cc 2022 AR 11/15 camino largo residential development p21-0300 — Vista City Council, November 15, 2022 (part 1 of 8)

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Department: Community Develo
® CITY COUNCIL
❑ COMMUNITY DEVELOPMENT COMMISSION
❑ SUCCESSOR AGENCY
❑ BUENA SANITATION DISTRICT
❑ JOINT POWERS FINANCING AUTHORITY
Item No: PH1
Prepared by: Patsy Chow, Deputy Director/City Planner Meeting Date: November 15, 2022 John Conley, Director
Approved by: Amanda Lee, Acting City Manager Agenda Location: Public Hearing SUBJECT: CAMINO LARGO RESIDENTIAL DEVELOPMENT (P21-0300) RECOMMENDATION:

1. Open, conduct, and close a public hearing to receive testimony regarding Planning Case No. P21- 0300, the Camino Largo project. The following options are provided for the City Council's consideration:

Approve the Project:

2. Adopt City Council Resolution No. 2022- , approving a Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program for 46 single-family homes located at 2123 N. Santa Fe Avenue (Assessor's Parcel Number (APN) 159-240-07).

3. Adopt City Council Resolution No. 2022- , authorizing and approving the summary vacation of a portion of an open space easement on APN 159-240-31.

4. Introduce and adopt City Council Ordinance No. 2022- , approving a Zone Change from A-1 Agricultural Zone to R-1-13 Residential Zone Small Lot Development to allow for 46 single-family homes on a 9.3-acre site located at 2123 N. Santa Fe Avenue (APN 159-240-07-00).

5. Adopt City Council Resolution No. 2022- , approving a General Plan Amendment, Site Development Plan, and Tentative Subdivision Map for 46 single-family homes located at 2123 N. Santa Fe Avenue.

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Deny the Project:

6. Adopt City Council Resolution No. 2022- , denying a General Plan Amendment, Zone Change, Site Development Plan, and Tentative Subdivision Map for 46 single-family homes located at 2123 N.

Santa Fe Avenue.

CORRELATION TO CITY COUNCIL GOALS: Homelessness & Housing.

PRIOR ACTION: On June 22, 2021, discussed a proposed application for a General Plan Amendment and Zone Change on a 9.3-acre site at 2123 N. Santa Fe Avenue (APN 159-240-07) for 48 single-family homes (No Vote).

ACTION: Opened, conducted and closed public hearing; Adopted Reso. No. 2022-169 approving MND; Adopted Reso.

No. 2022-170 authorizing summary vacation; Introduced Ord. No. 2022-21; Adopted Reso. No. 2022-171 approving GPA, SDP, and TSM; and directed staff to work with applicant to improve u-turn design. Vote: 3-2, Contreras and Melendez opposed
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Clerk/Se etary
11 /15/2022 PH 1 Page 1 of 1307

MEETING DATE: NOVEMBER 15, 2022 PAGE 2
SUBJECT: CAMINO LARGO RESIDENTIAL DEVELOPMENT (P21-0300) PRIOR PLANNING COMMISSION ACTION: On July 19, 2022, adopted Planning Commission Resolution No. 2022-13 (Exhibit 7), recommending City Council denial of a General Plan Amendment, Zone Change, Tentative Subdivision Map, and Site Development Plan to develop a 46-lot single-family residential subdivision located at 2123 N. Santa Fe Avenue (Vote: 6-0, Aguilera absent). The Planning Commission staff report and minutes from the July 19, 2022, meeting are included as Exhibit 6.

STATEMENT ON THE SUBJECT: The proposed project consists of a Summary Vacation of a portion of an open space easement, General Plan Amendment, Zone Change, Site Development Plan, and Tentative Subdivision Map to develop 46 single-family dwelling units, drainage improvements, wet and dry utilities, private streets, common and private open space (including one large common open space area), and all associated infrastructure on a 9.3-acre parcel located at 2123 N. Santa Fe Avenue. The proposed 46 homes result in a density of 4.95 dwelling units per acre. The General Plan currently designates the project site as Rural Residential (RR) (maximum one dwelling per acre), and to accommodate the 46 homes; the project requires a General Plan Amendment from RR to Medium Density (MD) residential (maximum 10 dwelling units per acre) and a Zone Change from the Agricultural Zone (A-1) to the Residence Zone (R-1-B) incorporating the small lot subdivision standards, with a minimum size of 3,600 square foot lots.

The project includes the conversion of a former nursery to residential land use. Converting to residential land use would demolish 10,600 square feet (sf) of existing structures that includes a greenhouse and a shed. The 46 homes (4-bedroom plans with optional 5th bedroom) range from 2,129 sf to 2,374 sf and have a height of no greater than 35 feet. Architecturally, the project provides three residential styles:

Santa Barbara, Farmhouse, and Spanish Ranch, each constructed with stucco facades enhanced with wood and brick accents. Flat planes would be disrupted, with portions of the residences recessed further from the street front, covered front porches, and pitched roofs. Retaining walls are planned for each lot with maximum heights of approximately five feet. Conceptual architectural plans are included as Exhibit B of Exhibit 4.

The 46 single-family homes would provide garage parking for two vehicles with two guest parking spaces on the driveway. An additional 46 open guest parking spaces are distributed throughout the site. In all, a total of 230 parking spaces would be provided onsite.

The project would provide 14,923 sf of common open space along the eastern perimeter of the project site. In addition, the project offers landscaped areas (including slopes) that would support a variety of groundcover and shrubs with mature trees within the eastern and northern perimeter of the project site as well as within buffers between individual rear yards.

Access would be provided by four private cul-de-sac streets and one private street that extends from Camino Largo. Resident parking would be provided via two -car garages and individual driveways, with additional parking being provided along both sides of each cul-de-sac private street. Camino Largo would be improved from an unclassified road to a two-way paved street with a curb and gutter system and sidewalks. The pavement along Camino Largo would be improved to a minimum width of 28 feet. In addition, the four private cul-de-sac streets would be 40 feet wide, curb to curb, to accommodate on -street parking on both sides of the streets, which would meet the proposed parking requirements set forth in the small lot subdivision/residential development standards. The project would also include adding a stop sign on Camino Largo at the intersection with N. Santa Fe Avenue. The project initially anticipated two trees at the southeast corner of Camino Largo and North Santa Fe Avenue (within the road right-of-way for N. Santa Fe Avenue) would be removed to improve line of sight when turning south onto N. Santa Fe Avenue from Camino Largo. However, the City removed the trees under an existing authorized maintenance agreement, so this project no longer proposes this activity. 11 /15/2022 PH 1 Page 2 of 1307

MEETING DATE: NOVEMBER 15, 2022 PAGE 3
SUBJECT: CAMINO LARGO RESIDENTIAL DEVELOPMENT (P21-0300) For a complete description of the project, please refer to July 19, 2022, Planning Commission staff report (Exhibit 6) and the Revised IS/MND, which contains subsequent minor project changes made since July 19, 2022, as a result of the IS/MND recirculation.

Planning Review. The project is a proposed Summary Vacation of a portion of an open space easement, General Plan Amendment, Zone Change, Site Development Plan, and Tentative Subdivision Map.

Following approval of a Tentative Subdivision Map, the developer has three years (with additional extensions of two or more years granted by the State under various Assembly and Senate Bills if applicable at that time) to process a Final Map, otherwise the Tentative Subdivision Map expires. The Final Map requires approval by the City Council, which may commence when a licensed engineer submits a map that substantially complies with the Tentative Subdivision Map and satisfies the applicable conditions, including the completion of street and other public improvements or the provision of bonds guaranteeing the construction of those improvements, typically within one year. Legal lots are created upon recordation of the Final Map, and homes may be constructed. Consistent with State law and City policy, associated discretionary permits approved in conjunction with a subdivision map are also valid for the term and life of the map.

The project proposes land use designation of Medium Density (MD) residential (maximum of 10 dwelling units per acre) that would allow a maximum of 93 units on the subject site. The proposed density of approximately 4.95 dwelling units per acre is below the maximum of 10 dwelling units per acre permitted by the proposed General Plan designation. Therefore, the proposed 46 single-family homes under this project would be consistent with the proposed MD General Plan designation for the site. The site would be re -zoned to R-1-B, Residence Zone, as a small lot subdivision in accordance with Chapter 18.33 of the Development Code.

Small Lot Development: Regulations were adopted by the City Council on May 10, 2022, after receiving the Planning Commission's recommendation of approval for the new regulations. Small lot subdivisions are intended to provide an alternative to the traditional single-family subdivisions, thereby increasing options for fee simple homeownership opportunities.

Development standards in the small lot subdivision ordinance concerning minimum lot area, lot width, parking, open space, landscaping, storage, building height, and setbacks are applied in this case.

Conceptual architectural plans for the homes are proposed and included as part of this request. Building permits will be required for subsequent development of the single-family units on the site, which will be limited by the building height and setback standards as shown on the conceptual site development plans - typical lot detail. The minimum lot size requirement of 3,600 sf is being met. The maximum allowable building height is 35 feet or two stories, whichever is less. The proposed height for the units is a maximum of 29 feet. The minimum lot width of 45 feet applies and the proposed lots are approximately 50 feet wide, which meets this standard. Four parking spaces per lot are required, and all lots include two -car garages and two parking spaces on the driveway. On -street parking is being provided on both sides of the private streets for 46 on -street parking spaces for this project.

All areas not occupied by structures, driveways, parking areas, and pedestrian walkways shall have landscaping in the form of street trees, landscaped parkways, and slope erosion control planting; therefore, the project meets the applicable landscaping requirements. The overall landscaping of the project would consist of a variety of native and non-native evergreen and deciduous trees and shrubs that would provide shade, ornamental accents, and slope stabilization. Non-native vines would be used for freestanding and any plantable walls where applicable. Non-native and native shrubs would be used on slopes, turf or grass would be limited to the open space areas, and primarily native plants would be used for the biofiltration basins. Plant selection is based on the Water Efficient Landscaping Ordinance in the City's Development Code, Chapter 18.56.
11 /15/2022 PH 1 Page 3 of 1307

MEETING DATE: NOVEMBER 15, 2022 PAGE 4
SUBJECT: CAMINO LARGO RESIDENTIAL DEVELOPMENT (P21-0300) All of the proposed plant species would require low or moderate water use and be fairly drought tolerant, except for turf areas, which would require high water use. Common usable open space requirements would also be satisfied through the provision of one open space/park area totaling 14,923 sf. A total of 9,200 sf of common usable open space is required for this project; therefore, the open space requirement is being met on the site. Further, 9,200 sf of private usable open space would be divided among the 46 units, meeting the minimum required 200 sf of private usable open space per unit with a minimum 10-foot dimension.

Minimum setbacks are required as follows:
• 20-foot front yard from driveway line to face of garage and 10-foot front yard from driveway line to the remainder of the residential unit;
• 5-foot side yards with no encroachments allowed; and
• 10-foot rear yards with no encroachments allowed.

The project, as proposed, meets all setback requirements.

Each home will include a minimum of 160 cubic feet of enclosable overhead storage in the garage.

Proposed units would be constructed per the requirements of the California Building Code (CBC) that is in effect at the time building plans are submitted for permit approvals (including CALGreen requirements) and would include Heating, Ventilating and Air Conditioning (HVAC) units mounted on the ground.

As proposed, the project is consistent with applicable development standards for a small lot development in the R-1-B Zone.

General Plan: The proposed General Plan designation for the project site is Medium Density Residential 10 dwelling units per acre (10 du/ac). This land use designation supports residential uses, such as single- family detached units on smaller lots. Allowable uses in this designation and in the R-1-B Zone include single-family dwelling, accessory buildings, home occupations, and flower and vegetable gardening; therefore, the proposed single-family subdivision would be consistent with the General Plan. Further, the project would improve an underutilized site in a residential neighborhood with single-family homes on individual lots. In addition, the proposed development would provide a higher level of design quality, thereby helping preserve and enhance Vista's identity and image (Land Use and Community Identity (LUCI) Goal 1 in the General Plan).

Zoning / Development Code: The site is proposed to be zoned R-1-B Residence Zone for small lot development. The R-1-B zone allows for a single-family dwelling on each lot and accessory buildings (i.e., detached garage), home occupations, and flower and vegetable gardening. Therefore, if the City Council approves the applicant's request for a Tentative Subdivision Map and Site Development Plan, the proposed residential development would be consistent with the land uses permitted in the R-1-B Zone.

Open Space Easement Vacation: In 2009, an Open Space Easement was recorded on the vacant parcel south of the project site and across the private road of Camino Largo (APN 159-240-31). The San Diego County Recorder recorded the Open Space Easement ("OS Easement") as Document No. 2009-0419582 on July 28, 2009 (see Exhibit 8). The northern portion of the OS Easement overlaps the paved road of Camino Largo, a condition that has existed for at least the past five consecutive years, going back to 2017. The paved condition of this northern portion of the OS Easement has prevented this portion from being used for the open space purpose for which it was dedicated, and the applicant desires to vacate the conflicting portion of the OS Easement. Removing the conflicting portion of the OS Easement that overlaps the paved road will properly confine the OS Easement to only cover the parcel's actual open space area and will remove any potential conflict between this portion of the OS Easement and the proposed project improvements and the historic use of the Camino Largo roadway. As described in Exhibit 2, the OS Easement vacation area's disturbed and degraded condition as a paved road for the past five 11 /15/2022 PH 1 Page 4 of 1307

MEETING DATE: NOVEMBER 15, 2022 PAGE 5
SUBJECT: CAMINO LARGO RESIDENTIAL DEVELOPMENT (P21-0300) consecutive years meets the summary vacation requirement of the California Streets and Highways Code Section 8333(a).

Environmental Review. A Mitigated Negative Declaration (MND) was prepared for the proposed project, which is included as Exhibit "A" to Exhibit 1. The mitigation requirements are summarized in Appendix J of the MND. The public review period for the draft MND started on May 11, 2022, and ended on May 30, 2022. Five comment letters were received during that period, and written responses were prepared (contained in Appendix I of the MND). Impacts to Biological Resources, Cultural Resources and Tribal Cultural Resources, Hazardous Materials, and Noise were found to be potentially significant, but the proposed mitigation measures would result in less than significant impacts.

The Final IS/MND package was presented to the City Planning Commission on July 19, 2022. Prior to the hearing, the City received a comment letter on July 15, 2022 after the close of the public review period.

The July 15, 2022, comment letter was submitted by Delano & Delano on behalf of the Guajome Alliance for Responsible Development (GuARD). The comments in the July 15, 2022 letter did not trigger the recirculation of the Draft IS/MND pursuant to CEQA Guidelines Section 15073; however, the City determined that it would recirculate portions of the Draft IS/MND as a Revised IS/MND to provide the public an opportunity to review the additional analysis that further demonstrates the project's consistency with the applicable air quality attainment plan in the Air Quality section, and clarification to the language in the Land Use and Planning, and Population and Housing sections to explain that while the project site is not identified in Appendix B of the General Plan 2021-2029 Housing Element, the City's intent is to provide housing on underutilized sites, and that the project would assist in meeting the City's overall housing needs as outlined in the Regional Housing Needs Assessment (RHNA).

The information in the Revised IS/MND concluded there would be no new significant impacts that were not previously disclosed, nor would new or revised mitigation measures or project revisions be required. The Revised IS/MND was also available for a 20-day public review period from September 14, 2022 to October 3, 2022.

As noted in the Revised IS/MND, the City requested that reviewers limit their comments to the revised portions of the Revised IS/MND. A total of 12 comment letters were received on the Revised IS/MND, including one letter from a public agency, one from a law firm, and 10 from individuals. This Final Revised IS/MND contains topical responses to comments on Air Quality and Land Use and Planning (Topical Response No. 1 and Topical Response No. 2, respectively). The Revised IS/MND contains minor project changes for the following issues: (i) Camino Largo is no longer described as a gravel road; (ii) added recognition that the project site was annexed into the City in 2018; (iii) language added to define the cul de sac streets and private street near Lot B as private; (iv) language added to eliminate any requirement that the project remove two trees at the southeast corner of Camino Largo and North Santa Fe Avenue; (v) the drainage infrastructure has been modified to remove infrastructure from within the open space easement; and (vi) added requirement to summarily vacate of a portion of an open space easement.

Regarding the summary vacation, a portion of the existing 56-foot-wide reciprocal private road and utility easement which encompasses Camino Largo, a paved roadway, is located within an open space easement that was recorded in 2009 (see Exhibit 8). Due to this, it is necessary to vacate a 20-foot-wide portion of the open space easement that is paved and within the existing 56-foot-wide private drive reciprocal access and utility easement (recorded in 2013) to ensure no conflict between the open space easement, the proposed project improvements and the historic use of the roadway. This action is now required as part of the project approvals. The drainage infrastructure has been modified to move infrastructure outside of the open space easement. To accommodate this change, the project includes a pump station to regulate and release storm water drainage flows to the east, which would then be directed across Camino Largo. The pump station would be designed to be compliant with stormwater hydromodification requirements. At the time of final engineering and approval of project site plans, the applicant would demonstrate that the pump would not exceed the applicable noise requirements. The 11 /15/2022 PH 1 Page 5 of 1307

MEETING DATE: NOVEMBER 15, 2022 PAGE 6
SUBJECT: CAMINO LARGO RESIDENTIAL DEVELOPMENT (P21-0300) pump may be submerged or, if it is not submerged and is greater than three horsepower, it would be required to be enclosed.

The above -described project changes, including the vacation of a portion of the open space easement, would not result in additional environmental impacts not previously evaluated.

Traffic: The project proposes 46 single-family dwelling units, which will generate a total of 460 trips per day as identified in the Local Transportation Study report prepared by LLG, November 30, 2021.

Because the project will generate less than 500 trips per day, the project is concluded to have no significant transportation impacts (based on Vehicle Miles Traveled or VMT) for purposes of CEQA. No VMT analysis is triggered, and VMT-related improvements are not required. Senate Bill 743 (SB 743) resulted in a shift in the measure of effectiveness for determining transportation impacts from Level of Service (LOS) and vehicular delay to VMT. As of July 1, 2020, VMT analyses are required for use in all CEQA documents, and LOS analyses may not be used as a basis for requiring transportation -related improvements as project mitigation.

The North County Transit District (NCTD) provides transit service in Vista. Within the project area, NCTD operates two bus routes: Route 303 is a high -frequency route that travels between the Oceanside Transit Center and the Vista Transit Center and travels along North Santa Fe Avenue in the project area; Route 318 also travels between the Oceanside Transit Center and the Vista Transit Center and travels along Bobier Drive, within one mile of the project site. Route 303 has a bus stop approximately 0.10 mile south of the project site. The project would not affect these existing bus operations or facilities.

Planning Commission Hearing. A public hearing was held at the Planning Commission on July 19, 2022, to consider the project. At the completion of the hearing, the Planning Commission voted to recommend denial of the project, citing that the proposed project would not help preserve the existing surrounding neighborhoods. Findings for the denial are outlined in the Planning Commission Resolution 2022-13 (Exhibit 7).

Down Payment Assistance Program. California West Communities (CalWest), the applicant for the proposed project, is proposing to financially sponsor a First -Time Homebuyer program to assist five income -qualifying prospective homebuyers with purchasing a home in the proposed development. The proposed program is unique, as no other First -Time Homebuyer program is funded by a developer within the City. Additionally, the program targets households at or below 150 percent of the Area Median Income (AMI). Traditionally, publicly funded down payment assistance programs require households to be at or below 120 percent AMI. CalWest's goal is to increase homeownership for the "missing middle" (120 to 150 percent AMI) by financially contributing up to $875,000 for five households. This contribution will make owning a home more affordable for income -qualifying households. Below is an overview of the proposed program:
• Down payment and closing cost assistance in the form of a zero percent, non -amortizing, 30-year deferred second mortgage, known as a "silent second"
• An equity share provision for the first 15 years
• The second mortgage becomes due and payable, in full, upon sale of the property, transfer of the deed, and if the homeowner no longer occupies the property as their primary residence • Eligible applicants must be at or below 150 percent of the AMI ($160,350 for a family of four) • The loan cannot exceed 20 percent of the acquisition price • A preference is provided to households that have four or more persons • A preference is provided to eligible buyers who have lived and/or worked in Vista continuously for the past two years
• The maximum loan amount cannot exceed $175,000
11 /15/2022 PH 1 Page 6 of 1307

MEETING DATE: NOVEMBER 15, 2022 PAGE 7
SUBJECT: CAMINO LARGO RESIDENTIAL DEVELOPMENT (P21-0300) The proposed program will be administered by a nonprofit agency, who will work directly with the applicant and first mortgage lender. Loan payoffs and applicable equity share will be recirculated into the program to continue to assist prospective income -qualifying homebuyers. Although the City will not be involved in servicing the loan, staff is supportive of the program. The program can make a significant impact in Vista homeownership, where often housing prices are outpacing income growth.

FISCAL IMPACT: The estimated value of the project at completion is approximately $39 million, which is anticipated to generate approximately $57,720 per year in property tax revenue for the City.

EXHIBITS:

1. City Council Resolution No. 2022- , approving a Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program for 46 single-family homes located at 2123 N. Santa Fe Avenue (APN 159-240-07-00) with Exhibit A (page 8)

2. City Council Resolution No. 2022- , authorizing and approving the summary vacation of a portion of an open space easement on APN 159-240-31 with Exhibits A and B (page 1143)

3. City Council Ordinance No. 2022- approving a Zone Change from A-1 Agricultural Zone to R-1-13 Residential Zone Small Lot Development to allow for 46 single-family homes on a 9.3-acre site located at 2123 N. Santa Fe Avenue (APN 159-240-07-00) with Exhibit A (page 1149)

4. City Council Resolution No. 2022- , approving a General Plan Amendment, Site Development Plan and Tentative Subdivision Map for 46 single-family homes located at 2123 N. Santa Fe Avenue with Exhibits A, B and C (page 1152)

5. City Council Resolution No. 2022- , denying a General Plan Amendment, Zone Change, Site Development Plan and Tentative Subdivision Map for 46 single-family homes located at 2123 N. Santa Fe Avenue with Exhibit A (page 1232)

6. July 19, 2022, Planning Commission Staff Report and Minutes (page 1278)

7. Planning Commission Resolution 2022-13 (page 1294)

8. Open Space Easement recorded by the San Diego County Recorder as Document No. 2009-0419582

9. Location Map (page 1307) (p. 1297)

10. Large Scale Plans (limited distribution)
11 /15/2022 PH 1 Page 7 of 1307

RESOLUTION NO. 2022-

A RESOLUTION OF THE CITY COUNCIL OF THE CHARTERED CITY OF

VISTA, CALIFORNIA, APPROVING A MITIGATED NEGATIVE DECLARATION AND MITIGATION MONITORING AND REPORTING PROGRAM FOR 46
SINGLE-FAMILY HOMES LOCATED AT 2123 N. SANTA FE AVENUE
APPLICANT: CALIFORNIA WEST COMMUNITIES
PLANNING CASE NO. P21-0300
The City Council of the City of Vista does resolve as follows:

Findings. The City Council hereby finds and declares the following:

A. The applicant filed an application for a Summary Vacation of a portion of an Open Space Easement, General Plan Amendment, Zone Change, Site Development Plan and Tentative Subdivision Map to develop 46 single-family dwelling units located at 2123 N. Santa Fe Avenue.

B. A Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program was prepared for the project.

C. A notice describing the proposed project and the intent to adopt a Mitigated Negative Declaration was duly mailed to all property owners within 500 feet of the property boundaries and published in the "Union Tribune," a newspaper of general circulation, more than 30 days prior to the City Council public hearing in order to provide an opportunity for public comment on the Mitigated Negative Declaration.

D. The Draft Mitigated Negative Declaration was available for a 20-day public review period from May 11, 2022, to May 30, 2022. Five comment letters were received regarding the information included in the Draft Mitigated Negative Declaration. The City's responses to the comments received are included in the Mitigated Negative Declaration, attached hereto as Exhibit "A".

E. Potentially significant environmental impacts in the areas of biological resources, cultural resources, hazards, land use, and noise would be mitigated to less than significant levels with implementation of the mitigation measures included in the Mitigation Monitoring and Reporting Program, attached hereto as Appendix "J" to Exhibit "A".

F. On July 19, 2022, the Planning Commission held a public hearing, duly noticed and conducted in the manner required by law, on said application and proposed Mitigated Negative Declaration, and at said public hearing every person wishing to address the Planning Commission regarding said application and Mitigated Negative Declaration had an opportunity to do so.

G. The City received a July 15, 2022, comment letter from Delano & Delano and determined that, although the letter did not trigger recirculation of the Draft Mitigated Negative Declaration, the City recirculated portions of the Draft Mitigated Negative Declaration ("Revised Draft Mitigated Negative Declaration") to provide the public with an opportunity to review the additional analysis related to the sections of Air Quality, Land Use and Planning, and Population and Housing.

P21-0300 RESO MND
EXHIBIT 1
11 /15/2022 PH 1 Page 8 of 1307

RESOLUTION 2022-

CITY COUNCIL OF THE CHARTERED CITY OF VISTA
PAGE 2
H. The Revised Draft Mitigated Negative Declaration was available for a 20-day public review period from September 14, 2022, to October 3, 2022. 12 comment letters were received regarding the information included in the Revised Draft Mitigated Negative Declaration.

The City's responses to the comments received are included in the Mitigated Negative Declaration, attached hereto as Exhibit "A". As a result of the Revised Draft Mitigated Negative Declaration, there would be no new significant impacts that were not previously disclosed, nor would new or revised mitigation measures or project revisions be required.

I. On November 15, 2022, the City Council held a public hearing, duly noticed and conducted in the manner required by law on said applications and proposed Mitigated Negative Declaration, and at said public hearing, every person wishing to address the City Council regarding said application and Mitigated Negative Declaration had an opportunity to do so.

J. In accordance with the California Environmental Quality Act and the State CEQA Guidelines, the City Council has reviewed and considered said application and Mitigated Negative Declaration, all written comments received, and all comments presented at the public hearing in reaching its decision on the application.

2. Action.

A. The above recitals are true and correct.

B. Based upon the Initial Study and the reports, comments and recommendations received, the City Council finds and determines that there is no substantial evidence in the record before it that the project, if mitigated as proposed in the Mitigation Monitoring and Reporting Program, may have a significant effect on the environment.

C. The City Council, pursuant to Section 15074 of the California Environmental Quality Act Guidelines, hereby adopts the Mitigated Negative Declaration and Mitigation Monitoring and Reporting Program, a copy of which is attached hereto as Exhibit "A", and Appendix "J" to Exhibit "A".

D. The City Council hereby authorizes and directs the City Planner to prepare and file a Notice of Determination with respect to said Mitigated Negative Declaration in the office of the County Clerk of the County of San Diego, as provided in the California Environmental Quality Act.

P21-0300 RESO MND
11 /15/2022 PH 1 Page 9 of 1307

RESOLUTION 2022-

CITY COUNCIL OF THE CHARTERED CITY OF VISTA
PAGE 3

3. Adoption. PASSED AND APPROVED at a regular meeting held on the 1511 day of November, 2022, by the following vote:

AYES:

NOES:

ABSTAIN:

APPROVED AS TO FORM:

WALTER CHUNG, CITY ATTORNEY
By:

APPROVED
Walter C. Chung
20221104160627

JUDY RITTER, MAYOR
ATTEST:

KATHY VALDEZ, CITY CLERK
By:

Exhibits:

A. Mitigated Negative Declaration / Mitigation Monitoring and Reporting Program P21-0300 RESO MND
11 /15/2022 PH 1 Page 10 of 1307

CITY OF VISTA
C A L I F 0 R N I A
PROJECT NAME: Camino Largo Residential Project
PROJECT LOCATION: Northeast of the intersection of North Santa Fe Avenue and Camino Largo north of Taylor Street and south of Osborne Street APN: 159-240-07
PROJECT APPLICANT: California West Communities
5927 Priestly Drive, Suite 110
Carlsbad, CA 92008
(760) 918-6768
LEAD AGENCY: City of Vista
Community Development Department
Planning Division
200 Civic Center Drive, Vista, CA 92084
Patsy Chow, Deputy Director of Community Development /
City Planner
(760) 643-5390

PUBLIC REVIEW
PERIOD:

September 14. 2022 to October 3, 2022
A Revised Initial Study/Mitigated Negative Declaration (IS/MND) for the Camino Largo Residential Project (project) was prepared and circulated for a 20-day public review beginning September 14, 2022 and closing on October 3, 2022.

