Item 19 - Attachment A - Exhibit A - The Farm in Poway Final EIRFINAL ENVIRONMENTAL IMPACT REPORT
The Farm in Poway EIR
Prepared for:
City of Poway
13325 Civic Center Drive
Poway, California 92064
Contact: David De Vries, City Planner
Prepared by:
605 Third Street
Encinitas, California 92024
Contact: Asha Bleier
JUNE 2020
Printed on 30% post-consumer recycled material.
The Farm in Poway EIR 11872
June 2020 TOC-i
Table of Contents
Section Page No.
ACRONYMS AND ABBREVIATIONS ........................................................................................................................... ACR-i
1 EXECUTIVE SUMMARY ................................................................................................................................... 1-1
1.1 Description .......................................................................................................................................... 1-1
1.2 Summary of Significant Effects and Mitigation Measures that Reduce or Avoid the
Significant Impacts ............................................................................................................................. 1-3
1.3 Areas of Controversy .......................................................................................................................... 1-3
1.4 Issues to be Resolved by the Decision-Making Body ....................................................................... 1-3
1.5 Project Alternatives ............................................................................................................................ 1-3
1.6 Environmentally Superior Alternative ................................................................................................ 1-5
2 INTRODUCTION .............................................................................................................................................. 2-1
2.1 Purpose and Intended Uses .............................................................................................................. 2-1
2.1.1 EIR Purpose ........................................................................................................................... 2-1
2.1.2 Intended Use of the EIR ........................................................................................................ 2-1
2.2 EIR Legal Authority ............................................................................................................................. 2-2
2.2.1 Lead Agency .......................................................................................................................... 2-2
2.2.2 Responsible and Trustee Agencies ...................................................................................... 2-2
2.3 EIR Type, Scope and Content, and Format ....................................................................................... 2-3
2.3.1 Type of EIR............................................................................................................................. 2-3
2.3.2 EIR Scope and Content ......................................................................................................... 2-3
2.3.3 EIR Format ............................................................................................................................. 2-3
2.4 EIR Process ......................................................................................................................................... 2-5
2.4.1 Draft EIR ................................................................................................................................ 2-5
2.4.2 Final EIR ................................................................................................................................ 2-5
3 PROJECT DESCRIPTION ................................................................................................................................. 3-1
3.1 Project Objectives ............................................................................................................................... 3-1
3.2 Project Description ............................................................................................................................. 3-2
3.2.1 Project Components ............................................................................................................. 3-2
3.2.2 General Plan and Zoning Amendments ............................................................................. 3-10
3.2.3 Specific Plan ........................................................................................................................ 3-10
3.2.4 Tentative Map ..................................................................................................................... 3-10
3.2.5 Project Design Features (PDFs) ......................................................................................... 3-11
3.3 Project Location ................................................................................................................................ 3-11
3.4 Environmental Setting ...................................................................................................................... 3-11
3.4.1 Regional Context ................................................................................................................. 3-11
3.4.2 Surrounding Environment .................................................................................................. 3-12
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3.5 Intended Uses of the EIR ................................................................................................................. 3-12
3.6 List of Past, Present, and Reasonably Anticipated Future Projects in the Project Area .............. 3-13
4 ENVIRONMENTAL ANALYSIS ......................................................................................................................... 4-1
4.1 Aesthetics ........................................................................................................................................ 4.1-1
4.1.1 Existing Conditions............................................................................................................. 4.1-1
4.1.2 Relevant Plans, Policies, and Ordinances ........................................................................ 4.1-2
4.1.3 Thresholds of Significance ................................................................................................ 4.1-5
4.1.4 Impacts Analysis ................................................................................................................ 4.1-5
4.1.5 Cumulative Impacts ........................................................................................................... 4.1-8
4.1.6 Mitigation Measures .......................................................................................................... 4.1-9
4.1.7 Other Considerations ......................................................................................................... 4.1-9
4.1.8 Level of Significance After Mitigation ............................................................................. 4.1-10
4.2 Air Quality ......................................................................................................................................... 4.2-1
4.2.1 Existing Conditions............................................................................................................. 4.2-1
4.2.2 Relevant Plans, Policies, and Ordinances ........................................................................ 4.2-7
4.2.3 Thresholds of Significance .............................................................................................. 4.2-16
4.2.4 Impacts Analysis .............................................................................................................. 4.2-18
4.2.5 Cumulative Impacts ......................................................................................................... 4.2-27
4.2.6 Mitigation Measures ........................................................................................................ 4.2-29
4.2.7 Level of Significance After Mitigation ............................................................................. 4.2-29
4.3 Biological Resources ....................................................................................................................... 4.3-1
4.3.1 Existing Conditions............................................................................................................. 4.3-1
4.3.2 Relevant Plans, Policies, and Ordinances ........................................................................ 4.3-5
4.3.3 Thresholds of Significance .............................................................................................. 4.3-12
4.3.4 Impacts Analysis .............................................................................................................. 4.3-12
4.3.5 Cumulative Impacts ......................................................................................................... 4.3-15
4.3.6 Mitigation Measures ........................................................................................................ 4.3-16
4.3.7 Level of Significance After Mitigation ............................................................................. 4.3-18
4.4 Cultural and Tribal Cultural Resources .......................................................................................... 4.4-1
4.4.1 Existing Conditions............................................................................................................. 4.4-1
4.4.2 Relevant Plans, Policies, and Ordinances ........................................................................ 4.4-7
4.4.3 Thresholds of Significance .............................................................................................. 4.4-17
4.4.4 Impacts Analysis .............................................................................................................. 4.4-17
4.4.5 Cumulative Impacts ......................................................................................................... 4.4-19
4.4.6 Mitigation Measures ........................................................................................................ 4.4-21
4.4.7 Level of Significance After Mitigation ............................................................................. 4.4-23
4.5 Energy .............................................................................................................................................. 4.5-1
4.5.1 Existing Conditions............................................................................................................. 4.5-1
4.5.2 Relevant Plans, Policies, and Ordinances ........................................................................ 4.5-3
4.5.3 Thresholds of Significance ................................................................................................ 4.5-9
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4.5.4 Impacts Analysis ................................................................................................................ 4.5-9
4.5.5 Cumulative Impacts ......................................................................................................... 4.5-14
4.5.6 Mitigation Measures ........................................................................................................ 4.5-14
4.5.7 Level of Significance After Mitigation ............................................................................. 4.5-14
4.6 Geology and Soils ............................................................................................................................ 4.6-1
4.6.1 Existing Conditions............................................................................................................. 4.6-1
4.6.2 Relevant Plans, Policies, and Ordinances ........................................................................ 4.6-4
4.6.3 Thresholds of Significance ................................................................................................ 4.6-7
4.6.4 Impacts Analysis ................................................................................................................ 4.6-7
4.6.5 Cumulative Impacts ......................................................................................................... 4.6-11
4.6.6 Mitigation Measures ........................................................................................................ 4.6-13
4.6.7 Level of Significance After Mitigation ............................................................................. 4.6-14
4.7 Greenhouse Gas Emissions ............................................................................................................ 4.7-1
4.7.1 Existing Conditions............................................................................................................. 4.7-1
4.7.2 Relevant Plans, Policies, and Ordinances ........................................................................ 4.7-4
4.7.3 Thresholds of Significance .............................................................................................. 4.7-16
4.7.4 Impacts Analysis .............................................................................................................. 4.7-19
4.7.5 Cumulative Impacts ......................................................................................................... 4.7-31
4.7.6 Mitigation Measures ........................................................................................................ 4.7-31
4.7.7 Level of Significance After Mitigation ............................................................................. 4.7-32
4.8 Hazards and Hazardous Materials ................................................................................................. 4.8-1
4.8.1 Existing Conditions............................................................................................................. 4.8-1
4.8.2 Relevant Plans, Policies, and Ordinances ........................................................................ 4.8-4
4.8.3 Thresholds of Significance .............................................................................................. 4.8-15
4.8.4 Impacts Analysis .............................................................................................................. 4.8-15
4.8.5 Cumulative Impacts ......................................................................................................... 4.8-21
4.8.6 Mitigation Measures ........................................................................................................ 4.8-22
4.8.7 Level of Significance After Mitigation ............................................................................. 4.8-23
4.9 Hydrology and Water Quality ........................................................................................................... 4.9-1
4.9.1 Existing Conditions............................................................................................................. 4.9-1
4.9.2 Relevant Plans, Policies, and Ordinances ........................................................................ 4.9-3
4.9.3 Thresholds of Significance ................................................................................................ 4.9-8
4.9.4 Impacts Analysis ................................................................................................................ 4.9-9
4.9.5 Cumulative Impacts ......................................................................................................... 4.9-16
4.9.6 Mitigation Measures ........................................................................................................ 4.9-17
4.9.7 Level of Significance After Mitigation ............................................................................. 4.9-17
4.10 Land Use and Planning ................................................................................................................. 4.10-1
4.10.1 Existing Conditions........................................................................................................... 4.10-1
4.10.2 Relevant Plans, Policies, and Ordinances ...................................................................... 4.10-2
4.10.3 Thresholds of Significance .............................................................................................. 4.10-6
4.10.4 Impacts Analysis .............................................................................................................. 4.10-7
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4.10.5 Cumulative Impacts ......................................................................................................... 4.10-9
4.10.6 Mitigation Measures ........................................................................................................ 4.10-9
4.10.7 Level of Significance After Mitigation ............................................................................. 4.10-9
4.11 Noise .............................................................................................................................................. 4.11-1
4.11.1 Existing Conditions........................................................................................................... 4.11-1
4.11.2 Relevant Plans, Policies, and Ordinances ...................................................................... 4.11-4
4.11.3 Thresholds of Significance .............................................................................................. 4.11-9
4.11.4 Impacts Analysis .............................................................................................................. 4.11-9
4.11.5 Cumulative Impacts ...................................................................................................... 4.11-26
4.11.6 Mitigation Measures ..................................................................................................... 4.11-27
4.11.7 Level of Significance After Mitigation .......................................................................... 4.11-33
4.12 Population and Housing ................................................................................................................ 4.12-1
4.12.1 Existing Conditions........................................................................................................... 4.12-1
4.12.2 Relevant Plans, Policies, and Ordinances ...................................................................... 4.12-2
4.12.3 Thresholds of Significance .............................................................................................. 4.12-7
4.12.4 Impacts Analysis .............................................................................................................. 4.12-7
4.12.5 Cumulative Impacts ......................................................................................................... 4.12-9
4.12.6 Mitigation Measures ..................................................................................................... 4.12-10
4.12.7 Level of Significance After Mitigation .......................................................................... 4.12-10
4.13 Public Services .............................................................................................................................. 4.13-1
4.13.1 Existing Conditions........................................................................................................... 4.13-1
4.13.2 Relevant Plans, Policies, and Ordinances ...................................................................... 4.13-6
4.13.3 Thresholds of Significance ........................................................................................... 4.13-15
4.13.4 Impacts Analysis ........................................................................................................... 4.13-15
4.13.5 Cumulative Impacts ...................................................................................................... 4.13-19
4.13.6 Mitigation Measures ..................................................................................................... 4.13-21
4.13.7 Level of Significance After Mitigation .......................................................................... 4.13-21
4.14 Recreation ...................................................................................................................................... 4.14-1
4.14.1 Existing Conditions........................................................................................................... 4.14-1
4.14.2 Relevant Plans, Policies, and Ordinances ...................................................................... 4.14-3
4.14.3 Thresholds of Significance .............................................................................................. 4.14-5
4.14.4 Impacts Analysis .............................................................................................................. 4.14-5
4.14.5 Cumulative Impacts ......................................................................................................... 4.14-6
4.14.6 Mitigation Measures ........................................................................................................ 4.14-7
4.14.7 Level of Significance After Mitigation ............................................................................. 4.14-7
4.15 Transportation ............................................................................................................................... 4.15-1
4.15.1 Existing Conditions........................................................................................................... 4.15-1
4.15.2 Relevant Plans, Policies, and Ordinances ................................................................... 4.15-23
4.15.3 Thresholds of Significance ........................................................................................... 4.15-26
4.15.4 Impacts Analysis ........................................................................................................... 4.15-29
4.15.5 Cumulative Impacts ...................................................................................................... 4.15-73
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4.15.6 Project Design Features ............................................................................................... 4.15-73
4.15.7 Mitigation Measures ..................................................................................................... 4.15-74
4.15.8 Level of Significance After Mitigation .......................................................................... 4.15-74
4.16 Utilities and Service Systems ........................................................................................................ 4.16-1
4.16.1 Existing Conditions........................................................................................................... 4.16-1
4.16.2 Relevant Plans, Policies, and Ordinances ...................................................................... 4.16-6
4.16.3 Thresholds of Significance ........................................................................................... 4.16-16
4.16.4 Impacts Analysis ........................................................................................................... 4.16-16
4.16.5 Cumulative Impacts ...................................................................................................... 4.16-20
4.16.6 Mitigation Measures ..................................................................................................... 4.16-21
4.16.7 Level of Significance After Mitigation .......................................................................... 4.16-21
4.17 Wildfire ........................................................................................................................................... 4.17-1
4.17.1 Existing Conditions........................................................................................................... 4.17-1
4.17.2 Relevant Plans, Policies, and Ordinances ...................................................................... 4.17-3
4.17.3 Thresholds of Significance .............................................................................................. 4.17-5
4.17.4 Impacts Analysis .............................................................................................................. 4.17-5
4.17.5 Cumulative Impacts ...................................................................................................... 4.17-10
4.17.6 Mitigation Measures ..................................................................................................... 4.17-11
4.17.7 Level of Significance After Mitigation .......................................................................... 4.17-11
5 OTHER CEQA CONSIDERATIONS ................................................................................................................... 5-1
5.1 Effects Found Not to Be Significant .................................................................................................. 5-1
5.1.1 Agriculture and Forestry Resources ..................................................................................... 5-1
5.1.2 Mineral Resources ................................................................................................................ 5-2
5.2 Growth-Inducing Effects ..................................................................................................................... 5-3
5.2.1 Population and Housing ....................................................................................................... 5-3
5.3 Mandatory Findings of Significance .................................................................................................. 5-4
5.4 Significant Unavoidable Impacts ....................................................................................................... 5-4
5.5 Significant Irreversible Environmental Changes ............................................................................... 5-5
6 ALTERNATIVES ............................................................................................................................................... 6-1
6.1 Introduction ......................................................................................................................................... 6-1
6.2 Scope and Purpose ............................................................................................................................ 6-1
6.3 Criteria for Selection, Analysis, and Feasibility of Alternatives ........................................................ 6-2
6.4 Rationale for the Selection of Alternatives ....................................................................................... 6-3
6.5 Alternatives Considered but Rejected from Analysis ....................................................................... 6-4
6.6 Analysis of the No Project/No Development Alternative .................................................................. 6-5
6.6.1 No Project/No Development Alternative Description and Setting ..................................... 6-5
6.6.2 Comparison of the Effects of the No Project/No Development Alternative
to the Proposed Project ........................................................................................................ 6-5
6.7 Reduced Density Alternative .............................................................................................................. 6-7
6.7.1 Reduced Density Alternative Description and Setting ........................................................ 6-7
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6.7.2 Comparison of the Effects of Reduced Density Alternative to the Proposed Project ....... 6-8
6.8 Reduced Development Footprint Alternative .................................................................................. 6-10
6.8.1 Reduced Development Footprint Alternative Description and Setting ........................... 6-10
6.8.2 Comparison of the Effects of Reduced Development Footprint Alternative
to the Proposed Project ...................................................................................................... 6-10
6.9 Determination of Environmentally Superior Alternative ................................................................ 6-12
7 REFERENCES ................................................................................................................................................. 7-1
8 LIST OF PREPARERS ...................................................................................................................................... 8-1
8.1 City of Poway ....................................................................................................................................... 8-1
8.2 Dudek .................................................................................................................................................. 8-1
9 RESPONSES TO COMMENTS ......................................................................................................................... 9-1
9.1 List of Commenters ............................................................................................................................ 9-1
9.2 Comment Letters Received and Responses to Comments ............................................................ 9-2
Appendices
A NOP-IS Public Scoping Comments
B Air Quality and Greenhouse Gas Emissions Analysis Technical Report
C Biological Resources Report
D Cultural Resources Survey Report
E Geologic Reconnaissance Report
F Drainage Study
G Priority Development Project – Stormwater Quality Management Plan
H Noise Technical Report
I Transportation Impact Analysis
J Sewer System Analysis
K Water Supply Study/Fire Flow Analysis
L Fuel Management Plan
M LLG Supplemental Transportation Memorandum
Figures
1-1 Site Plan ................................................................................................................................................... 1-33
1-2 Project Site Vicinity and Aerial Map ....................................................................................................... 1-35
3-1 Land Use Plan .......................................................................................................................................... 3-17
3-2 Conceptual Trail Network ........................................................................................................................ 3-19
3-3 Martincoit Road and Espola Road Intersection Improvements ............................................................ 3-21
3-4 Conceptual Street Network ..................................................................................................................... 3-23
3-5 Espola Road Improvements.................................................................................................................... 3-25
3-6 Conceptual Water Master Plan............................................................................................................... 3-27
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3-7 Conceptual Sewer Master Plan .............................................................................................................. 3-29
3-8 Conceptual Drainage Plan ...................................................................................................................... 3-31
3-9 Project Location ....................................................................................................................................... 3-33
3-10 Surrounding Land Uses........................................................................................................................... 3-35
3-11 Cumulative Projects ................................................................................................................................ 3-37
4.1-1 KOP Locations ...................................................................................................................................... 4.1-11
4.1-2 Visual Simulation 1: Espola Rd. & Martincoit Rd. .............................................................................. 4.1-13
4.1-3 Visual Simulation 2: Tam O’Shanter Dr. ............................................................................................. 4.1-15
4.1-4 Visual Simulation 3: St. Andrews Dr. & Villamoura Dr. ...................................................................... 4.1-17
4.1-5 Visual Simulation 4: St. Andrews Dr. & Del Paseo Dr. ....................................................................... 4.1-19
4.3-1 Vegetation Communities and Land Cover Types ................................................................................ 4.3-19
4.3-2 Project Location on USGS Map ........................................................................................................... 4.3-21
4.3-3 Project Location in Relation to City of Poway HCP Mitigation Area ................................................... 4.3-23
4.8-1 Project Site Hazards ............................................................................................................................. 4.8-25
4.11-1 Noise Measurement Locations ........................................................................................................ 4.11-35
