5.71 5,663 Annual
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 1.28 1.88 3.83 < 0.005 0.06 0.47 0.53 0.06 0.11 0.17 — 920 920 0.04 0.05 0.94 938
2.2. Construction Emissions by Year, Unmitigated
Cottonwood & Park Multifamily Detailed Report, 3/22/2024 9 / 47
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — —
2024 3.80 46.7 35.6 0.12 1.61 7.81 9.41 1.50 3.97 5.45 — 15,961 15,961 0.77 1.53 20.5 16,456 2025 2.74 14.4 31.9 0.04 0.46 3.74 4.20 0.43 0.90 1.33 — 8,117 8,117 0.36 0.45 19.0 8,278 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — —
2024 3.79 47.1 35.5 0.12 1.61 6.10 7.71 1.50 2.10 3.60 — 15,953 15,953 0.77 1.53 0.53 16,428 2025 2.71 14.7 29.7 0.04 0.46 3.74 4.20 0.43 0.90 1.33 — 7,918 7,918 0.37 0.45 0.49 8,064 2026 72.4 7.33 10.6 0.01 0.32 0.64 0.66 0.30 0.15 0.33 — 1,765 1,765 0.07 0.04 0.06 1,778 Average
Daily
— — — — — — — — — — — — — — — — —
2024 0.78 6.89 7.85 0.02 0.24 1.20 1.44 0.23 0.40 0.62 — 2,501 2,501 0.12 0.19 1.86 2,561 2025 1.91 10.3 21.0 0.03 0.33 2.59 2.92 0.30 0.62 0.93 — 5,556 5,556 0.26 0.32 5.71 5,663 2026 7.02 0.38 0.78 < 0.005 0.01 0.07 0.08 0.01 0.02 0.03 — 143 143 0.01 < 0.005 0.11 144 Annual — — — — — — — — — — — — — — — — —
2024 0.14 1.26 1.43 < 0.005 0.04 0.22 0.26 0.04 0.07 0.11 — 414 414 0.02 0.03 0.31 424 2025 0.35 1.88 3.83 < 0.005 0.06 0.47 0.53 0.06 0.11 0.17 — 920 920 0.04 0.05 0.94 938 2026 1.28 0.07 0.14 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 0.01 — 23.6 23.6 < 0.005 < 0.005 0.02 23.9
2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 22.3 8.62 101 0.17 0.31 13.9 14.2 0.29 3.52 3.81 167 23,066 23,233 18.0 0.72 57.2 23,952 Cottonwood & Park Multifamily Detailed Report, 3/22/2024 10 / 47
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 18.3 8.96 64.4 0.16 0.27 13.9 14.2 0.27 3.52 3.79 167 22,238 22,405 18.0 0.75 4.13 23,084 Average
Daily
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 20.1 9.01 80.4 0.17 0.29 13.8 14.1 0.28 3.50 3.78 167 22,399 22,566 18.0 0.75 26.2 23,265 Annual
(Max)
— — — — — — — — — — — — — — — — —
Unmit. 3.66 1.64 14.7 0.03 0.05 2.52 2.57 0.05 0.64 0.69 27.6 3,708 3,736 2.98 0.12 4.34 3,852
2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Mobile 9.53 6.46 67.1 0.16 0.12 13.9 14.0 0.12 3.52 3.63 — 16,269 16,269 0.77 0.62 54.5 16,529 Area 12.7 0.30 32.8 < 0.005 0.03 — 0.03 0.02 — 0.02 — 106 106 < 0.005 < 0.005 — 106 Energy 0.11 1.86 0.79 0.01 0.15 — 0.15 0.15 — 0.15 — 6,544 6,544 0.44 0.03 — 6,564 Water — — — — — — — — — — 24.1 148 172 2.48 0.06 — 251
Waste — — — — — — — — — — 143 0.00 143 14.3 0.00 — 499
Refrig. — — — — — — — — — — — — — — — 2.72 2.72
Total 22.3 8.62 101 0.17 0.31 13.9 14.2 0.29 3.52 3.81 167 23,066 23,233 18.0 0.72 57.2 23,952 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Mobile 9.32 7.10 63.6 0.15 0.12 13.9 14.0 0.12 3.52 3.63 — 15,547 15,547 0.82 0.66 1.41 15,766 Area 8.84 — — — — — — — — — — — — — — — —
Cottonwood & Park Multifamily Detailed Report, 3/22/2024 11 / 47
Energy 0.11 1.86 0.79 0.01 0.15 — 0.15 0.15 — 0.15 — 6,544 6,544 0.44 0.03 — 6,564 Water — — — — — — — — — — 24.1 148 172 2.48 0.06 — 251
Waste — — — — — — — — — — 143 0.00 143 14.3 0.00 — 499
Refrig. — — — — — — — — — — — — — — — 2.72 2.72
Total 18.3 8.96 64.4 0.16 0.27 13.9 14.2 0.27 3.52 3.79 167 22,238 22,405 18.0 0.75 4.13 23,084 Average
Daily
— — — — — — — — — — — — — — — — —
Mobile 9.20 7.01 63.4 0.15 0.12 13.8 13.9 0.12 3.50 3.62 — 15,656 15,656 0.81 0.65 23.5 15,895 Area 10.7 0.15 16.2 < 0.005 0.02 — 0.02 0.01 — 0.01 — 52.0 52.0 < 0.005 < 0.005 — 52.2 Energy 0.11 1.86 0.79 0.01 0.15 — 0.15 0.15 — 0.15 — 6,544 6,544 0.44 0.03 — 6,564 Water — — — — — — — — — — 24.1 148 172 2.48 0.06 — 251