This Final Revised IS/MND has been prepared in accordance with the requirements of the California Environmental Quality Act (CEQA) and the CEQA guidelines. The purpose of the Final Revised IS/MND is to provide the decision -making body, in this case the City of Vista (City), public and quasi -public agencies and groups, and the general public, environmental impact information relative to the proposed project. The City will consider the information contained in this Final Revised IS/MND prior to approving the project.

All written comments received on the Revised IS/MND during the public review period, responses to the comments on the Revised IS/MND, and new revisions to the Revised IS/MND to provide additional clarification and address comments received have been incorporated into this Final Revised IS/MND.

Each comment has been assigned a number with a corresponding response, which are provided in Attachment B to this Final Revised IS/MND.

Camino Largo Residential Project Final Revised IS/MND
T17TV2b22 PH 1 Page 11 of 1307

Following the public review period of the Revised IS/MND, clarifications and revisions have been incorporated into the Final Revised IS/MND in response to public comments received or the City's desire to clarify a matter. More specifically, clarifications have been made to Chapter 2, Environmental Setting and Project Description, pages 2-2 through 2-4 (as discussed below) to acknowledge that the proposed project entitlements include the approval of a summary vacation of a portion of an open space easement to accommodate the proposed project improvements within the existing disturbed portion of the roadway, Camino Largo. Additional minor clarifications have been made within Chapter 2, to recognize that the project site was annexed into the City in 2018, clarify the configuration of the access drives that extend from Camino Largo, and to eliminate the reference to Camino Largo as a gravel roadway. Lastly, the final sentence on page 2-2 has been eliminated as the project would not require the removal of the trees. The text modifications within the final environmental document do not affect the environmental analysis or conclusions of the IS/MND. Revisions to the IS/MND are reflected in a strikeout/underline format.

In accordance with CEQA Guidelines Section 15073.5(c)(4), the addition of new information that clarifies, amplifies, or makes insignificant modifications does not require recirculation as there are no new impacts and no new mitigation identified. An environmental document need only be recirculated when there is the identification of new significant environmental impact(s), or the addition of a new mitigation measure required to avoid a significant environmental impact.

CEQA Overview
The City prepared a Draft IS/MND that was available for a 20-day public review period from May 11, 2022 to May 30, 2022. All interested persons, organizations, and agencies had an opportunity during this time to submit written comments on the Draft IS/MND to the City. The City received five comment letters during the public review period for the Draft IS/MND. Subsequently, the City prepared a Final IS/MND, that includes the MMRP and Response to Comments received on the Draft IS/MND. The Final IS/MND package was presented to the City Planning Commission on July 19, 2022. Prior to the hearing, the City received a comment letter on July 15, 2022 after the close of the public review period.

The July 15, 2022 comment letter that was submitted by Delano & Delano on behalf of Guajome Alliance for Responsible Development (GuARD). The comments in the July 15, 2022 letter did not trigger the recirculation of the Draft IS/MND pursuant to CEQA Guidelines Section 15073. However, the City decided that it would recirculate portions of the Draft IS/MND as a Revised IS/MND to provide the public an opportunity to review the additional analysis that further demonstrates the project's consistency with the applicable air quality attainment plan in the Air Quality section, and clarification to the language in the Land Use and Planning, and Population and Housing sections to explain that while the project site is not identified in Appendix B of the General Plan 2021-2029 Housing Element, the City's intent is to provide housing on underutilized sites and the project would assist in meeting the City's overall housing needs as outlined in the Regional Housing Needs Assessment (RHNA).

The information in the Revised IS/MND concludes there would be no new significant impacts that were not previously disclosed, nor would new or revised mitigation measures or project revisions be required. The Revised IS/MND was also available for a 20-day public review period from September 14, 2022 to October 3, 2022. The City received 12 comment letters during the public review period for the Revised IS/MND.

as part of the Revised IS/MND or duplicates of comments made on the Draft IS/MND were deemed to be outside the scope of recirculated topics, For such comments, the reader is referred to a topical response that further explains the City's obligations to respond to comments outside of the scope of Revised IS/MND as outlined in CEQA Guidelines Section 15088 (Topical Response No. 3, Duplicate Comments or Other Comments Outside the Scope of the Revised IS/MND).

Lastly, because of comments made on the Revised IS/MND, it was determined that a portion of the existing 56-foot-wide reciprocal private road and utility easement which encompasses Camino Largo, a disturbed roadway, is located within an open space easement that was recorded in 2009 (see Figure 4, Existing Easements Overlay, Attachment A). To address this, the proposed project entitlements now include a summary vacation to vacate a 20-foot-wide portion of the open space easement that is disturbed and within the existing 56-foot-wide private drive reciprocal access and utility easement (recorded in 2013) to remove any potential conflict between the open space easement and the proposed project improvements (see Figure 5, Easement Area, and Figure 6, Vacation Request Overlay, Attachment A). Camino Largo has historically served as an access road for existing residents; for over five consecutive years since the open space easement was dedicated to the City. As noted above, the Final Revised IS/MND has been revised to reflectthatthis action would be required. Further the drainage infrastructure has been modified to remove infrastructure from within the open space easement as well (see Figure 3, Site Plan, Attachment A). To accommodate this change, the project includes a pump station to regulate and release flow to the east, which would then be directed across Camino Largo. The pump station would be designed to be compliant with stormwater hydromodification requirements. At the time of final engineering and approval or project site plans, the applicant would demonstrate that the pump would not exceed the applicable noise requirements.

The pump may be submerged or if not and greater than three horsepower it would be required to be enclosed.

These changes in the project description do not affect the analysis or impact conclusions contained within the Final Revised IS/MND or Draft IS/MND, as potential impacts resulting from the proposed improvements to Camino Largo were described and evaluated in the Draft IS/MND. Specifically, the analysis included the evaluation of the improvement of Camino Largo from an unclassified road to a two-way paved street with a curb and gutter system and sidewalks. Further, the document considered that the southern portion of Camino Largo would be paved to a minimum width of 28 feet. Vacation of a portion of the open space easement would occur prior to the start of construction and would not result in additional environmental impacts not previously evaluated, nor would it affect implementation of the proposed project improvements.

The Final Revised IS/MND also includes the Final IS/MND (including the Technical Appendices, and copies of the public letters commenting on the Draft IS/MND, the City's responses thereto, and the Mitigation Monitoring and Reporting Program (MMRP), which are included as Attachment C of this document.

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TABLE OF CONTENTS
Topic Pale
Chapter1 - Introduction.....................................................................................................................1-1 CEQAOverview............................................................................................................................ 1-1 Chapter 2 - Environmental Setting and Project Description..............................................................2-1 ProjectOverview.......................................................................................................................... 2-1 Existing Environmental Setting.................................................................................................. 2-1
SurroundingLand Uses.............................................................................................................. 2-2
Proposed Project Description..................................................................................................... 2-2
Chapter 3 - Initial Study Environmental Checklist..............................................................................3-1 ProjectInformation..................................................................................................................... 3-1
Environmental Factors Potentially Affected.............................................................................. 3-2
Environmental Determination....................................................................................................3-2 Evaluation of Environmental Impacts........................................................................................ 3-3
III. Air Quality.......................................................................................................... 3-4
XI. Land Use and Planning...................................................................................3-11 XIV. Population and Housing.................................................................................3-16 Chapter 4 - References and List of Preparers...................................................................................4-1 References.................................................................................................................................. 4-1
Individuals and Organizations Consulted.................................................................................. 4-3
Preparers..................................................................................................................................... 4-3
Attachment A - Figures
Attachment B - Responses to Comments on the Revised IS/MND Attachment C - Final IS/MND (June 2022)
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City of Vista
Chapter 1 - Introduction
Chapter 1 - Introduction
CEQA Overview
The City has prepared a Revised IS/MND for the proposed Camino Largo Residential Project General Plan Amendment, Zone Change, Tentative Subdivision Map, and Site Development Plan (project).

The Draft IS/MND was previously circulated for public review from May 11, 2022 to May 30, 2022. All interested persons and organizations had an opportunity during this time to submit their written comments on the Draft IS/MND to the City. Since the previous circulation, portions of the Draft IS/MND have been revised to provide additions and changes to the environmental analysis, pertaining to the issue areas of Air Quality, Land Use and Planning and Population and Housing (discussed further below). While these revisions do not meet the criteria described under State CEQA Guidelines Section 15073.5(b)(1), the City has determined to afford interested parties an opportunity to comment on the additional analysis and revised language and affected sections of the Draft IS/MND shall be recirculated.

Specifically, as a result of a comment letter that was received after the close of the previous public review comment period (May 11, 2022 to May 30, 2022), the City has revised portions of the Draft IS/MND as appropriate, to provide additional information and analysis to address whether the vehicle trips associated with the development of the project site would exceed what was accounted for in the State Implementation Plan (SIP). To determine this, additional analysis was conducted to demonstrate consistency between the proposed project and the growth assumptions used in the SIP. The analysis compares the SANDAG Series 13 Regional Data (which the 2020 Attainment Plan derives growth assumptions) to the number of units that are forecasted to be constructed in the City (number of units that have been recently constructed and/or are reasonably foreseeable to be constructed) throughout the planning horizon. After adjusting for projects that did not come to fruition and additional projects that have been approved/entitled and, including to be conservative, those that are pending/in review process at the City, there would be an additional 1,121 units to be constructed in the City since 2020.

The additional 1,121 units, which includes the proposed 46 units associated with the project, would result in 33,936 units, which is within the number of units that were considered in the SANDAG forecast and thereby the Attainment Plan for 2035 and 2050 (35,307 units and 40,181 units, respectively). Thus, the number of units and the associated vehicle trips in the proposed project would be consistent with the growth assumptions used to develop the region's Attainment Plan. Impacts would remain less than significant and this additional analysis does not merit changes to the Air Quality, Greenhouse Gas Emissions, and Energy Technical Report, as included as Appendix A of the Draft IS/MND (Attachment C).

In addition, the Land Use and Planning and Population and Housing sections are being recirculated to include clarifications in relation to the City's General Plan Housing Element and the Regional Housing Needs Assessment (RHNA). The City requested that reviewers limit their comments to the revised portions of the Revised IS/MND.

This Revised IS/MND includes onlythe sections of the Draft IS/MND that were recirculated: Air Quality; Land Use and Planning; and Population and Housing. The Draft IS/MND is included as Attachment C of this Revised IS/MND. As shown in this Revised IS/MND and based on the analysis contained in the Draft IS/MND, it has been determined that the proposed project would not result in any significant impacts that cannot be mitigated to less than significant levels. The Revised IS/MND concludes that the project would result in the following categories of impacts, depending on the environmental resource involved: no impact; less than significant impact; or less than significant impact with the implementation of project -specific mitigation measures. Therefore, preparation of a Mitigated Camino Largo Residential Project Final Revised IS/MND
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City of Vista
Chapter 1 - Introduction
Negative Declaration is appropriate. No additional mitigation measures are proposed as a result of the changes included in this Revised IS/MND.

Comments on both documents, the Draft IS/MND (circulated from May 11, 2022 to May 30, 2022) and this Revised IS/MND, are included in the Final Revised IS/MND (Please see Attachment B, Response to Comments on the Revised IS/MND and Attachment C, Final IS/MND).

In accordance with Section 15074 of the State CEQA Guidelines, prior to approving the project, the City Council will consider the Revised IS/MND together with any comments received during the public review process and approve the project only if it finds that there is no substantial evidence that the project will have a significant effect on the environment and that the Revised IS/MND reflects the independent judgment and analysis of the City Council.

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City of Vista Chapter 2 - Environmental Setting and Project Description Chapter 2 - Environmental Setting
and Project Description
Project Overview
The proposed project involves removal of a non -operational an existing nursery operation and the construction of 46 two-story detached single-family residential units on 46 separate lots. The project site is 9.3 acres in size and comprises one parcel (Assessor's Parcel Number [APN] 159-240-07).

The project site, which was annexed into the City in 2018, has a General Plan land use designation of Rural Residential (RR) and the project would require a General Plan Amendment to designate the site as Medium Density Residential (MD Residential) (10 dwelling units [du]/acre). The project would also require a zone change from Agricultural (A-1) to Residential (R-1-13, small lot subdivision, 3,600 square foot [sf] lots). The subject property is in the northwest portion of the City, within San Diego County (County) (see Figure 1, Regional Location, in Attachment A).

The property is located northeast of the intersection of North Santa Fe Avenue and Camino Largo, south of the City's boundary with the County of San Diego. Guajome Regional Park is located to the west across North Santa Fe Avenue and single-family residences are to the south and east of subject project site. Current vehicular access to the project site is provided by a gate along North Santa Fe Avenue, just north of Camino Largo GUFFeRtaGees to the is - via -a-gr,a el-privAte-road that eYAeRds from North Santa FeAveRUe (Figure 2, Project Vicinity, in Attachment A).

Existing Environmental Setting
City of Vista
Vista is a largely built out, predominantly low -density residential community located approximately seven miles inland from the Pacific Ocean in northern San Diego County. Clusters of urbanizing higher density areas are scattered throughout the central portion of the City and along arterial roads. Vista is located in the rolling topography of the western foothills of the San Marcos Mountains, with elevations ranging from approximately 200 feet to about 750 feet above mean sea level (amsl). Broad views are provided from various points throughout the City with some higher elevations offering vistas of the Pacific Ocean to the west. In addition to the topography of the mountains and hills, the City is vegetated from the low-level creek beds to the steep slopes of the foothills, which also provide some scenic attributes of the community. The City also has two major creeks that flow through its boundaries, Buena Vista Creek and Agua Hedionda Creek.

Project Site
The project site supports a non -operational commercial palm tree nursery. The nursery operations consisted of selling palm trees that were grown aboveground and maintained in box stock containers.

Remnants of the former nursery remain onsite including hoop frames of the former greenhouses, palm trees in box planters, and piles of green waste. There is a structure that is associated with the former nursery operations located in the south-central portion of the site and trucks and machinery scattered throughout the site. Physical improvements on the site consist of internal dirt access drives, chain link fencing and gates, and wooden electrical transmission poles and overhead wires.

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City of Vista Chapter 2 - Environmental Setting and Project Description Topographically, there is an east -west trending ridge situated in the north central portion of the project site. Elevations on the project site range from 361 feet amsl at the top of the ridge to 295 amsl in the southwestern corner of the property adjacent to Camino Largo.

Surrounding Land Uses
The project site is located immediately south of the City's northwest boundary. Land uses surrounding the projectsite include Osborne Street, rural residential and nurseries to the north, North Coast Church to the north/northwest, rural residential, and single-family homes in the Sandalwood neighborhood to the south, Rancho Guajome Adobe Museum and Rancho Guajome Regional Park (in the City of Oceanside) to the west (see Figure 2 in Attachment A). The closest school to the site is Guajome Park Academy located at 2000 North Santa Fe Avenue, approximately 0.25 mile southwest of the project site. The closest City fire station to the site is Vista Fire Department (VFD) Station No. 3 located at 1070 Old Taylor Road, approximately one mile to the east. The closest police station to the site is the San Diego County Sheriff's Department (SDCSD) located at 30 Main Street Unit G130, approximately two miles southeast of the project site. The nearest public airports to the project site are McClellan Palomar Airport and Oceanside Municipal Airport, each located approximately five miles south and west of the project site, respectively.

Proposed Project Description
The project includes the conversion of the former nursery to residential land uses. To do so, the project would demolish 10,600 square feet (sf) of existing structures that include a greenhouse and a shed.

As shown in Figure 3, Site Plan (see Attachment A), the project involves the construction of 46 two-story single-family residences. The homes would range from 2,129 sf to 2,374 sf and extend to a height of no greater than 35 feet.

Architecturally, the project would provide three residential styles: Santa Barbara; Farmhouse; and Spanish Ranch, each constructed with stucco facades that are enhanced with wood and brick accents.

Flat planes would be disrupted with portions of the residences recessed further from the street front, covered front porches, and pitched roofs. Internally, the development would have commonality by using a neutral color palette while expressing individuality through a variation of architectural features such as shutters, arches, and porch and entryway size and placement. Retaining walls are planned for each lot with maximum heights of approximately five feet.

The project would provide 14,923 sf of common open space along the eastern perimeter of the project site. In addition, the project provides landscaped areas (including slopes) that would support a variety of groundcover and shrubs with mature trees within the eastern and northern perimeter of the project site as well as within buffers between individual rear yards.

Access would be provided by five four private cul-de-sac streets and a private drive that extend from Camino Largo. Resident parking would be provided via two -car garages and individual driveways with additional parking being provided along both sides of each private cul-de-sac-street and one side of the private drive. Camino Largo would be improved from an unclassified gel road to a two-way paved street with a curb and gutter system and sidewalks. The pavement along the southern half of Camino Largo would be improved to a minimum width of 28 feet. In addition, the five four private cul-de-sac streets would be 40 feet wide curb to curb to accommodate on -street parking on both sides of the streets, and the private drive would be 32 feet in width, accommodating parking on one side, which would meet the proposed parking requirements set forth in the small lot subdivision/residential development ordinance which was adopted by the City Council on May 10, 2022. Camino Largo would be paved and extended to a minimum width of 28 feet. The project would also include the addition of Camino Largo Residential Project Final Revised IS/MND
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City of Vista Chapter 2 - Environmental Setting and Project Description a stop sign at the intersection of Camino Largo and North Santa Fe Avenue. fi+-C-�H line of sight when turning south nntn NnrFh Santa Fe Avenue from Gamine Large, f
Presently there is an open space easement that was recorded in 2009 that extends into the 56-foot- wide private drive/reciprocal access/utility easement (granted in 2013) that includes Camino Largo (see Figure 4, Existing Easements Overlay, Attachment A). The project entitlements now include a public service easement summary vacation for a portion of an open space easement that extends into Camino Largo to remove any potential conflict between the open space easement and the proposed project improvements that would occur within and adjacent to the roadway area. The proposed vacation area includes a 20-foot portion of the open space easement that extends into the 56-foot- wide private road/reciprocal access and utility easement along Camino Largo that extends from APN 159-240-06 in the east to APN 159-240-33 in the west to allow the applicant to construct the improvements within Camino Largo (see Figure 5, Easement Area and Figure 6, Vacation Request Overlay, Attachment A). The portion of the open space easement that would be vacated is disturbed and has historically served for over five consecutive years since the open space easement was dedicated to the City, as the access road for the existing residents would provide access to the project and continue to provide access to the residents to the east.

To accommodate storm water flows and maintain water quality, a 6,572-sf biofiltration basin would be constructed in the southwest corner of the project site and a 4,675-sf underground storage vault/modular wetland system (MWS) would be constructed along the eastern perimeter of the site. A pump station would be located at the southeastern perimeter of the site to direct and regulate runoff from the MWS to the eastern portion of the project site. The pump station would either be subterranean or if above ground and over three horsepower, it would be enclosed to meet City noise requirements.

Additional storm drain facilities including a curb and gutter system would be part of the project design.

Other new and/or upgraded onsite infrastructure would connect locally to existing water, sewer and storm drain infrastructure that are within an existing easement that parallels Camino Largo.

An electrical transmission line and pole that currently traverse the site would be removed and electrical utilities would be undergrounded. A quitclaim of the current San Diego Gas and Electric (SDG&E) utility easement noted on the Tentative Subdivision Map would occur with a new easement created for the underground infrastructure.

Demolition is slated to commence in November 2022, with grading and trenching for underground infrastructure to begin in late winter/early spring 2023. Site paving and construction of the homes follow, with project completion anticipated in fall of 2023. In all, the project would include 40,950 cubic yards (cy) of export.

The project would require a General Plan Amendment from RR (1 du/ac) to MD Residential (10 du/ac) and a zone change from A-1 to R-1-B (small lot subdivision), 3,600 sf lots (minimum size) to accommodate the proposed residences.

Construction Best Management Practices
The project would incorporate best management practices (BMPs) during construction to reduce emissions of fugitive dust. The San Diego Air Pollution Control District (SDAPCD) Rule 55 - Fugitive Dust Control states that no dust and/or dirt shall leave the property line. SDAPCD Rule 55 requires the following (SDAPCD 2009):
(1) Airborne Dust Beyond the Property Line: No person shall engage in construction or demolition activity subject to this rule in a manner that discharges visible dust emissions into the Camino Largo Residential Project Final Revised IS/MND
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City of Vista
Chapter 2 - Environmental Setting and Project Description atmosphere beyond the property line for a period or periods aggregating more than three minutes in any 60-minute period.
(2) Track-Out/Carry-Out: Visible roadway dust as a result of active operations, spillage from transport trucks, erosion, or track-out/carry-out shall:
(i) be minimized by the use of any of the following or equally effective track-out/carry-out and erosion control measures that apply to the project or operation:
(a) track -out grates or gravel beds at each egress point; (b) wheel -washing at each egress during muddy conditions, soil binders, chemical soil stabilizers, geotextiles, mulching, or seeding; and for outbound transport trucks;
(c) using secured tarps or cargo covering, watering, or treating of transported material; and
(ii) be removed at the conclusion of each workday when active operations cease, or every 24 hours for continuous operations. If a street sweeper is used to remove any track-out/carry-out, only PMio-efficient (particulate matter less than 10 microns in diameter) street sweepers certified to meet the most current South Coast Air Quality Management District (SCAQMD) Rule 1186 requirements shall be used. The use of blowers for removal of track-out/carry-out is prohibited under any circumstances.

The control measures listed below are the BMPs that the project would incorporate for dust control and are included in the air emissions modeling:
• A minimum of two applications of water shall be applied during grading between dozer/grader passes;
• Paving, chip sealing, or chemical stabilization of internal roadways shall be applied after completion of grading;
• Grading shall be terminated if winds exceed 25 miles per hour (mph); • All exposed surfaces shall maintain a minimum soil moisture of 12 percent; • Dirt storage piles shall be stabilized by chemical binders, tarps, fencing, or other erosion control; and
• Vehicle speeds shall be limited to 15 mph on unpaved roads.

Additional Appro vals
Besides review under CEQA, the applicant and/or contractor of the proposed project would be required to obtain the following additional approvals and/or permits from the City: General Plan Amendment, Zone Change, Tentative Subdivision Map, Site Development Plan, Right -of -Way Permit, Grading Permit, Landscape Construction Plan, summary vacation of the 20-foot-wide paved portion of the open space easement that extends into Camino L� and (eventually) Building Permits. These approvals require meeting certain Conditions of Project Approval prior to obtaining the required permits. In addition, before the Final (Subdivision) Map is recorded, all Conditions of Project Approval (which include the mitigation measures identified in this document) must be satisfactorily completed. Other public agency approvals are identified in Chapter 3.

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City of Vista Chapter 3 - Initial Study Environmental Checklist Chapter 3 - Initial Study
Environmental Checklist
Project Information
Project Title: Camino Largo Residential Project
Lead Agency Name and Address: City of Vista
Community Development Department
Planning Division
200 Civic Center Drive
Vista, CA 92084
CONTACT PERSON: Patsy Chow, Deputy Director of Community Development / City Planner
(760) 643-5390
PROJECT LOCATION: Northeast corner of North Santa Fe Avenue and Camino Largo PROJECT APPLICANT: California West Properties
5927 Priestly Drive, Suite 110
Carlsbad, CA 92008
(760) 918-6768
GENERAL PLAN DESIGNATION: RR (1 du/acre)
ZONING DESIGNATION: A-1
DESCRIPTION OF PROJECT: See Chapter 2, Proposed Project Description.

SURROUNDING LAND USES AND SETTING: See Chapter 2, Proposed Project Description.

OTHER PUBLIC AGENCY APPROVALS: The San Diego Regional Water Quality Control Board (SDRWQCB) is responsible for approving the Notice of Intent and a Storm Water Pollution Prevention Plan (SWPPP) in
accordance with the requirements of the most recent National Pollutant Discharge Elimination System (NPDES) General
Construction Activities Permit. The project would also require a quitclaim of the current utility easement noted on the Tentative Subdivision Map from San Diego Gas and Electric (SDG&E) with approval from CPUC through the Advice Letter process.

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City of Vista Chapter 3 - Initial Study Environmental Checklist Environmental Factors Potentially Affected
Based upon the initial evaluation presented in the following IS, it is concluded that the proposed project would not result in significant adverse environmental impacts.

Environmental Determination
On the basis of the initial evaluation of the attached Initial Study:
❑ I find the proposed project COULD NOT have a significant effect on the environment and NEGATIVE DECLARATION will be prepared.
® I find that although the project could have a significant effect on the environment there will not be a significant effect in this case because revisions in the project have been made or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared. ❑ I find that the proposed project MAY have a significant effect on the environment and an ENVIRONMENTAL IMPACT REPORT is required.
❑ I find that the proposed project MAY have a "potentially significant impact" or "potentially significant unless mitigated" impact on the environment, but at least one effect (1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.
❑ I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

Signature
Date
The signature below signifies thatthe applicant has read and accepts the mitigation measures detailed in the Mitigated Negative Declaration.

Applicant or Owner
Date
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City of Vista Chapter 3 - Initial Study Environmental Checklist Evaluation of Environmental Impacts
The following IS checklist provides analysis of the proposed project's potential to result in significant adverse environmental impacts. Section 15063(c) of the Guidelines indicates that the purpose of an Initial Study is to:

1. Provide the Lead Agency ("City of Vista") with information to use as the basis for deciding whether to prepare an Environmental Impact Report (EIR) or Negative Declaration;

2. Enable an applicant or Lead Agency to modify a project, mitigating adverse impacts before an EIR is prepared, thereby enabling the project to qualify for a Negative Declaration;

3. Assist the preparation of an EIR, if one is required, by:
a) Focusing the EIR on the effects determined to be significant; b) Identifying the effects determined not to be significant; c) Explaining the reasons why potentially significant effects would not be significant; and, d) Identifying whether a program EIR, tiering, or another appropriate process can be used for analysis of the project's environmental effects.

4. Facilitate environmental assessment early in the design of a project.

5. Provide documentation of the factual basis for the finding in a Negative Declaration that a project will not have a significant effect on the environment.

6. Eliminate unnecessary EIRs.

7. Determine whether a previously prepared EIR could be used with the project.

Impact Terminology
The following terminology is used to describe the level of significance of impacts:
• A finding of no impact is appropriate if the analysis concludes that the project would not affect the particular topic area in any way.
• An impact is considered less than significant if the analysis concludes that it would not cause substantial adverse change to the environment and requires no mitigation. • An impact is considered less than significant with mitigation incorporated if the analysis concludes that it would not cause substantial adverse change to the environment with the inclusion of environmental commitments that have been agreed to by the applicant. • An impact is considered potentially significant if the analysis concludes that it could have a substantial adverse effect on the environment.

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City of Vista Chapter 3 - Initial Study Environmental Checklist Ill. Air Quality
Potentially
SignificantLess than
MitigationSignificant
•
Would tl7e project
Impact
Incorporated
Impact
Impact
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
❑
❑
®
❑
non- attainment under an applicable federal or state
ambient air quality standard?
c. Expose sensitive receptors to substantial pollutant
❑
❑
®
❑
concentrations?
d. Result in other emissions (such as those leading to
odors) adversely affecting a substantial number of
❑
❑
®
❑
people?
The discussion below is summarized and based on the analysis and conclusions contained within the Camino Largo Residential Project Air Quality, Greenhouse Gas Emissions, and Energy Technical Report (AQ, GHG, and Energy Report) (HELIX 2O21a) prepared for the proposed project. The report is included as Appendix A to t#is-the Draft-IS/MND (Attachment Q.