4.13-1 Very High Fire Hazard Severity Area (VHFHSZ) Map ....................................................................... 4.13-23
4.15-1a Existing Conditions Diagram ............................................................................................................. 4.15-77
4.15-1b Existing Conditions Diagram ............................................................................................................. 4.15-79
4.15-2a Existing Pedestrian Network ............................................................................................................. 4.15-81
4.15-2b Existing Pedestrian Network ............................................................................................................ 4.15-83
4.15-3 Existing Pedestrian Demand ............................................................................................................ 4.15-85
4.15-4 Existing Bicycle Network ................................................................................................................... 4.15-87
4.15-5 Existing Bicycle Demand ................................................................................................................... 4.15-89
4.15-6a Project Traffic Distribution ................................................................................................................ 4.15-91
4.15-6b Project Traffic Distribution ................................................................................................................ 4.15-93
4.15-7a Project Traffic Volumes .................................................................................................................... 4.15-95
4.15-7b Project Traffic Volumes ..................................................................................................................... 4.15-97
4.15-8 Cumulative Projects .......................................................................................................................... 4.15-99
4.15-9 Walkshed Analysis ........................................................................................................................... 4.15-101
4.15-10 Bikeshed Analysis ........................................................................................................................... 4.15-103
Tables
1-1 Summary of Significant Effects ................................................................................................................ 1-6
1-2 Environmentally Superior Alternative ..................................................................................................... 1-31
3-1 Proposed Discretionary Approvals and Permits .................................................................................... 3-12
3-2 Cumulative Projects ................................................................................................................................ 3-13
4.2-1 Ambient Air Quality Standards ............................................................................................................... 4.2-8
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4.2-2 San Diego Air Pollution Control District Air Quality Significance Thresholds .................................... 4.2-17
4.2-3 Estimated Maximum Daily Construction Criteria Air Pollutant Emissions ........................................ 4.2-20
4.2-4 Estimated Maximum Daily Operational Criteria Air Pollutant Emissions .......................................... 4.2-21
4.2-5 Construction Activity Health Risk Assessment Results ...................................................................... 4.2-23
4.2-6 CALINE4 Predicted Carbon Monoxide Concentrations ...................................................................... 4.2-24
4.2-7 Estimated Maximum Daily Construction Criteria Air Pollutant Emissions – Mitigated .................... 4.2-29
4.2-8 Construction Activity Health Risk Assessment Results – Mitigated .................................................. 4.2-30
4.3-1 Existing Vegetation Communities and Land Cover Types .................................................................... 4.3-2
4.4-1 Cultural Resources within One Mile of the Project Site ....................................................................... 4.4-3
4.5-1 Hours of Operation for Construction Equipment ................................................................................ 4.5-11
4.5-2 Construction Equipment Diesel Demand ........................................................................................... 4.5-11
4.5-3 Construction Worker Vehicle Gasoline Demand ................................................................................ 4.5-11
4.5-4 Construction Vendor Truck Diesel Demand ........................................................................................ 4.5-12
4.5-5 Construction Haul Truck Diesel Demand ............................................................................................ 4.5-12
4.5-6 Petroleum Consumption – Operation ................................................................................................. 4.5-13
4.6-1 Deterministic Seismic Site Parameters ................................................................................................ 4.6-8
4.6-2 Seismic Hazard Probability .................................................................................................................... 4.6-8
4.7-1 Estimated Annual Construction GHG Emissions ................................................................................ 4.7-19
4.7-2 Estimated Annual Operational GHG Emissions .................................................................................. 4.7-20
4.7-3 San Diego Forward: The Regional Plan Consistency Analysis ........................................................... 4.7-22
4.7-4 Project Consistency with Scoping Plan GHG Emission-Reduction Strategies .................................. 4.7-25
4.9-1 Hydromodification Management Flow Control Best Management Practices ................................... 4.9-10
4.9-2 Summary of Rational Method Hydrologic Analysis ............................................................................. 4.9-14
4.10-1 Project Consistency with City of Poway General Plan ..................................................................... 4.10-10
4.11-1 Measured Community Outdoor Noise Levels ..................................................................................... 4.11-3
4.11-2 Construction Phase Distance to Nearest Pre-Existing Noise-Sensitive Receptors (in feet) ................ 4.11-10
4.11-3 Typical Construction Equipment Maximum Noise Levels ............................................................... 4.11-11
4.11-4 Construction Noise Modeling Summary Results for The Club ........................................................ 4.11-12
4.11-5 Construction Noise Modeling Summary Results for The Meadow ................................................. 4.11-12
4.11-6 Construction Noise Modeling Summary Results for The Farm ....................................................... 4.11-13
4.11-7 Construction Noise Modeling Summary Results for The Working Farm ........................................ 4.11-13
4.11-8 Construction Noise Modeling Summary Results for the Community Gardens .............................. 4.11-14
4.11-9 Construction Noise Modeling Summary Results for the Trail System ............................................ 4.11-14
4.11-10 Construction Noise Modeling Summary Results for the Basins ..................................................... 4.11-15
4.11-11 Construction Noise Modeling Summary Results for New Residential Homes ............................... 4.11-15
4.11-12 Construction Noise Modeling Summary Results for Private Street B ............................................ 4.11-16
4.11-13 Traffic Noise Modeling Results ......................................................................................................... 4.11-18
4.11-14 Future Ambient Noise Levels at Residential Facades .................................................................... 4.11-19
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4.11-15 Event Sound Levels ........................................................................................................................... 4.11-19
4.12-1 Dwelling Units by Type ......................................................................................................................... 4.12-8
4.13-1 Fire Stations in the City of Poway ........................................................................................................ 4.13-1
4.13-2 Schools in the City of Poway ................................................................................................................ 4.13-5
4.13-3 Projected School Enrollment as a Result of the Proposed Project ................................................ 4.13-17
4.13-4 Projected School Enrollment for 2022–2023 School Year ............................................................ 4.13-18
4.15-1 Intersection LOS and Delay Ranges .................................................................................................... 4.15-2
4.15-2 Freeway Segment LOS Criteria ............................................................................................................ 4.15-2
4.15-3 Existing Intersection Operations .......................................................................................................... 4.15-6
4.15-4 Existing Street Segment Operations ................................................................................................ 4.15-10
4.15-5 Existing Caltrans Ramp Meter Analysis – Fixed Rate ..................................................................... 4.15-13
4.15-6 Existing Freeway Mainline Operations ............................................................................................. 4.15-15
4.15-7 Bicycle Mobility .................................................................................................................................. 4.15-20
4.15-8 City of Poway Traffic Impact Significance Thresholds ..................................................................... 4.15-27
4.15-9 City of San Diego Traffic Impact Significant Thresholds ................................................................. 4.15-28
4.15-10 Trip Generation Rates – Proposed Project ...................................................................................... 4.15-30
4.15-11 Trip Generation Rates – Former StoneRidge Country Club ............................................................ 4.15-31
4.15-12 Trip Generation – Proposed Project ................................................................................................. 4.15-33
4.15-13 Trip Generation – Former StoneRidge Country Club ....................................................................... 4.15-35
4.15-14 Near-Term (Opening Year 2025) Intersection Operations .............................................................. 4.15-41
4.15-15 Near-Term (Opening Year 2025) Street Segment Operations ....................................................... 4.15-43
4.15-16 Near-Term (Opening Year 2025) Ramp Meter Analysis – Fixed Rate ............................................ 4.15-46
4.15-17 Near-Term (Opening Year 2025) Freeway Segment Operations .................................................... 4.15-47
4.15-18 Horizon Year 2035 Intersection Operations .................................................................................... 4.15-52
4.15-19 Horizon Year 2035 Street Segment Operations .............................................................................. 4.15-54
4.15-20 Horizon Year 2035 Ramp Meter Analysis – Fixed Rate .................................................................. 4.15-57
4.15-21 Horizon Year Freeway Segment Operations .................................................................................... 4.15-59
4.15-22 Planned Improvements – Pedestrian .............................................................................................. 4.15-61
4.15-23 Planned Improvements – Bicycle ..................................................................................................... 4.15-62
4.15-24 Amenities at Bus Stations Within Project Walkshed ....................................................................... 4.15-64
4.15-25 Existing Mid-Day Intersection Operations ........................................................................................ 4.15-65
4.15-26 Near-Term Mid-Day Intersection Operations ................................................................................... 4.15-66
4.15-27 Site Access ......................................................................................................................................... 4.15-67
4.15-28 Project Access Intersection Operations ........................................................................................... 4.15-68
4.15-29 City of Poway – Existing Baseline VMT/Capita ................................................................................ 4.15-69
4.15-30 The Farm in Poway – Project VMT/Capita ....................................................................................... 4.15-70
4.15-31 Impact Summary .............................................................................................................................. 4.15-71
4.15-32 Project Design Features .................................................................................................................... 4.15-73
4.15-33 Post-Mitigation Analysis .................................................................................................................... 4.15-75
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4.16-1 Wastewater Treatment Capacities ...................................................................................................... 4.16-4
4.16-2 Sewer Generation Factors ................................................................................................................... 4.16-5
4.16-3 Projected Sewer Demand .................................................................................................................... 4.16-5
4.16-4 Solid Waste Facility Capacity ............................................................................................................ 4.16-19
6-1 Environmentally Superior Alternative ..................................................................................................... 6-13
6-2 Comparison of Alternatives Relative to Project Objectives ................................................................... 6-13
9-1 List of Commenters ................................................................................................................................... 9-1
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Acronyms and Abbreviations
Acronym/Abbreviation Definition
2050 RTP/SCS 2050 Regional Transportation Plan
A/V audio-visual
AB Assembly Bill
ACOE U.S. Army Corps of Engineers
ADA Americans with Disabilities Act
ADT average daily traffic
AICUZ Air Installations Compatible Use Zone
ATCM Airborne Toxic Control Measure
Berglund WTP Lester J. Berglund Water Treatment Plant
BMP best management practice
CAA federal Clean Air Act
CAAQS California Ambient Air Quality Standards
CAL FIRE California Department of Forestry and Fire Protection
CalARP California Accidental Release Prevention
CalEEMod California Emissions Estimator Model
CalEPA California Environmental Protection Agency
CALGreen California Green Building Standards
CALINE4 California LINE Source Dispersion Model
Cal/OSHA California Occupational Safety and Health Administration
CalRecycle California Department of Resources Recycling and Recovery
Caltrans California Department of Transportation
CAP Corrective Action Plan
CAPCOA California Air Pollution Control Officers Association
CARB California Air Resources Board
CBC California Building Code
CDFG California Department of Fish and Game
CDFW California Department of Fish and Wildlife
CEC California Energy Commission
CEQA California Environmental Quality Act
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CERT Community Emergency Response Team
CFC California Fire Code
CGS California Geological Survey
CH4 methane
CHHSL California Human Health Screening Level
Clean Water Act federal Water Pollution Control Act Amendments of 1972
CNEL community noise equivalent level
CNMP Construction Noise Management Plan
CNRA California Natural Resources Agency
CO carbon monoxide
CO2 carbon dioxide
CO2e carbon dioxide equivalent
CPUC California Public Utilities Commission
CRHR California Register of Historical Resources
Acronyms and Abbreviations
The Farm in Poway EIR 11872
June 2020 ACR-ii
Acronym/Abbreviation Definition
CRPR California Rare Plant Rank
dB decibel
dBA A-weighted decibel
DEH County of San Diego Department of Environmental Health
Delta Sacramento–San Joaquin River Delta
DPM diesel particulate matter
DTSC California Department of Toxic Substances Control
EIR Environmental Impact Report
EISA Energy Independence and Security Act of 2007
EMS Emergency Medical Services
EO Executive Order
EPA U.S. Environmental Protection Agency
ERR Escondido Resource Recovery
ESA Endangered Species Act
EV electric vehicle
EVA emergency vehicle access
FEMA Federal Emergency Management Agency
FHSZ fire hazard severity zone
FMP Fuels Management Plan
GHG greenhouse gas
gpm gallons per minute
GWP global warming potential
HARRF Hale Avenue Resource Recovery Facility
HCFC hydrochlorofluorocarbon
HERO Human and Ecological Risk Office
HFC hydrofluorocarbon
HRA health risk assessment
HVAC heating, ventilation, and air-conditioning
I-15 Interstate 15
IFC International Fire Code
ips inches per second
JRMP Jurisdictional Runoff Management Program
KOP Key Observation Point
kWh kilowatt-hours
Ldn day–night average noise level
Leq equivalent noise level over a given period
LLG Linscott, Law & Greenspan
Lmax greatest sound level measured during a designated time interval or event
Ln statistical sound level
LOS level of service
LUST leaking underground storage tank
MBTA Migratory Bird Treaty Act
mgd million gallons per day
MMT CO2e million metric tons of CO2 equivalent
MRZ Mineral Resource Zone
MS4 Municipal Separate Storm Sewer Systems
MT metric tons
Acronyms and Abbreviations
The Farm in Poway EIR 11872
June 2020 ACR-iii
Acronym/Abbreviation Definition
MTBE methyl tertiary butyl ether
MT CO2e metric tons of CO2 equivalent
MTS San Diego Metropolitan Transit System
MWD Metropolitan Water District of Southern California
N2O nitrous oxide
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NCWRP North City Water Reclamation Plant
NFPA National Fire Protection Association
NHTSA National Highway Traffic Safety Administration
NO2 nitrogen dioxide
NOP Notice of Preparation
NOx oxides of nitrogen
NPDES National Pollutant Discharge Elimination System
NPDES National Pollutant Discharge Elimination System
NRHP National Register of Historic Places
O3 ozone
OPR Governor’s Office of Planning and Research
OR-RM Open Space – Resource Management
OS-C Open Space – Conservation
OSHA Occupational Safety and Health Administration
OS-R Open Space – Recreation
P-C Production-Consumption
PC Planned Community
PCBs polychlorinated biphenyls
PDF project design feature
PFC perfluorocarbon
PFD City of Poway Fire Department
PLWTP Point Loma Wastewater Treatment Plant
PM10 particulate matter with an aerodynamic diameter less than or equal to 10 microns
PM2.5 particulate matter with an aerodynamic diameter less than or equal to 2.5 microns
Poway Subarea
HCP/NCCP
Poway Subarea Habitat Conservation Plan/Natural Community Conservation Plan
ppm parts per million
PPV peak particle velocity
PRD Planned Residential Development
PUSD Poway Unified School District
PVGB Poway Valley Groundwater Basin
RAQS Regional Air Quality Strategy
R-C Residential – Cottage
RCNM Roadway Construction Noise Model
RCRA Resource Conservation and Recovery
Regional Plan San Diego Forward: The Regional Plan
RFS Renewable Fuel Standard
R-G Residential – Garden
R-H Residential – Homestead
RHNA Regional Housing Needs Assessment
Acronyms and Abbreviations
The Farm in Poway EIR 11872
June 2020 ACR-iv
Acronym/Abbreviation Definition
R-M Residential – Meadow
ROW right-of-way
RPS Renewables Portfolio Standard
RSL Regional Screening Level
R-T Residential – Twin
RTIP Regional Transportation Improvement Program
RTP Regional Transportation Plan
RWQCB Regional Water Quality Control Board
SALS Saint Andrews Lift Station
SANDAG San Diego Association of Governments
SANTEC/ITE San Diego Traffic Engineers’ Council/Institute of Traffic Engineers
SARA Superfund Amendments and Reauthorization Act
SB Senate Bill
SCIC South Coastal Information Center
SCS Sustainable Communities Strategy
SDAB San Diego Air Basin
SDAPCD San Diego Air Pollution Control District
SDCWA San Diego County Water Authority
SDG&E San Diego Gas & Electric
SF6 sulfur hexafluoride
SIP State Implementation Plan
SLCP short-lived climate pollutant
SO2 sulfur dioxide
SoCalGas Southern California Gas
SOx sulfur oxides
SR State Route
SWPPP Stormwater Pollution Prevention Plan
SWRCB State Water Resources Control Board
TAC toxic air contaminant
TPHg gasoline hydrocarbons
TWLTL two-way left-turn lane
USFWS U.S. Fish and Wildlife Service
UWMP Urban Water Management Plan
v/c volume-to-capacity
VHFHSZ Very High Fire Hazard Severity Zone
VMT vehicle miles traveled
VOC volatile organic compound
WPO Watershed Protection, Stormwater Management, and Discharge Control Ordinance
ZEV zero emissions vehicle
The Farm in Poway EIR 11872
June 2020 1-1
1 Executive Summary
1.1 Description
The Farm in Poway project (proposed project) consists of approximately 117.2 acres and includes a total of
160 homes and a mix of open space and recreational uses. Accessory dwelling units are permissible on
detached single-family residences as required by state law. The proposed project would revitalize the
decommissioned StoneRidge Country Club and associated 18-hole golf course through the development of a
community with homes, open space, recreation, and commercial amenities. See Chapter 3, Project Description,
for additional information.
The new land uses proposed by The Farm in Poway Specific Plan (Specific Plan) (The Farm in Poway LLC 2020)
include two open space uses and five residential land uses. Open Space – Conservation (OS-C) is designed to
serve as a physical and visual buffer between existing residential uses and new residential development, and may
be planted with agriculture or naturalized drought-tolerant landscaping. Open Space – Recreation (OS-R) would
allow up to 30,000 gross square feet of non-residential buildings that can be used for educational, social, and
recreational uses. The Residential – Twin (R-T) allows for development of up to 22 twin homes. Residential –
Cottage (R-C) allows for the development of up to 90 detached single-family homes. Residential – Garden (R-G)
allows for the development of up to 13 detached single-family homes. Residential – Homestead (R-H) allows for
the development of up to 20 detached single-family homes. Residential – Meadow (R-M) allows for the
development of up to 15 detached single-family homes. All of the land use locations within the proposed projects
are presented in Figure 1-1, Site Plan.
The proposed project would include approximately 70.37 acres of open space, which would consist of 55.72
acres of OS-C and 14.65 acres of OS-R. The residential land uses would encompass approximately 33.85 acres,
ranging in density from 2.5 to 10.7 dwelling units per acre; overall density of the project is 1.4 dwelling units per
acre. A simple majority approval by the voters of the City of Poway (City) at a special or general election (similar to
Proposition FF voting requirements for open space) would be required for future increases in density as
incorporated into the Poway Municipal Code by ordinance.
Specific Plan and Zone Reclassification
The project site is currently designated in the City of Poway Land Use and Zoning map as “Open Space-
Recreation (OS-R)” (City of Poway 1991). A General Plan amendment and zoning amendment would be processed
concurrently with the Specific Plan to designate the project site as “Planned Community (PC-9).” The amendment
consists of both a map amendment and a Zoning Ordinance text amendment. Currently, the Planned Community
(PC) zone may only be applied to properties 300 acres or larger. The proposed text amendment would revise the
text to allow the project site, at its current size to be zoned as PC similar to the Poway Road Specific Plan. This
new section would be added to the Zoning Ordinance that briefly describes The Farm in Poway Planned
Community. This designation and zoning would be consistent with other specific plan areas throughout the City.
Future changes to the proposed open space designations or increases in residential density or intensity of land
uses would be subject to simple majority approval by the voters of the City at a special or general election
(Proposition FF voting requirements apply to an open space redesignation).
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June 2020 1-2
Tentative Subdivision Map
The proposed project includes a tentative subdivision map. The map depicts the grading and drainage, individual
residential lots, common ownership lots, public streets, private driveways, and infrastructure improvements. The map
would be submitted concurrently with the Specific Plan. One or more final subdivision map(s) would be recorded.
Project Approvals
Approvals required to implement the proposed project include (1) a General Plan Amendment, (2) a Zone Change
to Planned Community (PC) Zone, (3) a Tentative Subdivision Map, (4) a Specific Plan, (5) a Conditional Use
Permit, (5) a Development Review, (6) an Environmental Assessment, and (7) a Proposition FF Rezone Vote.
Location
The project site is located in the northern portion of the City, and consists of the decommissioned StoneRidge
Country Club and associated 18-hole golf course. The project site is bordered by Espola Road to the south; St.
Andrews Drive to the north and west; and Cloudcroft Drive, Tam O’Shanter Drive, and Boca Raton Lane to the
east. The project site consists of approximately 117.2 acres and currently has an address of 17166 Stoneridge
Country Club Lane, Poway, California 92064. Figure 3-9, Project Location, shows the location of the project site
within the County of San Diego (County) and the City. Figure 1-2, Project Site Vicinity and Aerial Map, depicts an
aerial view of the project site and vicinity.
Setting
In a regional context, the City is situated near the middle of the County, approximately 20 miles north of
downtown San Diego via Interstate 15 (I-15). The project site is approximately two miles east of I-15. The City
boundary is approximately one-half mile west of the project site. I-15 runs generally parallel to the City’s western
border and provides connections to San Diego and Riverside Counties. The City’s geographic setting is
characterized by a network of hillsides and valleys and comprises an area that has many natural resources
including creeks and channels, canyons, grassland areas, and mountains.
The surrounding residential development consists of mostly single-family homes. Some multi-family homes exist
west of the middle of the project site, along Port Marnock Drive, and surrounded by the project site along
Villamoura Drive and Valle De Lobo Drive. Planned community projects exist to the east of the project site, and
open space designated for resource management exists southeast of the project site. The rest of the project site
is surrounded by residential uses varying in density.
The location, density, and intensity of rural and suburban-style development within the surrounding communities
have mainly developed through planned residential development, and are generally characterized by low-density
single-family neighborhoods with pockets of medium-density single-family development (duplex units and small
detached homes).
1 – Executive Summary
The Farm in Poway EIR 11872
June 2020 1-3
1.2 Summary of Significant Effects and
Mitigation Measures that Reduce or Avoid
the Significant Impacts
Table 1-1, Summary of Significant Effects, provides a summary of impact analysis, mitigation, and level of
significance of impact after mitigation for each issue area. Chapter 4, Environmental Analysis, of this
Environmental Impact Report (EIR) contains the analyses of all issue areas and includes proposed mitigation
measures for identified impacts. As discussed in this EIR, implementation of the proposed project would result in
significant impacts to air quality, biological resources, cultural and tribal resources, geology and soils, greenhouse
gas emissions, hazards and hazardous materials, noise, and transportation. However, these significant impacts
would all be mitigated to a less-than-significant levels. The proposed project would not result in any
significant and unavoidable impacts.
1.3 Areas of Controversy
A Notice of Preparation (NOP) was circulated from May 10, 2019, to June 10, 2019, for public review and
comment. The Initial Study, NOP, and Public Scoping comments are provided in Appendix A of this EIR. Areas of
controversy raised in the NOP public comment letters include the following:
Aesthetics
Air Quality
Biological Resources
Cultural and Tribal Cultural Resources
Energy
Green House Gas Emissions
Hydrology and Water Quality
Land Use and Planning
Noise
Public Services
Transportation
Utilities and Service Systems
Wildfires
1.4 Issues to be Resolved by the Decision-Making Body
An EIR is an information document, used to inform the decision makers and the public of the environmental
effects of a given project. The EIR includes discussion and inclusion of mitigation measures to reduce
environmental impacts. The decision-making body must decide whether or how to mitigate significant impacts.
The EIR includes a reasonable range of alternatives that might reduce significant impacts while still attaining
some of the project’s objectives. The decision makers must determine if any of these alternatives could
substantially reduce significant impacts and still meet project objectives.
1.5 Project Alternatives
Three alternatives have been developed over time as the proposed project has evolved with agency meetings and input:
No Project/No Development Alternative
Reduced Density Alternative
Reduced Development Footprint Alternative
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The Farm in Poway EIR 11872
June 2020 1-4
These alternatives are discussed below in this order, as some evolved from the analysis of prior alternatives. All of
these alternatives are analyzed in detail within Chapter 6, Alternatives, of this EIR. While some of these would
avoid or reduce the proposed project’s impacts, they do not meet most of the proposed project’s objectives.
No Project/No Development Alternative
The California Environmental Quality Act (CEQA) requires an evaluation of the “No Project” alternative so that
decision makers can compare the impacts of approving the proposed project with the impacts of not approving it
(California Public Resources Code, Section 21000 et seq.). According to CEQA Guidelines Section 15126.6(e), the No
Project Alternative must include the assumption that conditions at the time of the NOP (i.e., baseline
environmental conditions) would not be changed since the proposed project would not be implemented.
The No Project/No Development Alternative assumes that the proposed project would not be developed, which
means there would be no residential, recreational, park, trail, and other community and conservation uses
developed on site. Traffic improvements would not be constructed. None of proposed project site would be
permanently preserved as open space. In its existing condition, the site would remain an unsightly, abandoned,
former golf course/clubhouse property. Maintenance and abatement would continue to be required to ensure the
health, safety, and welfare of the public.
In comparing the No Project/No Development Alternative to the proposed project, CEQA provides that the “lead
agency should proceed to analyze the impacts of the no project alternative by projecting what would reasonably
be expected to occur in the foreseeable future if the project were not approved, based on current plans and
consistent with available infrastructure and community services” (14 CCR 15126.6[e][3][C]).
The No Project/No Development Alternative is compared to the proposed project as though it would remain in its
existing condition; however, as noted under CEQA, the existing site, an abandoned former golf course facility,
retains underlying General Plan land use designations and zoning. Thus, development of the existing site,
consistent with available infrastructure and services, is a reasonably expected occurrence in the foreseeable
future, even if the proposed project were not approved. As such, while no impacts are noted in the various
environmental categories for the No Project/No Development Alternative as of this writing, it is reasonable to
project future development on site because it is highly unlikely the existing site would remain in an undeveloped
condition; and, instead, another development proposal is likely to occur with same or similar impacts as identified
for the proposed project.