Waste — — — — — — — — — — 143 0.00 143 14.3 0.00 — 499
Refrig. — — — — — — — — — — — — — — — 2.72 2.72
Total 20.1 9.01 80.4 0.17 0.29 13.8 14.1 0.28 3.50 3.78 167 22,399 22,566 18.0 0.75 26.2 23,265 Annual — — — — — — — — — — — — — — — — —
Mobile 1.68 1.28 11.6 0.03 0.02 2.52 2.54 0.02 0.64 0.66 — 2,592 2,592 0.13 0.11 3.89 2,632 Area 1.96 0.03 2.95 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 8.62 8.62 < 0.005 < 0.005 — 8.65 Energy 0.02 0.34 0.14 < 0.005 0.03 — 0.03 0.03 — 0.03 — 1,083 1,083 0.07 0.01 — 1,087 Water — — — — — — — — — — 3.99 24.4 28.4 0.41 0.01 — 41.6 Waste — — — — — — — — — — 23.6 0.00 23.6 2.36 0.00 — 82.7 Refrig. — — — — — — — — — — — — — — — 0.45 0.45
Total 3.66 1.64 14.7 0.03 0.05 2.52 2.57 0.05 0.64 0.69 27.6 3,708 3,736 2.98 0.12 4.34 3,852
3. Construction Emissions Details
3.1. Site Preparation (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Cottonwood & Park Multifamily Detailed Report, 3/22/2024 12 / 47
Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
3.65 36.0 32.9 0.05 1.60 — 1.60 1.47 — 1.47 — 5,296 5,296 0.21 0.04 — 5,314 Dust
From
Material
Movement
— — — — — 7.67 7.67 — 3.94 3.94 — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.10 0.99 0.90 < 0.005 0.04 — 0.04 0.04 — 0.04 — 145 145 0.01 < 0.005 — 146 Dust
From
Material
Movement
— — — — — 0.21 0.21 — 0.11 0.11 — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.02 0.18 0.16 < 0.005 0.01 — 0.01 0.01 — 0.01 — 24.0 24.0 < 0.005 < 0.005 — 24.1 Dust
From
Material
Movement
— — — — — 0.04 0.04 — 0.02 0.02 — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Cottonwood & Park Multifamily Detailed Report, 3/22/2024 13 / 47
Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.07 0.06 0.86 0.00 0.00 0.15 0.15 0.00 0.03 0.03 — 169 169 0.01 0.01 0.68 172 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.42 4.42 < 0.005 < 0.005 0.01 4.48 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.73 0.73 < 0.005 < 0.005 < 0.005 0.74 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
3.3. Grading (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
3.52 34.3 30.2 0.06 1.45 — 1.45 1.33 — 1.33 — 6,598 6,598 0.27 0.05 — 6,621 Cottonwood & Park Multifamily Detailed Report, 3/22/2024 14 / 47
Dust————— 3.61 3.61— 1.43 1.43———————
From
Material
Movement
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
—————————————————
Off-Road
Equipment
3.52 34.3 30.2 0.06 1.45— 1.45 1.33— 1.33— 6,598 6,598 0.27 0.05— 6,621 Dust
From
Material
Movement
————— 3.61 3.61— 1.43 1.43———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
—————————————————
Off-Road
Equipment
0.29 2.82 2.48 0.01 0.12— 0.12 0.11— 0.11— 542 542 0.02 < 0.005— 544 Dust
From
Material
Movement
————— 0.30 0.30— 0.12 0.12———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 Annual—————————————————
Off-Road
Equipment
0.05 0.51 0.45 < 0.005 0.02— 0.02 0.02— 0.02— 89.8 89.8 < 0.005 < 0.005— 90.1 Dust
From
Material
Movement
————— 0.05 0.05— 0.02 0.02———————
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00— 0.00 0.00 0.00 0.00 0.00 0.00 Cottonwood & Park Multifamily Detailed Report, 3/22/2024 15 / 47
Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.08 0.07 0.99 0.00 0.00 0.17 0.17 0.00 0.04 0.04 — 194 194 0.01 0.01 0.78 197 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.20 12.4 4.40 0.06 0.17 2.32 2.48 0.17 0.63 0.80 — 9,169 9,169 0.50 1.47 19.7 9,639 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.08 0.07 0.87 0.00 0.00 0.17 0.17 0.00 0.04 0.04 — 183 183 0.01 0.01 0.02 185 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.19 12.8 4.45 0.06 0.17 2.32 2.48 0.17 0.63 0.80 — 9,172 9,172 0.50 1.47 0.51 9,623 Average