AIR QUALITYDISCUSSm
a. LESS THAN SIGNIFICANT IMPACT. The San Diego Air Pollution Control District (SDAPCD) and San Diego Association of Governments (SANDAG) are responsible for developing and implementing the clean air plan for the attainment and maintenance of the ambient air quality standards (AAQS) in the San Diego Air Basin (SDAB). In addition, the SDAPCD relies on the State Implementation Plan (SIP), which is a series of comprehensive plans that describe how an area will attain the national ambient air quality standards (NAAQS), The SIP also includes the SDAPCD's plans and control measures for attaining the ozone NAAQS. The regional air quality plan for San Diego County is SDAPCD's 2020 Plan for Attaining the National Ambient Air Quality Standards for Ozone in San Diego County (Attainment Plan).

The two principal criteria for conformance to the Attainment Plan are (1) whether the project would result in an increase in the frequency or severity of existing air quality violations, cause or contribute to new violations, or delaytimely attainment of air quality standards, and (2) whether the project would exceed the assumptions in the Attainment Plan.

The Attainment Plan relies on information from the California Air Resources Board (CARB) and SANDAG, including projected growth in the San Diego County, and mobile, area, and all other source emissions to project future emissions and determine from that the strategies necessary for the reduction of stationary source emissions through regulatory controls. CARB's mobile source emission projections and SANDAG's growth projections are based on population, employment and transportation trends, and land use plans developed by the local governments. Accordingly, projects that propose development that is consistent with the population and employment growth anticipated by these land use plans would be consistent with the Attainment Plan. If a project proposes development that results in growth greater than that anticipated in the adopted land use plans and SANDAG's growth projections upon which the Attainment Plan is based, the project may conflict with the Attainment Plan and could have a potentially significant impact on air quality. This situation would Camino Largo Residential Project Final Revised IS/MND
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City of Vista Chapter 3 - Initial Study Environmental Checklist warrant further analysis to determine if the project would exceed the growth projections used in the Attainment Plan for the specific subregional area.

CARB's mobile source emission projections and SANDAG's growth projections are based on population, employment and transportation trends, and land use plans developed by the local governments. Accordingly, projects that propose development that is consistent with the population and employment growth anticipated by these land use plans would be consistent with the Attainment Plan. If a project proposes development that results in growth greater than that anticipated in the adopted land use plans and SANDAG's growth projections upon which the Attainment Plan is based, the project may conflict with the Attainment Plan and could have a potentially significant impact on air quality.

SANDAG Series 13, Regional Data represent the baseline forecast, which is presented in the adopted 2015 Regional Plan and 2018 Regional Transportation Plan, from which the 2020 Attainment Plan derives growth projections. The SANDAG Series 13 Regional Data for the City indicates the City will support an additional 9,312 dwelling units between the years 2012 through 2050, for a total of 40,181 units in the year 2050: the SANDAG Series 13 Regional Data also predicts 35,307 units by 2035 for the City. To provide a conservative analysis, New Tables AO-1 and AQ-2 identify the projects from Table 40 of the General Plan Update Housing Element that have come to fruition in addition to projects that have either been approved by the City or are in the process of being heard for consideration/approval by the City since 2020 (City 2021: 2022). As shown in new Tables AO-1 and AO-2 below, to date adjusting for projects that did not come to fruition and additional projects that have been approved/entitled and conservatively including those that are pending/in review process with the City, including the proposed project, there is an additional 1,121 units within the City that have either been approved and/or are pending.

Table AQ-1. Entitled/Approved Units (as of August 17, 2022) Project
U n its
Vista Grande Subdivision
28 Bella Vista Apartments
48 North Santa Fe Plaza Apartments
19 The Alcove at Pala Vista
5 Taylor Terrace Apartment Development
12 619 Towns
10 Cedar Road Townhomes
35 Vista Hannalei
45 Civic Center Villas
10 Nassar Homes
22 Green Oak Villas
107
Pheasant Hill
24 Santa Anita Townhomes
24 Nueva Vista
22 Campbell Annexation
2 Brandin Iron Estates
4 Green Oak Ranch
3 Vista Grande Parcel Map
4 Foothill Drive Tentative Subdivision Map
6 Vista Grande Annexation
14 Anderson Lane Minor Subdivision
3 Alta Vista Subdivision
9 Alliance North Santa Fe
F 60
Warmlands Subdivision
I Li
-
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City of Vista
Chapter 3 - Initial Study Environmental Checklist
Project
Units
Olive Avenue Annexation
8 Anza Avenue Subdivision
15 TOTAL
550
Source: City 2022, Adopted and Certified Housing Element 2021-2029 Table AQ-2. Pending Projects (as of August 17, 2022)
Project
U n its
505 N Santa Fe Avenue
17 Sunset Drive Townhomes
38 1304 N. Santa Fe Apartments
36 1790 Knapp Drive Subdivision
9 1205 Melrose Way Subdivision
15 Highland Parcel Map
4 Rancho Lomas Verdes Annexation
153
Camino Largo Subdivision
46 650 Sycamore
253
TOTAL
571
Source: City 2022, Vista Interactive Map/Development Projects According to the California Department of Finance. the Citv had a total of 32.815 units as of the 2020 census. SANDAG Series 13 Regional Data have predicted 35,307 units by 2035 and 40,181 units by 2050. The additional 1,121 units, which includes the proposed 46 units associated with the project, would result in 33,936 units, which is within the number of units that were considered in the SANDAG forecast and thereby the Attainment Plan for 2035 and 2050. Thus, the project would be consistent with the growth assumptions used to develop the region's Attainment Plan and. therefore. impacts would be less than significant.

NIL 111. 19.
. _
lip
• _ I \ AI
eensmstent with the grevAh assumption used te develep the regien's At-tainnient Plan. As By develeping an underutilized site and helping the Gity meet its heusing needs, the prejeet weuild be residential grevAh the Gity as a result ef the preject, and the related Ghanges On regional ........ are aleeeunted fer the SIP, whieh is erafted te bring the San Diege Air Basin (SIDAB) inte attainment fee all „riteria pollutants Additionally, as detailed in item III b., below, the project would not result in any construction or operational period emissions in exceedance of established thresholds. Therefore, the proposed project would not conflict with or obstruct implementation of the Attainment Plan.

Impacts would be less than significant.
b. LESS THAN SIGNIFICANT IMPACT. The project would generate criteria pollutants in the short-term during construction and the long-term during operation. To determine whether a project would result in a cumulatively considerable net increase in criteria pollutant emissions that would violate an air quality standard or contribute substantially to an existing or projected air quality violation, the AQ, GHG, and Camino Largo Residential Project Final Revised IS/MND
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City of Vista Chapter 3 - Initial Study Environmental Checklist Energy Report (HELIX 2021a) evaluate the project's anticipated emissions using the quantitative emission thresholds established by the SDAPCD.

Construction Emissions
The project's temporary construction emissions were estimated using CalEEMod. The results of the modeling of the project's construction emissions of criteria pollutants and ozone precursors are shown in Table AQ43, Maximum Daily Construction Emissions. The data are presented as the maximum anticipated daily emissions for comparison with the SDAPCD thresholds. The complete CalEEMod output and a thorough discussion on methodology is provided in the AQ, GHG, and Energy Report (HELIX 2021a).

Table AQ43. Maximum Daily Construction Emissions
Construction Phase
V0C*
NOx*
C0*
sox*
PMso*
PM2.5*
Demolition

2.6 25.7

20.6 <0.1

2.3 1.3
Site Preparation

3.2 33.1

19.7 <0.1

19.8 11.4
Grading

1.9 20.9

15.3 <0.1

8.2 4.3
Paving

1.1 11.1

14.6 <0.1

0.6 0.5
Utilities

1.4 14.1

15.4 <0.1

0.7 0.7
Building Construction - 2022

1.7 15.6

16.4 <0.1

0.8 0.8
Building Construction - 2023

1.6 14.4

16.2 <0.1

0.7 0.7
Architectural Coatings - 2023

0.2 1.3

1.8 <0.1

0.1 0.1
Maximum Daily Emissions'

6.4 94.7

46.2 0.2

33.2 17.4
SDAPCD Thresholds
137
250
550
250
100
67 Exceed Thresholds?
No
No
No
No
No
No
Source: CalEEMod; USEPA AP-42 (output data is provided in Appendices A and B of the Draft IS/MND [Attachment Cl) 1 CalEEMod automatically calculates the maximum daily emissions based on overlapping phases for each year. For this project, the maximum daily emissions would occur in 2022 during the demolition, site preparation, and some grading activities overlap.
* Pollutant Emissions (pounds per day)
VOC = volatile organic compound; NOx = nitrogen oxides; CO = carbon monoxide; SOx = sulfur oxides; PMso = particulate matter 10 microns or less in diameter; PM2.5 = particulate matter 2.5 microns or less in diameter; SDAPCD = San Diego County Air Pollution Control District As shown in Table AQ43, the project's temporary construction -related criteria pollutant and precursor emissions would be below the SDAPCD's significance thresholds. Therefore, the project's construction activities would not result in a cumulatively considerable net increase of criteria pollutants that would violate any air quality standard or contribute substantially to an existing or projected air quality violation. Impacts would be less than significant.

Operational Emissions
The project's long-term maximum daily and annual operational emissions were also estimated using CaIEEMod. The results of the modeling of the project's operational emissions of criteria pollutants and precursors are shown in Table AQ-24, Operational Emissions. The data are presented as the maximum anticipated daily emissions and annual emissions for comparison with the SDAPCD thresholds. The complete CalEEMod output and a thorough discussion on methodology is provided in the AQ, GHG, and Energy Report (HELIX 2021a).

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City of Vista Chapter 3 - Initial Study Environmental Checklist Table AQ-14. Operational Emissions
Source I VOC* I NOx* CO* SOx* PMso* I PM2.5*
Dailv Emissions (pounds per davl2
Area

1.9 <0.1

3.8 <0.1
<0.1
<0.1
Energy
<0.1

0.3 0.1
<0.1
<0.1
<0.1
Mobile

1.5 1.8

15.1 <0.1

3.6 1.0
Total Project Emissions'

3.4 2.2

19.0 <0.1

3.7 1.0
SDAPCD Daily Thresholds
137
250
550
250
100
67 Exceed Daily Threshold?
No
No
No
No
No
No
Annual Emissions (tons ner vear)
Area

0.3 <0.1

0.3 <0.1
<0.1
<0.1
Energy
<0.1
<0.1
<0.1
<0.1
<0.1
<0.1
Mobile

0.3 0.3

2.7 <0.1

0.2 0.2
Total Project Emissions'

0.6 0.4

3.1 <0.1

0.2 0.2
SDAPCD Annual Thresholds
15 40
100
40 15
10 Exceed Annual Threshold?
No
No
No
No
No
No
Source: CaIEEMod (output data is provided in Appendix A of the Draft IS/MND [Attachment Cl) 1 Totals may not sum due to rounding.
2 Winter emissions are very slightly higher for most substances.

VOC = volatile organic compound; NOx = nitrogen oxides; CO = carbon monoxide; Sox = sulfur oxides; PM10 = particulate matter 10 microns or less in diameter; PM2.5 = particulate matter 2.5 microns or less in diameter; SDAPCD = San Diego County Air Pollution Control District As shown in Table AQ-24 the project's long-term emissions of criteria pollutants and precursors would not exceed the SDAPCD daily or annual screening thresholds. Therefore, the project's operational activities would not result in a cumulatively considerable net increase of criteria pollutants that would violate any air quality standard or contribute substantially to an existing or projected air quality violation. Impacts would be less than significant.
c. LESS THAN SIGNIFICANT IMPACT. Impacts to sensitive receptors are typically analyzed for operational period carbon monoxide (CO) hotspots and exposure to toxic air contaminants (TACs). An analysis of the project's potential to expose sensitive receptors to these pollutants is provided below.

Construction Diesel Particulate Matter Emissions
Implementation of the project would result in the use of heavy-duty construction equipment, haul trucks, on -site generators, and construction worker vehicles. These vehicles and equipment could generate the TAC diesel particulate matter (DPM). Generation of DPM from construction projects typically occurs in a localized area (e.g., at the project site) for a short period of time. Because construction activities and subsequent emissions vary depending on the phase of construction (e.g., grading, building construction), the construction -related emissions to which nearby receptors are exposed to would also vary throughout the construction period. During some equipment -intensive phases such as grading, construction -related emissions would be higher than other less equipment - intensive phases such as building construction. Concentrations of mobile -source DPM emissions are typically reduced by 70 percent at approximately 500 feet.

The dose (of TAC) to which receptors are exposed is the primary factor used to determine health risk.

Dose is a function of the concentration of a substance in the environment and the extent of exposure a person has with the substance; a longer exposure period to a fixed number of emissions would result in higher health risks. Current models and methodologies for conducting cancer health risk assessments are associated with longer -term exposure periods (typically 30 years for individual residents based on guidance from Office of Environmental Health Hazard Assessment [OEHHA]) and Camino Largo Residential Project Final Revised IS/MND
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City of Vista Chapter 3 - Initial Study Environmental Checklist are best suited for evaluation of long duration TAC emissions with predictable schedules and locations.

These assessment models and methodologies do not correlate well with the temporary and highly variable nature of construction activities. Cancer potency factors are based on animal lifetime studies or worker studies where there is long-term exposure to the carcinogenic agent. There is considerable uncertainty in trying to evaluate the cancer risk from projects that will only last a small fraction of a lifetime. Considering this information, the highly dispersive nature of DPM, and the fact that construction activities would occur at various locations throughout the project site, it is not anticipated that construction of the project would expose sensitive receptors to substantial DPM concentrations.

Impacts would be less than significant.

Construction Asbestos and Lead Based Paint Emissions
Asbestos dust and lead are known carcinogens classified as TACs by CARB. Both may be found in buildings constructed prior to 1979 when lead was used in some paint and asbestos was used as a component of some building materials such as walls, ceilings, insulation, or fireproofing. Demolition of existing structures erected prior to 1979 could result in the disturbance of asbestos and lead building materials resulting in emissions.

Airborne asbestos is regulated in accordance with the National Emission Standards for Hazardous Air Pollutants (NESHAP) asbestos regulations. Federal and state regulations prohibit emissions of asbestos from demolition or construction activities. Following identification of friable asbestos, federal and state Occupational and Safety Health Administration (OSHA) regulations require that asbestos trained, and certified abatement personnel perform asbestos abatement and that all asbestos - containing materials removed from on -site structures be hauled to a licensed receiving facility and disposed of under proper manifest by a transportation company certified to handle asbestos. In accordance with the SDAPCD Rule 1206, Asbestos Removal, Renovation, and Demolition, prior to commencement of demolition operations and prior to submitting the notifications required by Section (e) of Rule 1206, a facility survey shall be performed to determine the presence or absence of asbestos containing materials, regardless of the age of the facility (SDAPCD 2017). USEPA's Lead Renovation, Repair and Painting Rule (RRP Rule) requires that firms performing renovation, repair, and painting projects that disturb lead -based paint in structures built before 1978 have their firm certified by USEPA (or an authorized state), use certified renovators who are trained by USEPA- approved training providers, and follow lead -safe work practices. These regulations specify precautions and safe work practices that must be followed to minimize the potential for release of asbestos fibers or lead dust and require notice to federal and/or local government agencies prior to beginning demolition or renovation that could disturb asbestos containing materials. Therefore, compliance with established regulations would ensure that potential impacts associated with asbestos containing materials and lead -based paint during project demolition activities, Impacts would be less than significant.

Localized Carbon Monoxide Hotspots
A CO hotspot is an area of localized CO pollution caused by severe vehicle congestion on major roadways, typically near intersections. Vehicle exhaust is the primary source of CO. In an urban setting, the highest CO concentrations are generally found within close proximity to congested intersections.

Under typical meteorological conditions, CO concentrations tend to decrease as distance from the emissions source (i.e., congested intersection) increase. Project -generated traffic has the potential of contributing to localized "hot spots" of CO off site. Because CO is a byproduct of incomplete combustion, exhaust emissions are worse when fossil -fueled vehicles are operated inefficiently, such as in stop -and -go traffic or through heavily congested intersections, where the level of service (LOS) is severely degraded.

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City of Vista Chapter 3 - Initial Study Environmental Checklist The CAR also recommends evaluation of the potential for the formation of locally high concentrations of CO, known as CO hot spots. A CO hot spot is a localized concentration of CO that is above the state or national 1-hour or 8-hour CO ambient air standards. To verify that the project would not cause or contribute to a violation of the 1-hour and 8-hour CO standards, an evaluation of the potential for CO hot spots at nearby intersections was conducted.

The project's Local Transportation Study (Linscott, Law, and Greenspan, Engineers [LLG] 2021) evaluated whether there would be a change in the LOS at the intersections affected by the proposed project. The potential for CO hot spots was evaluated based on the results of the transportation study.

The Transportation Project -Level Carbon Monoxide Protocol (CO Protocol; California Department of Transportation [Caltrans] 1998) was followed to determine whether a CO hot spot is likely to form due to project -generated traffic. In accordance with the CO Protocol, CO hot spots are typically evaluated when: (a) the LOS of an intersection decreases to an LOS E or worse; (b) signalization and/or channelization is added to an intersection; and (c) sensitive receptors such as residences, schools, hospitals, etc., are located in the vicinity of the affected intersection or roadway segment.

According to the transportation study, three intersections would operate at LOS E or F in the horizon year and experience an increase in delay from the project:
• N Santa Fe Ave & Osborne Street - LOS E (AM)
• N Santa Fe Ave & Taylor Street - LOS E (AM)
• N Santa Fe Ave & Bobier Drive - LOS E/F (AM/PM)
Therefore, consistent with the CO Protocol, these findings indicate that further screening is required.

Although the SDAPCD does not, various air quality agencies in California have developed conservative screening methods. The screening methods of the Sacramento Metropolitan Air Quality Management District (SMAQMD) are used for this project because ambient CO concentrations within the SMAQMD jurisdiction are higherthan forthe project area, as measured by CARB, resulting in a more conservative analysis. The SMAQMD guidance states that a project will not result in a significant impact to local CO concentrations if it meets all of the below criteria:
• The affected intersection carries less than 31,600 vehicles per hour; The project does not contribute traffic to a tunnel, parking garage, bridge underpass, urban street canyon, below -grade roadway, or other location where horizontal or vertical mixing of air would be substantially limited; and
• The affected intersection, which includes a mix of vehicle types, is not anticipated to be substantially different from the County average, as identified by EMFAC or CaIEEMod models (SMAQMD 2009).

The highest traffic volume at the affected intersections is estimated to be 4,510 vehicles at the intersection of North Santa Fe Avenue and East Bobier Drive during the AM peak hour (LLG 2021). The intersection is not located in a tunnel, urban canyon, or similar area that would limit the mixing of air, nor is the vehicle mix anticipated to be substantially different than the County average. There would be no potential for a CO hotspot or exceedance of State or federal CO ambient air quality standard because the maximum traffic volume would be substantially less than the 31,600 vehicles per hour screening level; because the congested intersection is located where mixing of air would not be limited; and because the vehicle mix would not be uncommon. Impacts would be less than significant.

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City of Vista Chapter 3 - Initial Study Environmental Checklist d. LESS THAN SIGNIFICANT IMPACT. The State of California Health and Safety Code Sections 41700 and 41705, and SDAPCD Rule 51, prohibit emissions from any source whatsoever in such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to the public health or damage to property.

According to the SCAQMD CEQA Air Quality Handbook, land uses associated with odor complaints include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting activities, refineries, landfills, dairies, and fiberglass molding operations (SCAQMD 1993).

The project, consisting of a residential development, would not include any of these uses nor are there any of these land uses in the project vicinity.

Emissions from construction equipment, such as diesel exhaust, and volatile organic compounds (VOCs) from architectural coatings and paving activities may generate odors; however, these odors would be temporary, intermittent, and not expected to affect a substantial number of people.

Additionally, such odors would be confined to the immediate vicinity of construction equipment. By the time such emissions reach any sensitive receptor sites, they would be diluted to well below any level of air quality concern. Furthermore, short-term construction -related odors are expected to cease upon the drying or hardening of the odor -producing materials. Long-term operation of the project would not be a substantial source of objectionable odors. Therefore, the project would not create objectionable odors affecting a substantial number of people. Impacts would be less than significant.

LAND USEAND PLANNING DISCUSSION
a. No IMPACT. The physical division of an established community typically refers to the construction of a linear feature, such as an interstate highway or railroad tracks, or removal of a means of access, such as a local road or bridge that would impact mobility within an existing community or between a community and outlying area. No new major supporting infrastructure facilities would need to be constructed and/or extended to the project site that could result in a physical disruption to an established land use or the local pattern of development The project site is within an urban area developed primarily with residential uses, in addition to a church, a museum, and county park nearby.

The proposed project includes the construction of 46 single-family homes on a lot that supports a non -operational nursery located within an area that has residential land uses to the south and east.

As stated in Section I of this IS/MND, the project is designed to adhere to the General Plan land use and community design goal of sharing common development patterns among neighborhoods. Thus, the project would be consistent with the surrounding land uses and would not divide an established community. Therefore, the proposed project would not physically divide an established community. No impact would occur.

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City of Vista Chapter 3 - Initial Study Environmental Checklist b. LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED. The proposed project's consistency with the City's General Plan (adopted 2012), the Municipal Code, and other land use plans and policies, and the surrounding land uses is discussed below.

General Plan 2030 Update
Land Use and Community Identity Element
The environmental goals and policies that apply to the proposed project are as follows:

LUCI Goal 2: Preserve and enhance the characteristics and features of neighborhoods that share common development patterns, topography, major streets, and zoning patterns.

LUCI Policy 2A Discourage subdivision design that disrupts the existing development pattern within established neighborhoods.

The design of the proposed project maintains the existing residential character of the surrounding area. The homes would be single-family similar to the neighborhood to the south and would not disrupt the existing pattern of development. Currently the site supports the remnants of a former nursery that is no longer operational. Conversely, the project would be a continuation of the denser residential development that is occurring further south of the site, creating a cohesive development pattern. In addition, the proposed residences would have a maximum height of 35 feet. Therefore, the proposed development would be compatible and consistent with the Land Use and Community Identity Element of the City's General Plan 2030 Update.

Circulation Element
As discussed in the Transportation/Traffic section of this IS/MND, the Circulation Element of the Vista General Plan 2030 Update (City 2012) states that the City has established LOS D as the threshold for acceptable operating conditions in designated areas. In addition, if a roadway or intersection is currently operating at a capacity less than LOS, additional traffic will have a substantial effect if it adds more than an average two seconds of delay.

Although the project would result in an increase in traffic near the site, the roadways and intersections within the study area would not conflict with the City's established LOS goals. Therefore, the project would not conflict with the Circulation Element of the City's General Plan.

Housing Element
The project site is designated as RR and would require a General Plan Amendment to MD Residential to accommodate the 46 single-family residences.

As part of the RHNA that was included in the City's General Plan Housing Element Update, the City has recognized the potential for underutilized parcels within the City f^r +h^ nr^;^^t �;+^ to accommodate higher density residential land uses as is demonstrated in the parGel sn^rvfin analysis of peter+,al heuising sites that the Gity prepared te identify underutilized sites designated fer residential er mixedd- s^ develepme t, to help meet the RHNA targets for the
2021-2029 planning period. This analysis which is also insl ded as Appendix R to the City's General Plan Housing Element Update, did not alleGate a residential density to the site, but did identify the n^rsol as suitable for residential development (Git„ 2021). Specifically, the RHNA allocation for the 2021-2029 planning period assigned Vista a new housing need of 2,561 units.

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City of Vista Chapter 3 - Initial Study Environmental Checklist The project would require a General Plan Amendment and zone change to accommodate the residential land uses; however, the transition of the site from previous agricultural land uses to residential is an extension of the existing land uses to the south. Therefore, these actions would not constitute a conflict with a land use plan adopted for the purposes of avoiding or mitigating an environmental effect as the proposed residences would be compatible with the like land uses that already exist south of the site. Moreover, the current RR designation and A-1 zone indicate the site is suitable for residential development since single-family residences are allowed uses by right in the current A-1 zone.

Resource Conservation and Sustainability Element
The applicable goals and policies that apply to the proposed project are as follows:

RCS Goal 2: Reduce GHG emissions from community activities and municipal facilities and operations within the City boundaries to support the State's efforts under Assembly Bill 32, Senate Bill 375, and other state and federal mandates, and to mitigate the community's contributions to global climate change.

RCS Policy 2.7: Through California Environmental Quality Act (CEQA) documents, evaluate and disclose the contribution new projects could have on climate change and require mitigation measures as appropriate.

RCS Goal 4: Preserve, protect, and enhance water quality in watersheds to which the City contributes storm water and urban runoff.

RCS Policy 4.6: Require the incorporation of Low Impact Development (LID) techniques in accordance with current storm water regulations to manage storm water and urban runoff, reduce runoff and pollution, reduce the footprint of development on each parcel, and assist in maintaining or restoring the natural hydrology of the site.

RCS Goal 12: Acknowledge, preserve, and protect the City's Native American heritage.

RCS Policy 12.3: Ensure that the San Luis Rey Band of Mission Indians is notified of any proposed discretionary planning or grading applications affecting lands with potential archaeological resources.

RCS Policy 12.2: In collaboration with NAHC and the San Luis Rey Band of Mission Indians, adopt procedures for protecting significant archeological features, and apply to projects requiring discretionary City approval.

The proposed project meets RCS Policy 2.7 and Goal 2 through the GHG emissions analysis prepared in Section VIII in this CEQA document. As previously described, the design of the proposed project incorporates a number of LID techniques and facilities that meets RCS Policy 4.6 and Goal 4. As discussed in Section V and in mitigation measures CR-1 through CR-6, procedures for protecting unknown significant archaeological features are appropriately described and included. As a result, the project would not conflict with the Resource Conservation and Sustainability Element of the City's General Plan.

Noise Element
The discussion below analyzes potential exterior/interior noise impacts after completion of the project as evaluated as part of the project Noise Assessment Study prepared by HELIX and included as Appendix G of the Draft IS/MND included as Attachment C.

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City of Vista
Chapter 3 - Initial Study Environmental Checklist
Exterior Noise Levels
Future on -site residential land uses would be exposed to noise from vehicular traffic along North Santa Fe Avenue west of the project site. The noise levels associated with vehicular traffic were modeled at the project site using Horizon Year 2050+ project average daily traffic (ADT) to conservatively assess future traffic noise conditions at the project site. The new residential land uses would not be compliant with the General Plan Noise Element limits if exterior use areas are exposed to noise exceeding 65 community noise equivalent level (CNEL).

Noise level contours were generated for North Santa Fe Avenue. The model provides the distances at which noise levels would exceed 65 CNEL. The 65 CNEL noise level contour would extend approximately 100 feet from the roadway centerline. The backyard exterior use areas of Lots 1 and 2 are located approximately 90 feet from North Santa Fe Avenue (see Figure 3 in Attachment A).

Therefore, at this distance, these areas may not be compatible with the City General Plan noise level limits for residential developments. Mitigation measure LU-1 would require the placement of permanent noise walls to reduce noise levels at these locations and reduce impacts to less than significant.

LU-1 On -Site Noise Barriers. Noise levels within the backyard areas of Lots 1 and 2 may be exposed to noise levels exceeding the City General Plan noise compatibility standards and shall be reduced to below 65 CNEL.

Noise reduction for these exterior use areas shall be accomplished through on -site noise barriers (walls). The wall shall be at least 6 feet in height and would break the line -of -sight between the backyards and North Santa Fe Avenue. To appropriately reduce noise levels, the wall should be constructed at the pad elevation for each lot.

The sound attenuation barrier must be solid. It can be constructed of masonry, wood, plastic, fiberglass, steel, or a combination of those materials, as long as there are no cracks or gaps, through or below the wall. Any seams or cracks must be filled or caulked. If wood is used, it can be tongue and groove and must be at least one inch total thickness or have a density of at least 3.5 pounds per square foot. Where architectural or aesthetic factors allow, glass or clear plastic 3/8 of an inch thick or thicker may be used on the upper portion, if it is desirable to preserve a view.