Reduced Density Alternative
The Reduced Density Alternative would include the development of 25 percent fewer residential units and larger
unified lot sizes, for a total of 120 residential units. General Plan Land Use and Zoning Amendments would be
required under this alternative, similar to the proposed project. Although fewer units would be developed, the
footprint of disturbance to construct the reduced number of residences would be roughly the same as the proposed
project since the lot sizes would be larger. The reduced density alternative would include some open space and
recreation amenities, but to a much lesser degree compared to the proposed project, and would not include the
Event Barn or social clubs.
1 – Executive Summary
The Farm in Poway EIR 11872
June 2020 1-5
Reduced Development Footprint Alternative
The Reduced Development Footprint Alternative would eliminate any development or improvements in the
southwestern portion of the project site, located along the proposed Private Street B, as well as in the
southwest corner of the project site. The reduction in homes would also result in a reduction in open space
and recreational amenities.
1.6 Environmentally Superior Alternative
As shown in Table 1-2, Environmentally Superior Alternative, implementation of the No Project/No Development
Alternative would result in the greatest reduction in significant impacts when compared to the proposed project.
Because the No Project/No Development Alternative would result in the least amount of impacts to the
environment, it would be the environmentally superior alternative. However, Section 15126.6(e)(2) of the CEQA
Guidelines states that if the environmentally superior alternative is the No Project Alternative, the EIR also must
identify an environmentally superior alternative among the other alternatives.
Aside from the No Project/No Development Alternative, the Reduced Development Footprint Alternative would
result in the least amount of environmental impacts. As compared to the proposed project, impacts associated
with biological resources, hazards, noise, and transportation would be reduced. Therefore, this alternative is
identified as the Environmentally Superior Alternative. However, the proposed project would mitigate all of these
impacts to a level less than significant.
1 – Executive Summary
The Farm in Poway EIR 11872
June 2020 1-6
Table 1-1. Summary of Significant Effects
Impact
No. Impact Mitigation
Conclusion
and
Mitigation
Effectiveness
Air Quality
AQ-1 The proposed project would
result in daily construction
emissions that would
exceed the significance
thresholds for oxides of
nitrogen (NOx) and carbon
monoxide (CO).
MM-AQ-1 During project construction, the City of Poway shall ensure that the project
contractor adheres to the following measures to reduce diesel particulate
emissions, including, but not limited to:
1) All construction equipment greater than 75 horsepower shall be equipped with
Tier 4 Interim diesel engines or better.
2) The engine size of construction equipment shall be the minimum size
suitable for the required job.
3) The number of construction equipment operating simultaneously shall be
minimized through efficient management practices to ensure that the smallest
number is operating at any one time.
4) Construction equipment shall be maintained in tune per the manufacturer’s
specifications.
5) The prime contractor will provide the City of Poway verification of equipment
type used during construction.
Less-than-
Significant
Impact
AQ-2 The proposed project would
result in toxic air contaminant
(TAC) exposure from
construction diesel exhaust
emissions that would result in
cancer risk on site above the
10 in 1 million threshold, as
well as Chronic Hazard Index
less than one. Therefore, TAC
emissions from construction
of the proposed project may
expose sensitive receptors to
substantial pollutant
concentrations.
See MM-AQ-1. Less-than-
Significant
Impact
1 – Executive Summary
The Farm in Poway EIR 11872
June 2020 1-7
Table 1-1. Summary of Significant Effects
Impact
No. Impact Mitigation
Conclusion
and
Mitigation
Effectiveness
AQ-CU-1 The proposed project would
result in a potentially
significant cumulative
impact from criteria air
pollutant emissions during
construction.
See MM-AQ-1.
Biological Resources
BR-1 The proposed project
would result in significant
impacts to nesting birds if
suitable nesting habitats,
such as mature trees, are
removed during the
general bird breeding
season from February 1 to
September 15.
MM-BR-1 Removal of habitat that supports active nests in the proposed project area of
disturbance shall occur outside of the breeding season for nesting birds
(February 1 to September 15). If removal of the habitat in the proposed area of
disturbance must occur during the breeding season, a qualified biologist shall
conduct a pre-construction survey to determine the presence or absence of
nesting birds or raptors protected under the Migratory Bird Treaty Act and
California Fish and Game Code. The pre-construction survey shall be conducted
within 10 3 calendar days prior to the start of construction activities (including
removal of vegetation) and shall include the limits of disturbance as well as 300
feet (500 feet for raptors) from the area of disturbance. The applicant shall submit
the results of the pre-construction survey to the City of Poway (City) for review
and approval prior to initiating any construction activities.
1) If nesting birds are detected, a letter report or mitigation plan (pre-
construction survey) in conformance with applicable state and federal law
(e.g., appropriate follow-up surveys, monitoring schedules, construction,
noise barriers, and/or buffers up to 300 feet) shall be prepared and include
proposed measures to be implemented to ensure that take of birds or eggs,
or disturbance of breeding activities, is avoided. The report or mitigation
plan shall be submitted to the City for review and approval. The
recommendations contained in the mitigation plan shall be implemented to
the satisfaction of the City.
2) If nesting birds are not detected during the pre-construction survey, no
further mitigation is required.
3) If nesting birds are detected and construction activities are to occur during the
Less-than-
Significant
Impact
1 – Executive Summary
The Farm in Poway EIR 11872
June 2020 1-8
Table 1-1. Summary of Significant Effects
Impact
No. Impact Mitigation
Conclusion
and
Mitigation
Effectiveness
breeding season the following mitigation measures shall be implemented:
a) No vegetation clearing shall occur within 300 feet of an active raptor
nest and 100 feet of an active nest of a non-listed bird species until a
biologist has determined that the young have fledged from the nest or
that the nest is inactive (i.e., abandoned).
b) A mitigation plan outlining active nest avoidance measures in
conformance with applicable state and federal law shall be prepared
and submitted to the City of Poway for review and approval.
c) During construction, active nests shall be monitored on a daily basis to
determine the effectiveness of the avoidance measures being
implemented. The biologist shall monitor all active nests until all young
have fledged or until the nest is determined inactive.
d) A minimum 300-foot buffer between the location of an active raptor
nest and the nearest construction activity shall be maintained until
the young have fledged from the nest or until the nest is determined
inactive. For nests of non-raptor birds, a buffer of 100 feet shall be
maintained.
4) While no specific noise level thresholds have been established for raptors or
other non-listed bird species, construction activities that are expected to
generate noise levels above the ambient noise level shall be measured by
an acoustician technician. The active nest shall also be monitored by a
biologist to determine if there is any effect on the breeding behavior of the
particular species from the elevated noise levels. If it is determined that the
elevated noise level is having an effect on the breeding behavior of the
nesting bird species, then the noise generating construction activity shall be
suspended in the vicinity of the active nest until such time as all of the
young birds have fledged or until the nest is determined inactive.
1 – Executive Summary
The Farm in Poway EIR 11872
June 2020 1-9
Table 1-1. Summary of Significant Effects
Impact
No. Impact Mitigation
Conclusion
and
Mitigation
Effectiveness
BR-2 The proposed project would
impact 0.16 acres of
wetland/riparian and other
sensitive natural
communities.
MM-BR-2 Impacts to jurisdictional waters require a 404 permit from the U.S. Army Corps
of Engineers, a 401 state water quality certification from the Regional Water
Quality Control Board, and a 1602 streambed alteration agreement from the
California Department of Fish and Wildlife. Impacts to the sensitive habitat,
including jurisdictional waters, within the project site require compensating
mitigation, restoration, or revegetation, or a combination thereof, inside a
priority Mitigation Area as defined by the Poway Subarea Habitat Conservation
Plan/Natural Community Conservation Plan (Poway Subarea HCP/NCCP),
Section 5.5. This can be achieved by one of the following:
1) Purchase or dedication of lands inside the City of Poway’s Mitigation Area as
a biological open space.
2) Payment of in-lieu fees into a mitigation bank administered by the City of
Poway or a land trust acting as an agent of the City of Poway.
Applicable permits necessary to develop over the wetland habitat features in the
project site require a no-net-loss ratio. The Poway Subarea HCP/NCCP states
that mitigation ratios of 2:1 would be required for impacts to fresh water marsh
and open water. As described in the following table, the total mitigation for
jurisdictional waters impacts is estimated to total 0.39 acres, but requires
approval by the aforementioned resource agencies through their respective
permit processes, which would occur before project development.
Less-than-
Significant
Impact
Mitigation Requirements
Vegetation Community Impact Mitigation Ratio Total Mitigation Required
Freshwater Marsh 0.02 2:1 0.04
Open Water 0.14 2:1 0.28
Concrete-Lined Channel 0.07 1:1 0.07
Total 0.16 — 0.39
Source: Appendix C
1 – Executive Summary
The Farm in Poway EIR 11872
June 2020 1-10
Table 1-1. Summary of Significant Effects
Impact
No. Impact Mitigation
Conclusion
and
Mitigation
Effectiveness
BR-3 The proposed project would
impact 0.23 acres of
jurisdictional waters and
wetlands.
See MM-BR-2. Less-than-
Significant
Impact
BR-4 The proposed project would
result in the unavoidable
impact of trees and
sensitive habitats on the
project site, therefore being
in conflict with local
regulations.
See MM-BR-2.
MM-BR-3 If it is not feasible to avoid trees on the project site, the project applicant shall
replace all impacted trees as follows:
1) Native coast live oaks (Quercus agrifolia) will be mitigated at minimum
ratios of 10:1 for directly impacted oak trees and 5:1 for indirectly impacted
oak trees, as required by the City’s HCP/NCCP, 4:1 ratio and shall use 24-
inch box specimen trees to be located on site.
2) Any non-native trees removed will be replaced with one 15-gallon tree per
750 square feet of ornamental landscape (20 percent of which shall be 24-
inch box specimen trees).
Less-than-
Significant
Impact
BR-CU-1 The proposed project would
potentially contribute to a
cumulatively considerable
impact to nesting birds.
See MM-BR-1. Less-than-
Significant
Impact
BR-CU-2 The proposed project
would potentially
contribute to a
cumulatively considerable
impact to
wetland/riparian and
other sensitive natural
communities.
See MM-BR-2. Less-than-
Significant
Impact
BR-CU-3 The proposed project would
potentially contribute to a
cumulatively considerable
impact to jurisdictional
waters and wetlands.
See MM-BR-2. Less-than-
Significant
Impact
1 – Executive Summary
The Farm in Poway EIR 11872
June 2020 1-11
Table 1-1. Summary of Significant Effects
Impact
No. Impact Mitigation
Conclusion
and
Mitigation
Effectiveness
BR-CU-4 The proposed project would
potentially contribute to a
cumulatively considerable
impact to mature and
protected trees.
See MM-BR-3. Less-than-
Significant
Impact
Cultural and Tribal Cultural Resources
CUL-1 The proposed project has
the potential to unearth
subsurface prehistoric
archaeological materials
during ground-disturbing
activities, resulting in a
potentially significant
impact.
MM-CUL-1 An archaeological resources monitoring program to mitigate potential impacts to
undiscovered, buried, or previously undetected elements of any archaeological
resources within the project site shall be implemented to the satisfaction of the
Lead Agency. The program shall and include the following:
1) Prior to issuance of a grading permit, the applicant shall provide written
verification that a qualified archaeologist has been retained to implement
the monitoring program. This verification shall be presented in a letter from
the project archaeologist to the Lead Agency. The qualified archaeologist
(project archaeologist) shall engage a Native American Kumeyaay
representative to participate in the monitoring program. The Native
American Kumeyaay monitor will be responsible to advise the project
archaeologist regarding culturally sensitive artifacts or landforms within the
project.
2) The certified project archaeologist and Kumeyaay representative shall
attend the pre-grading meeting with the contractors to explain and
coordinate the requirements of the monitoring program.
3) Archaeological and Native American monitoring shall be required during
grading, unless the project archaeologist determines that the potential for
cultural resources has been exhausted. The Native American monitor shall
coordinate on-site monitoring with the project archaeologist. Full- or- part-
time inspections may be considered depending upon the rate of excavation,
the materials excavated, and the presence and abundance of artifacts and
features. The project archaeologist, in consultation with the Kumeyaay
representative, shall provide the City of Poway with any recommendations
for reduced monitoring protocol.
Less-than-
Significant
Impact
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The Farm in Poway EIR 11872
June 2020 1-12
Table 1-1. Summary of Significant Effects
Impact
No. Impact Mitigation
Conclusion
and
Mitigation
Effectiveness
The consulting archaeologist shall direct the field monitor during grading of
all areas identified for development.
Native American monitoring will be required during grading, unless the certified
archaeologist determines that the potential for cultural resources has been
exhausted. The Native American monitors will be directed by the project
archaeologist. Native American monitors/representatives from the Kumeyaay
nation and The Jamul Indian Village of California shall be invited to participate in
the monitoring program.
During the original cutting of previously undisturbed deposits, the archaeological
monitor and Native American representative shall be on site, as determined by
the consulting archaeologist, to perform inspections of the excavations. Full- or
part-time inspections may be needed depending upon the rate of excavation, the
materials excavated, and the presence and abundance of artifacts and features.
Isolates and clearly non-significant deposits will be minimally documented in
the field so the monitored grading can proceed.
4) In the event that previously unidentified cultural resources are discovered
during the monitoring program, the project archaeologist and Kumeyaay
representative shall have the authority to divert or temporarily halt ground-
disturbance operation in the area of discovery to allow for the evaluation of
potentially significant cultural resources. The project archaeologist shall
contact the Lead Agency at the time of discovery. All discovered cultural
resources shall be recorded and tested using standard archaeological
protocols. Any resources determined to not be CEQA-significant shall be
released to the grading program. For any resources that are determined to
be CEQA-significant and eligible for the California Register of Historical
Resources, the project archaeologist, in consultation with the lead agency
and the Kumeyaay representative, shall determine the appropriate
measures to be implemented in order to mitigate adverse impacts to the
significant site. The applicant, at their sole discretion, shall consider the
possibility of preserving the significant site, if feasible. If preservation is not
feasible, a Research Design and Data Recovery Program to mitigate impacts
shall be prepared by the project archaeologist, in consultation with the
1 – Executive Summary
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June 2020 1-13
Table 1-1. Summary of Significant Effects
Impact
No. Impact Mitigation
Conclusion
and
Mitigation
Effectiveness
Kumeyaay representative, and approved by the lead agency. Data recovery
mitigation shall be completed at the location of a significant discovery before
grading can resume at that location. The archaeologist, in consultation with the
Lead Agency, shall determine the significance of the discovered resources. The
Lead Agency must concur with the evaluation before construction activities will
be allowed to resume in the affected area. For significant cultural resources that
are discovered and that will be destroyed by grading, a Research Design and
Data Recovery Program to mitigate impacts shall be prepared by the consulting
archaeologist and approved by the Lead Agency before being carried out using
professional archaeological methods. If any human remains are discovered, all
grading at that location must stop and the County of San Diego Coroner’s office
and Lead Agency shall be contacted. In the event that the remains are
determined to be of Native American origin, the Most Likely Descendant, as
identified by the Native American Heritage Commission, shall be contacted in
order to determine proper treatment and disposition of the remains.
Before construction activities are allowed to resume in the location of any
discovered significant cultural deposits, the artifacts shall be recovered and
features recorded using professional archaeological methods. The
archaeological monitor(s) shall determine the amount of material to be
recovered for an adequate artifact sample for analysis.
5) Human Remains: If human remains are encountered during grading,
California Health and Safety Code Section 7050.5 states that no further
disturbance shall occur until the San Diego County Medical Examiner’s
Office has made the necessary findings as to origin. The City of Poway, the
Native American Kumeyaay representative, and the applicant shall be
immediately notified of the discovery of any possible human remains.
Further, pursuant to California Public Resources Code Section 5097.98(b),
remains shall be left in place and free from disturbance until a final
decision as to their treatment and disposition has been made. If the
medical examiner determines that the remains are of Native American
1 – Executive Summary
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June 2020 1-14
Table 1-1. Summary of Significant Effects
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No. Impact Mitigation
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origin, the NAHC must be contacted within 24 hours. The NAHC must then
immediately identify the Most Likely Descendant(s) (MLD) for purposes of
receiving notification of discovery. The MLD shall then make
recommendations within 48 hours and engage in consultation concerning
the treatment of the remains as provided in Public Resources Code Section
5097.98. The Kumeyaay monitor for grading will not necessarily be named
as the MLD, and therefore, cannot provide direction until the MLD is
determined.
6) All cultural material collected during the grading monitoring program shall be
cataloged, analyzed, and subsequently processed and curated according to
the current professional laboratory and repository standards. The collections
and associated records shall be transferred, including title, to an appropriate
curation facility, to be accompanied by payment of the fees necessary for
permanent curation.
7) A report documenting the monitoring program, any field investigations, and
results of any data recovery programs or site evaluations field and analysis
results and interpreting the artifact and research data within the research
context shall be completed and submitted to the satisfaction of the Lead Agency
prior to the issuance of any building permits. The report will include DPR Primary
and Archaeological Site Forms.
1 – Executive Summary
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June 2020 1-15
Table 1-1. Summary of Significant Effects
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No. Impact Mitigation
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CUL-2 In the event of accidental
discovery of any human
remains during
construction of the
proposed project, impacts
associated with the
disturbance of human
remains would be
potentially significant.
See MM-CUL-1
MM-CUL-2 As specified by California Health and Safety Code, Section 7050.5, if human remains
are found on the project site during construction or during archaeological work, the
person responsible for the excavation, or his or her authorized representative, shall
immediately notify the County of San Diego Coroner’s office and the City of Poway
Development Services Division. Determination of whether the remains are human
shall be conducted on site and in situ (where they are discovered) by a forensic
anthropologist, unless the forensic anthropologist and the Native American monitor
agree to remove the remains to an off-site location for examinations. No further
excavation or disturbance of the site or any nearby area reasonably suspected to
overlie adjacent remains shall occur until the County of San Diego Coroner’s office
has made the necessary findings as to origin and disposition. A temporary
construction exclusion zone may be established surrounding the area of the discovery
so that the area would be protected, and consultation and treatment shall occur as
prescribed by law or as otherwise recommended by a qualified professional in
concurrence with Tribal representatives or other represented entities. In the event
that the remains are determined to be of Native American origin, the most likely
descendant, as identified by the Native American Heritage Commission, shall be
contacted in order to determine proper treatment and disposition of the remains in
accordance with California Public Resources Code, Section 5097.98. The Native
American remains shall be kept in situ, or in a secure location in close proximity to
where they were found, and the analysis of the remains shall only occur on site and in
the presence of a Native American monitor.
Less-than-
Significant
Impact
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June 2020 1-16
Table 1-1. Summary of Significant Effects
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No. Impact Mitigation
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CUL-3 If unknown tribal resources
were unearthed during
grading activities, then
implementation of the
proposed project has the
potential to cause a
substantial adverse change in
the significance of a tribal
cultural resource, as defined
in Section 21074 of the
California Public Resources
Code.
See MM-CUL-1. Less-than-
Significant
Impact
Geology and Soils
GEO-1 The proposed project could
result in potentially
significant impacts
associated with seismic-
related ground failure,
including liquefaction, due
to the unknown depth of
groundwater on-site and
the potential for liquefiable
soils.
MM-GEO-1 The Geologic Reconnaissance (Appendix E) includes the following recommendations,
which shall be incorporated as mitigation measures to minimize soil erosion or the
loss of topsoil, and potential risks associated with liquefaction:
1) Prior to issuance of a grading permit, an additional geotechnical study shall
be completed that includes a subsurface investigation to evaluate the
underlying geologic conditions on the property and to provide specific
geotechnical recommendations. This study shall include evaluation of
surficial deposits, and a rippability analysis of the granitic rock in areas of
planned development.
2) The site is underlain by surficial units that include artificial fill, alluvial, and
colluvial deposits. These deposits shall require remedial grading in the form
of removal and compaction where improvements are planned.
3) Cut slopes shall be observed by an engineering geologist during grading to
verify that the soil and geologic conditions do not differ significantly from
those anticipated. Additional recommendations will be provided in the event
that adverse conditions are encountered, such as but not limited to, scaling
of loose rock fragments from proposed cut slopes.
Less-than-
Significant
Impact
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June 2020 1-17
Table 1-1. Summary of Significant Effects
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No. Impact Mitigation
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GEO-2 The proposed project could
result in a potentially
significant impact associated
with soil erosion because on-
site artificial fill, alluvium,
and colluvium deposits are
presently unsuitable to
support fill and/or structural
loads where improvements
are planned.
See MM-GEO-1. Less-than-
Significant
Impact
GEO-3 The proposed project could
result in a potentially
significant impact relative
to the location of expansive
soils on-site that may result
in substantial direct or
indirect risks to life or
property.
MM-GEO-2 The Geological Reconnaissance (Appendix E) includes the following
recommendations, which shall be incorporated as mitigation measures to
minimize potential risks from expansive soil:
1) Samples of soil materials to be used for fill shall be tested in the
laboratory to determine the maximum density, optimum moisture content,
and, where appropriate, shear strength, expansion, and gradation
characteristics of the soil.
2) Where practical, soils having an Expansion Index greater than 50 should be
placed at least 3 feet below finish pad grade and should be compacted at a
moisture content generally 2 to 4 percent greater than the optimum
moisture content for the material.
Less-than-
Significant
Impact
GEO-4 If unexpected intact
paleontological resources
are unearthed during
ground-disturbing activities,
then the proposed project
could result in significant
impacts to unique
paleontological resources
or sites, or unique geologic
features.
MM-GEO-3 Prior to commencement of project construction, a qualified paleontologist shall
be retained to attend the project pre-construction meeting and discuss proposed
grading plans with the project contractor(s). If the qualified paleontologist
determines that proposed grading/excavation activities would likely affect
previously undisturbed areas of Pleistocene-age alluvial deposits as a result of
cuts into native soils, then monitoring shall be conducted as outlined below.