Daily
— — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.07 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 15.2 15.2 < 0.005 < 0.005 0.03 15.4 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.02 1.05 0.36 < 0.005 0.01 0.19 0.20 0.01 0.05 0.07 — 754 754 0.04 0.12 0.70 791 Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.51 2.51 < 0.005 < 0.005 < 0.005 2.54 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 0.19 0.07 < 0.005 < 0.005 0.03 0.04 < 0.005 0.01 0.01 — 125 125 0.01 0.02 0.12 131
3.5. Building Construction (2024) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Cottonwood & Park Multifamily Detailed Report, 3/22/2024 16 / 47
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
1.20 11.2 13.1 0.02 0.50 — 0.50 0.46 — 0.46 — 2,398 2,398 0.10 0.02 — 2,406 Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.16 1.45 1.69 < 0.005 0.06 — 0.06 0.06 — 0.06 — 310 310 0.01 < 0.005 — 311 Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.03 0.26 0.31 < 0.005 0.01 — 0.01 0.01 — 0.01 — 51.3 51.3 < 0.005 < 0.005 — 51.4 Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Worker 1.57 1.41 16.4 0.00 0.00 3.20 3.20 0.00 0.75 0.75 — 3,453 3,453 0.18 0.13 0.38 3,498 Vendor 0.08 3.10 1.42 0.01 0.03 0.55 0.57 0.03 0.15 0.18 — 2,172 2,172 0.09 0.30 0.14 2,264 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — —
Worker 0.20 0.18 2.14 0.00 0.00 0.41 0.41 0.00 0.10 0.10 — 450 450 0.02 0.02 0.82 457 Vendor 0.01 0.40 0.18 < 0.005 < 0.005 0.07 0.07 < 0.005 0.02 0.02 — 280 280 0.01 0.04 0.31 293 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Cottonwood & Park Multifamily Detailed Report, 3/22/2024 17 / 47
Annual — — — — — — — — — — — — — — — — —
Worker 0.04 0.03 0.39 0.00 0.00 0.07 0.07 0.00 0.02 0.02 — 74.5 74.5 < 0.005 < 0.005 0.14 75.6 Vendor < 0.005 0.07 0.03 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 46.4 46.4 < 0.005 0.01 0.05 48.5 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
3.7. Building Construction (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
1.13 10.4 13.0 0.02 0.43 — 0.43 0.40 — 0.40 — 2,398 2,398 0.10 0.02 — 2,406 Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
1.13 10.4 13.0 0.02 0.43 — 0.43 0.40 — 0.40 — 2,398 2,398 0.10 0.02 — 2,406 Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.78 7.26 9.06 0.02 0.30 — 0.30 0.28 — 0.28 — 1,666 1,666 0.07 0.01 — 1,671 Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.14 1.32 1.65 < 0.005 0.05 — 0.05 0.05 — 0.05 — 276 276 0.01 < 0.005 — 277 Cottonwood & Park Multifamily Detailed Report, 3/22/2024 18 / 47
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Worker 1.52 1.16 17.5 0.00 0.00 3.20 3.20 0.00 0.75 0.75 — 3,587 3,587 0.17 0.12 13.5 3,642 Vendor 0.09 2.84 1.32 0.01 0.03 0.55 0.57 0.03 0.15 0.18 — 2,133 2,133 0.09 0.30 5.53 2,230 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Worker 1.50 1.29 15.3 0.00 0.00 3.20 3.20 0.00 0.75 0.75 — 3,387 3,387 0.18 0.13 0.35 3,432 Vendor 0.08 2.94 1.36 0.01 0.03 0.55 0.57 0.03 0.15 0.18 — 2,134 2,134 0.09 0.30 0.14 2,226 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — —
Worker 1.03 0.89 10.8 0.00 0.00 2.21 2.21 0.00 0.52 0.52 — 2,374 2,374 0.12 0.09 4.03 2,409 Vendor 0.06 2.03 0.93 0.01 0.02 0.38 0.40 0.02 0.10 0.12 — 1,482 1,482 0.07 0.21 1.67 1,548 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — —
Worker 0.19 0.16 1.97 0.00 0.00 0.40 0.40 0.00 0.09 0.09 — 393 393 0.02 0.02 0.67 399 Vendor 0.01 0.37 0.17 < 0.005 < 0.005 0.07 0.07 < 0.005 0.02 0.02 — 245 245 0.01 0.03 0.28 256 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
3.9. Paving (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — —
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Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.80 7.45 9.98 0.01 0.35 — 0.35 0.32 — 0.32 — 1,511 1,511 0.06 0.01 — 1,517 Paving 1.23 — — — — — — — — — — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.02 0.15 0.20 < 0.005 0.01 — 0.01 0.01 — 0.01 — 29.6 29.6 < 0.005 < 0.005 — 29.7 Paving 0.02 — — — — — — — — — — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 0.03 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 4.90 4.90 < 0.005 < 0.005 — 4.91 Paving < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.06 0.05 0.61 0.00 0.00 0.13 0.13 0.00 0.03 0.03 — 134 134 0.01 0.01 0.01 136 Vendor < 0.005 0.17 0.08 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 — 125 125 0.01 0.02 0.01 131 Cottonwood & Park Multifamily Detailed Report, 3/22/2024 20 / 47
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.65 2.65 < 0.005 < 0.005 < 0.005 2.69 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.45 2.45 < 0.005 < 0.005 < 0.005 2.56 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.44 0.44 < 0.005 < 0.005 < 0.005 0.45 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.41 0.41 < 0.005 < 0.005 < 0.005 0.42 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
3.11. Paving (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.76 7.12 9.94 0.01 0.32 — 0.32 0.29 — 0.29 — 1,511 1,511 0.06 0.01 — 1,516 Paving 1.23 — — — — — — — — — — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.03 0.26 0.37 < 0.005 0.01 — 0.01 0.01 — 0.01 — 56.2 56.2 < 0.005 < 0.005 — 56.4 Cottonwood & Park Multifamily Detailed Report, 3/22/2024 21 / 47
Paving 0.05 — — — — — — — — — — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.01 0.05 0.07 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 9.30 9.30 < 0.005 < 0.005 — 9.33 Paving 0.01 — — — — — — — — — — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.05 0.05 0.57 0.00 0.00 0.13 0.13 0.00 0.03 0.03 — 132 132 0.01 0.01 0.01 133 Vendor < 0.005 0.16 0.08 < 0.005 < 0.005 0.03 0.03 < 0.005 0.01 0.01 — 123 123 < 0.005 0.02 0.01 128 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.94 4.94 < 0.005 < 0.005 0.01 5.01 Vendor < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 4.57 4.57 < 0.005 < 0.005 < 0.005 4.77 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.82 0.82 < 0.005 < 0.005 < 0.005 0.83 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.76 0.76 < 0.005 < 0.005 < 0.005 0.79 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
3.13. Architectural Coating (2026) - Unmitigated
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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.12 0.86 1.13 < 0.005 0.02 — 0.02 0.02 — 0.02 — 134 134 0.01 < 0.005 — 134 Architectu
ral
Coatings
72.0 — — — — — — — — — — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.01 0.08 0.11 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 12.8 12.8 < 0.005 < 0.005 — 12.8 Architectu
ral
Coatings
6.91 — — — — — — — — — — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 2.12 2.12 < 0.005 < 0.005 — 2.13 Architectu
ral
Coatings
1.26 — — — — — — — — — — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — —
Cottonwood & Park Multifamily Detailed Report, 3/22/2024 23 / 47
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Worker 0.27 0.24 2.88 0.00 0.00 0.64 0.64 0.00 0.15 0.15 — 664 664 0.03 0.03 0.06 673 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — —
Worker 0.03 0.02 0.28 0.00 0.00 0.06 0.06 0.00 0.01 0.01 — 64.2 64.2 < 0.005 < 0.005 0.10 65.2 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 0.05 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 10.6 10.6 < 0.005 < 0.005 0.02 10.8 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
Mobile source emissions results are presented in Sections 2.6. No further detailed breakdown of emissions is available.
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Cottonwood & Park Multifamily Detailed Report, 3/22/2024 24 / 47
Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Condo/To
wnhouse
— — — — — — — — — — — 2,385 2,385 0.13 0.02 — 2,394
Enclosed
Parking
Structure
— — — — — — — — — — — 1,618 1,618 0.09 0.01 — 1,624
Parking
Lot
— — — — — — — — — — — 180 180 0.01 < 0.005 — 181
Total — — — — — — — — — — — 4,184 4,184 0.23 0.03 — 4,198 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Condo/To
wnhouse
— — — — — — — — — — — 2,385 2,385 0.13 0.02 — 2,394
Enclosed
Parking
Structure
— — — — — — — — — — — 1,618 1,618 0.09 0.01 — 1,624
Parking
Lot
— — — — — — — — — — — 180 180 0.01 < 0.005 — 181
Total — — — — — — — — — — — 4,184 4,184 0.23 0.03 — 4,198 Annual — — — — — — — — — — — — — — — — —
Condo/To
wnhouse
— — — — — — — — — — — 395 395 0.02 < 0.005 — 396
Enclosed
Parking
Structure
— — — — — — — — — — — 268 268 0.02 < 0.005 — 269
Parking
Lot
— — — — — — — — — — — 29.9 29.9 < 0.005 < 0.005 — 30.0
Total — — — — — — — — — — — 693 693 0.04 < 0.005 — 695
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4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Condo/To
wnhouse
0.11 1.86 0.79 0.01 0.15 — 0.15 0.15 — 0.15 — 2,359 2,359 0.21 < 0.005 — 2,366 Enclosed
Parking
Structure
0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Parking
Lot
0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.11 1.86 0.79 0.01 0.15 — 0.15 0.15 — 0.15 — 2,359 2,359 0.21 < 0.005 — 2,366 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Condo/To
wnhouse
0.11 1.86 0.79 0.01 0.15 — 0.15 0.15 — 0.15 — 2,359 2,359 0.21 < 0.005 — 2,366 Enclosed
Parking
Structure
0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Parking
Lot
0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.11 1.86 0.79 0.01 0.15 — 0.15 0.15 — 0.15 — 2,359 2,359 0.21 < 0.005 — 2,366 Annual — — — — — — — — — — — — — — — — —
Condo/To
wnhouse
0.02 0.34 0.14 < 0.005 0.03 — 0.03 0.03 — 0.03 — 391 391 0.03 < 0.005 — 392 Enclosed
Parking
Structure
0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Parking
Lot
0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Cottonwood & Park Multifamily Detailed Report, 3/22/2024 26 / 47
Total 0.02 0.34 0.14 < 0.005 0.03 — 0.03 0.03 — 0.03 — 391 391 0.03 < 0.005 — 392
4.3. Area Emissions by Source
4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Consume
r
Products
8.15 — — — — — — — — — — — — — — — —
Architectu
ral
Coatings
0.69 — — — — — — — — — — — — — — — —
Landscap
e
Equipme
nt
3.85 0.30 32.8 < 0.005 0.03 — 0.03 0.02 — 0.02 — 106 106 < 0.005 < 0.005 — 106 Total 12.7 0.30 32.8 < 0.005 0.03 — 0.03 0.02 — 0.02 — 106 106 < 0.005 < 0.005 — 106 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Consume
r
Products
8.15 — — — — — — — — — — — — — — — —
Architectu
ral
Coatings
0.69 — — — — — — — — — — — — — — — —