Interior Noise Levels
Traditional architectural materials are conservatively estimated to attenuate noise levels by 15 CNEL; therefore, if exterior noise levels at a building fagade exceed 60 CNEL, interior noise levels may exceed the 45 CNEL limit set forth in the City General Plan Noise Element for residential uses. The 60 CNEL noise level contour generated by North Santa Fe Avenue would extend 170 feet from the roadway centerline. The residences on Lots 1 and 2 have fagades that are located within 110 feet of North Santa Fe Avenue and would therefore be exposed to noise levels exceeding 60 CNEL. To ensure that the project's habitable rooms do not exceed 45 CNEL, mitigation measure LU-2 would be required.

LU-2 On -site Interior Noise Level Reduction. For the project's Lot 1 and 2 habitable areas (both living rooms and bedrooms), the following measures shall be incorporated in the design of the project to reduce interior noise levels to 45 CNEL or less:
• Minimum exterior wall requirement of STC 46 with a construction of standard 3/8-inch exterior one coat stucco over 1.0-inch rigid R-4 insulation over 1/2-inch shearwall on 2x6 studs with 5/8-inch Type "X" Drywall.

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City of Vista Chapter 3 - Initial Study Environmental Checklist • Minimum window requirement of STC 28 with a vinyl frame window construction of dual glazing window thickness 1/8-inch and 1/2-inch air gap. • Appropriate means of air circulation and provision of fresh air intake shall be incorporated in the project to allow windows to remain closed for extended intervals of time so that acceptable levels of noise can be maintained on the interior. • Buildings shall provide mechanical ventilation in accordance with the 2019 California Mechanical Code.

Other General Plan Elements
The proposed project would be adequately served by existing public services and would require compliance with the City's building and fire codes and with the seismic regulations within the CBC. The

9.3-acre project site does not contain any designated open space. Consequently, no inconsistencies with the City's Public Safety Element and Healthy Vista Elements are anticipated as a result of project implementation.

Habitat Conservation Plan or Natural Community Preservation Plan As discussed in Section IV, Biological Resources, of this IS/MND, the MHCP is a comprehensive, multiple jurisdictional planning program designed to develop an ecosystem preserve in northwestern San Diego County. Implementation of the regional preserve system is intended to protect viable populations of key sensitive plant and animal species and their habitats, while accommodating continued economic development and quality of life for residents of the north county region (AM EC 2003).

The project site is not within the planning area boundary of the MHCP and is not adjacent to any focused planning areas of the MHCP. Furthermore, the City does not have a Subarea Plan although the guidance contained within the MHCP is used as a basis for assessing projects within a regional context. The project would not conflict with the MHCP and no impacts would occur.

Zoning Ordinance
The project would require a zone change from A-1 to R-1-B (small lot subdivision), 3,600-sf lots (minimum size). The site's agricultural zoning is not an indication of a land use regulation enacted to protect scenic resources. According to the VMC Chapter 18.10, a variety of uses in addition to raising crops could occur under this zoning, including single-family residences, packing or processing plants for crops, silos, accessory buildings (including workshops and barns), farm labor housing, and residential care/transition homes. Comparatively, the residential land uses would result in a similar level of site disturbance in relation to what is allowed under the A-1 zone and would not involve the use of industrial chemicals associated with agricultural production.

Traffic Impact Analysis Guidelines
Implementation of SB 743 resulted in a shift in evaluating transportation impacts from LOS and vehicular delay to vehicles miles traveled (VMT). In response to SB 743 the City prepared guidelines to assess VMT, Traffic Impact Analysis Guidelines (City 2020). According to the City's Traffic Impact Analysis Guidelines, projects that are not consistent with the applicable General Plan land use designation only require a VMT analysis if the anticipated ADT would be greater than 500 trips (City 2020). As discussed in Section XVII, Transportation/Traffic, the project is not consistent with the City's General Plan land use designation for the site and will require a General Plan Amendment. However, Camino Largo Residential Project Final Revised IS/MND
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City of Vista Chapter 3 - Initial Study Environmental Checklist the project would generate a total of 460 ADT. The project would not exceed 500 trips per day, and therefore is below the threshold to require a VMT analysis.

Summary
With implementation of Mitigation Measures LU-1, and LU-2, the project would not conflict with any plan, policy, or regulation adopted for the purpose of avoiding an environmental impact.

POPULATIONAND HOUSING DISCUSSION
a. No IMPACT. Growth inducing impacts are caused by those characteristics of a project that foster or encourage population and/or economic growth, such as new housing (direct) or creation of a newjob center or the expansion of infrastructure to increase capacity (indirect).

The proposed project would directly add to the City's population by introducing 46 new single-family residences. According to SANDAG's 2019 population and housing estimates, the average household size in Vista is 3.26 people (SANDAL 2020). Applying this rate, an additional 46 residences could result in a population increase of approximately 150 people. Conservatively, if all homes were occupied by new residents, the project would represent an increase in the City's population of less than one -tenth of a percent.

The City's General Plan designates the project site as RR and is zoned as A-1, and the project would require a General Plan Amendment and zone change to accommodate the proposed residential land uses.
,.

As discussed in Section III, the City is forecasted to support an additional 9,312 dwelling units between the ,years 2012 through 2050, for a total of 40,181 units in the ,year 2050. Conservatively, to date, the City has an additional 1,121 units that have either been approved/entitled and/or are pending Camino Largo Residential Project Final Revised IS/MND
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City of Vista Chapter 3 - Initial Study Environmental Checklist under review process by the City. The additional 1,121 units, which includes the proposed 46 units associated with the project, would result in 33,936 units, which is within the planning projection.

Therefore, the population associated with the project has been accounted for in forecasts that are associated with local olanning documents and is not considered substantial unplanned growth.

In addition, a RHNA was prepared for the City in accordance with California law that requires local governments to facilitate and encourage the production of housing to accommodate population and employment growth. The 2021-2029 RHNA target for the City is 2,561 homes distributed among various income levels. In an effort to achieve this goal, the City has recognized the potential for underutilized sites throughout the City to accommodate higher density residential land uses.

Therefore, while the project would directly induce population in the area through the construction of new homes, this development is consistent with the City's intent to provide additional residential development throughout the City including those properties that are deemed underutilized. Given that the project would be within the planning forecasts and provide a portion of the RHNA allocation, it would not represent a significant impact due to unanticipated or unplanned growth. Direct impacts are less than significant.

The project does not involve any activities or features that would indirectly induce growth.

Infrastructure would be extended to the site; however, this extension would be from the existing municipal facilities that serve the greater project area and would not involve the installation of any infrastructure that would expand capacity beyond the site. Improvements to the current site access would also occur through upgrades to Camino Largo. The project site, which is already surrounded by existing development including a museum and regional park to the west, a church to the north, and existing residential neighborhood to the south, would not provide any new or future potential to accommodate development beyond the site. Therefore, the project would not indirectly contribute to substantial growth. Indirect impacts are less than significant. b. No IMPACT. The project site does not currently support any housing. Thus, the project would not displace any people. Therefore, the project would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere. No impact would occur.

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City of Vista Chapter 4 - References and List of Preparers Chapter 4 - References
and List of Preparers
References
Section 15150 of the State CEQA Guidelines permits an environmental document to incorporate by reference other documents that provide relevant data. The documents listed below are hereby incorporated by reference. The pertinent material is summarized throughout this IS/MND where that information is relevant to the analysis of impacts of the proposed project. Referenced documents that are followed by a star (*) are on file and available for review at the City of Vista Planning Division office located at 200 Civic Center Drive, Vista. Referenced documents that are followed by a double star (**) are available on the City's web site at htto:// www.cityofvista.com/ . bHA. 2021a. Preliminary Hydrology and Hydraulic Report. August 31. 2021b. Storm Water Quality Management Plan. December 6.

California Air Pollution Control Officers Association (CAPCOA). 2017. User's Guide for CalEEMod Version 2016.3.2. Available at: http://www.caCAPCOAleemod.com/ .

California Department of Conservation. 2021. Farmland Mapping and Monitoring Program. Available at: httr)s://maps.conservation.ca.gov/DLRP/CIFF/.
1996. Division of Mines and Geology. Update of Mineral Land Classification: Aggregate Materials in the Western San Diego County Production - Consumption Region. DMG Open - file Report 96 -04.

California Department of Finance. 2020. E-1 Population Estimates for Cities, Counties, and the State —January 1, 2019 and 2020. Accessed October 27, 2020. Available at:
http://www.dof.ca.gov/Forecasti ng/Demograph ics/Estimates/e-l/.

California Department of Forestry and Fire Protection (CAL FIRE). 2009. Very High Fire Hazard Severity Zones in LRA, As Recommended by CAL FIRE. June 11.

California Department of Transportation (Caltrans). 2013. Transportation and Construction Vibration Guidance Manual. September. Available at: https://www.dtsc- ssfl.com/files/lib cega/ref draft peir/Chap4 10-
Noise/68395 Caltrans, 2013b Vibration Guidance.pdf.

California Stormwater Quality Association (CASQA). 2019. Stormwater Best Management Practices Construction Handbook.

Federal Emergency Management Agency (FEMA). 2012. National Flood Hazard Layer FIRMette 06073CO757G. Available at: FIRMETTE 3723dd97-1765-4ffa-8b6e-7ce73b35f94c.r)df (fema.gov).

Camino Largo Residential Project Final Revised IS/MND
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City of Vista
Chapter 4 - References and List of Preparers
HELIX Environmental Planning, Inc. (HELIX). 2021a. Air Quality and Greenhouse Gas Emissions Technical Report. December.
2021b. Biological Resources Due Diligence Assessment of the Camino Largo Property. June 2021c. Addendum to Cultural Resources Survey and Assessment. December. 2021d. Noise Assessment. December.

San Diego Association of Governments (SANDAL). 2020. Demographic and Socioeconomic Estimates, Jurisdiction, Vista. August 19.

San Diego, County of. 2017. Multi -Jurisdictional Hazard Mitigation Plan. October.

South Coast Air Quality Management District (SCAQMD). 1993. CEQA Air Quality Handbook.

Tan, S.S., and Giffen, D.G. 1995, Landslide hazards in the northern part of the San Diego Metropolitan area, San Diego County, California, Landslide hazard identification map no. 35, Plate 35A, Department of Conservation, Division of Mines and Geology, DMG Open File Report 95-04.

United States Department of Commence Bureau of Census (U.S. Census Bureau). 2021. United States Census Bureau Quick Facts. Available at: https://www.census.gov/quickfacts/ fact/table/ocea ns id ecityca I ifo rn ia,vistacityca I ifo rn ia/ PST045221.

Vista, City of. 2022. Vista Interactive Map/List of Development Projects. August. 2022 and 2021. Housing Element 2021-2029. Available at:
https://www.cityofvista.com/home/showpublisheddocument/24161/6375816352233700

00. 2020. Parks and Facilities. Accessed October 27, 2020. Available at:
https://www.cityofvista.com/city-services/city-departments/recreation-com m- services/parks-and-facilities.
2020. Traffic Impact Analysis Guidelines. December.
2017. Sewer Master Plan 2017 Update, City of Vista Comprehensive Sewer Management Plan. August.
2012. Vista General Plan Update 2030. February.
2011. Vista General Plan Update 2030. Draft Program Environmental Impact Report. May.

Vista Irrigation District (VID). 2018. Potable Water Master Plan. April 9. 2016. 2015 Urban Water Management Plan. June 22.

Vista Unified School District (VUSD). 2020. Vista Unified School District Developer Fee Justification Study. August 13. Available at:
https://www.vistausd.org/UserFiles/Servers/Server 3644895/File/Vista%2OUnified%20SD %20F1 NAL%2ODeveloper%2OFee%2OJ ustification%2OStudy,%202020.pdf.

Camino Largo Residential Project Final Revised IS/MND
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City of Vista Chapter 4 - References and List of Preparers Individuals and Organizations Consulted
John Conley, AICP - Director of Community Development and Engineering, City of Vista Patsy Chow - Deputy Director of Community Development/City Planner Preparers
Kara Palm - Project Manager, HELIX Environmental Planning, Inc.

Julie McCall, Principal Environmental Planner, Ouality Assurance/Quality Control Toni Belzman Prineipal Envirenmental Planner, Quality Assuranee/Quiality Centre! Brendan Sullivan - Environmental Planner
Sean Bohac - Senior GIS Specialist
Ana Topete - Word Processor/Document Specialist
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City of Vista
Chapter 4 - References and List of Preparers
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Attachment A
Figures
The following section contains content that was obtained from a third party and may not achieve the same level of Americans with Disabilities Act (ADA) and Section 508 accessibility as other parts of this document. 11 /15/2022 PH 1 Page 43 of 1307

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Page 49 of 1301 ends

Attachment B
Responses to Comments on the
Revised IS/MND
The following section contains content that was obtained from a third party and may not achieve the same level of Americans with Disabilities Act (ADA) and Section 508 accessibility as other parts of this document. 11 /15/2022 PH 1 Page 50 of 1307

Responses to Comments
Pursuant to the California Environmental Quality Act (CEQA) Guidelines Section 15073, the Revised Initial Study/Mitigated Negative Declaration (IS/MND) was circulated for a 20-day period between September 14, 2022 to October 3, 2022 to interested parties for review and comment, including individuals that commented on the Draft IS/MND during the initial public review period of the Draft IS/MND from May 11, 2022 to May 30, 2022. No new significant environmental effects were identified during the public comment period for the Revised IS/MND.

CEQA Guidelines Section 15074 requires the decision -making body to consider the proposed Revised IS/MND together with any comments received during the public review process. The City of Vista has prepared this Responses to Comments package to address environmental comments received during the CEQA public review period for the Revised IS/MND. There is no requirement for a formal response to each of the comments received (unlike the requirement for a Final Environmental Impact Report) under Public Resources Code Sections 21091(d) and (f), and CEQA Guidelines Section 15074(b). However, to provide the Lead Agency with additional information upon which to base their decision, all comment letters received on the Revised IS/MND were evaluated for environmental issues, and written responses to comments on environmental issues were prepared. Twelve comment letters were received on the Revised IS/MND (see Table RTC-1). This Responses to Comments contains a copy of the comment letters and the City of Vista's response.

In accordance with CEQA Guidelines Section 15088.5(f)(2), when an environmental document is revised only in part and the lead agency is recirculating only the revised portions, the lead agency may request that reviewers limit their comments to the revised chapters or portions of the recirculated document.

Further, this CEQA Guidelines Section states the lead agency's request for reviewers to limit the scope of their comments shall be included either within the text or within an attachment of the revised document. As indicated on page 1-1 of the Revised IS/MND, the City requested that reviewers limit their comments to the revised portions of the Revised IS/MND, including the Air Quality, Land Use and Planning, and Population and Housing sections.

The comments have been made a part of the public record. The comments received on the Revised IS/MND during the public review period resulted in a change to the project description of the Revised IS/MND to include that the project entitlements now include a public service easement summary vacation for a 20-foot portion of an open space easement that extends into Camino Largo hat has historically served as an access road for existing residents; for over five consecutive years since the open space easement was dedicated to the City. The vacation will remove any potential conflict between the open space easement historic use of this roadway and the proposed project improvements that would occur within and adjacent to the disturbed open space area. The Draft IS/MND analyzed the proposed improvements as part of the project as a whole and they are identified in both the Draft IS/MND and Revised IS/MND (pages 2-3 and 2-4). Moreover, as shown in the new Figure 3, Site Plan, the project has been redesigned to remove the storm drain infrastructure out of the open space easement. As redesigned, a new pump station that would be compliant with stormwater hydromodification requirements and not exceed noise standards would regulate and release stormwater from the modular wetland system in the eastern portion of the site.

Additional minor clarifications have been made within Chapter 2, that acknowledge that the site was annexed into the city in 2018, to eliminate the reference to Camino Largo as a gravel roadway, clarify 11 /15/2022 AkI Page 51 of 1307

the configuration of the access drives that extend from Camino Largo, and that no offsite trees are being removed. The revisions on pages 2-3 and 2-4 and the text modifications within the final environmental document do not affect the environmental analysis or conclusions of the IS/MND. As such, no new information has been presented in the Final IS/MND that would require recirculation of the Revised IS/MND pursuant to CEQA Guidelines Section 15073.5. No new significant environmental impacts would result from the project or from new mitigation measures proposed for implementation.

TABLE RTC-1

COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD FOR THE REVISED IS/MND Comment Letter
Agency/Name
Date
A
Andrea Jacobs
October 2, 2022
B
Chris Jacobs
October 2, 2022
C
Delano and Delano
October 3, 2022
D
County of San Diego
October 5, 2022
E
Gabriel Jacobs
October 2, 2022
F
Joe and Paula Gregory
October 1, 2022
G
John Simone
September 28, 2022
H
Michael Jacobs
October 2, 2022
1 Norma Domurat
September 14, 2022
J
Phil Church
October 3, 2022
K
Robert Hugh
October 1, 2022
L
Ursula Sack
October 3, 2022
Additionally, the City has prepared three topical responses to address several common comments relating to the issues of air quality (air quality plan consistency), land use and planning (General Plan consistency, Regional Housing Needs Assessment, and SANDAG forecasting), and duplicate comments (i.e., comments the same as previously submitted on the Draft IS/MND during the initial public review period) or comments that are out of the scope of the Revised IS/MND. Thus, for such comments, the reader is referred to one or more of the topical responses that are presented below.

Topical Response No. 1, Air Quality
This topical response addresses the various comments raised during the review period for the Revised IS/MND as they relate to the recirculated Air Quality Section. In summary, comments on the Revised IS/MND that pertain to Air Quality are related to the project's consistency with the applicable air quality plans. The information contained herein, responds to such comments and commentors are referred back to this response, as appropriate.

As detailed in Section Ill.a of the Final Revised IS/MND (pages 3-4 through 3-6), one of the principal criteria for determining conformance to the San Diego Air Pollution Control District's (SDAPCD's) 2020 Plan for Attaining the National Ambient Air Quality Standards for Ozone in San Diego County (Attainment Plan) includes "whether the project would exceed the assumptions in the Attainment Plan." The discussion goes on to explain, "If a project proposes development that results in growth greater than that anticipated in the adopted land use plans and SANDAG's growth projections upon which the Attainment Plan is based, the project may conflict with the Attainment Plan and could have a potentially significant impact on air quality. This situation would warrant further analysis to determine if the project would exceed the growth projections used in the Attainment Plan for the specific subregional area." 11 /15/2022 AkI Page 52 of 1307

Comments were received that misinterpreted the above citations, stating that if a project proposes development that results in growth greater than assumed by SANDAG's growth projections, that project would, in fact, result in a significant and unavoidable impact. The citation above states that "the project may conflict with the Attainment Plan and could have a potentially significant impact." Page 3-5 of the Revised IS/MND goes on to state that "This situation would warrant further analysis." As discussed below and in greater detail in Section Ill.a of the Final Revised IS/MND (pages 3-4 through 3-6), the project would be consistent with the growth assumptions used to develop the region's Attainment Plan and therefore concludes that impacts associated with project's consistency with the applicable air quality plans would be less than significant.

The project site is zoned as Agricultural (A-1) and designated in the Vista General Plan as Rural Residential (RR). The project would require both a zone change to Residential (R-1-13, small lot subdivision, 3,600 square foot [sf] lots) and General Plan amendment to Medium Density Residential (MD Residential). However, while the proposed zoning and land use designation are not consistent with the existing land use plans and regulations, and the changes proposed by the project would result in increased residential density on the project site, Section Ill.a of the Revised IS/MND shows that the project would not result in growth that would exceed SANDAG's projections. Tables AQ-1 and AQ-2 of the Revised IS/MND (pages 3-5 and 3-6) identify entitled, approved, and/or pending projects within the City (as of August 17, 2022) and represent the most up to date numbers identifying that there are currently a total of 1,121 residential units that are under construction or may be constructed. The project is included on the pending project list (Table AQ-2) as it has an active application with the City.

This provides a conservative analysis by accounting for the proposed units in the City's overall future housing stock and allows for impacts to be assessed on a worst -case scenario considering all of the pending projects are developed as proposed. The reader is referred to the strike out/underline changes that were provided in the Revised IS/MND (Page 3-6):

According to the California Department of Finance, the City had a total of 32,815 units as of the 2020 census. SANDAG Series 13 Regional Data have predicted 35,307 units by 2035 and 40,181 units by 2050. The additional 1,121 units, which includes the proposed 46 units associated with the project, would result in 33,936 units, which is within the number of units that were considered in the SANDAG forecast and therebv the Attainment Plan for 2035 and 2050.

As concluded in the Final IS/MND and Revised Final IS/MND, the project would not result in any significant impacts that could not be mitigated to less than significant. The conclusions and supporting analysis contained in the IS/MND that the proposed project would not result in significant environmental effects are supported by substantial evidence contained in the record. Project impacts are adequately analyzed and assessed based on established methodologies and identified CEQA significance thresholds. Where potentially significant impacts are identified, feasible mitigation measures are identified that would avoid or reduce impacts to below a level of significance. Therefore, the project would not result in a significant environmental impact due to a conflict with the applicable air quality plan.

Topical Response No. 2, Land Use and Planning
This topical response addresses various comments raised during the review period for the Revised IS/MND as they relate to the recirculated Land Use and Planning Section. In summary, comments received on the Revised IS/MND that pertain to Land Use and Planning are related to the project's consistency with the policies contained with the City's General Plan Land Use and Community Identify 11 /15/2022 AkI Page 53 of 1307

(LUCI) Element, the proposed General Plan Amendment and zone change, the Regional Housing Needs Assessment (RHNA), and the San Diego Association of Governments (SANDAG) forecasting. The information contained herein responds to such comments and as appropriate commentors are referred to this response.

General Plan Land Use and Community Identity Element Consistency Comments were received that asserted that the project is not consistent with the following General Plan LUCI Element goals and policies:

LUCI Goal 2: Preserve and enhance the characteristics and features of neighborhoods that share common development patterns, topography, major streets, and zoning patterns.

LUCI Policy 2.4: Discourage subdivision design that disrupts the existing development pattern within established neighborhoods.

Currently the site supports the remnants of a former nursery that is permanently closed for commercial operation. With project implementation, the project site would transition from an idle agricultural/ commercial land use to a residential use. The project area is comprised of a variety of land uses, including a church situated on 40 acres, Rancho Guajome regional park, a school, and single-family residential neighborhoods. Existing residential neighborhoods include a mixture of homes on larger lots and subdivisions on smaller lots. Development patterns reflect these existing uses and are predominantly characterized by single-family residential development in addition to the nearby regional park and church. The project proposes two-story single-family homes that would maintain the exiting residential character of the surrounding area. This pattern is similar to the Sandalwood neighborhood approximately 310 feet to the south of the project, as well as other single-family neighborhoods in the broader project area. Thus, the project would be a continuation of the denser residential development that is occurring further south of the site, creating a cohesive development pattern. Additionally, the project would also place its larger lots (approximately 6,000 sq ft.) along the northern boundary of the site to create greater separation from the existing larger lots within the County to the north. As indicated in LUCI Goal 2, that beyond maintaining common development patterns, the City seeks to preserve and enhance neighborhoods that share major streets. The proposed project, like the Sandalwood and other residential neighborhoods to the south, is situated along the North Santa Fe Avenue corridor, a major street within the City. The project would not change the character of this major street either physically or functionally.

Topographically, the project would not result in major alterations to the existing landforms, and there are no unique landforms or topographic features on the project site. Existing on -site elevations would largely be maintained. The site's northern perimeter would be sloped with the development pads contour graded to blend into the existing topography. Other manufactured slopes are also proposed within the site in between lots. These slopes would support ornamental landscaping that would provide separation between the proposed residences, as well as properties to the north.

In relation to zoning patterns as identified in LUCI Goal 2, the area surrounding the project site is comprised of a variety of zoning designations. Surrounding properties have zoning designations ranging from Specific Plan (SP) and Agriculture (A-1) to the south; A-1, Rural Residential (RR), and Commercial (C-1) to the north; Office Professional (OP) to the northwest; Estates (E-1) and Open Space (OS) to the east and northeast; and A-1 to the west and northwest. Thus, the project area is not characterized by a 11 /15/2022 AkI Page 54 of 1307

single zone or exclusively designated for residential uses, in particular large -lot single family residential development, as alleged in the comments. Therefore, since no single zoning pattern has been established and the project the project maintains the existing residential character of the surrounding area it would be consistent with the overall zoning pattern of residential development to the north, south, and east.

Moreover, the project would promote LUCI Goal 9 to promote a range of housing types and sizes for a variety of incomes and ages and is reinforced through LUCI Goal 14 that encourages the City to update zoning regulations and/or other guidelines regulating land use to implement the LUCI goals and policies.

General Plan Amendment and Zone Change
The project site is zoned as A-1 and designated in the Vista General Plan as RR. The project would require both a zone change to Residential (R-1-13, small lot subdivision, 3,600 square foot [sf] lots) and General Plan amendment to Medium Density Residential (MD Residential). However, while the proposed zoning and land use designations are not consistent with the existing land use plans and regulations, neither the zoning nor General Plan land use designation are indicative of a plan, policy, or regulation that were adopted for the purpose of avoiding or mitigation an environmental effect. As discussed in the Revised IS/MND, the variety of allowable uses under the A-1 zone are not suggestive of environmental protection (i.e., more intense agricultural uses that could involve the use of industrial chemicals). Likewise, the ability to use the site for agricultural purposes is limited due to the existing surrounding development (residential neighborhoods, a church, museum, and county park) that are not compatible with agricultural production
In addition, Government Code Section 63358 recognizes that the General Plan is a programmatic tool, and once it is adopted, it does not remain static and thus allows provisions for general plan amendments so jurisdictions may respond to or accommodate changes in development patterns and needs. Lastly, as identified through the IS/MND process, the project would not result in any significant impacts that could not be mitigated to less than significant and therefore would not cause significant environmental impacts due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

Regional Housing Needs Assessment
Comments were submitted that the City's Housing Element, as of November 2020, had a remaining RHNA need of 1,549 units. The City's Draft General Plan Housing Element, dated May 2021, identifies the current need, which is cited in the Revised IS/MND as 2,561 units. The Revised IS/MND does not identify the project site on the City's housing site inventory contained within the General Plan Housing Element Update. However, for informational purposes, the Revised IS/MND does identify that the RHNA allocation for the 2021-2029 planning period assigned Vista a new housing need of 2,561 units. While the project site is not specifically identified, the development of residential housing at the project site would assist the City in meeting the projected RHNA needs and would be consistent with the intent of transitioning underutilized properties to residential development.

The reader is also referred to the strike out/underline changes that are contained in the Revised IS/MND (Page 3-12):

As Dart of the RHNA that was included in the Citv's General Plan Housing Element Update. the City has recognized the potential for underutilized parcels within the City fer the pFejeet site to 11 /15/2022 Nk) Page 55 of 1307

accommodate higher density residential land uses ;r d^m^R-stFated On the paFeel specific aRalysis of petential housing sites that the Gity pFepaFed to identify undeFutilized siter, designated for . id-e- tialA-FMixed use development to help meet the Regi nal Hewsing Needs Assessment (RHNA targets for the 2021-2029 planning period. This , alysis w"i^" is alse deRtial deRSity t9 the site, but did- idelq4y the paFeel as suitable for residential develepmeRt (Ci2�). Specifically, the RHNA allocation for the 2021-2029 planning period assigned Vista a new housing need of 2,561 units.

It is noted that at the time of the development of the most current RHNA (approved July 2020), the RHNA also accounted for a number of projects that were approved or foreseeably approved and provided a credit towards the total housing need in the City. Similarly, Tables AQ-1 and AQ-2 of the Revised IS/MND identify entitled, approved, and/or pending projects within the City and represent the most up to date numbers, identifying that there is currently 1,121 units that are under construction or may be constructed that account for part of the needs assessment. The project is included on the pending project list (Table AQ-2) as it has an active application with the City. This provides a conservative analysis by accounting for the proposed units in the City's overall future housing stock and allows for impacts to be assessed on a worst case scenario considering all of the pending projects are developed as proposed.

San Diego Association of Governments Forecasting
Lastly, comments were made regarding the development of the SANDAG Series 13 and 14 Forecasts.