1) A qualified paleontologist or a paleontological monitor under the
direction and supervision of a qualified paleontologist, shall be on site
during original cutting of Pleistocene-age alluvial deposits. A
Less-than-
Significant
Impact
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June 2020 1-18
Table 1-1. Summary of Significant Effects
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No. Impact Mitigation
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paleontological monitor is defined as an individual who has at least
one year of experience in field identification and collection of fossil
materials, and who is working under the direction of a qualified
paleontologist. Monitoring of the noted geologic unit shall be conducted
at least half-time at the beginning of excavation, and may be either
increased or decreased thereafter depending upon initial results (per
direction of a qualified paleontologist).
a) Qualified Paleontologist: The project paleontologist is a person who has
a Ph.D. or M.S. or equivalent in paleontology or closely related field (e.g.,
sedimentary or stratigraphic geology, evolutionary biology); has a
demonstrated knowledge of Southern California paleontology and
geology; and has documented experience performing professional
paleontological procedures and techniques.
b) Qualified Paleontological Monitor: A paleontological monitor is defined as
an individual with at least one year of experience in field identification and
collecting of fossil materials.
2) Monitoring of the noted geologic unit shall be conducted at least half-time at
the beginning of the excavation, and may be either increased or decreased
thereafter by the qualified paleontologist depending upon initial results of
monitoring.
3) In the event that well-preserved fossils are discovered, a qualified
paleontologist shall have the authority to temporarily halt or redirect
construction activities in the discovery area to allow recovery in a timely
manner (typically on the order of one hour to two days). All collected fossil
remains shall be cleaned, sorted, cataloged and deposited in an
appropriate scientific institution (such as the San Diego Natural History
Museum) at the applicant’s expense.
4) A report (with a map showing fossil site locations) summarizing the results,
analyses, and conclusions of the above-described monitoring/recovery program
shall be submitted to the City of Poway within three months of terminating
monitoring activities.
1 – Executive Summary
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June 2020 1-19
Table 1-1. Summary of Significant Effects
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No. Impact Mitigation
Conclusion
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Effectiveness
Greenhouse Gas Emissions
GHG-1 The proposed project would
result in 4,245 metric tons
of carbon dioxide
equivalent (MT CO2e) per
year, which would be
greater than the
significance threshold of
900 MT CO2e per year
MM-GHG-1 The applicant or its designee shall include the following features to reduce
greenhouse gas emissions during operation:
1) Develop a comprehensive pedestrian network designed to provide safe
bicycle and pedestrian access between the various internal proposed
project land uses, which will include design elements to enhance walkability
and connectivity and shall minimize barriers to pedestrian access and
interconnectivity. Physical barriers—such as walls or landscaping—that
impede pedestrian circulation shall be eliminated.
2) Include special safety mobility features such as enhanced crosswalks for
high visibility, pedestrian signals with countdown timers, leading pedestrian
interval timing, Americans with Disabilities Act (ADA)-compliant curb ramps,
and smart adaptive signals that can adjust signal phasing and extend
pedestrian walk time based upon time of day. The smart adaptive signals
help to optimize traffic flows to reduce idling time.
3) Promote ridesharing programs through a multi-faceted approach, such as
designating a certain percentage of parking spaces for ridesharing vehicles,
designating adequate passenger loading and unloading and waiting areas
for ridesharing vehicles, or providing a website or message board for
coordinating rides.
4) Install Energy Star rated heating, cooling, lighting, and appliances.
5) Outdoor lighting shall be light emitting diodes (LED) or other high-efficiency
lightbulbs.
6) Implement water-sensitive urban design practices in new construction.
7) Strategically plant trees to provide shade.
8) Equip structures with outdoor electric outlets in the front and rear of the
structure to facilitate use of electrical lawn and garden equipment.
9) Outdoor pavement, such as walkways and patios, shall include paving
materials with three-year Solar Reflective Index (SRI) of 0.28 or initial SRI of
0.33, or other equivalent cool pavement.
Less-than-
Significant
Impact
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June 2020 1-20
Table 1-1. Summary of Significant Effects
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No. Impact Mitigation
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MM-GHG-2 The applicant or its designee shall purchase and retire greenhouse gas (GHG)
offsets to reduce the proposed project’s GHG emissions level to 900 metric tons
of carbon dioxide equivalent (MT CO2e) per year, consistent with the
performance standards and requirements set forth below.
1) The GHG offsets shall be secured from an accredited registry that is
recognized by the California Air Resources Board (CARB) or a California air
district, or from an emissions reduction credits program that is
administered by CARB or a California air district.
2) The GHG offsets shall represent the past reduction or sequestration of one
MT CO2e that is “not otherwise required,” in accordance with California
Environmental Quality Act Guidelines Section 15126.4(c)(3).
3) The GHG offsets shall be real, permanent, quantifiable, verifiable, and
enforceable.
4) The quantity of GHG offsets required to achieve the service population value
set forth above shall be calculated in and supported by technical
documentation that is submitted to the City as part of the Mitigation
Monitoring and Reporting Program, using an approved methodology
demonstrating the quantity of reductions is valid and sufficient.
5) The applicant shall offset the proposed project’s GHG emissions prior to
receiving the 80th certificate of occupancy from the City. This represents 50
percent of the proposed project’s residential build-out and thus the
proposed project’s emissions would be offset prior to completion of the
proposed project.
Hazards and Hazardous Materials
HAZ-1 Many of the structures on
the project site have the
potential to contain
asbestos-containing
materials, lead-based paint,
and universal wastes; and
electrical components, such
MM-HAZ-1 Prior to demolition or renovation of project site structures that were built before
1980, a hazardous building materials survey shall be conducted by a California
Department of Public Health (DPH) Certified Asbestos Consultant and/or
Certified Site Surveillance Technician and a California DPH Certified Lead
Inspector/Risk Assessor or Sampling Technician. A report documenting material
types, conditions and general quantities will be provided, along with photos of
positive materials and diagrams. Demolition or renovation plans and contract
Less-than-
Significant
Impact
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June 2020 1-21
Table 1-1. Summary of Significant Effects
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No. Impact Mitigation
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and
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as transformers, which could
contain polychlorinated
biphenyls (PCBs). Should
demolition or alteration
occur without proper
identification and abatement
of these hazardous building
materials, this could pose a
significant hazard to the
public or environment.
specifications shall incorporate any abatement procedures for the removal of
material containing asbestos, lead-based paint, universal wastes and/or
polychlorinated biphenyl (PCB)-containing equipment. All abatement work shall
be done in accordance with federal, state, and local regulations, including those
of the U.S. Environmental Protection Agency (which regulates disposal), Air
Pollution Control District, Occupational Safety and Health Administration, U.S.
Department of Housing and Urban Development, California Occupational Safety
and Health Administration (which regulates employee exposure), and the South
Coast Air Quality Management District.
HAZ-2 A former leaking
underground storage tank
(LUST) case is located at
the southwest corner of the
project site. While this case
received regulatory closure
from the San Diego
Regional Water Quality
Control Board (San Diego
RWQCB), methyl tertiary
butyl ether (MTBE)
contamination was allowed
to remain in groundwater
on the project site.
Contaminated groundwater
could pose a significant
hazard to the public or
environment should the site
be redeveloped
MM-HAZ-2 The San Diego Regional Water Quality Control Board (San Diego RWQCB) is the
regulatory agency in charge of the former leaking underground storage tank
(LUST) case on the project site. Prior to construction or excavation activities in
the area of the former LUST, San Diego RWQCB will be consulted regarding
requirements necessary to meet the advisories of the LUST closure letter and
requirements for residential development in order to protect human health and
the environment. Requirements set forth by the San Diego RWQCB will be
implemented prior to excavation and development of the project site. An
example of these requirements may include participation in the County of San
Diego Department of Environmental Health Voluntary Assistance Program and a
soils management plan prepared by a Geotechnical Engineer or Geologist.
Less-than-
Significant
Impact
1 – Executive Summary
The Farm in Poway EIR 11872
June 2020 1-22
Table 1-1. Summary of Significant Effects
Impact
No. Impact Mitigation
Conclusion
and
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Effectiveness
Noise
NOI-1 During proposed grading
activities for the on-site trail
system that are expected as
close as 25 feet to off-site
noise-sensitive receptors,
and retention basin
construction involving the
assemblage of equipment
working right at the edge of
the construction zone in
each phase and within 15
feet of existing residences,
construction noise levels
are anticipated to exceed
the City’s construction noise
limit of 75 A-weighted
decibel (dBA) Leq over an
eight-hour period.
MM-NOI-1 Prior to the issuance of a Construction Permit, the project applicant/owner or
construction contractor shall prepare and submit to the City of Poway Planning
Division for its review and approval a Construction Noise Management Plan
(CNMP). Prior to the issuance of a Construction Permit, construction plans shall
also include a note indicating compliance with the CNMP is required. The CNMP
shall be prepared or reviewed by a qualified acoustician (retained at the project
applicant/owner or construction contractor’s expense) and feature the following:
1) A detailed construction schedule, at daily (or weekly, if activities during each
day of the week are typical) resolution and correlating to areas or zones of
on-site project construction activities and the anticipated equipment types
and quantities involved. Information shall include expected hours of actual
operation per day for each type of equipment per phase and indication of
anticipated concurrent construction activities on site.
2) Suggested locations of a set of noise-level monitors, attended by a
qualified acoustician or another party under his/her supervision or
direction, at which sample outdoor ambient noise levels will be
measured and collected over a sufficient sample period and
subsequently analyzed (i.e., compared with applicable time-dependent
A-weighted decibel [dBA] thresholds) to ascertain compliance with the
eight-hour City of Poway threshold of 75 dBA equivalent noise level
over a consecutive eight-hour period. Sampling shall be performed, at a
minimum, on the first (or otherwise considered typical construction
operations) day of each distinct construction phase (e.g., each of the
five listed phases in Table 4.11-2, Construction Phase Distance to
Nearest Pre-Existing Noise-Sensitive Receptors).
3) If sample collected noise level data indicates that the eight-hour noise
threshold has or will be exceeded, construction work shall be suspended (for
the activity or phase of concern) and the project applicant/owner or
construction contractor shall implement one or more of the following
measures as detailed or specified in the CNMP:
Less-than-
Significant
Impact
1 – Executive Summary
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June 2020 1-23
Table 1-1. Summary of Significant Effects
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No. Impact Mitigation
Conclusion
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Effectiveness
a) Administrative controls (e.g., reduce operating time of equipment and/or
prohibit usage of equipment type[s] within certain distances).
b) Engineering controls (upgrade noise controls, such as install better engine
exhaust mufflers).
c) Install noise abatement on the project site boundary fencing (or within the
project site, as practical and appropriate) in the form of sound blankets or
comparable temporary barriers to occlude construction noise emission
between the project site (or specific equipment operation as the situation
may define) and the noise-sensitive receptor(s) of concern.
The implemented measure(s) shall be reviewed or otherwise inspected and
approved by the qualified acoustician (or another party under his/her
supervision or direction) prior to resumption of the construction activity or
process that caused the measured noise concern or need for noise
mitigation. Noise levels shall be re-measured, after installation of said
measures, to ascertain post-mitigation compliance with the noise threshold.
As needed, this process shall be repeated and refined until noise level
compliance is demonstrated and documented. A report of this implemented
mitigation and its documented success shall be provided to the City of Poway
Planning Division.
The project applicant/owner or construction contractor shall make available a
telephone hotline so that concerned neighbors in the community may call to
report noise complaints. The CNMP shall include a process to investigate these
complaints and, if determined to be valid, detail efforts to provide a timely
resolution and response to the complainant—with copy of resolution provided to
the City of Poway Planning Division.
1 – Executive Summary
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June 2020 1-24
Table 1-1. Summary of Significant Effects
Impact
No. Impact Mitigation
Conclusion
and
Mitigation
Effectiveness
NOI-2 Regarding proposed
construction of Private
Street B, when the entire
assemblage of
construction equipment is
working right at the edge
of the construction zone
in each phase, within 36
feet of existing
residences, construction
noise levels are
anticipated to reach up to
78 dBA Leq. Assuming
relatively steady work,
this would result in an
exceedance of the City’s
construction noise limit of
75 dBA Leq over an eight-
hour period.
See MM-NOI-1. Less-than-
Significant
Impact
NOI-3 Regarding proposed rock
blasting event noise, at 400
feet of existing off-site
residences, eight-hour noise
levels are anticipated to
reach up to 80 dBA Leq.
Assuming a heavily confined
per-delay charge weight of
18.5 pounds, this would
result in an exceedance of
the City’s construction noise
limit of 75 dBA Leq over an
eight-hour period.
MM-NOI-2 The project applicant/owner or its construction contractor(s) shall prepare, or
cause to be prepared, a blasting/drilling monitoring plan. The plan shall be site
specific, based on general and exact locations of required blasting and the
results of a project-specific geotechnical investigation. The blasting plan shall
include a description of the planned blasting methods, an inventory of receptors
potentially affected by the planned blasting, and calculations to determine the
area affected by the planned blasting that include estimates of the pre-blast drill
noise levels, air-blast overpressure sound levels, and groundborne vibration
levels at each residence within 500 feet of a blasting location. Where potential
exceedances of relevant noise and vibration exposure limits are identified, the
blasting/drilling monitoring plan shall identify mitigation measures shown to
effectively reduce noise and vibration levels (e.g., altering orientation of blast
progression, increased delay between charge detonations, pre-splitting) to be
Less-than-
Significant
Impact
1 – Executive Summary
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June 2020 1-25
Table 1-1. Summary of Significant Effects
Impact
No. Impact Mitigation
Conclusion
and
Mitigation
Effectiveness
implemented in order to demonstrate compliance with these thresholds.
Additionally, all project phases involving blasting shall conform to the following
requirements:
1) All blasting shall be performed by a blast contractor and blasting personnel
licensed to operate per appropriate regulatory agencies.
2) Prior to blasting, a qualified geotechnical professional shall inspect and
document the existing conditions of facades and other visible structural
features or elements of the nearest residential buildings. Should this
inspector determine that some structural features or elements appear
fragile or otherwise potentially sensitive to vibration damage caused by
the anticipated blasting activity, the maximum per-delay charge weights
and other related blast parameters shall be re-evaluated to establish
appropriate quantified limits.
3) Each blast shall be monitored and recorded with an air-blast overpressure
monitor and groundborne vibration accelerometer that is located outside
the closest residence to the blast. This data shall be recorded, and a post-
blast summary report shall be prepared and be available for public review or
distribution as necessary.
4) Blasting shall not exceed 0.5 inches per second peak particle velocity at the
nearest occupied residence, in accordance with the California Department
of Transportation’s Transportation and Construction Vibration Guidance
Manual.
5) To ensure that potentially impacted residents are informed, the applicant
shall provide notice by mail to all property owners within 1,000 feet of the
project at least one week prior to a scheduled blasting event. Notice shall
also be provided to Maderas Golf Course and the Green Valley Civic
Association.
6) Pre-blast drilling operations associated with blasting preparations shall be
performed in a manner consistent with adherence to City of Poway
regulations and guidance.
NOI-4 Regarding The Event Barn MM-NOI-3 Operation of any “regular event” at The Event Barn (and The Social), as defined by Less-than-
1 – Executive Summary
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June 2020 1-26
Table 1-1. Summary of Significant Effects
Impact
No. Impact Mitigation
Conclusion
and
Mitigation
Effectiveness
and The Social, under the
right conditions the
occurrence and duration of
regular events could risk
exceeding the required off-
site residential land use
threshold of 60 dBA CNEL
as identified by the Specific
Plan. The on-site noise limit
of 70 dBA CNEL may also
be exceeded under the
right conditions. At the
same venue, the
occurrence, type, intensity
and duration of special
events (especially those
during nighttime hours)
would also risk exceeding
the same standards.
3.2.3.B of The Farm in Poway Specific Plan Additional Open Space Standards,
shall conform to the following acoustical conditions:
1) Daytime (within 8 a.m. to 7 p.m.)
a) Attendance shall not exceed 300, including residents, guests, visitors,
and any on-site support staff that host the event in progress.
b) Event duration shall not exceed a cumulative total of three hours.
c) The aggregate sound level from live (acoustic) or amplified music shall
not exceed a total of 103 A-weighted decibel (dBA) at a distance of 10
feet. If speakers are positioned to distribute the amplified sound, they
must be positioned in such a manner that The Event Barn Wall provides
linear occlusion between the speaker and the nearest existing residential
receptors south of Espola Road.
d) If any proposed event parameters above are not listed or may exceed the
indicated constraints, then a qualified acoustician shall prepare or review a
predictive sound propagation analysis prior to the proposed event in order
to identify need for recommended noise control or sound abatement
implantation measures that could include (but not be limited to):
i. Via the pre-installed house audio-visual (A/V) system or on A/V
hardware supplied by the hosted event performers, set electronic
controls on amplified sound levels to comply with recommended
front-of-stage and/or property line expectations.
ii. Install temporary noise walls, curtains, or other barrier forms so as to
improve containment and absorption of sound within The Event Barn
Lawn venue space and minimize spill-over noise to the property line
and community beyond.
iii. Install on-site sound level measurement systems (e.g., akin to
NTiAudio or comparable supplier technology) to monitor event sound
levels in real-time and provide alerts to event hosts and
administrators. Collected data and alerts offer opportunity to provide
feedback to event performers as part of implementing administrative
control of sound emission levels.
Significant
Impact
1 – Executive Summary
The Farm in Poway EIR 11872
June 2020 1-27
Table 1-1. Summary of Significant Effects
Impact
No. Impact Mitigation
Conclusion
and
Mitigation
Effectiveness
Collected data from 1.d.iii can also provide documentation that an event
was fully compliant with required sound limits at the property line(s), and
might be used to support assertions that future events having identical
conditions (e.g., an annual seasonal festival) would also be compliant
and thus waive the need for additional monitoring (at the discretion or
approval of the City of Poway).
2) Evening (7 p.m. to 10 p.m.)
a) Attendance shall not exceed 300, including residents, guests, visitors,
and any on-site support staff that host the event in progress.
b) Event duration shall not exceed a cumulative total of three hours.
c) The aggregate sound level from live (acoustic) or amplified music shall
not exceed a total of 98 dBA at a distance of 10 feet. If speakers are
positioned to distribute the amplified sound, they must be positioned in
such a manner that The Event Barn Wall provides linear occlusion
between the speaker and the nearest existing residential receptors south
of Espola Road.
d) If any proposed event parameters above are not listed or may exceed the
indicated constraints, then a qualified acoustician shall prepare or review a
predictive sound propagation analysis prior to the proposed event in order to
identify need for recommended noise control or sound abatement
implantation measures that could include (but not be limited to):
i. Via the pre-installed house A/V system or on A/V hardware supplied
by the hosted event performers, set electronic controls on amplified
sound levels to comply with recommended front-of-stage and/or
property line expectations.
ii. Install temporary noise walls, curtains, or other barrier forms so as to
improve containment and absorption of sound within The Event Barn
Lawn venue space and minimize spill-over noise to the property line
and community beyond.
iii. Install on-site sound level measurement systems (e.g., akin to NTiAudio
or comparable supplier technology) to monitor event sound levels in real-
time and provide alerts to event hosts and administrators.
1 – Executive Summary
The Farm in Poway EIR 11872
June 2020 1-28
Table 1-1. Summary of Significant Effects
Impact
No. Impact Mitigation
Conclusion
and
Mitigation
Effectiveness
Collected data from 2.d.iii can also provide documentation that an event was
fully compliant with required sound limits at the property line(s), and might be
used to support assertions that future events having identical conditions (e.g.,
an annual seasonal festival) would also be compliant and thus waive the
need for additional monitoring (at the discretion or approval of the City of
Poway).
3) Conduct of a “special event” (i.e., that is not considered a “regular event”) at
The Event Barn (and The Social), as defined by 3.2.3.B of The Farm in Poway
Specific Plan Additional Open Space Standards, shall require a City-approved
Temporary Use Permit. At the City’s discretion, the Temporary Use Permit
application may require the approval of a predictive sound propagation
analysis prepared by a qualified acoustician to identify recommended noise
control and sound abatement implementation measures that—as
implemented properly by the permit applicant—would be expected to result in
event-attributed noise levels that are compliant with the Farm in Poway
Specific Plan Additional Open Space Standards as follows:
a) No greater than 60 dBA CNEL at the property lines of existing residential
receptors adjoining the project site; and,
b) No greater than 70 dBA CNEL at the property lines of on-site residential
receptors within the project site.
NOI-5 Regarding The Meadow
(Amphitheater), under the
right conditions the
occurrence and duration of
regular events could risk
exceeding the required off-
site residential land use
threshold of 60 dBA CNEL
as identified by the Specific
Plan. The on-site noise limit
of 70 dBA CNEL may also
be exceeded under the
MM-NOI-4 Operation of any “regular event” at The Meadow (Amphitheater), as defined by
3.2.3.B of The Farm in Poway Specific Plan Additional Open Space Standards,
shall conform to the following acoustical conditions:
1) Daytime (within 8 a.m. to 7 p.m.)
a) Attendance shall not exceed 300, including residents, guests, visitors,
and any on-site support staff that host the event in progress.
b) Event duration shall not exceed a cumulative total of three hours.
c) The aggregate sound level from live (acoustic) or amplified music shall
not exceed a total of 97 A-weighted decibel (dBA) at a distance of 10
feet. If speakers are positioned to distribute the amplified sound, they
must be positioned in such a manner that The Event Barn Wall provides
Less-than-
Significant
Impact
1 – Executive Summary
The Farm in Poway EIR 11872
June 2020 1-29
Table 1-1. Summary of Significant Effects
Impact
No. Impact Mitigation
Conclusion
and
Mitigation
Effectiveness
right conditions. At the
same venue, the
occurrence, type, intensity,
and duration of special
events (especially those
during nighttime hours)
would also risk exceeding
the same standards.
linear occlusion between the speaker and the nearest existing residential
receptors south of Espola Road.
d) If any proposed event parameters above are not listed or may exceed the
indicated constraints, then a qualified acoustician shall prepare or review a
predictive sound propagation analysis prior to the proposed event in order to
identify need for recommended noise control or sound abatement
implantation measures that could include (but not be limited to):
i. Via the pre-installed house audio-visual (A/V) system or on A/V
hardware supplied by the hosted event performers, set electronic
controls on amplified sound levels to comply with recommended
front-of-stage and/or property line expectations.
ii. Install temporary noise walls, curtains, or other barrier forms so as to
improve containment and absorption of sound within The Event Barn
Lawn venue space and minimize spill-over noise to the property line
and community beyond.
iii. Install on-site sound level measurement systems (e.g., akin to NTiAudio
or comparable supplier technology) to monitor event sound levels in real-
time and provide alerts to event hosts and administrators. Collected data
and alerts offer opportunity to provide feedback to event performers as
part of implementing administrative control of sound emission levels.