Total 8.84 — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
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Consume 1.49 — — — — — — — — — — — — — — — —
r
Architectu
ral
Coatings
0.13 — — — — — — — — — — — — — — — —
Landscap
e
Equipme
nt
0.35 0.03 2.95 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 8.62 8.62 < 0.005 < 0.005 — 8.65 Total 1.96 0.03 2.95 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 8.62 8.62 < 0.005 < 0.005 — 8.65
4.4. Water Emissions by Land Use
4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Condo/To
wnhouse
— — — — — — — — — — 24.1 138 162 2.48 0.06 — 242
Enclosed
Parking
Structure
— — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Parking
Lot
— — — — — — — — — — 0.00 9.40 9.40 < 0.005 < 0.005 — 9.43 Total — — — — — — — — — — 24.1 148 172 2.48 0.06 — 251
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Condo/To
wnhouse
— — — — — — — — — — 24.1 138 162 2.48 0.06 — 242
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Enclosed — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00 Parking
Structure
Parking
Lot
— — — — — — — — — — 0.00 9.40 9.40 < 0.005 < 0.005 — 9.43 Total — — — — — — — — — — 24.1 148 172 2.48 0.06 — 251
Annual — — — — — — — — — — — — — — — — —
Condo/To
wnhouse
— — — — — — — — — — 3.99 22.9 26.9 0.41 0.01 — 40.1
Enclosed
Parking
Structure
— — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Parking
Lot
— — — — — — — — — — 0.00 1.56 1.56 < 0.005 < 0.005 — 1.56 Total — — — — — — — — — — 3.99 24.4 28.4 0.41 0.01 — 41.6
4.5. Waste Emissions by Land Use
4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Condo/To
wnhouse
— — — — — — — — — — 143 0.00 143 14.3 0.00 — 499
Enclosed
Parking
Structure
— — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Parking
Lot
— — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — 143 0.00 143 14.3 0.00 — 499
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Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Condo/To
wnhouse
— — — — — — — — — — 143 0.00 143 14.3 0.00 — 499
Enclosed
Parking
Structure
— — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Parking
Lot
— — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — 143 0.00 143 14.3 0.00 — 499
Annual — — — — — — — — — — — — — — — — —
Condo/To
wnhouse
— — — — — — — — — — 23.6 0.00 23.6 2.36 0.00 — 82.7
Enclosed
Parking
Structure
— — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Parking
Lot
— — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — 23.6 0.00 23.6 2.36 0.00 — 82.7
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Condo/To
wnhouse
— — — — — — — — — — — — — — — 2.72 2.72
Total — — — — — — — — — — — — — — — 2.72 2.72
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Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Condo/To
wnhouse
— — — — — — — — — — — — — — — 2.72 2.72
Total — — — — — — — — — — — — — — — 2.72 2.72
Annual — — — — — — — — — — — — — — — — —
Condo/To
wnhouse
— — — — — — — — — — — — — — — 0.45 0.45
Total — — — — — — — — — — — — — — — 0.45 0.45
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
Type
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
4.8. Stationary Emissions By Equipment Type
Cottonwood & Park Multifamily Detailed Report, 3/22/2024 31 / 47
4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
Type
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
Type
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
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Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetatio
n