These comments provide a synopsis of the SANDAG process for developing population and housing forecasts and do not raise an environmental issue with regard to the adequacy of the Revised IS/MND. It is noted that the SANDAG model considers a variety of factors, including those identified by the commentor. As specified by SANDAG, additional factors are also considered including economic conditions and return on investment calculations into the projections of development, redevelopment, and infill. However, because the development of the SANDAG forecasts do not raise any environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

Topical Response No. 3, Duplicate Comments or Comments Out of the Scope of the Revised IS/MND
The City of Vista (City) prepared a Draft IS/MND for the project that was circulated for a 20-day public review period from May 11, 2022 to May 30, 2022. The City received five comment letters during the public review period for the Draft IS/MND. Subsequently, the City prepared a Final IS/MND that included a Mitigation Monitoring and Reporting Program (MMRP) and responses to the comments (from the five comment letters) received on the Draft IS/MND, which was presented to the City Planning Commission on July 19, 2022. Prior to the Planning Commission hearing, the City received an additional comment letter (dated July 15, 2022) from legal representation of adjacent property owners that raised additional issues and concerns relative to air quality, land use, and population/housing. To address these additional comments, the City decided to prepare a Revised Draft IS/MND and recirculate only the revised portions of the Revised Draft IS/MND to provide the public an opportunity to review the additional analysis and clarifications pertaining to these three focused issues. Thus, a Revised Draft IS/MND, containing revised Air Quality, Land Use and Planning, and Population and Housing sections, was circulated for a 20-day public review period from September 14, 2022 to October 3, 2022. 11 /15/2022 AkI Page 56 of 1307

Consistent with CEQA Guidelines Section 15088.5(f)(2), which applies when an EIR is revised only in part and the lead agency is recirculating only the revised portions, the lead agency may request that reviewers limit their comments to the revised chapters or portions of the recirculated document.

This comment does not raise any environmental issues with respect to the adequacy of the Revised IS/MND relative to Air Quality, Land Use and Planning, and/or Population and Housing and therefore, no response is required, consistent with CEQA Guidelines Section 15088.5(f)(2). Comments that are duplicates of those previously submitted during the initial circulation of the Draft IS/MND have been responded to in the Response to Comments on the Draft IS/MND that is included as Attachment C of the Final Revised IS/MND. Please also see Section IV, Biological Resources and Section XVII, Transportation/Traffic of the Draft IS/MND.
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COMMENTS
A-1 FT)his proposed project has all the components of a poorly thought out plan. Which means the ecution can be expected to be even worse.

The tentative map is drawn with lots 8, 9, 20, 21, 33, 34, 42, and 43 in violation of the reciprocal A-2 Leasement with the Marcones, and this "revised" IS/MND is filled with inaccuracies, false statements, and a clear bias in favor of the developer.

A-3 It's hard to believe that anyone who signed the revised IS/MND even read it. On page 2-1 of the project overview it accurately describes the land as an "existing nursery operation" yet further along on the same page, underneath project site heading, it claims that Choice Nursery "supports a non -operational commercial palm tree nursery." A-4 Esnboxurther description of this site attempts to convince people of the closure of the nursery by ating.,operations consisted of selling palm trees that were grown aboveground and maintained stock containers."
A-5 This is an outright lie. I took these pictures of palm trees planted directly in the ground, not in containers, on Sunday, September 25th, 2022.

RESPONSES
A-1 The comment expresses an opinion that appears to be in general opposition to the project. As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

A-2 The existing and proposed conditions associated with the easement along Camino Largo have been clarified in the Final Revised IS/MND.

Page 2 ends

Presentiv there is an open space easement that was recorded in 2009 that extends into the 56-foot-wide private drive/reciprocal access/utility easement (granted in 2013) that includes Camino Largo (see Figure 4, Existing Easements Overlay, Attachment A). The project entitlements now include a public service easement summary vacation for a portion of an open space easement that extends into Camino Largo to remove any potential conflict between the open space easement and the proposed project improvements that would occur within and adjacent to the roadway area. The proposed vacation area includes a 20-foot portion of the open space easement that extends into the 56-foot-wide private road/reciprocal access and utility easement along Camino Largo that extends from APN 159-240-06 in the east to APN 159-240-33 in the west to allow the applicant to construct the improvements within Camino Largo (see Figure 5, Easement Area and Figure 6, Vacation Request Overlay, Attachment A). The portion of the open space easement that would be vacated is disturbed and has historically served for over five consecutive years since the open space easement was dedicated to the City, as the access road for the existing residents would provide access to the Droiect and continue to provide access to the residents to the east.

Further, page 2-4 of the Final Revised IS/MND has been revised to read as follows:

COMMENTS

RESPONSES
into Camino Largo, and (eventually) Building Permits. These approvals require meeting certain Conditions of Project Approval prior to obtaining the required permits. In addition, before the Final (Subdivision) Map is recorded, all Conditions of Project Approval (which include the mitigation measures identified in this document) must be satisfactorily completed.

Other public agency approvals are identified in Chapter 3.

The comment also states the IS/MND is inaccurate and not objective; however, the comment does not provide any facts or other information to support this statement. As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

A-3 Page 2-1 of the Final Revised IS/MND has been revised to clarify that the nursery is non -operational. Specifically, the first sentence in the Project Overview section has been revised as follows:

The proposed project involves removal of an existing a non- operational nursery Viand the construction of 46
two-story detached single-family residential units on 46 separate lots.

This correction does not change the impact conclusions of the of the environmental analysis contained in the Revised IS/MND.

A-4 The comment questions the operational status of Choice Nursery as described in the IS/MND. This business is listed as being permanently closed, the phone numbers associated with Choice Nursery are no longer in service, and the site no longer operates as a commercial nursery. This comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND and therefore, no further response is required.

A-5 This comment states that the IS/MND erroneously describes the extent of the former nursery operations on the project site. As noted in response A-4 above, Choice Nursery no longer operates as a commercial nursey on the site. When it was operational, Choice Nursery was a supplier of palm trees and stored and maintained palm trees in box containers within the site. The commentor has provided photographs of palm trees that are planted in the ground on the project site and claims they support the assertion that the former nursery operations are mischaracterized in the IS/MND. These photographs, however, are part RTC-9
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COMMENTS RESPONSES
RTC-10
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COMMENTS
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RESPONSES
RTC-11
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COMMENTS

RESPONSES
RTC-12
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COMMENTS
Additional proof of a sloppy tentative map is on page 2-2 where the Revised IS/MIND states that, A-61 "current access to the site is via a gravel private road that extends from North Santa Fe Avenue (Figure 2, Project Vicinity, in Attachment A)" and not from Camino Largo. Any logical person would conclude the road extending from North Santa Fe be used to access this project.

A-7 Further document inaccuracy that occurs on page 2-2 is when it falsely states that "access would be provided by five private cul-de-sac streets that extend from Camino Largo." One look at the tentative map shows only 4 cul-de-sacs and 1 dead end street with no cul-de-sac. iiii helixepi.com
A-8 As the document continues, so does confusion, false information, and a sense that no-one really knows what's going on. Page 2-2 reads that "Camino Largo would be improved from an

RESPONSES
A-6 The referenced text in the Revised IS/MND pertains to the existing access point to the project site. Under existing conditions, vehicular access to the project site is provided by a gate along North Santa Fe Avenue, just north of Camino Largo. Access is not currently provided along Camino Largo. The Final Revised IS/MND (page 2-1) has been revised to clarify this existing access point. The comment also states that Camino Largo logically would be used to provide access to the project. As described in the Proposed Project Description in the Final Revised IS/MND (page 2-2), access to the project site is proposed to be provided by five streets extending from Camino Largo.

A-7 The comment states the Revised IS/MND inaccurately describes proposed access to the project site as another example of the inadequacy of the IS/MND. The IS/MND (on page 2-2) indicates that access would be provided by five private cul-de-sac streets that would extend from Camino Largo. The comment purports that this is an A-8
incorrect description because the tentative map depicts four cul-de-sacs and one dead-end street with no cul-de-sac. By definition, a cul-de-sac is "a street or passage closed at one end" (Merriam -Webster:
https://www.merriam-webster.com/dictionary/cul-de-sac) . Cul-de-sacs can (and often do) terminate with a rounded turnaround, but a dead-end street without a turnaround is technically still considered a cul-de-sac.

However, the IS/MND is revised to acknowledge that the easternmost drive is configured differently from the other access drives. Page 2-2 has been revised to read as follows:

Access would be provided by 4 e four private cul-de-sac streets and a private drive that extend from Camino Largo. Resident parking would be provided via two -car garages and individual driveways with additional parking being provided along both sides of each cul-de-sac-private street and on one side of the private drive.

Given the definition above of a cul de sac, the clarification of the configuration of the access roads that extend from Camino Largo does not change.

The comment raises questions about the accuracy of the description of proposed improvements to Camino Largo in the Revised IS/MND. As described in the Proposed Project Description of the Revised IS/MND RTC-13
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COMMENTS RESPONSES
RTC-14
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COMMENTS
A-g unclassified gravel road to a two-way paved street with a curb and gutter system and Cont. sidewalks."
This document is confusing two very separate roads. Cal West purposely misleads everyone by writing "Camino Largo" across their entire proposed road on their tentative map. The issue with this is that their proposed road consists of 3 distinct parts; 1.) The current, existing Camino Largo that is already paved. In no place along this road does it exist as unclassified or gravel.

A-9 2.) Parallel to this paved, drivable road is the property line of the proposed project site. Here begins a hillside ranging between 3ft - 20ft at any given point alongside the currently paved Camino Largo.

3.) This 3rd part is a dirt road actually located on the project site. This is unpaved however, it's entirely dirt, not gravel.

More confusion about this project is revealed on page 2-2 when it states, "Camino Largo would A-10 be paved and extended to a minimum width of 28 feet." When I met with the Cal West team, Thursday, September 22nd, 2022, they told me that there would be 40ft of drivable road; 20 ft for traffic headed Westbound, and 20ft of drivable road headed Eastbound. There should be no discrepancy here between what is stated in the MND and statements made by the developers.

Still further absurdities lay ahead on page 2-2 when it claims that "the project would also include the addition of a stop sign at the intersection of Camino Largo and North Santa Fe Avenue." A-11 Only one stop sign!? For cars that already have to stop? How would that be beneficial or aid in the reduction of traffic in any way? Traffic which is acknowledged further on in the revised IS/MND as being a LOS E/F level!
A-12Additionally, Cal West plans to demolish trees that exist in protected wetlands, which is not even F located on their project site.

With all the muddled lies on page 2-2, how can anyone trust that Cal West will actually follow A-13 construction best management practices outlined on page 2-3? Who is going to be on -site to ensure these "construction best management practices" will be followed? Who is going to enforce this? What are the consequences if these are not followed? On page 3-6 there is an admission that there will be pollutants in the air from the project, short term and long term. They say they have no overall effect for the entire City of Vista. My concern A-14 is the effect they will have on the neighbors of the project site and specifically, my family at 266 Camino Largo. We are at the bottom of the hill. All this air pollution will flow down to our air space and lessen the quality of air, and life, for us.

The clear bias in favor of Cal West with no regard to the humans living in the surrounding area A-15 continues on page 3-10. First, the revised IS/MND states that the level of service for carbon monoxide pollution is severely degraded at the following crossroads:
"• N Santa Fe Ave & Osborne Street — LOS E (AM)
• N Santa Fe Ave & Taylor Street — LOS E (AM)

RESPONSES
A-9 Please refer to Response A-8 and Topical Response, No. 3, Duplicate Comments and Comments Out of the Scope of the Revised IS/MND, no further response is required.

A-10 The comment notes that the Revised IS/MND states that Camino Largo would be improved to a minimum pavement width of 28 feet but also explains that in conversations with the applicant, it was discussed that Camino Largo would have 40 feet of drivable road. This comment is consistent with the description in the Revised IS/MND of a minimum of 28 feet, indicating that the roadway may be improved beyond the 28 feet, in particular, it would be improved from an unclassified road to a two-way paved street with a curb and gutter system and sidewalks.

A-11 As this comment notes, a stop sign is proposed at the westbound approach of the Camino Largo/North Santa Fe Avenue intersection, which is indicated in the Proposed Project Description of the Revised IS/MND (page 2). Please refer to Response D-9.

A-12 The project would not remove any trees that are located outside of the project site. It was initially anticipated that two trees at the southeast corner of Camino Largo and North Santa Fe Avenue (within the road right-of-way of North Santa Fe Drive) would be removed to improve sight visibility for vehicles turning onto North Santa Fe Drive as part of the project; however, the City subsequently removed the trees under an existing authorized maintenance agreement. As such, this is no longer proposed by the project. The Proposed Project Description section of the Revised IS/MND (page 2-3) has been revised to reflect this change.

A-13 The project has incorporated the best management practices (BMPs) identified on page 2-3 of the Revised IS/MND as part of the project design and as such, these BMPs would become conditions of approval.

Prior to the issuance of a grading permit, the applicant would be required to prepare a construction management plan that would demonstrate in part how it would comply with these BMPs and the City would be responsible for monitoring compliance. The construction management plan would identify an onsite representative and inspections, as well as the penalties for violation of the plan.

RTC-15
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COMMENTS

RESPONSES
A-14 As a development project, there would be air emissions associated with short-term construction and long-term operation as the project site transitions from a non -operating nursery to residential land uses. As discussed in more detail in Air Quality, Greenhouse Gas Emissions, and Energy Technical Report for the Camino Largo Residential Project included as Appendix A to the Revised IS/MND, the San Diego Air Pollution Control District (SDAPCD) has developed screening level thresholds for both construction and operation emissions with the goal of attaining the national and state ambient air quality standards. The ambient air quality standards identify concentrations of pollutants in the ambient air below which no adverse effects on the public health and welfare are anticipated. As presented in Table AQ-13, Maximum Daily Construction Emissions, on page 3-7 and Table AQ-14, Operational Emissions on page 3-8 of the Revised IS/MND, the project does not exceed these thresholds. The project would, therefore, not result in levels of air pollution that would result in an adverse effect on human health, and impacts would be less than significant, both in relation to the surrounding land uses and City-wide.

A-15 The commentor states that the IS/MND indicates that due to the level of service (LOS) at three traffic study intersections, there is a degradation of air pollution in relation to carbon monoxide (CO). However, this is misconstrued, the discussion of the LOS is in relation to the standard procedures that trigger the evaluation of CO hotspots. As stated on page 3-10 pf the Revised IS/MND, in accordance with the CO Protocol, CO hot spots are typically evaluated when (a) the LOS of an intersection decreases to an LOS E or worse; (b) signalization and/or channelization is added to an intersection; and (c) sensitive receptors such as residences, schools, hospitals, etc., are located in the vicinity of the affected intersection or roadway segment.

The Revised IS/MND indicates that three traffic study intersections would operate at LOS E or F in the horizon year and experience an increase in delay from the project. Therefore, consistent with the CO Protocol, these findings indicate that further screening is required. Using additional conservative screening methods developed by the Sacramento RTC-16
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COMMENTS
• N Santa Fe Ave & Bobier Drive — LOS E/F (AM/PM)"
A-15 It is clear that this much traffic is detrimental to the even smaller intersection of North Santa Fe cont. and Camin Largo not only from pollution but traffic congestion. Due to heavy congestion in the North Santa Fe corridor, how will this affect carbon monoxide levels at the intersection of Camino Largo and North Santa Fe?
The crossroad of Camino Largo and North Santa Fe Ave compared with the crossroads of Bobier Drive and North Santa Fe, is an inadequate marker for comparison because Bobier is a A-16 Public street that has a constant flow of traffic controlled by stoplights. In contrast, Camino Largo is a private, dead-end street, about 500ft in total length, with no assistance to allow stopped traffic to flow.

Esing the baseline of 31,600 vehicles per hour, for traffic volume to try to "prove" that impacts A-17ouldbe "less than significant" is purposely misleading and only useful to further personal gendas of development.

The revised IS/MND further disregards the impact on quality of life the development will have on A-18 existing families and neighbors by dismissing them as not "a substantial number of people" (page 3-11). How can the City value people's quality of life lower than a developer's desire to make money?
Continuing it's biased slant in favor of Cal West, the revised IS/MND stated that "the project is designed to adhere to the General Plan land use and community design goal of sharing common development patterns among neighborhoods [and that] the project would be consistent with the surrounding land uses and would not divide an established community." This is 100% A-19 wrong. If one looks at a map, the wetlands directly South of the project site delineate the natural boundary of neighborhoods. The common development pattern for this project site can be seen North and East. It is the semi -rural pattern. (Below in the list image, the project site is outlined in blue, Sandalwood in red. In the 2nd image, it's zoomed in to focus on these two sites to show the comparison.)

RESPONSES
Metropolitan Air Quality Management District, as identified on page 3-10 of the Revised IS/MND, it was determined that the project would not result in a significant impact to local CO concentrations because it meets all of the following criteria:
• The affected intersection carries less than 31,600 vehicles per hour; • The project does not contribute traffic to a tunnel, parking garage, bridge underpass, urban street canyon, below -grade roadway, or other location where horizontal or vertical mixing of air would be substantially limited; and
• The affected intersection, which includes a mix of vehicle types, is not anticipated to be substantially different from the County average, as identified by EMFAC or CalEEMod models (SMAQMD 2009).

As indicated on page 3-10 of the Revised IS/MND, impacts in relation to CO Hotspots would be less than significant.

A-16 The intersection of Bobier Drive and North Santa Fe Avenue is included within the Traffic Impact Analysis in relation to establishing the existing conditions and future traffic conditions in the study area and is not a point of comparison to evaluate project -related impacts. As the comment raises associated traffic concerns, no further response is required. Please refer to Topical Response, No. 3, Duplicate Comments and Comments Out of the Scope of the Revised IS/MND.

A-17 As the comment raises associated traffic concerns, no further response is required. Please refer to Topical Response, No. 3, Duplicate Comments and Comments Out of the Scope of the Revised IS/MND. However, please refer to comment A-15 above. The screening criteria is one factor that is used to determine if there is an impact as related to CO Hotspots.

A-18 The comment states that the IS/MND disregards impacts on the quality of life of neighbors by dismissing them as not a substantial number of people. The referenced page in the IS/MND and associated commentary pertains to other emissions such as odors. The CEQA threshold, pursuant to Appendix G of the CEQA Guidelines specifically states, "Would the project result in other emissions (such as those leading to odors) RTC-17
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COMMENTS

RESPONSES
adversely affecting a substantial number of people" (emphasis added).

There is no subjective value implied by the threshold or the impact conclusion in the IS/MND. The threshold merely uses a qualitative metric to determine the significance of the impact under CEQA. As described in Item X.d of the Revised IS/MND (page 3 11), impacts regarding other emissions, including odors, would be less than significant, and this conclusion would be the same regardless of the number of people residing in the surrounding area for the reasons discussed in this section of the Revised IS/MND.

A-19 Please refer to Topical Response, No. 2, Land Use and Planning.

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RTC-19
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COMMENTS
!R:

RESPONSES
RTC-20
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COMMENTS
ETo
claim that "the proposed project would not physically divide an established community" and A-20hat "no impact would occur" is incorrect, biased, and harmful to all that live in the area, including wildlife.

The revised IS/MND continues its attempt of persuasion by claiming the project meets the LUCI goals.

As shown in the previous picture, this project does the opposite of LUCI Goal 2 and 2.4. It plans to destroy the natural features and characteristics of the semi -rural neighborhood. It aims to demolish the topography and disregard the existing zoning patterns to the North and East. It does nothing to maintain the existing residential character. If it were to maintain the character, it A-21 would keep the A-1 zoning and not have to change from Rural Residential to Medium Density Residential. Its plan is to use the small lot subdivision zoning that was just voted in on May of 2022. Such small lots have never existed before this year! It is explicitly admitted on page 3-12 that this type of density does not exist in this area because if approved it will be "creating a cohesive development pattern" and not adding to an already existing pattern.

On page 3-12 regarding the housing element, the revised IS/MND admits that "this analysis, which is also included as Appendix B to the City's General Plan Housing Element Update, did A-22 not allocate a residential density to the site." This shows that the City already planned adequately for higher density development and this specific request to R-1-B zoning is unnecessary for the city to meet its housing requirements.

This is further supported by the fact that land use was considered by SANDAG, the RHNA and Vista's housing element when they planned out future development. The RHNA concluded that A-23 2,561 units would be needed. When these numbers were put together, the plan was for urban zones with infill along the metro line. They also took into consideration land use policies already established within the city. Specifically preserving open spaces and agricultural lands.

SADANG 13 and 14 are responsible for generating projected growth for the city of Vista. This includes birth, death, and migration. This ultimately determines the number of units the city will need. When they performed their evaluations, it was done so with land use considered.

A-24 Meaning population and density are accounted for.

Thus the number generated is from the land parcels evaluated at said land density and zoning.

So when SANDAG determined the amount of units to make, that number was based off of the project site's A-1 zoning and RR density.

Lastly, Vista's housing element also took into account existing land use. The housing element A-25 \[ lays out where they think development should occur in the city of Vista. Because the housing

RESPONSES
A-20 The commenter disagrees with the analysis and impact conclusion in the Revised IS/MND pertaining to physical division of an established community; however, the comment does not provide any facts or other information to support this statement. As described in Section Xl.a of the Revised IS/MND (page 3-11), the physical division of an established community typically refers to the construction of a linear feature, such as an interstate highway or railroad tracks, or removal of a means of access, such as a local road or bridge that would impact mobility within an existing community or between a community and outlying area. The project does not include any of these features and does not propose any physical barriers that would preclude movement from within and surrounding the project site to areas outside of the project area.

In relation to wildlife, this comment concerns issues not addressed in the Revised IS/MND (Biological Resources, threshold d [wildlife movement]).

The commentor appears to infer that that development of the project site would impact the movement of wildlife. The project site is a former nursery and is surrounded by a variety of developed uses, such as a church to the north/northwest and a residential neighborhood to the south. North Santa Fe Avenue, along the project's western boundary is a two-lane road with a posted speed limit of 45 miles per hour, which would act as a barrier for a successful wildlife corridor. Native resident or migratory wildlife corridors do not exist on the project site, and the property does not contain any biological resources that are protected by local policies. Please refer to Topical Response, No. 3, Duplicate Comments and Comments Out of the Scope of the Revised IS/MND.

A-21 Please refer to Topical Response, No. 2, Land Use and Planning.

A-22 Please refer to Topical Response, No. 2, Land Use and Planning.

A-23 Please refer to Topical Response, No. 2, Land Use and Planning.

A-24 Please refer to Topical Response, No. 2, Land Use and Planning.

A-25 Please refer to Topical Response, No. 2, Land Use and Planning.

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11 /15/2022 PH 1 Page 71 of 1307

COMMENTS
A-25 element was informed by the RHNA, which found that the need for increased density is along Cont. transit lines, as previousiy mentioned, there is no need for anything higher than RR density at this project site.

EFturtrheadmission that this site requires no zone and density change occurs on page 3-13. It A-26atesthat "the current RR designation and A-1 zone Indicate the site is suitable for residential evelopment since single-family residences are allowed uses by right in the current A-1 zone." ral-West has presented the City with a sloppy plan, and this poorly revised ISlMND. Which is A-27ot only biased, it's inaccurate and filled with poor comparisons. How can this be something that supposed to be considered seriously by the City Council?

RESPONSES
A-26 Please refer to Topical Response, No. 2, Land Use and Planning.

A-27 The comment states that the Revised IS/MND is inaccurate, biased, and poorly written; however, the comment does not provide any facts or other information to support this statement. It also expresses an opinion that appears to be in general opposition to the project. As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

RTC-22
11 /15/2022 PH 1 Page 72 of 1307

COMMENTS
From: Patsv Chow
To: Kara Palm
Subject: FW: Response to Revised IS/MND for Camino Largo Development Date: Monday, October 3, 2022 6:44:38 PM
Attachments: RE Due 10.14.2020 - 1600-2020-0126-R5 Vista channel Maintenance Draft for review.Ddf From: Chris Jacobs
Sent: Sunday, October 2, 2022 5:28 PM
To: Patsy Chow ; [email protected]
Subject: Response to Revised IS/MND for Camino Largo Development How is it acceptable to submit a document with so many falsities, and then when asked to revise it, B-1 fail to correct any of the most simple errors?
B-2 [—Simple fact #1: Contrary to what is stated in the IS/MND the site is actively being used by Choice Nursery.

Simple fact #2: Camino Largo is not a gravel road as claimed by the IS/MND.

It is clear that whoever put the IS/MIND together has never been to the proposed development site or even googled the location. A quick google search would have easily avoided making this simple B-3 mistake.

How can the city council trust the remainder of the document when two of the most basic facts have clearly not been checked by the writers.

The IS/MND also claims that more housing is needed and that this project would provide for that housing in Vista. This is a false claim. With just a small amount of research my brother was able to B-4 determine that the needed housing is already accounted for. The IS/MND ignores the fact that the housing element accounts for land use and that no zoning needs to be changed to accomodate for the rest of the RHNA units.

Ehe IS/MND claims it fits with the development pattern of the area. This is a flat out lie. Not a single B-5urrounding home in the area matches this proposed development. There is an example image in he City General Plan, that literally says do not allow any development like what is being proposed.

B-6 CThe revised IS/MND was supposed to address traffic and environmental impact.

How does this revised IS/MND accurately reflect its environmental impact when it again ignores the 10 Acres of protected wetlands directly to the south. Thatwetlands is the habitat to a wide range of B-7 animal and plant life, and the construction proposed directly across from it will take away almost 10 Acres of land that those animals currently enjoy. There will clearly be an impact and that isn't even addressed. Perthe attached documentfrom the City of Vista, there are a number of animals that call this area home and should not be disturbed.

RESPONSES
B-1 The comment states that the Draft IS/MND and the Revised IS/MND contain false information and inaccuracies; however, the comment does not provide any facts or other information to support this statement. As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

B-2 The comment states that the IS/MND is inaccurate because the site is currently being used by Choice Nursery. The Revised IS/MND on page 2-1, Chapter 2, Environmental Setting and Project Description, Existing Land Uses notes that status of the site, including the storage of equipment and vehicles but Choice Nursery is no longer operating a commercial business at the site, and it is listed as permanently closed with associated phone numbers disconnected (also see Response to A-4).

B-3 The comment states that the IS/MND is inaccurate because it states that Camino Largo is a gravel road. This minor correction has been made in the Final Revised IS/MND. Please see the following revisions included in the Final Revised IS/MND on page 2-2, fifth paragraph, second sentence, Project Description Camino Largo would be improved from an unclassified
gkroad to a two-way paved street with a curb and
gutter system and sidewalks. The pavement along the
southern half of Camino Largo would be improved to a
minimum width of 28 feet.

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11 /15/2022 PH 1 Page 73 of 1307

COMMENTS

RESPONSES
This correction does not change the impact conclusions or the environmental analysis contained in the Revised IS/MND.

B-4 Please refer to Topical Response, No. 2, Land Use and Planning.

B-5 Please refer to Topical Response, No. 2, Land Use and Planning.

B-6 As discussed in the Revised IS/MND, none of the comments that were received in the letter submitted on July 15, 2022, on behalf of the Guajome Alliance for Responsible Development (GuARD), after the close of the public review period (May 11, 2022 to May 30, 2022), including those related to transportation/traffic, resulted in triggering the requirements of recirculation as identified in the California Environmental Quality Act Guidelines Section 15073.5(b)(1), However, the City decided to provide additional analysis in relation to air quality and clarifications to the land use and planning and population and housing sections of the IS/MND. The City subsequently prepared a Revised IS/MND to afford interested parties an opportunity to comment on the additional analysis and revised language, therefore recirculating the affected sections of the Draft IS/MND. There were no revisions to Transportation/Traffic, Section XVIL Please refer to Topical Response No. 3, Duplicate Comments or Comments Outside of the Scope of the Revised IS/MND.

B-7 As discussed in Response A-20, the property does not contain any biological resources that are protected by local policies. During the due diligence for the project site and the vegetation surveying conducted in January 2022, no sensitive plant or any animal species were observed.