Collected data from 1.d.iii can also provide documentation that an event was
fully compliant with required sound limits at the property line(s), and might be
used to support assertions that future events having identical conditions (e.g.,
an annual seasonal festival) would also be compliant and thus waive the need
for additional monitoring (at the discretion or approval of the City of Poway).
2) Evening (7 p.m. to 10 p.m.)
a) Attendance shall not exceed 300, including residents, guests, visitors,
and any on-site support staff that host the event in progress.
b) Event duration shall not exceed a cumulative total of three hours.
c) The aggregate sound level from live (acoustic) or amplified music shall not
exceed a total of 92 dBA at a distance of 10 feet. If speakers are positioned
to distribute the amplified sound, they must be positioned in such a manner
1 – Executive Summary
The Farm in Poway EIR 11872
June 2020 1-30
Table 1-1. Summary of Significant Effects
Impact
No. Impact Mitigation
Conclusion
and
Mitigation
Effectiveness
that The Event Barn Wall provides linear occlusion between the speaker and
the nearest existing residential receptors south of Espola Road.
d) If any proposed event parameters above are not listed or may exceed the
indicated constraints, then a qualified acoustician shall prepare or review a
predictive sound propagation analysis prior to the proposed event in order
to identify need for recommended noise control or sound abatement
implantation measures that could include (but not be limited to):
i. Via the pre-installed house A/V system or on A/V hardware supplied
by the hosted event performers, set electronic controls on amplified
sound levels to comply with recommended front-of-stage and/or
property line expectations.
ii. Install temporary noise walls, curtains, or other barrier forms so as to
improve containment and absorption of sound within The Event Barn
Lawn venue space and minimize spill-over noise to the property line
and community beyond.
iii. Install on-site sound level measurement systems (e.g., akin to NTiAudio
or comparable supplier technology) to monitor event sound levels in real-
time and provide alerts to event hosts and administrators.
Collected data from 2.d.iii can also provide documentation that an event was
fully compliant with required sound limits at the property line(s), and might be
used to support assertions that future events having identical conditions (e.g.,
an annual seasonal festival) would also be compliant and thus waive the need
for additional monitoring (at the discretion or approval of the City of Poway).
3) Conduct of a “special event” (i.e., that is not considered a “regular event”)
at The Meadow, as defined by 3.2.3.B of The Farm in Poway Specific Plan
Additional Open Space Standards, shall require a City-approved Temporary
Use Permit. At the City’s discretion, the Temporary Use Permit application
may require the approval of a predictive sound propagation analysis
prepared by a qualified acoustician to identify recommended noise control
and sound abatement implementation measures that—as implemented
properly by the permit applicant—would be expected to result in event-
attributed noise levels that are compliant with The Farm in Poway Specific
1 – Executive Summary
The Farm in Poway EIR 11872
June 2020 1-31
Table 1-1. Summary of Significant Effects
Impact
No. Impact Mitigation
Conclusion
and
Mitigation
Effectiveness
Plan Additional Open Space Standards as follows:
a) No greater than 60 dBA CNEL at the property lines of existing residential
receptors adjoining the project site; and,
b) No greater than 70 dBA CNEL at the property lines of on-site residential
receptors within the project site.
Transportation
TRA-1 The proposed project would
exacerbate level of service
(LOS) F during the AM/PM
peak hours at Intersection
17, Pomerado Road/Stone
Canyon Road.
MM-TRA-1 Intersection 17. Pomerado Road/Stone Canyon Road – Prior to Certificate of
Occupancy, the proposed project shall modify the traffic signal to provide
east/west split phasing.
Less-than-
Significant
Impact
TRA-CU-1 The proposed project would
exacerbate LOS F during the
AM/PM peak hours at
Intersection 17, Pomerado
Road/Stone Canyon Road.
See MM-TRA-1. Less-than-
Significant
Impact
Table 1-2. Environmentally Superior Alternative
Issue Areas with Potentially Significant Impacts
Proposed
Project
Alternatives Considered
1 2 3
No Project/No
Development
Reduced Density
Alternative
Reduced Development
Footprint Alternative
Air Quality LTS ▼ ▼ ▼
Biological Resources LTS ▼ ▬ ▼
Cultural and Tribal Cultural Resources LTS ▼ ▬ ▬
Geology and Soils LTS ▼ ▬ ▬
Greenhouse Gas Emissions LTS ▼ ▬ ▬
1 – Executive Summary
The Farm in Poway EIR 11872
June 2020 1-32
Table 1-2. Environmentally Superior Alternative
Issue Areas with Potentially Significant Impacts
Proposed
Project
Alternatives Considered
1 2 3
No Project/No
Development
Reduced Density
Alternative
Reduced Development
Footprint Alternative
Hazards and Hazardous Materials LTS ▼ ▬ ▼
Noise LTS ▼ ▼ ▼
Transportation and Traffic LTS ▼ ▼ ▼
Notes: LTS = Less than Significant with mitigation measures.
▲ Alternative is likely to result in greater impacts to issue when compared to Project.
▬ Alternative is likely to result in similar impacts to issue when compared to Project.
▼ Alternative is likely to result in reduced impacts to issue when compared to Project.
Site Plan
The Farm in Poway
FIGURE 1-1SOURCE: The Farm in Poway, LLC, 2020Z:\Projects\j1187201\MAPDOC\IS
1 – Executive Summary
The Farm in Poway EIR 11872
June 2020 1-34
INTENTIONALLY LEFT BLANK
AntelopeStattion
as
nt er
ver la nd
Pass Rd
r
ay
d
Dorse
Wh i
k Station Rd
Po rd
Whitew d C ny on
Sole
e De Lo b o Dr
t Dr
Edi na Way
o u r a D rldWineryRd
S a g e w
Espo la R d
Valle
Verde Park
Poway Fire
Department Station 2
Painted Rock
Elementary School
Maderas
Golf Course
Chaparral
Elementary School
Blue Sky
Ecological Reserve
Project Site Vicinity and Aerial Map
The Farm in Poway
SOURCE: SANGIS 2017, 2019
0 1,000500Feet
Project Specific Plan
FIGURE 1-2
1 – Executive Summary
The Farm in Poway EIR 11872
June 2020 1-36
INTENTIONALLY LEFT BLANK
The Farm in Poway EIR 11872
June 2020 2-1
2 Introduction
This draft Environmental Impact Report (EIR) for The Farm in Poway project and associated discretionary actions
described in Chapter 3, Project Description, (collectively referred to throughout this EIR as the “proposed project”)
has been prepared for the City of Poway (City) in accordance with the California Environmental Quality Act (CEQA)
Statute (California Public Resources Code, Section 21000 et seq.) and CEQA Guidelines (14 CCR 15000 et seq.),
as well as CEQA’s Significance Determination Thresholds (Appendix G of the CEQA Guidelines).
The proposed project includes recommendations to help maintain the City’s “City in the Country” motto and
lifestyle, through the adoption of The Farm in Poway Specific Plan (Specific Plan) for the proposed project (The
Farm in Poway LLC 2020), the purpose of which is to develop a link between implementing policies of the Poway
Comprehensive Plan: General Plan (General Plan) (City of Poway 1991) and the individual development proposals
in a defined area. As required by Government Code Section 65450 et seq., the Specific Plan contains land uses
and development regulations that plans to serve regional housing needs through infrastructure requirements,
including single-family housing; maintain the City’s extensive open space areas, proximity to jobs and services,
and school district rating, through implementation measures for the development of a specific geographic area—
in this instance, that area is referred to as the project site or Specific Plan area.
The proposed project seeks to implement the recommendations of the proposed Specific Plan. These provisions
require that a specific plan be consistent with the adopted general plan. The City has responded to this mandate
by adopting Specific Plan policies and objectives for the proposed project. The City will consider the Specific Plan
policies and objectives when evaluating the alternatives presented in this EIR. Please refer to Chapter 3 for
further details regarding the components of the proposed project.
2.1 Purpose and Intended Uses
2.1.1 EIR Purpose
This EIR seeks to do the following:
Inform governmental decision makers and the general public of the potentially significant environmental
effects of the proposed project.
Identify the ways that environmental damage can be avoided or significantly reduced.
Reduce environmental impacts by identifying changes in the proposed project through the use of
alternatives or mitigation measures.
Streamline environmental review for subsequent projects consistent with the project.
2.1.2 Intended Use of the EIR
The EIR is an informational document that will provide decision makers, responsible or trustee agencies (as
defined under CEQA), other interested public agencies or jurisdictions, and members of the public with
information about (1) the potential for significant adverse environmental impacts that would result from the
development of the proposed project, (2) possible ways to minimize any significant environmental impacts, and
(3) feasible alternatives to the proposed project (PRC Section 21002.1[a]; 14 CCR Section 15121[a]).
Responsible Agencies will use this EIR to fulfill their legal authority to issue permits for the proposed project.
2 – Introduction
The Farm in Poway EIR 11872
June 2020 2-2
The City is the Lead Agency for the EIR and will perform the entitlement processing of the proposed project. When
deciding whether to approve the proposed project, the City will use the information in this EIR to consider
potential impacts to the physical environment associated with the proposed project. Subsequent to the
certification of the Final EIR, agencies with permitting authority over all or portions of the proposed project will use
the Final EIR as the basis for their evaluation of the environmental effects related to the proposed project that will
culminate with the approval or denial of applicable permits.
This EIR evaluates the potential environmental impacts of the proposed project. This EIR evaluates all elements
of the proposed project, including the construction (short-term) and operational (long-term) impacts associated
with its development. General Development Plans will be developed over time and will provide precise
engineering and construction plans for the housing and recreational elements included in the proposed project.
These plans are currently not available; however, their environmental impacts can be estimated and a
mitigation strategy developed that would apply to future improvements. When the General Development Plans
are available for all or portions of the proposed project area, the City will evaluate these detailed plans against
this EIR, and determine if the mitigation is adequate or if additional mitigation is warranted. Pursuant to CEQA
Guidelines Section 15162 and 15168(c)(2), when examining future development actions within the proposed
project area, if the City finds no new effects could occur or no new mitigation measures would be required
other than those analyzed and/or required in this EIR, the City can approve the activity as covered under this
EIR without additional environmental documentation. If additional analysis is required, it can be streamlined by
tiering from this EIR pursuant to CEQA Guidelines Sections 15152, 15153, and 15168 (e.g., through
preparation of a Mitigated Negative Declaration, Addendum, or Supplemental or Subsequent EIR).
2.2 EIR Legal Authority
2.2.1 Lead Agency
The City is the Lead Agency, defined in CEQA Guidelines Sections 15050 and 15367 as the “public agency which has
the principal responsibility for carrying out or approving a project.” This EIR is intended to analyze the environmental
impacts associated with the discretionary actions that require ultimate approval by the Poway City Council and further
by the voters of the City of Poway through a general or special election.
2.2.2 Responsible and Trustee Agencies
Responsible agencies have discretionary approval over one or more actions involved with development of the
proposed project, and responsible and trustee agencies are state agencies with discretionary approval or
jurisdiction by law over natural resources, which may be impacted. Table 3-1, Proposed Discretionary Approvals
and Permits, in Chapter 3 lists all approvals (e.g., permits, financing approvals, or participation agreements) that
are expected to be required from the City and other public agencies. Trustee agencies are defined in Section
15386 of the CEQA Guidelines as agencies that have jurisdiction by law over natural resources affected by a
project that are held in trust for the people of the State of California, including the California State Lands
Commission; University of California, San Diego; California Department of Fish and Wildlife; and California
Department of Parks and Recreation.
2 – Introduction
The Farm in Poway EIR 11872
June 2020 2-3
2.3 EIR Type, Scope and Content, and Format
2.3.1 Type of EIR
This EIR has been prepared as a project EIR, as defined in Section 15161 of the CEQA Guidelines. In accordance
with CEQA, this EIR examines the environmental impacts of the proposed project, which is composed of a series
of actions. The combined actions can be characterized as one large project for the purpose of this study and are
herein referred to as the “proposed project.” The EIR focuses primarily on the physical changes in the
environment that would result from the adoption and implementation of the proposed project, and other related
actions described more fully in Chapter 3, including anticipated impacts that could result during future
construction and operation.
2.3.2 EIR Scope and Content
The scope of analysis for this EIR was determined by the City as a result of initial project review and consideration
of comments received in response to the Notice of Preparation circulated June 10, 2019, and a scoping meeting
held on Thursday, May 23, 2019, at the City of Poway City Council Chambers located at 13325 Civic Center Drive,
Poway. The Notice of Preparation and public comments received are included as Appendix A of this EIR. Through
these scoping activities, the proposed project was determined to have the potential to result in significant
environmental impacts to the following subject areas:
Aesthetics
Air Quality
Biological Resources
Cultural and Tribal Cultural Resources
Energy
Geology and Soils
Greenhouse Gas Emissions
Hazards and Hazardous Materials
Hydrology and Water Quality
Land Use and Planning
Noise
Population and Housing
Public Services
Recreation
Transportation
Utilities and Services Systems
Wildfire
The intent of this EIR is to determine whether implementation of the proposed project would have a significant
effect on the environment through analysis of the issues identified during the scoping process. Each
environmental issue area includes the following: a presentation of the threshold(s) of significance for the
particular issue area under evaluation based on CEQA’s Significance Determination Thresholds; an issue
statement; an assessment of impacts associated with implementation of the proposed project; a summary of the
significance of project impacts; and recommendations for mitigation measures, as appropriate. Pursuant to CEQA
Guidelines Section 15126, all discretionary actions associated with the proposed project are considered in this
EIR when evaluating its potential impacts on the environment, including the construction of future development
and operational phases. Impacts are identified as direct or indirect, short term or long term, and assessed on a
plan-to-ground basis. The plan-to-ground analysis addresses the changes or impacts that would result from
implementation of the proposed project compared to existing ground conditions.
2 – Introduction
The Farm in Poway EIR 11872
June 2020 2-4
2.3.3 EIR Format
Organization
The following is brief overview of the various chapters of this EIR:
Chapter 1, Executive Summary. This chapter provides a summary of the EIR; a brief description of the
proposed project; an identification of areas of controversy; and a summary table identifying significant
impacts, proposed mitigation measures, and the significance of impact after mitigation. A summary of the
proposed project alternatives and a comparison of the potential impacts of the alternatives with those of
the proposed project are also provided.
Chapter 2, Introduction. This chapter contains an overview of the legal authority, purpose, and intended
uses of the EIR, as well as its scope and content. It also provides a discussion of the CEQA environmental
review process, including public involvement.
Chapter 3, Project Description. Provides a detailed discussion of the proposed project, including
background, objectives, and key features.
Chapter 4, Environmental Analysis. This chapter provides a detailed evaluation of the potential
environmental impacts associated with the proposed project for environmental and land use issues.
The analysis of each issue begins with a discussion of the existing conditions, regulatory framework,
and a statement of the specific thresholds used to determine the significance of impacts, followed by
an evaluation of potential impacts and identification of specific mitigation measures to avoid or
reduce significant impacts (if any). A statement regarding the significance of the impact after
mitigation is also provided.
Chapter 5, Other CEQA Considerations. This chapter evaluates the potential influence the proposed
project may have on economic or population growth within the project vicinity and the region, either
directly or indirectly. It identifies all of the issues determined in the scoping and preliminary
environmental review process to not be significant, and briefly summarizes the basis for these
determinations. It also identifies impacts that are significant and unavoidable, or irreversible, as well as
describes mandatory findings of significance.
Chapter 6, Alternatives. This chapter provides a description of the alternatives to the proposed project,
including the No Project/No Build Alternative.
Chapter 7, References Cited. This chapter lists all of the references cited in the EIR.
Chapter 8, Individuals Consulted/Preparers. This chapter provides identifies all of the agencies,
organizations, and individuals responsible for the preparation of the EIR.
Technical Appendices
Technical reports, used as a basis for much of the environmental analysis in the EIR, have been summarized in
the EIR, and are included as appendices to this EIR. The technical reports prepared for the proposed project and
their location in the EIR are listed in the table of contents.
2 – Introduction
The Farm in Poway EIR 11872
June 2020 2-5
Incorporation by Reference
As permitted by CEQA Guidelines Section 15150, this EIR references several technical studies and reports. Information
from these documents is briefly summarized in this EIR, and their relationship to this EIR is described in the respective
chapters. All reference materials are included in Chapter 7, and are hereby incorporated by reference.
2.4 EIR Process
The City, as Lead Agency, is responsible for the preparation and review of this EIR. The EIR review process occurs
in two basic stages. The first stage is the Draft EIR, which offers the public the opportunity to comment on the
document, and the second stage is the Final EIR.
2.4.1 Draft EIR
In accordance with CEQA Guidelines Section 15105, the Draft EIR is distributed for review to the public and
interested and affected agencies for a review period of 45 days. The purpose of the review period is to allow the
public an opportunity to provide comments “on the sufficiency of the document in identifying and analyzing the
possible impacts on the environment and ways in which the significant effects of the project might be avoided
and mitigated” (14 CCR 15204). In accordance with CEQA Guidelines Sections 15085 and 15087 (a) (1), upon
completion of the Draft EIR, a Notice of Completion will be filed with the State Office of Planning and Research
and a Notice of Availability of the Draft EIR will be issued in a newspaper of general circulation in the area.
2.4.2 Final EIR
Comments addressing the scope and adequacy of the environmental analysis will be were solicited during the
Draft EIR public review. Following the end of the public review period, the City, as the Lead Agency, will provide
has provided written responses to comments received on the Draft EIR per CEQA Guidelines Section 15088. All
comments and responses will be were considered in the review of the EIR. Further, as a result of tribal
consultation conducted during public review of the Draft EIR, there were minor changes, clarifications, and
reorganization of mitigation measures in Section 4.4.6, Cultural and Tribal Resources, Mitigation Measures. The
changes do not raise important new issues about significant effects on the environment. Such changes are
insignificant as the term is used in Section 15088.5(b) of the California Environmental Quality Act (CEQA)
Guidelines. Refer to Section 4.4.6 for further details.
Detailed responses to the comments received during public review, a Mitigation Monitoring and Reporting
Program, and Findings of Fact, and a Statement of Overriding Considerations for impacts identified in the Draft
EIR as significant and unmitigable will be were prepared and compiled as part of the EIR finalization process. This
document constitutes the Final EIR will that will be available for public review at least 14 days before the City
Council hearing in order to provide commenters the opportunity to review the written responses to their comment
letters. The culmination of this process is a public hearing where the City Council will determine whether to certify
the Final EIR and adopt the Mitigation Monitoring and Reporting Program, and Findings of Fact, and Statement of
Overriding Considerations as being complete and in accordance with CEQA.
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The Farm in Poway EIR 11872
June 2020 3-1
3 Project Description
This chapter describes The Farm in Poway project (proposed project). As required by Section 15124 of the
California Environmental Quality Act (CEQA) Guidelines, this chapter contains the precise location and
boundaries of the proposed project; a statement of objectives sought by the proposed project; a general
description of the proposed project’s technical, economic, and environmental characteristics and its
environmental setting; and a statement briefly describing the intended uses of the Environmental Impact
Report (EIR). Consistent with Section 15124 of the CEQA Guidelines, this chapter also includes, to the extent
known, a list of the agencies expected to use the EIR in their decision making, and a list of permits and other
approvals required to implement the proposed project.
3.1 Project Objectives
Section 15124(b) of the CEQA Guidelines requires an EIR to include a statement of objectives sought by a
project. The objectives assist the City of Poway (City), as lead agency, in developing a reasonable range of
alternatives to the proposed project to be evaluated in the EIR. The project objectives also assist the decision
makers in preparing findings or, if necessary, a statement of overriding considerations. The statement of
objectives should also include the underlying purpose of a project.
The proposed project includes the adoption of a new specific plan—the Farm in Poway Specific Plan (Specific
Plan) (The Farm in Poway LLC 2020)—the purpose of which is to establish a link between implementing policies
of the general plan and the individual development proposals in a defined area. As required by Government Code
Section 65450 et seq., the Specific Plan contains land uses and development regulations, infrastructure
requirements, and implementation measures for the development of a specific geographic area; in this instance,
it is referred to as the project site or Specific Plan area. These provisions require that a specific plan be consistent
with the adopted general plan. The City has responded to this mandate by adopting Specific Plan policies and
objectives for the proposed project. The City will consider the Specific Plan policies and objectives when
evaluating the alternatives presented in this EIR.
The underlying purpose of the proposed project is to revitalize the decommissioned StoneRidge Country Club and
associated 18-hole golf course through the development of a new community with unique homes and interrelated
open space, recreation, and commercial amenities on approximately 117.2 acres in the City of Poway. Project
implementation would be guided by the following statement of project objectives (The Farm in Poway LLC 2020):
1. Preserve over 47 percent of the Specific Plan area as permanent open space by allowing for the
development of an environmentally-friendly conservation community, which can provide a mechanism
for financing the long-term maintenance and management of open space as a community amenity.
2. Assist the City in implementing the General Plan’s housing goals by providing opportunities for high
quality new housing to meet the needs of current and future Poway residents.