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
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Annual — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — —
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
Sequeste
red
— — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
Removed — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
Sequeste
red
— — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
Removed — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — —
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Avoided — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
Sequeste
red
— — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
Removed — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — —
5. Activity Data
5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Site Preparation Site Preparation 8/30/2024 9/13/2024 5.00 10.0 — Grading Grading 9/14/2024 10/26/2024 5.00 30.0 —
Building Construction Building Construction 10/27/2024 12/21/2025 5.00 300 — Paving Paving 12/22/2025 1/19/2026 5.00 20.0 —
Architectural Coating Architectural Coating 1/20/2026 3/9/2026 5.00 35.0 —
5.2. Off-Road Equipment
5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Site Preparation Rubber Tired Dozers Diesel Average 3.00 8.00 367 0.40 Site Preparation Tractors/Loaders/Backh
oes
Diesel Average 4.00 8.00 84.0 0.37
Grading Graders Diesel Average 1.00 8.00 148 0.41
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Grading Excavators Diesel Average 2.00 8.00 36.0 0.38
Grading Tractors/Loaders/Backh
oes
Diesel Average 2.00 8.00 84.0 0.37
Grading Scrapers Diesel Average 2.00 8.00 423 0.48
Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Building Construction Forklifts Diesel Average 3.00 8.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Cranes Diesel Average 1.00 7.00 367 0.29 Building Construction Welders Diesel Average 1.00 8.00 46.0 0.45 Building Construction Tractors/Loaders/Backh
oes
Diesel Average 3.00 7.00 84.0 0.37
Paving Pavers Diesel Average 2.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Average 2.00 8.00 89.0 0.36 Paving Rollers Diesel Average 2.00 8.00 36.0 0.38
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48
5.3. Construction Vehicles
5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Site Preparation — — — —
Site Preparation Worker 17.5 12.0 LDA,LDT1,LDT2
Site Preparation Vendor — 7.63 HHDT,MHDT
Site Preparation Hauling 0.00 20.0 HHDT
Site Preparation Onsite truck — — HHDT
Grading — — — —
Grading Worker 20.0 12.0 LDA,LDT1,LDT2
Grading Vendor — 7.63 HHDT,MHDT
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Grading Hauling 125 20.0 HHDT
Grading Onsite truck — — HHDT
Building Construction — — — —
Building Construction Worker 378 12.0 LDA,LDT1,LDT2
Building Construction Vendor 85.2 7.63 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck — — HHDT
Paving — — — —
Paving Worker 15.0 12.0 LDA,LDT1,LDT2
Paving Vendor 5.00 7.63 HHDT,MHDT
Paving Hauling 0.00 20.0 HHDT
Paving Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 75.6 12.0 LDA,LDT1,LDT2
Architectural Coating Vendor — 7.63 HHDT,MHDT
Architectural Coating Hauling 0.00 20.0 HHDT
Architectural Coating Onsite truck — — HHDT
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.
5.5. Architectural Coatings
Phase Name Residential Interior Area Coated
(sq ft)
Residential Exterior Area Coated
(sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
Architectural Coating 768,447 256,149 12,632 1,404 24,500 Cottonwood & Park Multifamily Detailed Report, 3/22/2024 37 / 47