The project site contains trees and shrubs that could support nesting sites for bird species protected under the Migratory Bird Treaty Act. Impacts to nesting birds could occur if vegetation clearing were to take place during the avian breeding season (generally February 1 to August 31). Mitigation Measure BR-1 reduces potential impacts to nesting birds to less than significant.

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COMMENTS

RESPONSES
Further as identified in the Final Revised IS/MND and in Response A-2, the project applicant would require a summary vacation of a 20-foot wide portion of the open space easement that is disturbed and historically served for over five consecutive years as the access for existing residents. The project does not include any improvements in the undisturbed portion of the open space easement. The attached document pertains to lands outside of the project site.

It is further stated in the IS/MND, page 3-15 that there is the potential for the project to have temporary indirect impacts to special -status wildlife from adverse "edge effects" on sensitive habitat within the adjacent parcel to the south. Edge effects typically include dust, construction -related soil erosion and runoff, lighting, and construction -related noise. Dust control, erosion control, and water quality protection measures are addressed in Section Chapter 2 and Section X, Hydrology and Water Quality of the IS/MND and would be part of the conditions of approval.

These include among other conditions, compliance with the San Diego Air Pollution Control District (SDAPCD) Rule 55 — Fugitive Dust Control and San Diego Regional Water Quality Control regulations (such as municipal separate storm sewer system permits and the preparation of a stormwater pollution prevention plan). Potential impacts from lighting would not be significant, as addressed in Section I, pages 3-5 and 3-6 of the IS/MND. However, construction -related noise could be significant within approximately 500 feet of a raptor nest or within 300 feet of a nesting bird. However, with the implementation of Mitigation Measure BR-1, as identified on pages 3-15 and 3-16 of the IS/MND, this impact would be reduced to less than significant levels.

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11 /15/2022 PH 1 Page 75 of 1307

COMMENTS
The revised IS/MND says thattherewill be limited traffic impact. Traffic is already a substantial issue at this location. The IS/MND claims that trafficflow is consistentwith that at the intersection of N.

Santa Fe and Bobier. That's saying that the traffic at North Santa Fe and Camino Largo, a two lane road with no stop signs or lights, is equivalent to the traffic at a 4 way intersection with 8 lanes of B-8 through traffic and 4 turn lanes that is governed by traffic lights? How is that not an issue? An issue that will clearly be impacted by the addition of46 homes which equates to at least that many new vehicles trying to access North Santa Fe and most likely double that many. 92 cars trying to leave for work every morning is an absurd amount to try and have access to North Santa Fe off of Camino Largo.

Speaking of which, the IS/MND purposely misleads the reader as to what Camino Largo is. Camino Largo is a paved private road that is located entirely on the land directly south of the proposed site.

There is no section of the current Camino Largo that exists on the land owned by the developer. All B 9 of their documents including the hijacking of the Camino Largo name fortheir proposed development leads the reader to believe that Camino Largo is currently accessible via the developers land. It is not. There will need to be significant grading and construction to create the Camino Largo road that the developer proposes.
f the amount of misinformation and general lazy effort that went into the IS/MND and its revision is B-10 reflective of the type of work this developer is putting into this development, the city needs to reject this proposal solely on that basis.

Thank you,
Ch ris J aco bs

RESPONSES
B-8 As this comment raises associated traffic concerns, no further response is required. Please refer to Topical Response No. 3, Duplicate Comments and Comments Out of the Scope of the Revised IS/MND.

B-9 Camino Largo is a private road and utility easement; the existing 28 feet of reciprocal access would be transferred to the project developer with the sale of the property Please refer to Response to A-2 and Topical Response No. 3, Duplicate Comments and Comments Out of the Scope of the Revised IS/MND, no further response is required.

B-10 The comment states that the Revised IS/MND contains a lot of misinformation and is of poor quality; however, the comment does not provide any facts or other information to support this statement. It also expresses opposition to the project. As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

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11 /15/2022 PH 1 Page 76 of 1307

COMMENTS
From:

Fisher, Kelly@Wildlife
Sent:

Mon, 1 Feb 2021 18:33:44 +0000
To:

Turner, Jennifer@Wildlife
Subject:

RE: Due: 10/14/2020-1600-2020-0126-R5 Vista Channel Maintenance Draft for review
Attachments:
1600-2020-0126-R5 SAA DRAFT 1 it kf_ jt_kf.doc
Ok, all cleaned up and track changes off
Kelly Fisher
Environmental Scientist
(858) 4674207
kell v.fisher(7wi Id life.ca.aov
California Department of Fish and Wildlife
Lake and Streambed Alteration Program
3883 Ruffin Road
San Diego, California 92123
Notifications for lake and Streambed Alteration Agreements Online —Lake and Streambed Alteration Notifications for standard projects are to be submitted electronically, through the Environmental Permit Information Management System (EPIMS). For more information about EPIMSor if you need help completing your online notification, please visit: httos:l/wildlife.ca.aov/Conservation/Environmental- Review/EPI MS.

Every Californian should conserve water. Find out howat: SaveOurWater.com Drought.CA.gov From: Turner, Jennifer@Wildlife
Sent: Monday, February 1, 2021 828 AM
To: Fisher, Kelly@Wildlife
Subject: RE: Due: 10/14/2020 - 1600-2020-0126-R5 Vista Channel Maintenance Draft for review Hey Kelly,
Thesewere fabulous revisions, and yes -very fancy! I caught a fewother additional typos but otherwise I'm goad with the way its shaping up. If you want me to send a clean copy when its ready I'll pass it along to Erinn.
-Jenn
From: Fisher, Kelly@Wildlife
Sent: Thursday, January 21, 2021 5:16 PM
To: Turner, Jennifer@Wildlife
Subject: RE: Due: 10/14/2020 - 1600-2020-0126-R5 Vista Channel Maintenance Draft for review

RESPONSES
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11 /15/2022 PH 1 Page 77 of 1307

COMMENTS
I think this should be very close to acceptable... I agonized over what to put in the tables, and how to get them to fit on the page. I left the track changes in for now, but I think I'd like to take them out before it goes to Erinn. I used hyperlinks to the Exhibits, each time they are mentioned in the agreement. Fancy, right?
Kelly Fisher
Environmental Scientist
(858) 4674207
kelly.fisherO,wi Id life.ca.gov
California Department of Fish and Wildlife
Lake and Streambed Alteration Program
3883 Ruffin Road
San Diego, California 92123
Notifications for Lake and Streambed Alteration Agreements Online —Lake and Streambed Alteration Notifications for standard projects are to be submitted electronically, through the Environmental Permit Information Management System (EPIMS). For more information about EPIMS or if you need help completing your online notification, please visit: https:ilwildlife.ca.,qov/Conservation/Environmental- Review/EPI MS.

Every Californian should conserve water. Find out howat: SaveOurWater.com Drought.CA.gov From: Fisher, Kelly@Wildlife
Sent: Monday, November 30, 20204:21 PM
To: Turner, Jennifer@Wildlife
Subject: RE: Due: 10/14/2020-1600-2020-0126-135 Vista Channel Maintenance Draft for review Cool, thanks! I'll look it over tomorrow. I drafted it before we had all the feedback on the San Diego one.

Kelly Fisher
Environmental Scientist
(858)467-4207
kelly.fisher(r)wild life.ca.gov
California Department of Fish and Wildlife
Lake and Streambed Alteration Program
3883 Ruffin Road
San Diego, California 92123
Notifications for Lake and Streambed Alteration Agreements Online —Lake and Streambed Alteration Notifications for standard projects are to be submitted electronically, through the Environmental Permit Information Management System (EPIMS). For more information about EPIMS or if you need help completing your online notification, please visit: https:llwildlife.ca.gov/ConservationtEnvironmental- Review/EPI MS.

RESPONSES
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COMMENTS
Every Californian should conserve water. Find out howat: SaveOurWater.com Drought.CA.gov From: Turner, Jennifer@Wildlife
Sent: Monday, Navember30, 20204-13 PM
To: Fisher, Kelly@Wildlife
Subject: RE: Due: 10/14/2020-1600-2020-0126-R5 Vista Channel Maintenance Draft for review Hey Kelly,
It maybe the end of the day, but I did get to all your reviews! This is my first pass. I think with this one, Erinn is going to have a lot of similar concerns to that of the City of SD's big Agreement, albeit this one is smaller in scope. We need to be specific about defining the impacts, habitat types, etc. Maybe its as easy as adding that additional Table 2 or 3, given the impacts will be so minimal? Let me know what you think.

Thanks (and sorry),
Jenn
From: Fisher, Kelly@Wildlife
Sent: Monday, November 30, 2020 2:24 PM
To: Turner, Jennifer@Wildlife
Subject: FW: Due: 10/14/2020-1600-2020-0126-R5 Vista Channel Maintenance Draft for review Here you going
Kelly Fisher
Environmental Scientist
(858)467-4207
kellv.fisher0wi Id life.ca.aov
California Department of Fish and Wildlife
Lake and Stream bed Alteration Program
3883 Ruffin Road
San Diego, California 92123
Notifications for Lake and Streambed Alteration Agreements Online —Lake and Streambed Alteration Notifications for standard projects are to be submitted electronically, through the Environmental Permit Information Management System (EPIMS). For more information about EPIMS or if you need help completing your online notification, please visit: https:/Iwildlife.ca.,qov/Conservation/Environmental- ReviewJEPl MS.

RESPONSES
RTC-29
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COMMENTS
Every Californian should conserve water. Find out howat: SaveOurWateccom Drought.CA.gov From: Fisher, Kelly@Wildlife
Sent: Thursday, October 15, 2020424 PM
To: Turner, Jennifer@Wildlife
Subject: Due: 10/14/2020-1600-2020-0126-R5 Vista Channel Maintenance Draft for review File location: U:\groups\region5khabtconsllLSANLSA Notification Files\1600-2020-0126-R5 Kelly Fisher
Environmental Scientist
(858)467-4207
kell v.fisher0wi Id life.ca.aov
California Department of Fish and Wildlife
Lake and Streambed Alteration Program
3883 Ruffin Road
San Diego, California 92123
Notifications for Lake and Streambed Alteration Agreements Online — Lake and Streambed Alteration Notifications for standard projects are to be submitted electronically, through the Environmental Permit Information Management System (EPIMS). For more information about EPIMS or if you need help completing your online notification, please visit: httt s:llwildlife.ca.gov/Conservation/Environmental- Review/EPI MS.

Every Californian should conserve water. Find out howat: SaveOurWateccom Drought.CA.gov

RESPONSES
RTC-30
11 /15/2022 PH 1 Page 80 of 1307

COMMENTS

CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE

SOUTH COAST REGION
3883 RUFFIN ROAD
SAN DIEGO, CALIFORNIA 92123

STREAMBED ALTERATION AGREEMENT
NOTIFICATION No. 1600-2020-0126-R5

VARIOUS STREAMS

CITY OF VISTA

CITY OF VISTA CHANNEL MAINTENANCE PROGRAM
This Streambed Alteration Agreement (Agreement) is entered into between the California Department of Fish and Wildlife (CDFW) and City of Vista (Permittee) as represented by John Conley.

RECITALS
WHEREAS, pursuant to Fish and Game Code section 1602, Permittee notified CDFW on June 12, 2020, that Permittee intends to complete the project described herein.

WHEREAS, pursuant to Fish and Game Code section 1603, CDFW has determined that the project could substantially adversely affect existing fish or wildlife resources and has included measures in the Agreement necessary to protect those resources.

WHEREAS, Permittee has reviewed the Agreement and accepts its terms and conditions, including the measures to protect fish and wildlife resources.

NOW THEREFORE, Permittee agrees to complete the project in accordance with the Agreement.

PROJECT LOCATION
The project is located within the bed, channel, and bank of Buena Vista Creek, Roman Creek, unnamed tributaries to Brengle Terrace Park Detention Basin, unnamed tributaries to Buena Vista Creek, an unnamed tributary to Agua Hedionda Creek, and unnamed tributaries to Guajome Wetlands; located throughout the City of Vista, County of San Diego, State of California; U.S. Geological Survey (USGS) maps San Marcos and San Luis Rey quadrangles. Individual project locations are listed in Exhibit A.

PROJECT DESCRIPTION

RESPONSES
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COMMENTS
The project is limited to those activities described in Permittee's Notification of Lake or Streambed Alteration for the City of Vista Channel Maintenance Program. The project consists of on -going maintenance activities at 42 facilities to remove debris, dirt, sediment, and vegetation to maintain adequate flow and flood control in stormwater channels. Channel maintenance activities may involve the use of hand tools, backhoes, dump trucks, excavators, mechanical pumps, and/or the use of smaller mechanical Notification #1600-2020-0126-R5
Streambed Alteration Agreement

Page 2 of 13 ends

equipment. At 35 of the maintenance sites, the proposed activities are a continuation of maintenance that has recurred periodically since 2009 under the authorization of Streambed Alteration Agreement #1600-2008-0345-R5, which expired December 31, 2018. With this Agreement, 7 new sites are being added to the list of facilities for which recurring maintenance is authorized. Activities proposed for each facility are provided in Exhibit B.

PROJECTIMPACTS
Existing fish or wildlife resources the project could substantially adversely affect Include:

REPTILES — coast patch -nosed snake (Salvadora hexalepis virgultea), two -striped gartersnake (Thamnophis hammondii), Coronado Island skink (Plestiodon skiltonianus interparietalis), Blainville's horned lizard (Phrynosoma blainvilln), orange -throated whiptail (Aspidoscelis hyperythra), coastal whiptail (Aspidoscelis tigris stejnegen); BIRDS — Coopers hawk (Accipiter coopers), least Bell's vireo (Vireo bellii pusillus), coastal California gnatcatcher (Polioptila californica californica), western bluebird (Sialia mexicana), yellow -breasted chat (Icteria virens), yellow warbler (Setophaga petechia); MAMMALS — western red bat (Lasiurus blossevillir), northwestern San Diego pocket mouse (Chaetodipus fallax fallax), Dulzura pocket mouse (Chaetodipus californicus femoralis); riparian vegetation which provides habitat for those species, and all other aquatic and wildlife resources in the project vicinity.

The adverse effects the project could have on the fish or wildlife resources identified above include: change in contour of bed, channel, or bank; change in channel cross- section; change in composition of channel materials; change to natural bed substrate; change in flow depth, width or velocity; change in sediment transport; increased turbidity; short-term release of contaminants; disruption to nesting birds and other wildlife; direct take of terrestrial species; disturbance from project activity; and loss or decline of riparian and/or emergent marsh habitat.

Vegetation communities and other cover types occurring within and adjacent to the facilities include disturbed wetland, coastal and valley freshwater marsh, southern riparian forest, southern arroyo willow riparian forest, nonnative riparian, Arundo- dominated riparian coast live oak woodland, nonnative woodland, eucalyptus woodland, Dieaan coastal sage scrub, disturbed (upland) habitat, and urban/developed. Where

RESPONSES
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COMMENTS
wetland and riparian cover is present, segments of unvegetated channel occurring beneath the cover were not separately mapped. Live tree removal is generally not anticipated; however, limited tree removal may be necessary where overgrowth inhibits channel flow. Because maintenance at the majority of the sites has recurred over 10 years, large tree development has not occurred within most maintenance limits. Most live tree vegetation growth removal is limited to trimming lower limbs as needed for maintenance access or public safety; the overall canopy is not appreciably reduced.

Exhibit C summarizes the acreage of each vegetation community and other cover type, within both the maintenance limit and the surrounding 100-foot buffer. The project totals Notification #1600-2020-0126-R5
Streambed Alteration Agreement

Page 3 of 13 ends

14.16 acres, with individual facility maintenance limits ranging from 0.0006 acre to

5.4302 acres. Exhibit B lists the maximum acreage of impact for each facility.

MEASURES TO PROTECT FISH AND WILDLIFE RESOURCES

1. Administrative Measures
Permittee shall meet each administrative requirement described below.

1.1 Documentation at Project Site. Permittee shall make the Agreement, any extensions and amendments to the Agreement, and all related notification materials and California Environmental Quality Act (CEQA) documents, readily available at the project site at all times and shall be presented to CDFW personnel, or personnel from another state, federal, or local agency upon request.

1.2 Providing Agreement to Persons at Project Site. Permittee shall provide copies of the Agreement and any extensions and amendments to the Agreement to all persons who will be working on the project at the project site on behalf of Permittee, including but not limited to contractors, subcontractors, Inspectors, and monitors.

1.3 Notification of Conflicting Provisions. Permittee shall notify CDFW if Permittee determines or learns that a provision in the Agreement might conflict with a provision imposed on the project by another local, state, or federal agency. In that event, CDFW shall contact Permittee to resolve any conflict.

1.4 Project Site Entry. Permittee agrees that CDFW personnel may enter the project site at any time to verify compliance with the Agreement.

1.5 Payment of Outstanding Fees. Permittee shall submit an annual fee to CDFW on or before December 31st of each year for work performed the preceding work program year. The fee shall be based on CDFW's "Agreement for Routine Maintenance" fees as described in the California Code of Regulations, Title 14,

RESPONSES
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COMMENTS
Section 699.5. As of January 1, 2020, the fee for each maintenance project completed per calendar year is $305.25. This per -project fee is changed periodically, and the amount submitted shall be the fee that is in effect at the time the fee is received by CDFW.

2. Avoidance and Minimization Measures
To avoid or minimize adverse impacts to fish and wildlife resources identified above, Permittee shall implement each measure listed below.

2.1 Minimize Disturbance to Stream. Disturbance or removal of vegetation shall not exceed the minimum necessary to complete operations. Except as otherwise Notification #1600-2020-0126-R5
Streambed Alteration Agreement

Page 4 of 13 ends

permitted in this Agreement, the removal of soil, vegetation, and vegetative debris from the stream bed or stream banks is prohibited. Permittee may remove all human generated debris, such as lawn and farm cuttings, garbage and trash.

2.2 Work Area Boundary. Work area boundaries shall be delineated by posting signs, staking, flagging, erecting temporary fencing, or otherwise clearly marking to minimize surface and vegetation disturbance. No paint or permanent discoloring agents shall be applied to rocks or vegetation to indicate limits of survey or construction activity where any sensitive biological resources occur. All temporary fencing and flagging shall be removed at the conclusion of construction activities.

2.3 Access to Work Site. Access to the work site shall be via existing roads and access ramps, to the extent practicable.

2.4 Oak Tree Root Avoidance. Heavy equipment shall not encroach on the root protection zone (i.e., 50 feet from the drip line) within undeveloped areas, nor shall equipment be staged/stockpiled in these areas. The qualified biologist shall flag root protection zones as off-limits at applicable facilities, prior to starting work.

2.5 Biological Monitor. Permittee shall have a biological monitor on site during project activity to monitor and enforce the conditions of this Agreement. A biological monitor is an individual experienced with construction level biological monitoring and who is able to recognize species in the project area and who is familiar with the habits and behavior of those species. Biological monitors shall have academic and professional experience in biological sciences and related resource management activities as it pertains to this project.

2.6 On -site Education. Permittee shall conduct an education program for all persons employed or otherwise working on the project site prior to performing any work on site. The program shall consist of a presentation from the biological monitor that

RESPONSES
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COMMENTS
Agreement and present at the maintenance site. The biologist shall also include as part of the education program information about the distribution and habitat needs of any special status species that may be present, legal protections for those species, penalties for violations, and project -specific protective measures included in this Agreement. Interpretation shall be provided for non-English speaking workers, and the same instruction shall be provided for any new workers prior to their performing work on site.

2.7 Leave Wildlife Unharmed. If any wildlife is encountered during the course of construction, said wildlife shall be allowed to leave the construction area unharmed and shall be flushed, hazed, or herded in a safe direction away from the project site.

Notification #1600-2020-0126-R5
Streambed Alteration Agreement

Page 5 of 13 ends

2.8 Seasonal Restrictions — Birds. To avoid impacts to nesting birds, Permittee shall not conduct vegetation clearing and trimming, dredging, and mechanized activities between February 15 and September 15. However, work may occur during this time if a qualified biologist conducts a pre -activity nesting survey prior to project activities to determine the presence or absence of nests within the maintenance limits or surrounding buffer area. The survey shall occur within 3 days prior to project activities that are proposed during the nesting season. If no active nests are found, then no further action is needed, and the activity may proceed within 3 days of the survey. If project activities at a particular site must cease for 5 or more consecutive days during the nesting season, repeat surveys are required to ensure new nesting locations have not been established. If an active nest is detected, project activities shall not occur within a 300-foot radius (500 feet for raptors) of the detected nest until the qualified biologist determines the nest Is no longer active. Permittee shall provide the results of the survey to CDFW upon request.

2.9 Seasonal Restrictions — Vireo. For facilities identified in Exhibit D as containing suitable habitat for least Bell's vireo (vireo), project activities shall not be conducted between March 15 and September 15, the recognized vireo breeding season, unless a current survey, conducted according to the Least Bell's Vireo Survey Guidelines (US Fish & Wildlife Service, 112001), confirms the absence of vireo.

2.10 Seasonal Restrictions — Gnatcatcher. For facilities identified in Exhibit D as containing suitable habitat for coastal California gnatcatcher (gnatcatcher), project activities shall not be conducted between February 15 and August 30, the recognized gnatcatcher breeding season, unless a current survey, conducted

RESPONSES
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COMMENTS
Guidelines (US Fish & Wildlife Service, 211997), confirms the absence of gnatcatcher.

2.11 Seasonal Restrictions — Bats. For facilities identified in Exhibit D as containing suitable habitat for special status bat species, a qualified biologist shall survey for roosting bats within 3 days prior to project activities. If bats are found to occupy the site, vegetation clearance shall be conducted during winter (November 1 through January 31) when bats are unlikely to have formed maternal roost sites or have young.

2.12 Protected Species. This Agreement does not authorize take, incidental or otherwise, of any protected species. For the purpose of this Agreement, "protected species" means the following: a species fully protected under state law; a species listed under the California Endangered Species Act (Fish & G. Code § 2050 et seq.) and/or Endangered Species Act (16 U.S.C. § 1531 et sec.); a species identified by CDFW as a species of special concern; or any other species Notification #1600-2020-0126-R5
Streambed Alteration Agreement

Page 6 of 13 ends

for which take is prohibited under state or federal law. No direct or indirect impacts shall occur to any protected species, except as may be authorized by a Natural Community Conservation Plan or one or more individual permits that authorize such impacts.

2.13 Notification to the Califomia Natural Diversity Database. If any protected species is observed in project surveys, Permittee shall cause a California Native Species Field Survey Form and survey map to be submitted to the Natural Diversity Database within 5 working days of the sightings. Instructions for submittal are available online at https://wildlife.ca.gov/Data/CNDDB .

2.14 Work in Flowing Stream. It is understood that removal of sediment and debris may require work within flowing or ponded water in some situations. However, no equipment shall be operated in areas of ponded or flowing water, except when specifically required to remove flowage impediments. Equipment operated in the water shall not be submerged to a point above any axle of said equipment.

Excavation equipment buckets may reach out into the water for the purpose of removing accumulated sediments.

2.15 Flow Diversions. In the event diversion of flows through or around the work site is required, diversions shall be done in a manner that shall prevent pollution and/or siltation and which shall provide flows to downstream reaches. Flows to downstream reaches shall be provided during all times that the natural flow would have supported aquatic life. Said flows shall be sufficient quality and quantity, and of appropriate temperature to support fish and other aquatic life both above and

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COMMENTS
below the diversion. Normal flows shall be restored to the effected stream immediately upon completion of work at that location.

2.16 Erosion Control Measures. Permittee shall utilize erosion control measures throughout all phases of operation where sediment runoff from exposed slopes threatens to enter a river, stream, or lake. Preparation shall be made so that runoff from steep, erodible surfaces will be diverted into stable areas with little erosion potential. Frequent water checks shall be placed on dirt roads, cat tracks, or other work trails to control erosion.

2.17 Spoil Sites. Dredged material shall be disposed of at an upland site with proper siltation controls. Spoil sites shall not be located where spoil will likely be washed back into the water or where it will cover aquatic or riparian vegetation.

2.18 Discharge of Silty/Turbid Water Prohibited. Silty/turbid water shall not be discharged into the stream. Such water shall be settled, filtered, or otherwise treated prior to discharge. Permittee's ability to minimize turbidity/siltation shall be the subject of pre -construction planning and feature implementation.

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2.19 Hiqh Turbidity/Siltation. Upon CDFW determination that turbidity/siltation levels resulting from project related activities constitute a threat to aquatic life, activities associated with the turbidity/siltation shall be halted until effective CDFW-approved control devices are installed or abatement procedures are initiated.

2.20 Operating Equipment and Vehicle Leaks. Any equipment or vehicles driven and/or operated within or adjacent to the stream shall be checked and maintained daily, to prevent leaks of materials that if introduced to water could be deleterious to aquatic life. Permittee shall maintain all vehicles and equipment in proper working condition to minimize fugitive emissions and accidental spills from motor oil, antifreeze, hydraulic fluid, grease, or other fluids or hazardous materials. All fuel or hazardous waste leaks, spills, or releases shall be stopped or repaired immediately and cleaned up at the time of occurrence. Permittee shall be responsible for spill material removal and disposal to an approved offsite landfill and spill reporting to the permitting agencies. Service construction equipment shall be stored at designated areas only. Service/maintenance vehicles shall carry appropriate equipment and materials to isolate and remediate leaks or spills. A spill containment kit shall be available onsite for all fueling, maintenance, and construction activities.

2.21 Staging and Storage. Staging and storage areas for equipment, materials, fuels, lubricants and solvents, shall be located outside of the stream channel and banks.

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welders, located within or adjacent to the stream shall be positioned over drip -pans. Vehicles must be moved away from the stream prior to refueling and lubrication.

2.22 Hazardous Materials. No debris, soil, silt, sand, bark, slash, sawdust, rubbish, construction waste, cement or concrete or washings thereof, asphalt, paint, oil or other petroleum products, or any other substances/materials associated with any project -related activity shall be allowed to contaminate the soil and/or enter into or be placed where they may be washed by rainfall or runoff into a stream or lake.

Any of these substances/materials, placed within or where they may enter a stream or lake, by Permittee or any party working under contract, or with the permission of Permittee, shall be removed immediately upon observation of their presence. When operations are completed, any excess materials or debris shall be removed from the work area.

3. Compensatory Measures
To compensate for adverse impacts to fish and wildlife resources identified above that cannot be avoided or minimized, Permittee shall implement each measure listed below.

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Streambed Alteration Agreement

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3.1 Mitigation for Authorized Impacts. Permittee has successfully completed compensatory mitigation for 47 maintenance sites previously authorized by Streambed Alteration Agreement 1600-2008-0348-R5. Thirty-five of those sites are included in this Agreement, and do not require additional compensatory mitigation. Four of the 7 newly added sites are existing concrete -lined channels that lack vegetation. The remaining 3 new sites are earthen channels wherein vegetation will be trimmed, and dead vegetation and debris will be removed. No new ground disturbance or alteration of the bed, channel, or banks will occur. No compensatory mitigation is required for maintenance of the new facilities.

3.2 Mitigation for Unauthorized Impacts. Permittee shall mitigate at a minimum 5:1 ratio for impacts beyond those authorized in this Agreement. In the event that additional mitigation is required, the type of mitigation shall be determined by CDFW and may include creation, restoration, enhancement and/or preservation.

4. Reporting Measures
Permittee shall meet each reporting requirement described below.

4.1 Annual Work Plan. Permittee shall submit an annual work plan to CDFW by July 1

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year.

4.2 Annual Post -Maintenance Report. Permittee shall submit an annual post - maintenance report to CDFW by October 1 of each year. The report shall include:
the maintenance that was performed at each facility, including the type and area of impact, dates that maintenance began and ended, and photo documentation of maintenance areas.

CONTACT INFORMATION
Any communication that Permittee or CDFW submits to the other shall be in writing and any communication or documentation shall be delivered to the address below by U.S. mail, fax, or email, or to such other address as Permittee or CDFW specifies by written notice to the other.