3. Provide for 160 homes with a range of housing types that are compatible with the adjacent established
residential community.
4. Replace dead and dying vegetation associated with the vacant and blighted golf course with new
agricultural uses and naturalized landscaping, thereby restoring the visual character of the neighborhood.
5. Restore the recreational opportunities previously provided by the golf course with a wide range of recreational,
educational, and social uses that meet the demands and lifestyles of new and existing residents.
3 – Project Description
The Farm in Poway EIR 11872
June 2020 3-2
6. Ensure new uses are compatible with new and existing homes by establishing setbacks, design
regulations and guidelines, best practices, and performance standards that protect the privacy and
quality of life for neighboring properties.
7. Create an internal network of roadways that minimize vehicle traffic impacts to existing neighborhoods
and discourage cut-through vehicle traffic.
8. Design narrow, curvilinear, and landscaped roadways that promote low speeds and support safety and
comfort for multiple modes of transportation including vehicles, alternative vehicles, pedestrians,
bicyclists and equestrians.
9. Establish a multi-use trail system for pedestrians, bicyclists, and equestrians with connections to major
amenities and adjacent neighborhoods.
10. Minimize the environmental impact of new development through best management and low impact
development practices, water and energy conservation measures, and green construction.
3.2 Project Description
3.2.1 Project Components
The proposed project is approximately 117.2 acres and includes a total of 160 single-family homes and a mix of
open space and recreational uses (see Figure 1-1, Site Plan). Accessory dwelling units are permissible on
detached single-family residences as required by state law. Residential land uses would compose approximately
33.85 acres and would range in density from 2.5 to 10.7 dwelling units per acre with an overall density of 1.4
dwelling units per acre. Open space and recreational uses would compose approximately 70.37 acres and would
be comprised of Open Space – Conservation (OS-C) and Open Space – Recreational (OS-R). Approximately 12.96
acres would be private streets. The proposed project is located in the northern portion of the City, approximately
two miles east of Interstate 15 (I-15) and bordering Espola Road to the south.
The new land uses proposed by the Specific Plan include two open space uses, which would both be permanently
preserved as open space through deed restriction. A specific plan amendment to revise the open space designation
can only be conducted through a simple majority approval by the voters of the City at a special or general election
(subject to Proposition FF voting requirements for open space)—as designated in the Specific Plan—and is required for
future increases in density and intensity as incorporated into the Poway Municipal Code by ordinance. Five residential
land uses are also proposed. The proposed land uses are described below (The Farm in Poway LLC 2020):
Open Space – Conservation (OS-C) is designed to serve as a physical and visual buffer between existing
residential uses and new residential development, maintaining neighbors’ privacy and providing the
visual backdrop for the new community. Parcels designated as OS-C shall be deed-restricted to ensure
that they are preserved as open space in perpetuity. Parcels designated as OS-C may be planted with
landscape, agriculture or naturalized drought-tolerant landscaping and may include trails, gardens, water
quality basins, and tot lots. Thematic structures and buildings as well as accessory buildings such as
sheds, greenhouses, and similar that are ancillary to agricultural and garden uses would also be
permitted with a maximum building coverage of 15 percent. Trails, tot lots, exercise stations, specialty
gardens, and events and retail sales associated with agricultural uses are permissible.
Open Space – Recreation (OS-R) is intended to replace the recreational amenities once provided by the
golf course to support new and existing residential uses within and around the project site. Up to 30,000
gross square feet of non-residential buildings would be permitted. Uses may consist of educational, social
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and recreational uses such as event barns, social clubs, fitness clubs, restaurants including brewpubs
and winebars, boutique retailers, bed and breakfast or boutique hotel, classrooms, a butterfly vivarium,
educational greenhouses, and similar facilities. Outdoor dining, a small grass amphitheater for outdoor
performances, athletic fields/courts, swimming pools, parks, a dog park, trails, events, and other outdoor
land uses are also permissible. The mix of uses (including all residential and non-residential uses) within
the Specific Plan area shall not exceed 2,524 New Net Average Daily Trips using rates in SANDAG’s (Not
So) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region, April 2002.
Residential – Twin (R-T): Allows for the development of up to 22 twin homes. Each unit would be situated
on its own lot and units are connected along a common interior property line.
Residential – Cottage (R-C): Allows for the development of up to 90 detached single-family homes.
Residential cottage homes would consist of 2–4 single-family homes arranged around a common motor
court space. Individual driveways and garages would take access from the motor court. Accessory
dwelling units are permissible as required by state law.
Residential – Garden (R-G): Allows for the development of up to 13 detached single-family homes.
Residential garden homes are single-family homes that take direct access from a private street. The
minimum lot width for garden homes is 70 feet. Accessory dwelling units are permissible as required by
state law.
Residential – Homestead (R-H): Allows for the development of up to 20 detached single-family homes.
Residential homestead lots would consist of single-family homes that take direct access from a private
street or existing public street, and are located in the Very High Fire Hazard Severity Zone. Accessory
dwelling units are permissible as required by state law.
Residential – Meadow (R-M): Allows for the development of up to 15 detached single-family homes.
Residential meadow homes would be large single-family homes that take direct access from a private
street. Accessory dwelling units are permissible as required by state law.
Open Space Land Use Districts
The approximately 70.37 acres of open space would consist of 55.72 acres of OS-C and 14.65 acres of OS-R.
Agricultural amenities permitted on OS-C land would include agriculture and horticulture, barns, greenhouses, and
similar accessory structures ancillary to agriculture, beekeeping, specialty community gardens, farm stands,
outdoor farmers markets, and incidental sales of plants or produce generated within the project site. Some
recreational amenities would also be permitted within OS-C land, including picnic pavilions, playgrounds and tot-
lots; trails for walking and biking; and trail amenities such as benches, signage, and kiosks. Events such as
community harvesting and planting, pick-your-own, educational tours, and similar are also permitted.
However, recreational amenities would primarily be located within OS-R land. In addition to the above listed
recreational amenities permitted within OS-C land, OS-R land would also permit athletic fields/recreational courts,
dog parks, open play fields and parks, a small outdoor amphitheater, and recreational clubs including but not
limited to swim, tennis, and fitness. As shown on Figure 3-1, Land Use Plan, these recreational amenities would
be divided into The Club, The Meadow, and The Farm.
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The Club
The Club would be located towards the middle of the project site, north of the R-C residential district (see Figure 3-
1). The Club would include a fitness center operated by a recreational management firm that would be available
to residents of the proposed project and members of the surrounding communities on a membership basis. In
addition to the fitness center, recreational amenities at The Club are anticipated to include amenities such as
tennis courts, pickle ball courts, swimming pools, various community rooms and related land uses. Parking
facilities would also be included for visitors of The Club. Parking facilities and the majority of the tennis courts
would be screened from adjacent residences by a sound wall that may be further screened with trees, shrubs,
and vines. The community trail, as described below, would be directly accessible from The Club.
The Meadow and Dog Park
The Meadow and Dog Park would be located directly adjacent to the east of The Club. The Meadow would include
a small grass amphitheater or outdoor performance space, large passive turf areas, picnicking facilities, and large
shade trees. The outdoor performance space may also be available for use by local community groups for
concerts in the park or similar events. Events would be open to the public, but coordinated by the Community
Association. The dog park would be open to the public, and would include an enclosed space for off-leash dog
play, benches, and a drinking fountain with dog bowl.
The Farm (The Event Barn and Education Center)
The Farm, referred to herein as The Event Barn and/or Education Center, would be located at the southernmost
portion of the project site, adjacent to Espola Road and at the proposed entrance of the project site at the
intersection of Espola Road and Martincoit Road (see Figure 3-1). The Education Center would include a vivarium, a
greenhouse, office/maintenance space, a classroom, a garden, and a picnic area. The Barn would include a multi-
purpose event venue, a café, and a wine and beer garden. Regulations regarding the type of events and hours of
operation are provided in the Specific Plan (see Section 3.2.3[b]) (The Farm in Poway LLC 2020). In summary,
regular events would include weddings, parties, theatrical performances, farmers markets, art exhibits, craft fairs,
food festivals, charitable donation events and similar events (The Farm in Poway LLC 2020). Special events would
also be permitted and would include outdoor weddings, parties, theatrical performances, concerts, art exhibits, craft
fairs, and food festivals; refer to the Specific Plan for further details (The Farm in Poway LLC 2020).
The Working Farm (Agrifields)
The Working Farm would be composed of agrifields located at the northernmost portion of the project site, along
the northwestern and northern project boundaries (see Figure 1-1). The Working Farm may include an iconic barn
for a farm operations office and equipment and material storage. Agricultural areas would be managed and
leased to one or more professional farmers or farming entities who will operate agricultural uses on behalf of the
property owner and shall be subject to Community Association Covenants, Conditions, and Restrictions.
Agriculture, horticulture, and garden uses would include the cultivation and harvesting of ornamental plants and
flowers, herbs and medicinal plants, with the exception of Cannabis, of which the cultivation, delivery, and sale
would be prohibited. Plants would be grown on the ground, in planting beds, in vertical structures, inside
greenhouses, in aquaponics ponds, or in other configurations. The Working Farm would be screened from
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residences by a minimum 10-foot-wide landscape buffer and structures, storage areas, and staging areas of the
Working Farm would be at least 50 feet from adjacent residential property. Farm operations hours would be
limited, and equipment would meet noise guidelines as regulated by the City.
On-site commercial processing and packaging of any agricultural product would not be permitted; however, farm
stands, outdoor farmers markets, and incidental sales of plants or produce generated from within the project site
would be a permitted use in both the OS-C and OS-R land use designations. Integrated Pest Management will be
the preferred method for pest control; however, limited use of pesticides may be permitted based upon the type
of chemical, method of application, and its compatibility with adjacent residential uses in accordance with permits
issued by, or regulations enforced by the County of San Diego (County) Department of Agriculture.
Community Gardens
Community gardens would be located throughout the project site, providing future residents a garden plot within
walking distance of their home. The community gardens would include planting beds and water and support
facilities to grow fruits and vegetables. Residents would sign up to use gardening plots and would be responsible
for the maintenance and harvesting of their plots; the Community Association will contract with a professional
community garden manager to maintain garden common areas and vacant plots to ensure they remain visually
attractive and free of pests and debris. Small tool sheds would store the tools and materials required to maintain
the community gardens. Gardens would be surrounded by drought-tolerant landscaping comprised of edible
plants, pollinator plants, succulents, and native vegetation.
Trail System
A multi-use trail system, as illustrated in Figure 3-2, Conceptual Trail Network, would circulate throughout the
project site to provide mobility and recreational opportunities for pedestrians, equestrians, and bicyclists. The
majority of the trail system would include decomposed granite or compacted earth trails with some concrete trails
primarily along the southern project boundary. Trails would connect to sidewalks along the proposed on-site
roadways and along existing adjacent residential streets to maximize access and connectivity. Bike racks, a trail
map and rules kiosk, and a bike repair station will be located at the Club. Trails would range from six to 15 feet in
width and all trails would be open to the public.
Residential Land Use Districts
Residential land uses would be divided into five land use districts (R-T, R-C, R-G, R-H, and R-M, as described
above), and would compose approximately 33.85 acres ranging in density from 2.5 to 10.7 dwelling units per
acre. The proposed project would allow for up to 160 single-family homes with a 35-foot maximum height limit. All
residences would include a minimum of two side-by-side garage spaces, in addition to driveway parking space.
Maintenance and operation of the community would be financed through a Master Community Association that
would be responsible for all private streets, private utilities, and common amenities, as well as for the long-term
maintenance and preservation of open space resources on the project site including the trail system. The
Community Association would also be required to contract with qualified professionals for the long-term care and
maintenance of the bioretention basins and fuel modification zones, which are described in more detail below.
The Community Association would also be responsible for enforcement of the Community Association’s
Covenants, Conditions, and Restrictions to ensure compliance with the Specific Plan. Accessory dwelling units are
permissible as required by state law.
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Project Approvals
The proposed project consists of the following entitlements and agency approvals, which would be processed
concurrently unless otherwise noted:
General Plan amendment
Zoning amendment
Specific Plan
Development Plan
Tentative map
Conditional Use Permit
EIR certification
Project Infrastructure
The project site is surrounded by existing development, primarily residential land uses, with existing
infrastructure. Any proposed new infrastructure needed to serve the proposed project would be connected to
existing infrastructure, which consists of vehicular access and circulation, water, sewer, drainage, and dry utilities
such as gas, electricity, and telecommunications. Some water and sewer infrastructure would be extended within
the project site as described below under Project Water System and Project Wastewater System. Additionally,
Martincoit Road would be extended north and improvements to Espola Road would occur as described below
under Project Circulation. Some existing infrastructure may also need to be relocated or replaced.
Project Circulation
The proposed project’s circulation system is designed to interconnect with the existing adjacent public street system
and deter cut-through automobile traffic. Primary vehicular access to the project site would be provided via an
improved signalized intersection at Espola Road and Martincoit Road. Improvements to this existing three-way
signalized intersection would include extension of Martincoit Road to the north, improved traffic signals, and additional
crosswalks (see Figure 3-3, Martincoit Road and Espola Road Intersection Improvements). Secondary access to the
project site would be provided via two stop-sign-controlled intersections: one along Tam O’Shanter, near the middle of
the project site, and one along Boca Raton Lane, near the northeastern boundary of the project site. See Figure 3-4,
Conceptual Street Network, for proposed roadway classifications and project circulation plan.
Twelve of the newly proposed single-family homes would take direct access from Boca Raton Lane and St.
Andrews Drive. Two emergency vehicle access (EVA) points would also be provided (See Figure 3-4). One EVA
would take direct access from Cloudcroft Drive, and the second would take access from Cloudcroft Court, via
Cloudcroft Drive. The Cloudcroft Court EVA point would also provide maintenance access for the San Diego
County Water Authority (SDCWA) right-of-way (ROW). The EVA points would be controlled by bollards to prevent
public access and allow pedestrian access.
Improvements to Espola Road would also occur. Espola Road will continue to provide three to four travel lanes
and a two-way center turn lane. The existing shoulders used for bicycles do not meet Class II standards; therefore,
the roadway would be widened by three feet on the north side to accommodate a Class II bike lane.
Improvements would also be made to the existing San Diego Metropolitan Transit System Route 945A bus stop
located at Espola Road and Martincoit Road. Approaching the intersection to the proposed project’s main entry at
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Martincoit Road, the two-way turn lane would be restriped to transition to a painted left-turn lane in both
directions. A five-foot-wide landscaped parkway strip and a six-foot-wide concrete sidewalk will also be
constructed on the north side of the Espola Road ROW fronting the project site. North of the ROW a meandering
nine-foot-wide concrete community trail will be provided. Additional landscaped areas would be provided between
the sidewalk and community trail and between the community trail and any proposed structures to comply with
the intent of the Poway Comprehensive Plan: General Plan (General Plan), which designates Espola Road as a
scenic roadway requiring a landscaped open space easement of 50 feet from the ultimate ROW (City of Poway
1991). See Figure 3-4 and Figure 3-5, Espola Road Improvements. In addition to sidewalks, circulation would be
provided through the proposed trail system for pedestrians, equestrians, and bicyclists, as previously described.
The proposed project’s internal street network would consist of all private streets. Roadways would be designed
as Complete Streets that accommodate automobiles, bicycles, pedestrians, tractors, low-speed vehicles, and
neighborhood electric vehicles. Internal roadways would consist of private streets and drives with and without
parking. All private streets, except those accessing motor courts, would include a sidewalk along one side
separated from the roadway by a five-foot-wide landscaped parkway. Motor courts would also be provided as a
shared driveway (technically a private street) for two or more of the R-C-designated homes and these common
access roads would provide access from the motor court to on-street parking areas.
Project Parking
The proposed project would provide adequate parking within the project site to minimize impacts to existing
residential streets in the vicinity and all parking would comply with the requirements of the City of Poway
Municipal Code unless otherwise specified within the Specific Plan. Each residential unit would include a
minimum of a two-car garage and two additional uncovered driveway spaces. Some residential units would
include a three-car garage and additional driveway spaces. On-street parking would also be provided throughout
the project site to serve as additional guest parking for residents and overflow parking for on-site recreational
uses. Non-residential off-street parking lots would be provided for non-residential uses within the project site,
including the recreational amenities, assembly spaces, and eating/drinking establishments. Regulations
regarding proposed project parking, including number of parking spaces, parking space dimensions, and
permitted use of parking spaces, are provided in the Specific Plan (The Farm in Poway LLC 2020).
Project Water System
The City’s Public Works Department would provide domestic water to the proposed project. The SDCWA provides
99 percent of the City’s water in the form of untreated water, with the remaining demand met through recycled
water purchased from the City of San Diego. All imported water is treated locally at the City’s water treatment
plant and then distributed via a complex and comprehensive system of pumps and pipes.
A series of regional SDCWA pipelines are located within and adjacent to the project site including the Ramona
pipeline—a 38-inch pipeline located in Espola Road—and two parallel pipelines located in an existing ROW that
runs diagonally through the site. These pipelines would be protected in place and uses have been restricted
within the SDCWA ROW that runs through the project site to ensure the long-term protection of these pipelines.
The proposed water system consists of a series of 12-inch pipes to create a looped system that would serve
all properties within the project site. Portions of the existing pipes would be removed based upon rerouting of
water distribution through the project site such that any existing loops in the system that serve the adjacent
properties are maintained. Lots facing St. Andrews Drive and Boca Raton Lane would connect directly into
existing pipes within these streets. The proposed project conceptual water master plan is illustrated in Figure
3-6, Conceptual Water Master Plan.
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Project Wastewater System
The proposed project would connect to the City’s sewer system. Wastewater collection and the City’s sewage
system are maintained and operated by the City’s Public Works Department to ensure sufficient capacity is
available for dry weather peak-flow conditions and storm or wet weather events. Wastewater collected in the
City’s sewage system is conveyed through the City of San Diego’s Municipal Wastewater System to the City of
Escondido’s Hale Avenue Resource Recovery Facility for treatment and disposal, and the Metro System for
treatment at either the North City Water Reclamation Plant or the Point Loma Wastewater Treatment Plant.
Existing sewer facilities pertinent to the proposed project consist of local gravity sewer lines and the Saint
Andrews Lift Station (Lift Station No. 2) and force main, which is located off site at the northern boundary of the
proposed project. The existing eight-inch gravity sewer lines surrounding and traversing the project site serve the
existing adjacent development. Flows from these existing eight-inch gravity sewer lines are either conveyed north
to the Saint Andrews Lift Station or south to an existing 12-inch line in Martincoit Road that was recently
upgraded by the City as part of a capital improvements project. Flows reaching the lift station are subsequently
pumped south by the force main via a four-inch PVC line, through the project site, and into Tam O’Shanter Drive.
Ultimately all flows are conveyed to the 12-inch line in Martincoit Road (see Appendix G, Priority Development
Project–Stormwater Quality Management Plan).
The proposed project would construct new eight-inch gravity sewer lines to connect the project site to the
existing gravity sewer system, with the exception of four residential lots located in the northeast corner of the
project site, which cannot currently flow by gravity north or south to connect to the existing sewer system.
These lots would be served by one of two options:
1. Installing a gravity flow sewer to the east and connecting to the existing system located in Indian Canyon
Lane, which is associated with Old Coach Estates.
2. Construction of private individual grinder pump systems. Each lot would require a grinder pump force
main to convey flows northerly to the existing gravity sewer system on St. Andrews Drive.
The proposed project’s sewer system is included as Figure 3-7, Conceptual Sewer Master Plan.
Project Drainage System
The project site drains in a general southern direction with the exception of the northern portion of the site, which
drains north. The project site currently has three total concrete brow ditches that convey on-site and off-site flows
to two separate outflow locations, one to the north and one to the south. Northern flows eventually drain into
Sycamore Creek and southern flows eventually drain into the Los Penasquitos (906) watershed.
Figure 3-8, Conceptual Drainage Plan, illustrates the proposed grading and drainage concept for the proposed
project. Grading of the project site respects the existing topography to the extent feasible and adheres to the City
of Poway Municipal Code Grading Standards. Grading for the project site is balanced at 508,900 cubic yards of
cut and fill to avoid export or import of dirt. As shown in Figure 3-8, the project site currently accepts stormwater
drainage from a number of adjoining properties. To maintain these existing drainage patterns and minimize
drainage impacts to existing neighborhoods, a series of public bypass storm drains would be provided to collect
this stormwater at the project site boundary and convey it through the site to the City’s existing storm drain
system downstream.
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The proposed project’s grading plan would drain all stormwater within the project site to swales that convey water
to private streets on site. Once in the street, stormwater is collected by catch basins and a private system of pipes
on site. These pipes then convey water to a series of bioretention basins that would release stormwater into the
City’s existing system via the bypass storm drains described above or via existing ditches, channels, or pipes
located adjacent to the project site.
Project Dry Utilities
Electrical power and natural gas would be provided by San Diego Gas & Electric. No major improvements to the
local distribution networks would be needed to support the growth facilitated by the proposed project. The
applicant will work with dry utility providers to ensure utility systems have adequate capacity to serve future
residential and commercial uses.
New development within the project site would be required to meet the requirements of the California Energy
Code (Title 24) and the California Green Building Standards, which include the most stringent requirements for
energy conservation in the country. To meet these requirements, all new development within the project site
would include rooftop photovoltaic solar panels, energy-efficient lighting and appliances, cool roofs, energy-
efficient windows, and other design features that significantly conserve energy. Telephone, cable TV, and internet
service would be available from a variety of providers.
Off-Site Improvements
Minor off-site improvements would be needed to connect the project site to the existing circulation system,
namely the expansion of the Espola Road and Martincoit intersection. Minor off-site utility improvements may also
consist of making connections to the adjacent existing water, wastewater, drainage, natural gas, electric, and
telecommunication systems. Additionally, off-site utility improvements include a gravity sewer line connection
alternative that starts in Boca Raton Lane, then heads south within the paved 60-foot public ROW, then turns east
within the paved 60-foot public ROW of Indian Canyon Lane, and then turns north within the 42-foot paved private
street (Butterfield Trail) to the public sewer connection.