To Permittee
John Conley
City of Vista
200 Civic Center Drive
Vista, California 92084
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Streambed Alteration Agreement

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To CDFW
California Department of Fish and Wildlife
South Coast Region
3883 Ruffin Road
San Diego, California 92123
Attn: Lake and Streambed Alteration Program
Notification #1600-2020-0126-R5

LIABILITY
Permittee shall be solely liable for any violations of the Agreement, whether committed by Permittee or any person acting on behalf of Permittee, including its officers, employees, representatives, agents or contractors and subcontractors, to complete the project or any activity related to it that the Agreement authorizes.

This Agreement does not constitute CDFW's endorsement of, or require Permittee to oroceed with. the oroiect. The decision to oroceed with the oroiect is Permittee's alone.

RESPONSES
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SUSPENSION AND REVOCATION
CDFW may suspend or revoke in its entirety the Agreement if it determines that Permittee or any person acting on behalf of Permittee, including its officers, employees, representatives, agents, or contractors and subcontractors, is not in compliance with the Agreement.

Before CDFW suspends or revokes the Agreement, it shall provide Permittee written notice by certified or registered mail that it intends to suspend or revoke. The notice shall state the reason(s) for the proposed suspension or revocation, provide Permittee an opportunity to correct any deficiency before CDFW suspends or revokes the Agreement, and include instructions to Permittee, if necessary, including but not limited to a directive to immediately cease the specific activity or activities that caused CDFW to issue the notice.

ENFORCEMENT
Nothing in the Agreement precludes CDFW from pursuing an enforcement action against Permittee instead of, or in addition to, suspending or revoking the Agreement.

Nothing in the Agreement limits or otherwise affects CDFW's enforcement authority or that of its enforcement personnel.

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OTHER LEGAL OBLIGATIONS
This Agreement does not relieve Permittee or any person acting on behalf of Permittee, including its officers, employees, representatives, agents, or contractors and subcontractors, from complying with, or obtaining any other permits or authorizations that might be required under, other federal, state, or local laws or regulations before beginning the project or an activity related to it. For example, if the project causes take of a species listed as threatened or endangered under the Endangered Species Act (ESA), such take will be unlawful under the ESA absent a permit or other form of authorization from the U.S. Fish and Wildlife Service or National Marine Fisheries Service.

This Agreement does not relieve Permittee or any person acting on behalf of Permittee, including its officers, employees, representatives, agents, or contractors and subcontractors, from complying with other applicable statutes in the Fish and Game

RESPONSES
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COMMENTS
Code including, but not limited to, Fish and Game Code sections 2050 et seq. (threatened and endangered species), section 3503 (bird nests and eggs), section 3503.5 (birds of prey), section 5650 (water pollution), section 5652 (refuse disposal into water), section 5901 (fish passage), section 5937 (sufficient water for fish), and section 5948 (obstruction of stream).

Nothing in the Agreement authorizes Permittee or any person acting on behalf of Permittee, including its officers, employees, representatives, agents, or contractors and subcontractors, to trespass.

AMENDMENT
CDFW may amend the Agreement at any time during its term if CDFW determines the amendment is necessary to protect an existing fish or wildlife resource.

Permittee may amend the Agreement at any time during its term, provided the amendment is mutually agreed to in writing by CDFW and Permittee. Permittee may amend this Agreement to add facilities. The amendment request shall include the project -level analysis needed to determine that the proposed facility, activities, and impacts are similar in location, size, and scope to those described in this Agreement.

To request an amendment, Permittee shall submit to CDFW a completed CDFW "Request to Amend Lake or Streambed Alteration" form and include with the completed form payment of the corresponding amendment fee identified in CDFW's current fee schedule (see Cal. Code Regs., tit. 14, § 699.5).

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TRANSFER AND ASSIGNMENT
This Agreement may not be transferred or assigned to another entity, and any purported transfer or assignment of the Agreement to another entity shall not be valid or effective, unless the transfer or assignment is requested by Permittee in writing, as specified below, and thereafter CDFW approves the transfer or assignment in writing.

The transfer or assignment of the Agreement to another entity shall constitute a minor amendment, and therefore to request a transfer or assignment, Permittee shall submit to CDFW a completed CDFW "Request to Amend Lake or Streambed Alteration" form and include with the completed form payment of the minor amendment fee identified in CDFW's current fee schedule (see Cal. Code Regs., tit. 14, § 699.5).

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EXTENSIONS
In accordance with Fish and Game Code section 1605, subdivision (b), Permittee may request one extension of the Agreement, provided the request is made prior to the expiration of the Agreement's term. To request an extension, Permittee shall submit to CDFW a completed CDFW "Request to Extend Lake or Streambed Alteration" form and include with the completed form payment of the extension fee identified in CDFW's current fee schedule (see Cal. Code Regs., tit. 14, § 699.5). CDFW shall process the extension request in accordance with Fish and Game Code section 1605, subdivisions (b) through (e).

If Permittee fails to submit a request to extend the Agreement prior to its expiration, Permittee must submit a new notification and notification fee before beginning or continuing the project the Agreement covers (Fish & G. Code, § 1605, subd. (f)).

EFFECTIVE DATE
The Agreement becomes effective on the date of CDFW's signature, which shall be: 1) after Permittee's signature; 2) after CDFW complies with all applicable requirements under the California Environmental Quality Act (CEQA); and 3) after payment of the applicable Fish and Game Code section 711.4 filing fee listed of https:ll www.wildlife.r-a.gov/Conservation] CEQA/Fees.

TERM
This Agreement shall expire on February 28, 2026, unless it is terminated or extended before then. All provisions in the Agreement shall remain in force throughout its term.

Permittee shall remain responsible for implementing any provisions specified herein to protect fish and wildlife resources after the Agreement expires or is terminated, as Fish and Game Code section 1605, subdivision (a)(2) requires.

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Streambed Alteration Agreement

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EXHIBITS
The documents listed below are included as Exhibits to the Agreement and incorporated herein by reference.

Exhibit A — Individual Facility Locations
Exhibit B — Project Activities Per Facility
Exhibit C — Vegetation Communities and Other Cover Types

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Exhibit D — Special Status Wildlife and Suitable Habitat Presence

AUTHORITY
If the person signing the Agreement (signatory) is doing so as a representative of Permittee, the signatory hereby acknowledges that he or she is doing so on Permittee's behalf and represents and warrants that he or she has the authority to legally bind Permittee to the provisions herein.

AUTHORIZATION
This Agreement authorizes only the project described herein. If Permittee begins or completes a project different from the project the Agreement authorizes, Permittee may be subject to civil or criminal prosecution for failing to notify CDFW in accordance with Fish and Game Code section 1602.

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CONCURRENCE
The undersigned accepts and agrees to comply with all provisions contained herein.

FOR CITY OF VISTA

RESPONSES
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COMMENTS
30 Buena Vista Crk at N. Co.

Buena Vista Creek
3119628
0'
Ford
117.24946
164204030
a
31 Buena Vista Crk at
Buena Vista Creek

33.19393
NIA
Melrose Dr
117.25398
l2A
Buena Vista Crk at La
Buena Vista Creek

33.19357
NIA
Tortu a or
117.25890
t2B
Buena Vista Crk, N of
Buena Vista Creek

33.19338
166440400
Hacienda Dr
117.26685
0 33
E Vista Way(Escondid.

Unnamed tributary to Buena
-

33.20501
176060280
Ave Wildland Park
Vista Creek
117.23681
0 35
Northern Terminus of
Unnamed tributary to Aqua

33.16461
NIA
Watson Way
Hedionda Creek
117.22228
38 Foothill Drive, North of
Unnamed tributary to Buena
-

33.20710
178022040
Vale Terrace Dr
Vista Creek
117.20820
0 41
Breeze Hill Drive at
Buena Vista Creek

33.19362
NIA
Hacienda Dr
117.26067
42 Buena Vista Park Duck
Roman Creek

33.15849
169011330
Pond InletlOutlet
117.24644
0 217023470
43 Shadowridge Drive at
Buena Vista Creek

33.16462
0,
Sycamore Ave
117.21728
217G23460
0 45
Monte Vista Detention
Unnamed tributary to Buena
-

33.19177
181022200
Basin Outlet
Vista Creek
117.21325
0 46
Delpy Ditch Inlet
Unnamed tributary to Buena
-

33.21606
NIA
Vista Creek
117.22936
47 Upper Roman Creek-
Roman Creek

33.16687
169011330
Buena Vista Park
117.24716
0 164205170
0,
164205270
0,
48 Buena Vista Creek at Vista
Buena Vista Creek
33A9845
164265300
Village Creekwalk
117.24620
0,
164205170
0,
164205300
0 164205230
49 Citrus to Creekwalk
Buena Vista Creek
3319922
0,
117.24354
164205180
0 50
Buena Vista Crk, N of The
Buena Vista Creek

33.19942
164205170
Wave Water ark
117.24673
0 51
Eucalyptus Ave. (Avalon
Buena Vista Creek

33.20121
N/A
Dr-Alesto St)117.23174
52 HacienLaTortuada (Melrose w
west to
Buena Vista Creek

33.19380
NIA
117.25634
53 Hacienda and Vista Village
Buena Vista Creek
_

33.19423
164320126
0,
Dr.
117.25244
164205280
Notification #1600-2020-0082-R5
Streambed Alteration Agreement
Exhibit A- Individual Facility Locations

Page 3 of 3 ends

RESPONSES
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COMMENTS
0-1-311-16.1,;
Toun#v of San jlego

PLANNING & DEVELOPMENT SERVICES
5510 OVERLAND AVENUE, SUITE 310, SAN DIEGO, CA 92123
(858) 505-6445 General • (858) 694-2705 Codes
(858) 565-5920 Building Services
www.SDCPDS.org

DAHVIA LYNCH

DIRECTOR
October 5, 2022
Ms. Patsy Chow
Deputy Director of Community Development/City Planner
City of Vista
Planning Division
200 Civic Center Drive
Vista, CA 92084
Sent via email to: pchow(cDcityofvista.com

REQUEST FOR COMMENTS ON THE NOTICE OF INTENT TO ADOPT A MITIGATED

NEGATIVE DECLARATION FOR THE CAMINO LARGO RESIDENTIAL PROJECT FOR THE

CITY OF VISTA
Dear Ms. Chow,
C-1 CThe County of San Diego (County) staff reviewed the City of Vista's (City) Notice of Intent to Adopt a Mitigated Negative Declaration (MND) for the Camino Largo Residential Project (Project), received on September 30, 2022.

County staff appreciates the opportunity to review the Project and offers the following comments C-2 for your consideration. Please note that none of these comments should be construed as County Esupport for this Project.

GENERAL

1. The County's Land Use and Environment Group has developed Guidelines for C-3 Determining Significance that are used to determine the significance of environmental impacts and mitigation options for addressing potentially significant impacts in the unincorporated portions of the county. Project impacts that could have potentially significant adverse effects to the unincorporated county or County facilities should be evaluated using the County's Guidelines for Determining Significance. These guidelines are available online at: http://www.sandiegocounty.qoy/pds/procquid.html .

2. Due to the location of the proposed project, the County recommends the city and the C-4 applicant work closely with the surrounding unincorporated residents located in close proximity to the project and keep them informed of the project's progress. Please include the Bonsall Community Sponsor Group informed as part of the effort.

RESPONSES
C-1 The comment is introductory. As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

C-2 The comment is introductory. As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

C-3 This comment identifies that the County's Land Use and Planning Group has developed Guidelines for Determining Significance that should be used for determining impacts in unincorporated areas of the County. As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

C-4
The County requests that the City works closely with residents in the unincorporated areas surrounding the project site. As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

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COMMENTS
Ms. Chow
October 5, 2022

Page 2 ends

C-5 3. The County previously submitted a Comment Letter on this project dated September 3, 2013. Please ensure that all relevant comments are addressed in the MND.

C-6 4. Please ensure that all project documents identify that the project site was annexed into the city in 2018.

VECTOR CONTROL
The County Vector Control Program (VCP) is responsible for the protection of public health C-7 through the surveillance and control of mosquitoes that are vectors for human disease including West Nile virus (WNV). The VCP has completed their review and has the following comments regarding the proposed project.

1. The VCP respectfully requests that the Mitigated Negative Declaration address potential impacts from possible mosquito breeding sources created by the project and that the project be designed and constructed in a manner to minimize those impacts. Specifically, ensure construction -related depressions created by grading activities, vehicle tires, and excavation do not result in depressions that will hold standing water. In addition, ensure C-g drains, Best Management Practices (BMPs), stormwater capture systems, and other structures do not create a potential mosquito breeding source. Any area that is capable of accumulating and holding at least % inch of water for more than 96 hours can support mosquito breeding and development. Finally, if habitat remediation is required for the project, the design should be consistent with guidelines for preventing mosquito habitat creation.

2. Please note, the VCP has the authority pursuant to state law and County Code to order the abatement of any mosquito breeding that does occur either during construction or after C-9 the project is completed that is determined to be a vector breeding public nuisance. The VCP will exert that authority as necessary to protect public health if the project is not designed and constructed to prevent such breeding.

3. For your information, the County of San Diego Guidelines for Determining Significance for Vectors can be accessed at
http://www.sandiegocounty.goy/content/dam/sdc/pds/docs/vector quidelines.pdf and the C-10 California Department of Public Health Best Management Practices for Mosquito Control in California is available at
https://wvwv.cdph.ca.gov/Programs/CI D/DCDC/Pages/MosquitoesandMosquitoBorneDis eases.aspx#

5. The VCP appreciates the opportunity to participate in the environmental review process C-11 for this project. If you have any questions regarding these comments, please contact Daniel Valdez at 858-688-3722 or by e-mail at Daniel.Valdez(cDsdcounty.ca.gov.

WATERSHED PROTECTION
C-12F1. The project could potentially generate stormwater impacts to adjacent parcels located in the unincorporated county. Therefore, the project must consider the following items:

RESPONSES
C-5 It is noted that the County previously submitted a letter on the Draft IS/MND. As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

C-6 This comment is a request by the County that all project documents identify that the project site was annexed into the City in 2018. As Page 2-1 of the Revised Final IS/MND has the following clarification:

The project site, which was annexed into the CitV in 2018, has a General Plan land use designation of Rural Residential (RR) and the project would require a General Plan Amendment to
designate the site as Medium Density Residential (MD
Residential) (10 dwelling units [du]/acre). The project would also require a zone change from Agricultural (A-1) to Residential (R-1-13, small lot subdivision, 3,600 square foot [sf] lots).

C-7 This comment is identifying the responsibility of the County Vector Control Program (VCP) to protect public health and is indicating that the County VCP has reviewed the document and is submitting comment. As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

C-8 This comment is in relation to concerns regarding vector control. Please refer to Topical Response No. 3, Duplicate Comments and Comments Out of the Scope of the Revised IS/MND.

C-9 This comment is in relation to concerns regarding vector control. Please refer to Topical Response No. 3, Duplicate Comments and Comments Out of the Scope of the Revised IS/MND.

C-10 The comment provides information regarding the County Guidelines for Determining Significance for vector control and provides a website address to access. As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

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COMMENTS
Ms. Chow
October 5, 2022

Page 3 ends

a. Compliance with the San Diego Municipal Storm Water Permit Order No. R9-2013- C-12 0001, (as amended by Order Nos. R9-2015-0001 and R9-2015-0100). The Project should consider implementing permanent Site Design, Source Control, Pollutant Cont. Control, and Hydromodification Management in accordance with your municipal jurisdiction's BMP Design Manual as required by the San Diego Municipal Storm Water Permit Order No. R9-2013-0001.

ROADS FIELD ENGINEERING

1. If the project has plans to out or trench within the County maintained roads within 3 years of the County repaving them, there will be a violation of the County's Cut Policy. There will C-13 then be a requirement to resurface the full width of the road with the same treatment.

Please coordinate with Lawrence Hirsch, Utility Coordinator, for any updates or questions at (858) 694-2215 or at lawrence.hirsch(cbsdcounty.ca.gov.

LAND AND WATER QUALITY

1. The Department of Environmental Health and Quality (DEHQ), Land and Water Quality Division, has reviewed the Notice of Intent to Adopt a MND for the Project. DEHQ records indicate that adjacent residences to the north and east of the project site are served by C-14 onsite wastewater (septic) systems. As such, grading plans for the project should be routed to DEHQ for review and concurrence prior to approval to ensure the proposed grading does not impact the existing septic systems and required septic reserve area on adjacent properties.

C-15 2. For further information on the review process and applicable fees, please contact Craig Caes, Supervising Environmental Health Specialist of the Land Use Program, at 858-694- 2551.

The County appreciates the opportunity to comment on this project. We look forward to receiving C-16 future documents related to this Project and providing additional assistance, at your request. If you have any questions regarding these comments, please contact Timothy Vertino, Land Use / Environmental Planner, at (858) 505-6677, or via e-mail at timothy.vertino(cDsdcounty.ca.gov.

Sincerely,
Lynnette Tessitore
Chief, Long Range Planning Division
Planning & Development Services
Enclosure: Attachment A: 2013 County of San Diego Comment Letter cc: Hunter McDonald, Policy Advisor, Board of Supervisors, District 5 Marvin Mayorga, Group Program Manager, LUEG
Mary Bennett, Administrative Analyst, DEHQ
Sue Waters, Land Use/Environmental Planner, DPW

RESPONSES
C-11 The comment provides contact information. As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

C-12 The comment is in relation to stormwater. No further response is required. Please refer to Topical Response No. 3, Duplicate Comments of Comments Outside of the Scope of the Revised IS/MND.

C-13 The comment is in relation to County maintained roads. No further response is required. Please refer to Topical Response No. 3, Duplicate Comments of Comments Outside of the Scope of the Revised IS/MND.

C-14 The comment requests that the County Department of Environmental Health and Quality (DEHQ) have an opportunity to review grading plans.

As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

C-15 The comment provides contact information for the County DEHQ. As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

C-16 The comment is in closing and provides contact information. As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

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COMMENTS
Attachment A
0 County of Aban Diego

MARK WARDLAW

PLANNING & DEVELOPMENT SERVICES
Pi--

OARREN GRETLER
Asskiml oirecEer
551D OVERLAND AVENUE. 5UITE 1IU, SAN DIEGO, GALIFORNIA-23 INFORMATION (650) 694.2960
TOLL FREE 600I¢1141017
Www.sd—rly-c. q.-1P0
September 3, 2013
City of Vista
Attn: John Conley
Community Development Department
200 Civic Center Drive
Vista, CA 92084
Via email to [email protected]
COMMENTS ON THE PROPOSED CAMINO LARGO 8 TENTATIVE SUBDIVISION MAP (PC NO. PC 0"5612-112)
Dear Mr. Conley
The County of San Diego has received and reviewed the Tentative Subdivision Map for Camino Largo 8 dated July 17, 2013 and appreciates this opportunity to comment. The County has comments that identify potentially significant environmental issues that may have an effect on the unincorporated lands of San Diego County. In addition, the comments may identify reasonable alternatives and mitigation measures that should be explored in the environmental document.

County Planning & Development Services (PDS) and Deparlment of Public Works (DPW) have completed their review and have the following comments regarding the content of the above documents.

GENERAL COMMENTS
The County of San Diego, Land Use and Environment Group has developed Guidelines for Determining Significance that are used to determine the significance of environmental impacts and mitigation options for addressing potentially significant impacts in the unincorporated portions of the County of San Diego, Project impacts that could have potentially significant adverse effects to the unincorporated County or County facilities should be evaluated using the

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County's Guidelines for Determining Significance. These guidelines are available online at: http:U www.sdcounty.ca.gov/dplulprocguid.html#guide .

2. The proposed project would require annexation to the City of Vista. The City's General Plan allows one unit per acre, while the County General Plan density allowance is one unit per 1, 2 or 4 acres, depending on slope. Due to the slope on the project site, the proposed project density would likely exceed the allowable density under the County's General Plan. The City should work with the surrounding residents and the Bonsall Community Planning Group to ensure the project is developed consistent with the surrounding community.

3. The incorrect County General Plan designation is listed on Sheet 1 of 4 in the General Notes section of the Tentative Subdivision Map. The existing General Plan Designation in this area is "Semi -Rural Residential 1 (1 DUI 1, 2, & 4 AC).

BIOLOGICAL RESOURCES

3. Though disturbed, the site could provide habitat for some animals and birds, particularly foraging habitat for raptors. A biological open space easement over a riparian area exists adjacent to the project site on the south side of Camino Largo. The environmental document should assess impacts to the biological resources on the site, including impacts to wildlife species that use the riparian habitat (Le,, loss of foraging habitat for raptors and other birds that could nest in the riparian trees).

T RA F F I CITRA N S P O R TAT I O N

4. Based on the Tentative Subdivision Map (PC 6-056/2-112), the proposed Camino Largo 8 project would generate 80 trips [8 Single Family Dwelling Units (DU) x 10 trips/DU]. The involved parcels were studied as part of the County's Transportation Impact Fee (TIF) program. The project should pay the County's TIF to mitigate local and regional cumulative traffic impacts to facilities located within the unincorporated area.

5. If the project is annexed into the City of Vista and the City collects SANDAG Regional Transportation Congestion Improvement Program (RTCIP) funds in the amount of $2,209 (per unit), County TIF should still be paid in the amount of $2,638 per single family unit.

Bonsall, Non -Village: 8 x $2,638 = $21,104

6. The remaining road right-of-way (ROW) width on Camino Largo, adjacent the project parcels should be included as part of the project's proposed annexation into the City of Vista, and should subsequently be maintained by the City of Vista.

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Mr. Conley
September 3, 2013

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The County of San Diego appreciates the opportunity to continue to participate in the environmental review process for this project. We look forward to receiving future environmental documents related to this project or providing additional assistance at your request. If you have any questions regarding these comments, please contact Jennifer Domeier, Land Use Environmental Planner at (858) 495-5204 or email ennifer.domeierfWsdcou nty.ca.gov.

Sin ly,
Darren Gretl r, Assistant Director
Planning & Development Services
e-mail cc:

Eddie Sprecco, Policy Advisor, Board of Supervisors, District 5 Megan Jones, Group Program Manager, LUEG
Michael Ott, Executive Officer, LAFCO
Richard Chin, Associate Transportation Specialist, Department of Public Works Nick Orliz, Land Development Project Manager, Planning & Development Services Julia Quinn, Environmental Planning Manager, Department of Public Works Margarette Morgan, Chair, Bonsall Community Sponsor Group Jennifer Domeier, Land Use Environmental Planner, Planning & Development Services

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COMMENTS

DELANO & DELANO
October 3, 2022
Patsy Chow, Deputy Director
Planning Divi si on
City of Vista
200 Civic Center Dr.

Vista, CA 92094
Re: Camino Largo Project (P21-0300) and Revised MND
Dare City of Vista',
This letter is submitted on behalf of Guajome Alliance for Responsible D-1
Development ("GuAR ') in tonnection with the proposed Camino Largo project ("Project") and Revised Mitigated Negative Declaration ("NIN.D" ).

The California Environmental Quality Act("CEQA"), Public Resources Code § 21000 et seq., requires the preparation of an Environmental impact Report ("EAR") whenever substantial evidence in the record supports a "fair argument" that significant environmental impacts may occur. Pub, Res. Code § 21080(d); No Ord, Inc. r. City ofTos D-2
Ange1es(1975)13Cal.3d68_ If there is"substantial evidence that the project might have [a significant impact on the environment], but the agency failed to secure preparation of the required EIR, the agency's action is to be set aside because the agency abused its discretion by failing to proceed in a `manner required by law_"' Friends of "B" .Sfreer v.

City ofHayward (1980) 106 Cal.App 3d 988, 1002 Here, the City should prepare an EIR before proceeding; the Project is likely to lead to several significant impacts.

On July 15, 2022, T submitted a letter on behalf ofGuARD, which, among other D-3
things, identified several inadequacies in the Project and MND The City recently issued the Revised MND. The Revised MND contains some amended language regarding air quality, land use/planning, and population and housing, but it still contains several critical flaws
The Revised MND asserts the "project would be consistent with the growth D-4
assumptions used to develop the region'sAttainment Plan and, therefore, [air quality] impacts would be less than significant." Revised MND at 3-0. This conclusion is not supported The Revised HIND notes that the "City had a total of 32,8 t5 units as of the 2020 census." Id. It also explains that "SANDAG Series 13 Regional Data have predicted 35,307 units by 2035 .. ." Id The Revised MND concludes that accounting

RESPONSES
D-1 The comment is an introductory statement that the comment letter has been submitted on behalf of GuARD. As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

D-2 The comment states that an Environmental Impact Report (EIR) should be prepared for the proposed project because the project is "likely to lead to several significant impacts." However, no facts or other evidence is provided to support this assertion. The conclusions and supporting analysis contained in the Draft IS/MND and Revised IS/MND that the proposed project would not result in significant environmental effects are supported by substantial evidence contained in the record. Project impacts are adequately analyzed and assessed based on established methodologies and identified CEQA significance thresholds. Where potentially significant impacts are identified, feasible mitigation measures are identified that would avoid or reduce impacts to below a level of significance (see Mitigation Measures CR-1 through CR-5, HAZ-1, and LU-1, and LU-2). Therefore, preparation of an EIR for the project is not warranted or required.

D-3 The comment states that although revisions have been made in response to the Delano & Delano/GuARD July 15, 2022 letter, the Revised IS/MND still contains critical flaws but does not provide any facts or other evidence to support this assertion. As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

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City of Vista
October 3, 2022

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for 1,121 entitled/approved units and pending units (including the Project's units) "would result in 33,936 units ...." Id However, in a section on Land Use and Planning impacts, the Revised MND notes that the City Housing Element Update "for the 2021 — 2029 planning period assigned Vista a new housing need of 2,561 units." Id at 3-12_ D-4 Therefore, by 2029 (the last year of the planning period) the total number of units would Cont. be 35,376 — 69 units higher than the Attainment Plan accounted for and with six )ears or development still to go. in other words, the City's own plans project more units by 2D29 than the air quality analysis assumed would be developed by 2035. And if we assumed a continued growth rate far those last six years comparable to the growth rate anticipated by the 2021 to 2029 period (320 units/year), the actual amount of development by 2035 would be 37,296 units — 1,989 units more than what the Attainment Plan anticipates.

D-5 And for these same reasons, the Revised MNO's analysis of land use/planning and population and housing impacts is insufficient.

Additionally, the City has not revised or otherwise responded to the several other comments regarding the inadequacies in the Project and MND, including the following:

The Project will lead to significant impacts to air quality and greenhouse gas emissions.
• The MND attempts to separate air emissions into construction and operational phases. However, it fails to account for the fact that such phases can, indeed D-6 are likely to, overlap, thereby increasing the amounts of emissions at any given time This is particularly stark in light of the emissions of just construction equipment alone.
• The MND averages construction emissions over the life of the Project. MND at 3-27. Such emissions should be calculated as they will actually occur, not averaged over a longer period of time_ See Taxpayers for Accountable School Bond Spending v. San Diego Unified School Dist. (2013) 215 Cal, App.4`s 1013, 1049. indeed, if construction emissions were appropriately accounted for, the Project would exceed the City's GHG Threshold.

The Project will lead to significant impacts to land use, aesthetics, and agricultural resources.

D-7 • The Project proposes to place dense residential uses in a rural, agricultural area. The Project is inconsistent with the surrounding area. Indeed, the staff report acknowledges the Project is surrounded mainly by agricultural zoning and generally rural and low -density General Plan designations. Staff Report at 6.
• The staff report claims the "property is surrounded by residential uses. .." Staff Report at 9. But this claim misses the fact that the dense project is incompatible with its much less dense surroundings.

RESPONSES
D-4 Please refer to Topical Response No. 1, Air Quality and No. 3, Land Use and Planning. The City acknowledges that the project was not accounted for in the current Attainment Plan, but the buildout intensity levels assumed under the current Attainment Plan have not been achieved, even assuming the 1,121 residential units that are under construction or may be constructed. The project is also in compliance with federal and state ambient air quality standards and would not result in significant air quality impacts with respect to the project's construction and operational -related emissions of ozone precursors or criteria air pollutants (see Table AQ 3 and AQ-4 of the Revised IS/MND and IS/MND). Because the population and employment growth anticipated by the Attainment Plan has not been achieved, in conjunction with the project's less -than -significant emission impacts, the project would not conflict or obstruct implementation of the local air quality plan.

With respect to accounting for the next six years of development, the Air Pollution Control District is required to update the Attainment Plan and its modeling on a triennial basis. (See Health & Safety. Code, § 40925, subdivision. (a) [every three years, district shall revise plans to attain state air quality standards to, among other things, incorporate projected emissions growth]). The Revised IS/MND does not use the housing needs allocation as identified in the Regional Housing Needs Assessment (RHNA) as a basis for comparison. Rather, this data is included for informational purposes to indicate that there is an identified need for additional housing in the City to support the future population projections. It is not relevant for analysis of the Attainment Plan.

Furthermore, the total allocated need of housing (2,561 units) does not account for the units that are already identified in the Draft General Plan Housing Element Update (May 2022) and are included in the Attainment Plan projections. Analysis of the housing needs as presented within the RHNA and the City's General Plan Housing Element Update are outside the scope of this project and associated CEQA environmental documentation.

D-5 The comment states that the analysis contained in the Land Use and Planning and Population and Housing sections of the Revised IS/MND is insufficient because the oroiect is not consistent with the oroiections in RTC-61
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the Attainment Plan. As discussed in response D-4 above, the project is consistent with the Attainment Plan projections. Please also refer to Topical Response No. 1 Air Quality and No. 2, Land Use and Planning.

D-6 No substantial evidence has been provided to support a fair argument that the proposed project failed to consider significant impacts associated with air quality impacts by failing to account for a presumed overlap between the construction and operational phases of the project.

As explained in Air Quality, Greenhouse Gas Emissions, and Energy Technical Report (December 2021), the project would be constructed in one phase. Construction of the project would commence in April 2022 and be completed in approximately March 2023 for a total construction duration of approximately one year. (Air Quality, Greenhouse Gas Emissions, and Energy Technical Report, Helix Environmental Planning, December 2021, page 1.) Therefore, there would be no overlap between the construction and operational phases of the Project
If construction occurred over a longer time, emissions could be reduced because of (1) a more modern and cleaner -burning construction equipment fleet mix than assumed in the air quality model, and/or (2) a less intensive buildout schedule with fewer daily emissions occurring over a longer time interval. Additionally, even if you were to sum the total daily operational emissions with the maximum daily construction emissions (an unrealistic scenario), the total daily criteria pollutant emissions would still be less than the applicable significance thresholds.

Additionally, the comment asserts construction period greenhouse gas (GHG) emissions should not have been amortized and if analyzed correctly, they would result in a significant and unavoidable impact. This is not accurate. As detailed in the Air Quality, Greenhouse Gas Emissions, and Energy Technical Report that is Appendix A of the Draft IS/MND (see Attachment C of the Final Revised IS/MND), the City has not adopted any threshold for construction period GHG emissions. To be conservative in accounting for all the project's GHG emissions, the construction emissions were amortized over the life of the project, consistent with the Association of Environmental Professionals guidance. Even if construction had been analyzed on its own and compared to the threshold used in the analysis, the impact conclusion would be the same— less than significant. Total construction period emissions were RTC-62
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estimated to be 699.8 MT CO2e, which is less than the threshold, adjusted for consistency with Senate Bill 32, of 966 MT CO2e.

D-7 The comment states that the project is inconsistent with surrounding land use/zoning designations and certain General Plan Land Use and Community Identity (LUCI) Element policies. Please refer to Topical Response No. 2, Land Use and Planning.

The comment also states that the project is not consistent with the intent of the small lot development regulations because it does not include affordable housing. The Small Lot Residential Requirements (Chapter 18.33 of the Vista Municipal Code), adopted by the City in May 2022, consist of specific development regulations to allow for small lot subdivisions to provide for additional fee simple ownership opportunities. These regulations do not prescribe or require affordable housing. Further, this statement is not related to an environmental issue and no further response is required under CEQA relative to this specific comment.

The comment further states that the General Plan Housing Element indicates the site should not be developed at anything greater than one dwelling unit. Please refer to Topical Response No. 2, Land Use and Planning.

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COMMENTS
City of Vista
October 3, 2022

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• The Project is inconsistent with several aspects of the City's General Plan.

For example, contrary to LUCI Policy 2.4, it disrupts the existing development pattern within the established neighborhood (the diagram on page 2-4 of the Land Use and Community Design Element demonstrates clearly how the Project violates this policy). And contrary to LUCI Policy

2.1, it does not provide for large -lot single-family residential development. • The staff report claims the City recently adopted small lot development D-7 regulations "to provide an alternative to the traditional single-family Cont. subdivisions, thereby increasing options for fee simple homeownership opportunities." Staff Report at 7. But there is no showing that the Project will provide affordable housing.
• Municipal Code Chapter 17.12 and the State Subdivision Map Act require findings for the approval of a tentative map. The Project does not meet these findings_ For example, it is inconsistent with the General Plan. The site is not suitable for the type of development. And the Project is Iikely to cause public health problems.
• The MND claims the site is identified in the City's Housing Element, but there is nothing in the Housing Element indicating the site should be developed at anything greater than one dwelling unit.

F_ The Project will lead to significant impacts to traffic. • The MND fails to consider significant impacts associated with construction traffic.

D-8 • The MND fails to consider significant impacts to applicable roadway segments and intersections.
• The MND fails to consider the potential for public health and safety impacts, including significantly unsafe conditions associated with the several private streets intersecting with Camino Largo.

The Project will lead to significant impacts to air quality and greenhouse gas emissions.
• The MND claims the site is identified in the City's Housing Element, but there is nothing in the Housing Element indicating the site should be D-9 developed at anything greater than one dwelling unit. As such, contrary to the MND's assertion, vehicle trips associated with the development of 46 residential uses on the Project site were not accounted for in the State Implementation Plan. MND at 3-9. Such impacts on air quality and greenhouse gas emissions will be significant.
• The MND attempts to separate air emissions into construction and operational phases. However, it fails to account for the fact that such phases can, indeed are likely to, overlap, thereby increasing the amounts of emissions at any given time. This is particularly stark in light of the emissions of just construction equipment alone.

RESPONSES
D-8 No substantial evidence was provided to support a fair argument that the proposed project failed to consider significant impacts associated with traffic.
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Construction Traffic: It was anticipated that 2,758 round trips, or 5,516 one-way haul truck trips, would be required for soil export over 20 workdays during the grading phase of construction, equating to 276 one- way haul truck trips, or passes, per day. Over an eight -hour construction day, it is assumed that 34 haul truck trips would occur per hour. The additional 34 construction trips were added to the existing traffic volumes on North Santa Fe Avenue south of the project site. (Noise Assessment Study, Helix Environmental, December 2021, page 15). The additional 34 construction trips did not trigger any California Environmental Quality Act (CEQA) significance criteria. The City requires traffic control plans for any construction activity that will disrupt traffic flow on City streets, and project conditions of approval would require that emergency access be maintained during construction. (IS/MND.

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Roadway segments and intersections. Senate Bill 743 (SB 743) changed how transportation impacts are analyzed under CEQA from a Level of Service (LOS) analysis that included vehicular delay, roadway capacity, and traffic congestion to Vehicle Miles Traveled (VMT). The project will generate a total of 460 trips per day. (Local Transportation Study report, prepared by Linscott, Law, and Greenspan (LLG), November 30, 2021 ("LTS Report"), attached to the IS/MND as Appendix H, see Attachment C of the Final Revised IS/MND) According to the City's Traffic Impact Analysis Guidelines, projects that are not consistent with the applicable General Plan land use designation only require a VMT analysis if the anticipated average daily trips (ADT) would be greater than 500 trips.

Because the project will generate less than 500 trips per day, the project is concluded to have no significant transportation impacts (VMT) for purposes of CEQA, no VMT-related improvements are required, and a VMT analysis is not needed. However, the LTS Report still analyzed the traffic impacts associated with the project with respect to study area intersections and street segments using the LOS criteria. The Circulation Element of the General Plan has established LOS D as the threshold for acceptable operating conditions in designated areas. In addition, if a roadwav or intersection is currently operatine at a capacity less than the RTC-65

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applicable LOS, additional traffic will have a substantial effect if it adds more than an average two seconds of delay. Although the project would increase traffic near the site, the roadways and intersections within the study area would not conflict with the City's established LOS goals.

Therefore, the project would not conflict with the Circulation Element of the City's General Plan. (LTS Report, page 40).

Safety issues. The development of the proposed project would not increase traffic hazards due to incompatible uses that could affect existing traffic or circulation in the project area. There would be no hazardous design features or incompatible uses introduced because of the project. Access to the project site would be provided by four private cul-de-sac streets and a private drive that extend north from Camino Largo. Camino Largo is currently a two-lane un-classified roadway.

Camino Largo would be paved and extended to a minimum width of 28 feet. (IS/MND, page 2-2). The project is a typical residential subdivision that is comparable to the surrounding land uses. (IS/MND. Page 3-49).

Final project improvement plans would be subject to City review and approval, ensuring that driveway intersections and internal circulation are safe with adequate sight distance and driveway widths, for entering and exiting the site. In addition, two trees were to be removed to improve sight visibility for vehicles turning onto North Santa Fe Drive as part of the project; however, the City subsequently removed the trees under an existing authorized maintenance agreement. As such, this is no longer proposed by the project.

A two-way left turn -lane is present along North Santa Fe Avenue at Camino Largo that allows southbound left turns into the project site outside the southbound through movement. The two-way left -turn lane along North Santa Fe Avenue also facilitates outbound left turns from Camino Largo by providing a refuge lane and enabling drivers to cross one direction of traffic at a time. The intersection analysis at the Camino Largo / North Santa Fe intersection results in LOS C or better in all scenarios. LLG concluded that no improvements were deemed necessary based on the presence of the two-way left -turn lane and the acceptable LOS results. Although, a stop sign installed on Camino Largo at North Santa Fe Avenue is recommended. (Local Transportation Study report, LLG, November 30, 2021, page 38).

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• The NIND averages construction emissions over the life of the Project. MND at 3-27. Such emissions should be calculated as they will actually occur, not averaged over a longer period of time. See Taxpayers for Accountable School D-g Bond Spending v. San Diego Unified School Dist. (2013) 215 Cal.App.4`v Cont. 1013, 1049. Indeed, if construction emissions were appropriately accounted for, the Project would exceed the City's GHG Threshold.

The Project will lead to significant impacts to noise.
• The MND dismisses substantial construction noise impacts because they will be temporary. MND at 3-46. But the temporary nature of a noise impact does not make it insignificant. See Berkeley Keep Jets Over the Bay Comm. v.

Board of Port Commissioners (2001) 91 Cal.App.41t' 1344, 1380 — 81. • The MND acknowledges the noise analysis found existing conditions far in excess of applicable limits. MND at 3-44. Yet the Project will not be providing mitigation to address these impacts. Indeed, where on -the -ground D-10 conditions are severe, the "relevant question" is whether the project's additional impacts will be significant "in light of the serious nature" of the existing problems. Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692, 718.
• The Proj ect's noise mitigation is vague and insufficient. See Citizens for Responsible and Open Government v. City of Grand Terrace (2008) 160 Cal.App 0' 1323, 1341 ("there is no evidence of any measures to be taken that would ensure that the noise standards would be effectively monitored and vigorously enforced").

Thank you for your consideration of these concerns.

D-11 Sincerely,
Everett DeLano

RESPONSES
D-10 Construction noise. Although the anticipated construction activities would generate temporary elevated noise levels, the application of Mitigation measure NOI-1 would reduce such impacts to less than significant levels.

Mitigation of Existing conditions. Based on Appendix G of the CEQA Guidelines, implementation of the project would result in a significant adverse impact if it would: Generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the General Plan or noise ordinance. The new residential land uses would not be compliant with the General Plan Noise Element limits if exterior use areas are exposed to noise exceeding 65 community noise equivalent level (CNEL).

Mitigation measure LUI-1 would require the placement of permanent noise walls to reduce noise levels at these locations and reduce impacts to less than significant. (IS/MND, page 3-38). If exterior noise levels at a building fagade exceed 60 CNEL, it is conservatively assumed that interior noise levels may exceed the 45 CNEL limit set forth in the General Plan's Noise Element for residential uses. To ensure that the project's habitable rooms do not exceed 45 CNEL, mitigation measure LU-2 would be required. (IS/MND, page 3-39).

Mitigation Measure. Assuming the comment is referring to mitigation measure LU- 1, a Construction Management Plan shall be prepared by the project applicant and submitted to the City of Vista Planning Division for approval prior to issuance of the grading permit. The measure outlines the measures that must be included to ensure compliance with the noise limit. Findings for the tentative map can be made to approve the tentative map.

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COMMENTS
From: Parsv Chow
To: Kara Palm
Subject: FW: Response to revised IS/MND
Date: Monday, October 3, 2022 6:51:58 PM
From: Gabriel Jacobs
Sent: Sunday, October 2, 2022 5:10 PM
To: John Conley ; Patsy Chow ; Patsy Chow

Subject: Response to revised IS/MND
From Gabriel Jacobs
Sent October 2, 2022
The revised IS/MND draws many false conclusions concerning the projects E-1 compatibility with the city's Housing Element, impacts on air quality, circulation element and traffic impact, and the Land use and community Identity Element of the city's 2030 General Plan.

E-2
The revised IS/MND has mischaracterized the city's need for housing. As stated in the housing element "as of November 2020, the city only had a remaining RHNA of 1,549 units." In 2021, 542 units were issued certificates of occupancy bringing the remaining RHNA to 1007 units. Based off of information provided within the MND from tables AQ1 and AQ2 regarding approved and pending units the city will have built enough units to satisfy the RHNA without including the proposed development at Camino Largo.

The construction of the original 2,561 units assigned to Vista by the RHNA is supposed to take place over a span of 8 years between 2021 and 2029. With the city's current projected rate of development we will reach the RHNA goal within the next couple years if not within the year.

As clearly expressed by the revised IS/MND, "If a project proposes development that results in growth greater than that anticipated in the adopted land use plans and SANDAG's growth projections upon which the Attainment Plan is based, the project may conflict with the Attainment Plan and could have a potentially significant impact on air quality."
Thus, its evident that this development would significantly impact air quality and is not compatible with the housing element as it would exceed growth assumptions.

RESPONSES
E-1 The comment expresses disagreement with the conclusions of the Revised IS/MND specifically related to the project's compatibility with the City's Housing Element, impacts on air quality, traffic impacts and associated consistency with the General Plan Circulation Element, and consistency with the General Plan Land Use and Community Identify Element. This comment is an
introductory statement that identifies the specific topics subsequently raised in the letter. Please refer to responses E-2 through E-6 for detailed responses to the issues raised.

E-2 Please refer to Topical Response No. 1, Air Quality and Topical Response No. 2, Land Use and Planning.

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The revised IS/MND makes further mischaracterizations when it attempts to insinuate that the land they want develop is "deemed underutilized" by the city.

In the revised IS/MND it is claimed that "the project site supports a non operational palm tree nursery and that the trees are "grown above ground and maintained in box stock containers" This claim is false. The nursery is a working E-3 nursery acting as a storage facility for Choice Nursery and is a place of employment for people. Additionally the vast majority of trees in the nursery are buried in the ground. My point being this property is not underutilized it is being utilized for what it was zoned for and not simply sitting empty and abandoned as the revised IS/MND would have believed. Furthermore, in the Housing Element under Appendix B is an inventory of underutilized properties. 2123 N Santa Fe Av Parcel number:1592400700 is not found within the 19 pages of listed property in this inventory.

Concerning traffic on North Santa Fe, the following is a quote from the Traffic Congestion Management Plan 2020.
"Travel times are more than twice the free flow speed in both directions on seven corridor segments during the morning peak period and five corridor segments during the evening peak hour.Three of the 12 intersections operate at LOS E or F during the a.m. peak hour, and two intersections operating at LOS F during the p.m. peak hour. The three intersections are at Osborne Street, Taylor Street, and Bobier Drive. N. Santa Fe Avenue and Taylor Street during the a.m. peak hour is the most congested intersection in Vista. The delay for the southbound E-4 through movement is a LOS F, and the northbound through movement is at LOS F also."
To those who are unaware the proposed land for project development falls in between Taylor and Osborne. These intersections already operate at a level of service that the city considers deficient. For the revised IS/MND to reach the conclusion that "the roadways and intersections within the study area would not conflict with the City's established LOS goals. Therefore, the project would not conflict with the Circulation Element of the City's General Plan" is blatantly false.

How could 460 ADT during construction of the project plus the additional 200 cars coming and going once the projects completion not conflict with the Circulation Element and make an already highly congested section of road worse? Furthermore, a VMT analysis should be required as it is a certainty that this development once completed will have inhabitants exceeding 500 daily trips.

Lastly regarding land use and the community and identity element, the revised E-5 IS/MND attempts to demonstrate that the development is consistent with LUCI goal 2, and LUCI Policy 2.4, by arguing that the zoning and population density to the south create a pattern which their development would continue. However

RESPONSES
E-3 The comment questions the operational status of Choice Nursery as described in the IS/MND. This business is listed as being permanently closed, and the site no longer operates as a commercial nursery (please see Response A-2). With regard to the site and the General Plan Housing Element, please refer to Topical Response No. 2, Land Use and Planning (Regional Housing Needs Assessment).

E-4 As the comment raises associated traffic concerns, no further response is required. Please refer to Topical Response No. 3, Duplicate Comments and Comments Out of the Scope of the Revised IS/MND.

E-5 Please refer to Topical Response No. 2, Land Use and Planning.

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E-5 this argument only holds merit so long as they are allowed to determine the cont. origination point of the pattern.

I make the argument that the origination point of the existing developmental pattern starts immediately north of Sandal Wood. On maps one can see that a protected wetlands acts as a natural barrier separating the high population residential zoning from the lower population density agricultural rural residential zoning. An examination of the area North of the wetlands will find single family houses on property an acre or bigger representative of the surrounding area.

E-6 This zoning and developmental pattern starts North of Sandal Wood and spreads out away in a north east direction. Furthermore, the planning commission agrees with my assessment of the situation and denied the project unanimously choosing to maintain rural neighborhoods, and rejected the development on the grounds that it violated the 2030 General Plan such that it was incompatible with the existing community and its surroundings; specifically citing density, and lot size differences and that it diminished the amount of rural zoning.

RESPONSES
E-6 Please refer to Topical Response No. 2, Land Use and Planning.

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COMMENTS
From:

To: Gars Palm
Subject: FW; P21-0300i Camino Largo 0emiopn et
Dom: Monday, October 3, 2022 6:57:02 PM
----Ch igirvsl Message—
From: joe gregmy 9mPmgregory@attnet>
Se:il: Saturday, October 1, 2022 7:25 PM
To: Patsy Chow ; Patsy Chow <pohowCaci.vista cos usr
Subject: P21-03001 Camino Largo Development
Dear Ms Chow,
My husband and I have followed arid attended meetings pertaining to the 46 house development proposed for F-1 CaminoLml;o.(P21-03UD).

F-2 F—We listened to the project engineer explain the mitigation steps to protect the creek from nrrofl•, fences for seclriry and planting of trees so we dumbies would think we were. still surrounded by nature_ What they cannot explain is how 100 plus vehicles will access n Santa Fe Ave. during, peak traffic when the three F-3 exist ng residences have a difficult time already in pan chic, to four schools in this area.

If the nccupanN of forty six (46' houses most with mciltiple vehicles attempt to access Camino Largo "a narrow F-4 two lane road' ix could take a very long time not to mention the time it would take all those vehicles to access A.

Santa Fe Ave., another long wait with backed up traffic.

We've lived here for fury nine 19 years. Accessing N Santa Fe Ave has never been easy or safe. When the trees over gFow where the road narrows there is zero visibility of nonh bound vehicles and these northbound vehicles F-5 ignore turn signals of those making right turns onto Camino Largo assuming we're going to turn right at Osborne St. 11m results in rear end accidents The south bound traffic on _N Santa Fe Ave. is also dangerous as u. is a somewhat blIIld CnTVe j LL1t llortlr of Oalxmre SL Iirese vehicles crane flyurg arcnur l Qwl curve cer a green light.

Please take into cersideration the safety of all involved. Fewer vehicles = less traffic, less traffic =fewer accidents F-6 I -fewer injuries and death. I lmow tax revonuc from this development is important but 1 hope the safety and well being of everyone travelling these roadways is mom impertarrL drank you Sincerely,
Joe and Paula Gregory

RESPONSES
F-1 This comment notes that the commentor has been following and attending meetings pertaining to the proposed project As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

F-2 As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

F-3 As the comment raises associated traffic concerns, no further response is required. Please refer to Topical Response No. 3, Duplicate Comments and Comments Out of Scope of the Revised IS/MND.

F-4 As the comment raises associated traffic concerns, no further response is required. Please refer to Topical Response No. 3, Duplicate Comments and Comments Out of Scope of the Revised IS/MND.

F-5 As the comment raises associated traffic concerns, no further response is required. Please refer to Topical Response No. 3, Duplicate Comments and Comments Out of Scope of the Revised IS/MND.

F-6 As the comment raises associated traffic concerns, no further response is required. Please refer to Topical Response No. 3, Duplicate Comments and Comments Out of Scope of the Revised IS/MND.

RTC-74
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COMMENTS
From: P..� nh—
To: Ka:a Nh
Subject. M: F21-CWG
Date: Monday, October 3, 2022 7:06 45 PM
From: John simone
Sent: Wednesday, September 28, 2022 2:40 PIV
To: Patsy Chow<[email protected]
Subject: P21-0300
Ms. Patsy Chow,
Please be advised that I am in opposition to the City of Vista moving forward with this housing development as currently purposed regardless of any mitigation measures that both the City G-1 of Vista and or the Project Proponent has put forth. The rational being that the City's Planning/development Commision voted unanimously to'KILL THIS PROJECT' because it simply did notfit the demographics of the area, meaning this project is a BAD FIT with the existing surrounding properties. Additionally, the planning commission recommended that another site/location be selected for a project of this type that fits with the surrounding demographics.

Lastly, I view any and all Impact assessments related to this project conducted by the Project G 2 Proponent or the City as flawed given the biased nature of the working collaboration to push this project by continued trickery and chicanery to the detriment of the surrounding neighbors who will be directly and forever negatively impacted.

G-3
Respectfully,
John Simone

RESPONSES
G-1 The comment expresses opposition to the project based on incompatibility with surrounding development. Please refer to Topical Response No. 2, Land Use and Planning.

G-2 The comment expresses an opinion that the environmental analysis conducted for the project is flawed and biased but does not provide any facts or other evidence to support this assertion. As this comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND, no further response is required.

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COMMENTS
From: Patsv Chow
To: Kara Palm
Subject: FW: Response to revised IS/MND
Date: Monday, October 3, 2022 6:31:47 PM
From: Michael Jacobs
Sent: Sunday, October 2, 2022 7:30 PM
To: Patsy Chow
Subject: Response to revised IS/MND
Dear Vista City Council and Interested Residents:

This is a statement of concern overthe rushed/ill conceived plan to overdevelop the community of Vista. Cal West is pushing to build 46 units on 9.6 acres. Thatwould H-1 make tiny lots for about 10 units per acre. Cal West presumptuously calls this "The Camino Largo Residential Project", even though they are not presently addressed to Camino Largo.

The site is labelled as "non -operational" by Cal West but it is operating as a H-2 storage/transfer site for a larger nursery firm. It has a manager on site to handle this function.

Under Proposed Project Description Cal West states: "Access would be provided by five cul-de-sac streets that extend from Camino Largo. Camino Largo would be improved from an unclassified gravel road to a two way paved road ...to a minimum of 28 feet. (Unclassified is a misleading term regarding Camino Largo. Camino Largo has a street sign naming it, that I purchased and placed there, and is a fire and access lane for the homes actually addressed to and accessed by it. Twenty feet wide of the road is H-3 paved that the fire department required me to complete.) "The project would also include the addition of a stop sign at the intersection of Camino Largo and North Santa Fe". (What value does a stop sign have in processing automobiles off of Camino Largo if it only stops traffic from one direction?) Traffic on Camino Largo will be seriously impacted and turning south will be inhibited and dangerous. This project needs to have a better traffic -flow plan! Perhaps, Cal West shou Id follow Sandalwood's plan with a second access road directly onto North Santa Fe.

Additional Approval: The current design Cal West wants to implement for the road of Camino Largo is to Quitclaim the existing 56ftwide easement back and then Quitclaim issue a 40 ft wide easement to replace it. The road Cal West wants to create would be a H-4 28 ft wide lane going two ways, making each side 14 ft wide. This 14 ft easement road would terminate at the end of the nursery property, meeting the 20 ft existing pavement I was required to complete by the fire department. So Cal West's design has a 14 ft wide road running into a 20 ftwide existing road.

RESPONSES
H-1 The comment expresses general concern about the proposed density of the project and the project name but does not provide any specific comments relative to the adequacy of the Revised IS/MND. No further response is required.

H-2 The comment questions the operational status of Choice Nursery as described in the IS/MND. This business is listed as being permanently closed, and the site no longer operates as a commercial nursery (please see Response A-2). As identified on page 2-1 of the Revised IS/MND the nursery is non -operational and it is noted that the site supports buildings and equipment associated with the former operations. This comment does not raise any specific environmental issues with respect to the adequacy of the Revised IS/MND and therefore, no further response is required.

H-3 Camino Largo, as identified in the Traffic Impact Analysis prepared for the proposed project and included as Appendix H of the Draft IS/MND, is an unclassified street. This definition indicates that the roadway is not classified as an arterial, collector, major street, etc., in the City's General Plan Circulation Element. It is acknowledged that Camino Largo has a street sign and functions as a fire and access lane. In relation to the project's circulation plan, this issue is out of the scope of the Revised IS/MND. Please refer to Topical Response No. 3, Duplicate Comments or Comments that are Out of the Scope of the Revised IS/MND.

H-4 Please refer to Response A-2 and Figure Easement Area and Figure 5 Vacation Request Overlay of the Final Revised IS/MND. Additionally, as shown in Figure 3, Site Plan as the roadway extends eastward beyond the project site it is tapered to match the width of the existing roadway (20 feet).

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COMMENTS

RESPONSES
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H-5
ZVI

COMMENTS
Land Use and Community Identity:

LUCI I this proposed project does the opposite of LUCI 2. It does not enhance the characteristics of the neighborhood because it reduces building space to "tiny lot sizes" notfound in nearby developments. (twill cause traffic congestion and "sprawl", itwill have to be rezoned to "small lot size" to accommodate its implementation.

LUCI policy 2.4 is a more appropriate Land Use application: Discourage subdivision design that disrupts the existing development pattern within established neighborhoods. The following statement in the Revised MND is a prejudiced fabrication when it states: "The design of the proproposed project maintains the existing residential character of the surrounding area. (This is a fabrication! The surrounding character has homes on adjacent lot sizes 10-20 times larger and over a distance, Sandalwood community, unique and exceptional in the area, has lots twice as large. There are no small division lot sizes of 3,600 sf in the area at all.

By including the so called Camino Largo Project on the Pending Project list with the other Pending Projects, and including them in the Attainment Plan numbers, City Council had prejudiced itself in favor of these projects being passed and all of Vista's residents potentially suffering "sprawl" and "congestion" due to City Council's poor judgement in choosing "housing quantity" ratherthan "housing /residential quality".

Too many on the Council have lost sight of its job to legislate for the people rather than for business money making interests. The people of Vista are watching! Keep in mind that your council tenure could only be as good as the next council election. Make the right choices! We the people are uniting. Vista Resident, Michael Jacobs 11 /15/2022

RESPONSES
H-5 Please refer to Topical Response No. 2, Land Use and Planning.

H-6 Please refer to Topical Response No. 1, Air Quality.

PH1
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Vista City CouncilNovember 15, 2022

Vista City Council
November 15, 2022