Off-site roadway improvements include the expansion of Espola Road/Martincoit Road to a signalized four-way
intersection, the provision of a pedestrian crossing on the west leg of the intersection with an enhanced
crosswalk for high visibility, pedestrian signals with countdown timers, leading pedestrian interval timing, ADA
compliant curb ramps, bicycle signal detection, and smart adaptive signals that can adjust signal phasing and
extent pedestrian walk times based upon time of day. These same mobility features are also recommended at the
Valle Verde Road/Espola Road intersection. Similarly, high visibility crosswalk and ADA complaint ramps would be
installed at the intersection of Valle Verde Road/St. Andrews Drive. In addition, the missing connection of the 5-
feet of contiguous sidewalk along the east side of Valle Verde Road, approximately 350 feet north of Edina Way to
Solera Way, would be constructed to provide continuous sidewalk.
Additional off-site roadway improvements would include improvements to the existing San Diego Metropolitan
Transit System bus stop at this intersection; various improvements to Espola Road including the widening of the
right-of-way by three feet on the north side to accommodate a standard Class II bike lane; and the development of
two secondary access points with stop-sign-controlled intersections located along Boca Raton Lane, one near the
middle of the project site and one near the northeast corner of the project site. The proposed project would also
include two EVA points, with one located along Cloudcroft Drive and the other along Cloudcroft Court at the
SDCWA easement.
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Construction and Phasing
The proposed project would be developed in phases (from south to north). Construction is anticipated to begin in
2021 and end in 2024.
3.2.2 General Plan and Zoning Amendments
The existing General Plan Land Use and Zoning Map designates the entire project site as “Open Space –
Recreation (OS-R)” (City of Poway 1991). A General Plan amendment and zoning amendment would be processed
concurrently with the Specific Plan to designate the project site as “Planned Community (PC-9).” The amendment
consists of both a map amendment and a zoning text amendments. Currently, the Planned Community (PC) zone
may only be applied to properties 300 acres or larger. The proposed text amendment would revise this portion of
the text to allow this project site of approximately 117.2 acres to be zoned as PC and would also require
increases in residential density or intensity of land uses to be approved by the voters of the City at a special or
general election. In addition, a new section would be added to the Zoning Ordinance that briefly describes the
Farm in Poway Planned Community. This designation and zoning would be consistent with other specific plan
areas throughout the City.
3.2.3 Specific Plan
Government Code Section 65453(a) authorizes local jurisdictions to adopt specific plans as a tool for the
systematic implementation of the general plan. A specific plan must be consistent with the adopted general plan,
but can provide a unique set of land uses, design regulations, and development standards not permitted under a
city’s existing zoning or by a city’s current standards. By allowing greater flexibility, development patterns can be
specifically tailored to the characteristics of a site, including creative design concepts, density ranges that differ
from a city’s zoning code, specially designed roadways, and a mix of uses unique to the specific plan area.
Specific plans may be adopted, in whole or in part, by either resolution or by ordinance. The Farm in Poway
Specific Plan would be adopted by resolution and ordinance. All development and improvements constructed
within the Specific Plan area would be required to be consistent with the City’s General Plan, the Specific Plan,
and the tentative map(s).
3.2.4 Tentative Map
The proposed project includes a tentative subdivision map. The map depicts the grading and drainage, individual
residential lots, common ownership lots, public streets, private streets, and infrastructure improvements. The map
would be submitted concurrently with the Specific Plan. One or more final subdivision map(s) would be recorded.
3.2.5 Project Design Features (PDFs)
As identified in Section 4.15, Transportation, the proposed project would implement transportation project design
features (PDFs) (PDF-TRA-1 through PDF-TRA-6) in order to improve intersection traffic, pedestrian mobility,
bicycle mobility, and site access.
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Additionally, as described in Section 4.2, Air Quality, the proposed project would implement one air quality PDF
(PDF-AQ-1), which would ensure that active sites be watered at least three times daily, a soil stabilizer be used, and
unpaved road travel be limited to 15 miles per hour, in order to restrict emissions of fugitive dust.
3.3 Project Location
The project site is located in the northern portion of the City and consists of the decommissioned StoneRidge
Country Club and associated 18-hole golf course. The project site is bordered by Espola Road to the south; St.
Andrews Drive to the north and west; and Cloudcroft Drive, Tam O’Shanter Drive, and Boca Raton Lane to the
east. The project site consists of approximately 117.2 acres and currently has an address of 17166 Stoneridge
Country Club Lane, Poway, California 92064. Figure 3-9, Project Location, shows the location of the project site
within the County and the City. Figure 1-2, Project Site Vicinity and Aerial Map, depicts an aerial view of the project
site vicinity.
3.4 Environmental Setting
The general environmental setting for the project area is provided in this section, in conformance with Section
15125 of the CEQA Guidelines. Currently, the project site is a former 18-hole golf course surrounded by existing
residential development. The StoneRidge County Club and golf course are no longer active, and the site is
currently characterized by disturbed, fallow land. Surrounding land uses include residential development in all
directions (Figure 3-10, Surrounding Land Uses). As a result, the site is subject to a number of previous and
ongoing anthropogenic disturbances that include pedestrian use, domestic pet use (i.e., dogs and cats), invasive
species, and regular night lighting and noise. The hydrology and vegetation composition of the site has changed
dramatically since the golf course operations have ceased. A 100-foot defensible space barrier adjacent to
surrounding structures requires weeds to be maintained at six inches or below, but the remaining site
experiences overgrowth of weed and existing plant materials. Trees determined to be dead or hazardous are
required to be removed. More detailed descriptions regarding specific environmental conditions are found at the
beginning of each section in Chapter 4, Environmental Analysis.
3.4.1 Regional Context
Regionally, the City is situated near the middle of the County, approximately 20 miles north of downtown San
Diego via I-15. The project site is approximately two miles east of I-15. The City boundary is approximately one-
half mile west of the project site. I-15 runs generally parallel to the City’s western border and provides
connections to San Diego and Riverside Counties.
3.4.2 Surrounding Environment
The surrounding residential development consists of mostly single-family homes. Some multi-family homes exist
west of the middle of the project site, along Port Marnock Drive, and surrounded by the project site along
Villamoura Drive and Valle De Lobo Drive. Planned community projects exist to the east of the project site and
open space designated for resource management exists southeast of the project site. The rest of the project site
is surrounded by residential uses varying in density, but mostly consists of single-family residences.
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3.5 Intended Uses of the EIR
In accordance with CEQA Guidelines Sections 15124(d) and 15160–15170, the City of Poway Development
Services prepared an Initial Study for the proposed project, which determined that an EIR would be required. The
Initial Study was included with the Notice of Preparation circulated by the City for public review on May 10, 2019.
The City also conducted a Public Scoping Meeting on May 23, 2019, from 6:30 p.m. to 8:00 p.m. in the City of
Poway City Council Chambers, 13325 Civic Center Drive, Poway, California. The Initial Study, Notice of Preparation,
and Public Scoping comments are provided in Appendix A of this EIR.
Consistent with CEQA Guidelines Section 15121(a), this EIR is an informational document that will inform
public agency decision makers and the public generally of the significant environmental effects of the
proposed project, identify possible ways to minimize the significant effects, and describe reasonable
alternatives to the proposed project.
Matrix of Project Approvals/Permits
The City is the Lead Agency, defined in CEQA Guidelines Sections 15050 and 15367 as the “public agency which
has the principal responsibility for carrying out or approving a project.” This EIR is intended to analyze the
environmental impacts associated with the discretionary actions that require ultimate approval by the Poway City
Council and further by the voters of the City of Poway through a general or special election.
Additionally, responsible agencies have discretionary approval over one or more actions involved with development
of a project, and responsible and trustee agencies are state agencies with discretionary approval or jurisdiction by
law over natural resources, which may be impacted. Table 3-1 lists all approvals (e.g., permits, financing approvals,
participation agreements) that are expected to be required from the City and other public agencies.
Table 3-1. Proposed Discretionary Approvals and Permits
Discretionary Approval/Permit Agency Title Agency Type
General Plan Amendment City of Poway Lead Agency
Rezone City of Poway Lead Agency
Specific Plan City of Poway Lead Agency
Tentative Map City of Poway Lead Agency
Conditional Use Permit City of Poway Lead Agency
Development Review City of Poway Lead Agency
Environmental Assessment City of Poway Lead Agency
Proposition FF Rezone Vote City of Poway Voters General or Special Election
401 Permit State Regional Water Quality Control
Board
Responsible Agency
404 Permit Army Corps of Engineers Responsible Agency
1602 Permit California Department of Fish and
Wildlife
Responsible Agency
3 – Project Description
The Farm in Poway EIR 11872
June 2020 3-13
3.6 List of Past, Present, and Reasonably Anticipated
Future Projects in the Project Area
Table 3-2 and Figure 3-11 present cumulative projects for the Specific Plan area and surrounding region.
Table 3-2. Cumulative Projects
Map Legend
Number Project Name and APNs Project Description
Entitlement
Status
City of Poway
1 The Hop Stop Craft Beer Bar and Kitchen
B19-0601
3142203900
New 2,350-square-foot restaurant and
brew pub with outdoor seating
Under
Construction
2 St. Bartholomew’s Episcopal Church
Remodel and Expansion Project
CUP18-019
2755101900
Proposed 13,422-square-foot addition
to an existing church
Under
Review
3 Crest Road Estates
TTM18-005
3161201800, 3161202500
6-lot single-family residential
subdivision
Under
Review
4 Aria Estates
B19-0086–B19-0092
3175342000
7-lot single-family residential
subdivision
Approved
5 Liguori Ranch
TTM 02-001
APNs: 2770210500, 2770210600,
2770210700, 2770210800,
2770210900, 2770211000,
2770110400, 2770110500,
2761401300 and 2761401400
31-lot single-family residential
subdivision with 29 residential lots and
2 open space lots
Under
Construction
6 Persepolis Estates
TTM 04-001
APN: 3172417600
5-lot single-family residential
subdivision
Under
Review
7 Chick-Fil-A
B18-1056
3171306500
New 4,586-square-foot restaurant with
drive-thru service
Finalized
8 Creekside Plaza
DR19-002
3178200900
New 5,000-square-foot commercial
building at existing shopping center
Approved
9 Animal Emergency Clinic DR17-
055/CUP18-005
3174900200
1,200-square-foot addition to an
existing veterinary hospital
Approved
10 United Oil
B18-0841
3175401500, 3175401600
Demolition of existing gas station and
auto repair and replacement with a
2,400-square-foot minimart, 1,000-
square-foot carwash, and adding two-
pump station for a total of eight
Approved
3 – Project Description
The Farm in Poway EIR 11872
June 2020 3-14
Table 3-2. Cumulative Projects
Map Legend
Number Project Name and APNs Project Description
Entitlement
Status
11 St Michaels’s Rectory
CUP 18-015
2754602600
Replace 4,570-square-foot rectory with
a 4,700-square-foot building and
adding 450 square feet to the
sanctuary
Under
Construction
12 Outpost
B18-1508, B18-1507
3174730700, 3174730800,
3174730900, 3174731000,
3174731100
Mixed-use development with 53
apartments and 40,000 square feet of
commercial space
Under
Construction
13 Meadowbrook
TTM16-001
3160204400
12-lot single-family residential
subdivision
Under
Review
14 Meriman Subdivision
TTM17-009
3212711900
5-lot single-family residential
subdivision
Under
Review
15 Cafagna Community Center
B19-0294
3174721300
New 23,511-square-foot community
center to replace existing 26,000-
square-foot facility
Under
Construction
16 Express Tire Commercial Center
PA18-009
3174904100
Preliminary application for the
construction of a 6,927-square-foot
commercial building (auto repair) and
10,527-square-foot retail building at
12619 Poway Road
Under
Review
17 Arcangeli Residential Care Facilities
B18-2314
3141934800
New 15-bed residential assisted care
facility
Approved
18 Residential Care Facility
B18-1906
3141934900
New 15-bed residential assisted care
facility
Under
Construction
19 Poway Commons
3174721800, 3174722300,
3174722400, 3174722500,
3171010600
Mixed-use development with 98
attached market-rate units, 44
affordable senior housing units, and
25,000 square feet of commercial
space
Approved
20 Villa de Vida
B19-0162
3171521400
New 54 affordable apartment units for
developmentally disabled adults
Under
Construction
21 Vista Maderas Subdivision
TTM06-002
2770710400, 2770710500,
2770711400, 2770711600
2770711900
6-lot single-family residential
subdivision
Approved
City of San Diego
22 Casa de Las Campanas
272-740-08-00
Construction of a 96,019-square-foot
skilled nursing building on a 22.29-acre
site as an expansion to the existing
Casa de Las Campanas retirement
community
Under
Construction
3 – Project Description
The Farm in Poway EIR 11872
June 2020 3-15
Table 3-2. Cumulative Projects
Map Legend
Number Project Name and APNs Project Description
Entitlement
Status
23 The Junipers
313-060-06-00
Construction of a subdivision of 112.26
acres to create 4 multi-family residential
lots with 536 attached/detached single-
family homes, 4 open space lots, and 1
private street lot from an existing
nonoperational golf course
Under
Review
24 24 Hour Fitness
313-050-10-00
Addition of a 3,550-square-foot pool
and spa to an existing 30,068-square-
foot commercial building on a 3.94-acre
site
Approved
25 Black Mountain Ranch North Village
(Subarea I)
678-230-19-00
Construction of 2,902 residential units
with 590,000 square feet of non-
residential uses. Approximately 80% of
the North Village has been constructed.
Continued construction includes 119
condominium units and 94 homes.
Under
Construction
26 Pacific Village
313-030-15-00
Redevelopment of an existing 41-acre
apartment complex, including the
construction of 600 dwelling units
Under
Construction
City of Escondido
27 Chalice Unitarian Universalist Congregation
PHG 15-0039
238-110-39-00
Expansion of the existing religious
facility through the construction of
2,991 square feet of offices, multi-
purpose/classrooms, and foyer
additions to the existing building. Also
includes addition of 10 parking spaces
for a total of 49 parking spaces. Street
improvements along Miller Avenue, as
well as water supply improvements
under Miller Avenue and on the project
site. New electric service for the multi-
purpose building would also be included
in the project.
Approved
28 661 Bear Valley Parkway – Residential
Development
SUB 15-0002
237-131-01-00, 237-131-02-00
Construction of a 55-unit residential
development with Bear Valley Parkway
(40.62 acres), frontage improvements,
private streets, dedicated open space,
and recreation lots, as well as the
phased improvement of a section of
Bear Valley Parkway to 4-lane major
road standards
Approved
3 – Project Description
The Farm in Poway EIR 11872
June 2020 3-16
Table 3-2. Cumulative Projects
Map Legend
Number Project Name and APNs Project Description
Entitlement
Status
29 Del Prado Planned Development
ENV15-0011, SUB15-0022 and 23,
PHG15-0031, AZ15-0002
238-130-11-00, 238-130-26-00, 238-130-
27-00, 238-130-35-00, 238-130-36-00.
Construction of 113 attached
townhome units on two lots, with 81
residences proposed for Del Prado
North and 32 residences proposed for
Del Prado South; construction of private
streets and parking areas within the
project site; shared recreational
facilities including pool, bathing deck,
trellis, BBQ area, and restroom facility;
demolition and removal of an existing
single-family home located in the
northwest corner of the site; and
landscaping and bio-retention basins to
provide flow control and water quality
treatment of stormwater runoff on 4.9-
acre lot
Approved
30 Oak Creek
SUB 13-0002
238-110-25-00, 238-110-35-00; 238-370-
01-00, 238-370-04-00, 238-370-05-00,
238-370-06-00, 238-370-07-00, 238-370-
08-00, 238-380-01-00
Construction of a 41.4-acre low-density
housing development project that would
include 65 single-family detached
residences
Approved
31 Westfield North County Theater Project
PHG15-0026
760-170-28-01, 760-170-28-02, 271-030-
20-00, 760-170-28-00, 760-170-28-03
Construction of a 50,341-square-foot
theater with approximately 10 screens
and 1,248 seats; construction of a new
outdoor pedestrian plaza between the
existing shopping mall and the
proposed theater; modification of the
current Master Sign Program to allow
for new signage on the project site
Under
construction
Land Use Plan
The Farm in Poway
FIGURE 3-1SOURCE: The Farm in Poway, LLC, 2020Z:\Projects\j1187201\MAPDOC\PD
3 – Project Description
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June 2020 3-18
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Not to Scale
Conceptual Trail Network
The Farm in Poway
FIGURE 3-2SOURCE: The Farm in Poway, LLC, 2020Z:\Projects\j1187201\MAPDOC\PD
3 – Project Description
The Farm in Poway EIR 11872
June 2020 3-20
INTENTIONALLY LEFT BLANK
Not to Scale
Martincoit Road and Espola Road Intersection Improvements
The Farm in Poway
FIGURE 3-3SOURCE: The Farm in Poway, LLC, 2020Z:\Projects\j1187201\MAPDOC\PD
3 – Project Description
The Farm in Poway EIR 11872
June 2020 3-22
INTENTIONALLY LEFT BLANK
Not to Scale
Conceptual Street Network
The Farm in Poway
FIGURE 3-4SOURCE: The Farm in Poway, LLC, 2020Z:\Projects\j1187201\MAPDOC\PD
3 – Project Description
The Farm in Poway EIR 11872
June 2020 3-24
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9' DG TRAIL 6' CONCRETE WALK
LANDSCAPED PARKWAY STRIP50' LANDSCAPE
EASEMENT
3' GLASS AND 3' MASONRYSOUND WALL
3' GLASS AND
3' MASONRY
SOUND WALL
PEELER POLE TRAIL FENCE
Not to Scale
Espola Road Improvements
The Farm in Poway
FIGURE 3-5SOURCE: The Farm in Poway, LLC, 2020Z:\Projects\j1187201\MAPDOC\PD
3 – Project Description
The Farm in Poway EIR 11872
June 2020 3-26
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Conceptual Water Master Plan
The Farm in Poway
FIGURE 3-6SOURCE: The Farm in Poway, LLC, 2020Z:\Projects\j1187201\MAPDOC\PD
3 – Project Description
The Farm in Poway EIR 11872
June 2020 3-28
INTENTIONALLY LEFT BLANK
Conceptual Sewer Master Plan
The Farm in Poway
FIGURE 3-7SOURCE: The Farm in Poway, LLC, 2020Z:\Projects\j1187201\MAPDOC\PD
3 – Project Description
The Farm in Poway EIR 11872
June 2020 3-30
INTENTIONALLY LEFT BLANK
Conceptual Drainage Plan
The Farm in Poway
FIGURE 3-8SOURCE: The Farm in Poway, LLC, 2020Z:\Projects\j1187201\MAPDOC\PD
3 – Project Description
The Farm in Poway EIR 11872
June 2020 3-32
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15
D EERVALLE Y E STATES
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Project Location
The Farm in Poway
SOURCE: SANGIS 2017, 2019Date: 6/13/2019 - Last saved by: agreis - Path: Z:\Projects\j1187201\MAPDOC\PD\Figure3-9_ProjectLocation.mxd02,0001,000 Feet
Project Boundary
FIGURE 3-9
Chula Vista
SolanaBeach
Encinitas
San Diego
Carlsbad
Oceanside
Lemon Grove
El Cajon
Santee
Poway
San Marcos
EscondidoVista
Imperial Beach
Coronado
Riverside
County
Mexico
209
75
52
94
125
241
9854
195
56
86
111
67
74
74
76 79
78
805
215
8
155
Project Site
3 – Project Description
The Farm in Poway EIR 11872
June 2020 3-34
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RS-2
RR-C
RR-C
PRD-3
PRD-1
RS-2
RC
RC
PF
PC-4
PC-4
PC-4
PF
RR-A
OS-R
OS-R
OS-R
OS-R
RS-4
RS-4
RS-4
RS-4
Surrounding Lands Uses
The Farm in Poway
SOURCE: SANGIS 2017, 2019; City of Poway 2019
0 500250Feet
Project Specific Plan
Residential Zone
RR-A, Residential Rural
RR-C, Residential Rural
RS-2, Residential single-family 2
RS-4, Residential single-family 4
RC, Residential Condominium
Special Purpose Zone
PRD-1, Planned Residential Development
PRD-3, Planned Residential Development
PC-4, Planned Community
PF, Public Facility
OS-R, Open Space - Recreation
FIGURE 3-10
3 – Project Description
The Farm in Poway EIR 11872
June 2020 3-36
INTENTIONALLY LEFT BLANK
1
2
3
4
5
6
7
89
11
12
13
14
15
16
17
18
19
20
22
23
2324
27
29
2830
31
10
56
78
67
15
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The Farm in Poway
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FIGURE 3-11
Project Boundary
Cumulative Projects
City of Poway
City of San Diego
City of Escondido
1 - The Hop Stop Craft Beer Bar and
Kitchen
2 - St. Bartholomew’s Episcopal Church
Remodel and Expansion Project
3 - Crest Road Estates
4 - Aria
5 - Liguori Ranch
6 - Persepolis States
7 - Chick-Fil-A
8 - Creekside Plaza
9 - Animal Emergency Clinic
10 - United Oil
11- St. Michaels’ Rectory
12 - Outpost
13 - Meadowbrook
14 - Meriman Subdivision
15 - Cafagna Community Center
16 - Express Tire Commercial Center
17 - Arcangeli Residential Care Facilities
18 - Residential Care Facility
19 - Poway Commons
20 - Villa de Vida
21 - Vista Maderas Subdivision
22 - Casa de Las Campanas
23 - The Junipers
24 - 24 Hour Fitness
25 - Black Mountain Ranch North Village
(Subarea I)
26 - Pacific Village
27 - Chalice Unitarian Universalist
Congregation
28 - 661 Bear Valley Parkway - ResidentialDevelopmet
29 - Del Prado Planned Development
30 - Oak Creek
31 - Westfield North County Theater Project
25
26
3 – Project Description
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June 2020 3-38
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The Farm in Poway EIR 11872
June 2020 4-1
4 Environmental Analysis
The following sections analyze the potential environmental impacts that may occur as a result of
implementation of The Farm in Poway project (proposed project). The environmental issues addressed in this
chapter include the following:
Aesthetics
Air Quality
Biological Resources
Cultural and Tribal Cultural Resources
Energy
Geology and Soils
Greenhouse Gas Emissions
Hazards and Hazardous Materials
Hydrology and Water Quality
Land Use and Planning
Noise
Population and Housing
Public Services
Recreation
Transportation
Utilities and Service Systems
Wildfire
Each issue analysis section includes a description of existing conditions, the criteria for the determination of
impact significance, evaluation of potential project impacts including cumulative impacts, mitigation
measures (if applicable), and a conclusion of significance after mitigation for impacts identified as requiring
mitigation (if applicable).
4 – Environmental Analysis
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June 2020 4-2
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4.1 – Aesthetics
The Farm in Poway EIR 11872
June 2020 4.1-1
4.1 Aesthetics
This section describes the existing visual conditions of The Farm in Poway project (proposed project) site and
vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation
measures related to implementation of the proposed project.
A Notice of Preparation (NOP) was circulated from May 10, 2019, to June 10, 2019. During the NOP comment
period, comment letters related to aesthetics focused on the following topics:
Preservation of views and privacy
Appearance of community along Espola Road
Conformance with community aesthetics
These comments were considered during the preparation of this Environmental Impact Report (EIR). However, it
should be noted that the preservation of private views and privacy is not under the purview of the California
Environmental Quality Act (CEQA). The Initial Study, NOP, and Public Scoping comments are provided in Appendix A
of this EIR.
4.1.1 Existing Conditions
Community Overview
The City of Poway (City) is situated in a network of hillsides and valleys and comprises an area that has many natural
resources including creeks and channels, canyons, grassland areas, and mountains. These areas provide the City
with aesthetic visual resources that add to the City’s rural character and support a significant amount of native
plant and animal life. Additionally, the vast amount of open space land in the City, which comprises approximately
50 percent of the total City land area, represents a significant part of the rural character of the City. While the City
has historically been characterized as a farming community over the last 100 years, it is currently characterized by
varying densities of residential land uses, limited commercial, industrial, public facility and recreational uses and
vast amounts of open space (City of Poway 1991).
Surrounding Land Uses
The land uses surrounding the project site consist of single- and multi-family residential development that includes
detached residences on a variety of lot sizes, attached residences of several different densities, and several
planned community developments; see Chapter 3, Project Description, for Figure 3-10, Surrounding Land Uses. The
surrounding development consists of mostly single-family homes zoned Residential Single-Family 4 (RS-4), which
is intended for 10,000-square-foot lots and maximum densities of four units per acre. A small cluster of residential
condominium-zoned (RC) multi-family homes exist along the western edge of the project boundary along Port
Marnock Drive, which allows for 12 units per acre. Along the northern portion of the project site, along Villamoura
Drive and Villa De Lobo Drive, similar RC zoned multi-family housing is present.
4.1 – Aesthetics
The Farm in Poway EIR 11872
June 2020 4.1-2
Scenic Vista
The City includes views of several mountain peaks, including Mt. Woodson, Iron Mountain, and Twin Peaks, in
addition to other prominent ridgelines that penetrate into the developed areas of the City. However, the City does
not specifically designate scenic vistas.
Scenic Highways
According to the California Department of Transportation (Caltrans) California Scenic Highway Mapping System, the
proposed project is not located adjacent to, or in the vicinity of, a designated state scenic highway or eligible state
scenic highway, nor are there any designated or eligible state scenic highways within the City’s limits (Caltrans
2011). The closest eligible state scenic highway is State Route (SR) 52, located approximately 11.5 miles south of
the project site. The closest designated State Scenic Highway is the portion of SR-125 between SR-94 and Interstate
8 near La Mesa, which is approximately 17 miles south of the project site.
The Poway Comprehensive Plan: General Plan (General Plan) contains local scenic roadways including Espola Road from
the western City limits to Poway Road, Poway Road from Espola Road to SR-67, SR-67 through the Poway City limits, and
Midland Road between Hilleary Road and Twin Peaks Road. Where not inhibited by existing or approved development, the
City requires a landscaped open space easement of 50 feet from the ultimate right-of-way along all scenic roadways (City
of Poway 2010). Espola Road is the only City-designated local scenic roadway within the vicinity of the proposed project.
Light and Glare
Upward-pointing or upward-reflected light from outdoor lighting is a significant source of nighttime light. Nighttime light
that spills outside of the intended area, as well as lighted signs, can be annoying to neighbors and potentially harmful to
motorists, cyclists, and pedestrians. Nighttime lighting can result in skyglow (the brightening of the night sky) and light
trespass (a result of spill light shining in undesirable locations). Nighttime lighting in excess of what is necessary for its
purpose is called light pollution. Light pollution cannot completely be eliminated, but it can be minimized to help create
dark skies and to decrease energy consumption. There are no existing sources of nighttime lighting within the boundary
of the project site, as the former StoneRidge County Club and associated golf course are no longer operating.
Glare is the result of sharply reflected light caused by sunlight or artificial light reflecting from highly finished
surfaces such as windows or brightly colored surfaces, and from the direct view of a bright, unshielded light source.
Glare can be uncomfortable (discomfort glare) or disabling (disability glare). Glare decreases visibility, but the level
of receptor sensitivity to glare can vary widely. There are no existing sources of glare at the project site, as the
StoneRidge County Club and associated golf course are no longer operating.
4.1.2 Relevant Plans, Policies, and Ordinances
State
California Environmental Quality Act
The California Environmental Quality Act (CEQA) (California Public Resources Code, Section 21000 et seq.) and CEQA
Guidelines (14 CCR 15000 et seq.) are primary sources for environmental legislation in California; they require projects
with potential adverse environmental effects (or impacts) undergo environmental review. Adverse environmental impacts
are typically mitigated as a result of the environmental review process in accordance with existing laws and regulations.
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California Scenic Highway Program
Created by the Legislature in 1963, the California Scenic Highway Program includes highways designated by
Caltrans as scenic. The purpose of this program is to preserve and protect the scenic beauty of California highways
and adjacent corridors through conservation and land use regulation. For a highway to be included in the program,
it must first be nominated by the specific city or county where it is located. The nomination/eligibility process also
entails that the city/county identify and define the scenic corridor of the highway to better understand the extent of
visual resources requiring conservation. For an eligible highway to be officially designated and included in the
program, the local government with jurisdiction over lands abutting the highway must implement a scenic highway
corridor protection program that safeguards the scenic appearance of the corridor. Corridor protection may be
achieved through a variety of means, including regulation of land uses and intensity of development, detailed land
and site planning, control of outdoor advertising, consideration of earthmoving and landscaping, and the design
and appearance of structures and equipment. If the local Caltrans district and State Scenic Highway coordinators
determine that the corridor protection program meets the five legislatively required elements discussed above, a
recommendation to designate the highway as scenic is forwarded to the Caltrans director. The Caltrans director
may revoke scenic highways that no longer comply with the program. There are no designated scenic highways
located in the proposed project’s vicinity.
Local
City of Poway Municipal Code – Chapter 13.15 – Street Lighting
Chapter 13.15 of the City’s Municipal Code (City of Poway 2019) provides regulations regarding street lighting standards
to minimize glare, light trespass, and artificial sky glow for the benefit of the citizens of the City, and to promote lighting
design that provides for public safety, utility, and productivity while conserving energy and resources.
Poway Comprehensive Plan: General Plan – Community Development Element
The General Plan Community Development Element includes the following policies and strategies that could apply
to the proposed project (City of Poway 1991):
Goal I – It is the goal of the City of Poway to preserve Poway’s unique and desirable character as “The City in the Country”
and to maintain high quality design and environmental standards in all new development and redevelopment.
Policy A – Streetscape: Seek to develop an attractive streetscape which reflects the rural, small town character
of the City.
Strategy 1: Streetscape design should encourage an aesthetic roadway area that integrates street
hardware, signs, lighting, landscaping, and pedestrian access.
Strategy 2: Screening such as solid walls or fencing should principally serve as a device to restrict visual
and acoustical impacts, but should also be designed to enhance the streetscape.
Strategy 3: Where trees are now encroaching into the public right-of-way, the City shall establish a program
that plants replacement trees in anticipation of removal of existing trees.
Strategy 6: Covenants, conditions, and restrictions (CC&Rs) shall be adopted for all new subdivisions which
require appropriate use and maintenance of lot areas which are visible from off-site in order to protect and
enhance the character and image of the City.
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Policy C – Site Design: Attractive, efficient site design shall be required of all development.
Strategy 18: For projects with slopes of 15 percent or greater, a visual impact analysis shall be prepared to
determine the most suitable location(s) for the building pad(s).
Policy D – Grading: Necessary grading should be done so as to minimize the disturbance to the site and the
environmental and aesthetic impacts.
Policy F – Architecture: The design of buildings should be aesthetically pleasing and consistent with the City’s desire
to retain Poway’s small town character and image.
Strategy 7: All structures shall be of a muted color scheme, with style and texture which reflect the
traditional/rural character of the community and natural environment. They shall not be bright, reflective,
metallic, or otherwise visually out of character with the community or natural setting. A color palette shall
be submitted as part of the site plan.
Policy I – Lighting: Lighting should provide for public convenience and safety but not conflict with the rural nature
of the community.
Strategy 1: Areas other than rural residential areas should be provided with street lights.
Strategy 2: Public and semi-public parking lots and driveways should be adequately lighted for public safety.
Except for single-family homes, only low pressure sodium lighting may be used for exterior lighting between
11:00 p.m. and dawn.
Strategy 3: All lighting shall be shielded and directed so as to not shine on adjoining properties.
Strategy 4: Lighting placed upon the building should be architecturally integrated into the design.
Strategy 5: Lighting shall be provided to adequately illuminate building entrances, access areas, parking
areas, walkways and stairways.
Strategy 6: Lighting for home security should generally be provided through street lighting, however,
supplemental residential-type lighting may be provided for security providing that it does not adversely
affect adjacent properties.
Poway Comprehensive Plan: General Plan – Transportation Element
The following from the General Plan Transportation Element could apply to the proposed project (City of Poway 2010):
Goal VI, Policy B – Scenic Roadways: Continue to identify, designate and preserve local scenic roadways.
Strategy 1: Where not inhibited by existing or approved development, an open space easement of 50 feet
from the ultimate right-of-way line shall be required along all scenic roadways, except Midland Road and
Espola Road south of Titan Way to Poway Road. This easement area shall be landscaped to enhance the
scenic roadway area using drought tolerant plant materials.
Strategy 2: Any new residential developments adjacent to a scenic roadway, except Midland Road, shall
have decorative solid walls and/or landscaped earthen berms to enhance the scenic quality of the area.
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Poway Comprehensive Plan: General Plan – Natural Resources Element
The following from the General Plan Natural Resources Element could apply to the proposed project (City of Poway 1991):
Goal II, Policy A – Scenic Areas: Scenic areas, prominent vistas and open space areas that typify Poway’s rural
history and image should be preserved and protected through appropriate land use policies.
Strategy 1: Significant open space areas and scenic vistas along local scenic roadways should be protected.
Strategy 2: The mountains, hillsides and prominent ridgelines are a valuable natural resource and should
be preserved through appropriate land use policies.
4.1.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to aesthetics are based on Appendix G of the CEQA
Guidelines. According to Appendix G of the CEQA Guidelines, except as provided in Public Resources Code Section
21099, a significant impact related to aesthetics would occur if the project would:
1. Have a substantial adverse effect on a scenic vista.
2. Substantially damage scenic resources including, but not limited to, trees, rock outcroppings, and historic
buildings within a state scenic highway.
3. In non-urbanized areas, substantially degrade the existing visual character or quality of public views of
the site and its surroundings. (Public views are those that are experienced from publicly accessible
vantage point). If the project is in an urbanized area, conflict with applicable zoning and other regulations
governing scenic quality.
4. Create a new source of substantial light or glare which would adversely affect day or nighttime views
in the area.
4.1.4 Impacts Analysis
Would the project have a substantial adverse effect on a scenic vista?
The City’s General Plan emphasizes the protection of scenic areas, prominent vistas, and open space areas that
typify the community’s rural history and image. Valuable scenic vistas include those of mountains, hillsides,
prominent ridgelines, and significant open space areas and scenic vistas along locally designated scenic
roadways. The City does not designate scenic vistas. Although not officially designated, major public open space
areas within the vicinity of the proposed project include the Lake Poway Recreation Area and Blue Sky Ecological
Reserve. Additionally, Mt. Woodson and Iron Mountain are located approximately 3.75 miles east and six miles
southeast, respectively.
Blue Sky Ecological Reserve trails are located in a canyon and beyond a small hill that is adjacent to the bend in Espola
Road. Due to the topography, the project site is not visible from the Blue Sky Ecological Reserve. Portions of the project
site may be visible from trails associated with the Lake Poway Recreation Area, and specifically the trails northwest of
the lake. However, the proposed project would develop residential and open space uses on an infill site in an urbanized
area and the project site is entirely surrounded by existing residential development. Therefore, due to the distance
between these trails and the project site, it would be difficult to distinguish the proposed project from adjacent existing
development and the project site would blend with the existing environment.
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From Mt. Woodson and associated trails, views of the project site would be similar as those from the
aforementioned trails surrounding Lake Poway, but more obscured as Mt. Woodson is approximately 2.25 miles
farther from the project site than Lake Poway. Finally, due to the distance and intervening topography, the project
site would not be distinguishable from Iron Mountain. Viewers oriented towards the project site from this location
would see the distant development which characterizes the City, and the various ridgelines to the east and north.
The proposed project would also be designed to maintain a low profile and would be scaled similarly to surrounding
land uses, which consist of single-family residential developments on a variety of lot sizes. All buildings would be
limited to a maximum height of 35 feet, with the exception of architectural appurtenances or thematic structures
such as towers, silos, windmills, or similar design features. The proposed project would include a 50-foot open
space easement along Espola Road that would include landscaping, as well as a multi-use trail; any parking areas
located within this setback shall be screened with a minimum three-foot-high berm and dense landscaping and 15-
gallon trees spaced at one per 15 lineal feet as required by The Farm in Poway Specific Plan (Specific Plan) (see
Figure 3-5, Espola Road Improvements). The multi-use trail system would also surround the majority of the project
site, acting as a buffer between the proposed project and surrounding development (see Figure 3-2, Conceptual
Trail Network). Further, the Project site is currently blighted, as the former golf course has been closed since 2017
and has fallen into disrepair. The proposed project would not substantially interrupt or obstruct available views from
any scenic areas. No designated scenic vistas would be impacted by the proposed project. Thus, impacts to scenic
vistas would be less than significant.
Would the project substantially damage scenic resources, including, but not limited to trees, rock outcroppings,
and historic buildings within a state scenic highway?
There are no officially designated or eligible highways within the City. The closest designated State Scenic Highway is
the portion of SR-125 between SR-94 and Interstate 8 near La Mesa, which is approximately 17 miles south of the
project site. Therefore, no impacts to scenic resources within a State Scenic Highway would occur.
As previously discussed, Espola Road is designated as a local scenic roadway by the City and County. While traveling
east, and along the southern boundary of the project site, Espola Road offers several long-range views of Mt. Woodson
and adjoining ridgelines. The City requires a landscaped open space easement of 50 feet from the ultimate right-of-way
along local scenic roadways, including this portion of Espola Road. Thus, the proposed project would establish an open
space easement of 50 feet from the ultimate right-of-way line of Espola Road. This easement would be landscaped with
drought tolerant plants and would follow water conservation principles to enhance the scenic roadway area. The scenic
easement along Espola Road would also include a multi-use trail and parking behind an earthen berm and landscape as
previously mentioned (see Figure 3-5). Adjacent residential homes, located beyond the scenic setback, would also be
clustered to preserve visual open space corridors through the site and would be screened by an informal pattern of trees
and shrubs. While the proposed project would comply with the City’s regulations governing local scenic roadways, Espola
Road is not a State Scenic Highway and thus no impacts would occur.
In non-urbanized areas, would the project substantially degrade the existing visual character or quality of public
views of the site and its surroundings? (Public views are those that are experienced from publicly accessible
vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other
regulations governing scenic quality?
CEQA Section 21071 defines an “urbanized area” as “(a) an incorporated city that meets either of the following
criteria: (1) Has a population of at least 100,000 persons, or (2) Has a population of less than 100,000 persons if
the population of that city and not more than two contiguous incorporated cities combined equals at least 100,000
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persons.” As of July 1, 2018, the US Census Bureau estimated the population of Poway to be 49,704 persons (U.S.
Census Bureau 2018a). While the City’s population is under 100,000 persons, the City is contiguous with the City
of San Diego, which was estimated to have a population of 1,425,976 persons as of July 1, 2018 (U.S. Census
Bureau 2018b). Therefore, the City would be considered an urbanized area per CEQA and therefore the first
question of this threshold would not apply to the proposed project, as it is directed at non-urbanized areas. CEQA
Section 21071 also defines an urbanized area for unincorporated areas; however, the City is an incorporated city,
so this definition was not considered.
The City’s existing General Plan Land Use and Zoning Map designates the entire project site as “Open Space
– Recreation (OS-R)” (City of Poway 1991). A General Plan amendment and zoning amendment would be
processed concurrently with the Specific Plan to designate the project site as “Planned Community (PC-9).”
The amendment consists of both a map amendment and zoning text amendments. Currently, a Planned
Community (PC) zone may only be applied to properties 300 acres or larger. The proposed text amendment
would revise this portion of the text to allow the project site of approximately 117.2 to be zoned as PC. In
addition, a new section would be added to the zoning ordinance that briefly describes The Farm in Poway
Planned Community and requirements for future voter approval for changes to residential density and open space
that are not addressed in the Specific Plan. This designation and zoning would be consistent with a few other
specific plan areas throughout the City. The proposed project would not conflict with zoning, as amended by
the project, as these discretionary approvals would allow for the proposed project.
The proposed project includes the adoption of a new specific plan, the Specific Plan (The Farm in Poway LLC 2020),
the purpose of which is to establish a link between implementing policies of the General Plan and the individual
development proposals in a defined area. As required by Government Code Section 65450 et seq., the Specific Plan
contains land uses and development regulations, infrastructure requirements, and implementation measures for the
development of a specific geographic area (referred to as the project site or Specific Plan area). These provisions
require that a specific plan be consistent with the adopted general plan. The Specific Plan includes a General Plan
Consistency Analysis, which demonstrates that the Specific Plan is generally consistent with applicable General Plan
policies. Additionally, the General Plan Consistency Analysis is outlined in Table 4.10-1, Project Consistency with City
of Poway General Plan. As described in Section 4.10, Land Use and Planning, the proposed project would not result
in a conflict with any applicable land use plan, policy, or regulation for the purpose of avoiding or mitigating an
environmental effect, which would include those governing scenic quality. All General Plan policies pertaining to scenic
quality, as identified in Section 4.1.2, Relevant Plans, Policies, and Ordinances, are addressed in Table 4.10-1.
Therefore, the proposed project would not conflict with any plans or policies governing scenic quality. The City has no
ordinances governing scenic quality. Thus, because the proposed project is in an urbanized area and would not conflict
with applicable zoning and other regulations governing scenic quality, impacts would be less than significant.
Would the project create a new source of substantial light or glare which would adversely affect day or nighttime
views in the area?
The project site currently contains the former StoneRidge Country Club golf course and associated buildings, which
are non-operational, and no lighting is currently used on site. The proposed project would demolish the StoneRidge
Country Club buildings and build 160 residential units and other uses, creating new sources of light on the project
site. However, all lighting within the project site would comply with Title 24 of the California Code of Regulations. In
addition to conformance with Title 24, the Specific Plan would include further lighting regulations limiting height,
intensity, and time-of-day use. Additionally, street lighting would be shielded to illuminate the streets, promote dark
skies, and inhibit any unnecessary nighttime lighting or glare. The proposed project would also comply with Chapter
13.15 of the City’s Municipal Code, as well as the City’s Supplemental Engineering Standards (City of Poway 2012)
with regard to outdoor lighting fixtures, street lighting, and safety lighting.
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Windows on the proposed residences and buildings, and associated cars, have the potential to create new sources of
glare. However, these uses and glare sources would not be inconsistent with the surrounding land uses, as the project
site is entirely surrounded by existing residential development. Also, the proposed project would not use highly reflective
materials. Therefore, compliance with applicable lighting regulations and visual consistency with surrounding
development would ensure that impacts due to new sources of light and glare would be less than significant.
4.1.5 Cumulative Impacts
Figure 3-11, Cumulative Projects, and Table 3-2, Cumulative Projects, identify the projects generally considered for
the cumulative analysis. More specifically, the geographic scope for analyzing cumulative impacts related to
aesthetics focuses on lands in near proximity to the project site (e.g., public roadways).
Scenic Vistas
Cumulative projects located in the Poway region would have the potential to result in a cumulative impact to scenic
vistas if, in combination, they would result in the obstruction, interruption, or detraction from a scenic vista. As
described in Section 4.1.1, Existing Conditions, the City does not specifically designate scenic vistas. However, the
City has open space recreational areas including the Lake Poway Recreational Area and Blue Sky Ecological Reserve,
which afford broad views of the City and various ridgelines to the north and east. Due to the distance of the project
site from these recreational areas, in addition to the existing residential land uses entirely surrounding the project site,
it would be difficult to distinguish the proposed project from adjacent existing development and the project site
would blend with the existing environment.
Furthermore, the closest cumulative project to the proposed project is the Vista Maderas Subdivision project located
approximately 0.9 miles east of the project site, as shown on Figure 3-11. Due to the distance between these projects,
in addition to the proposed project’s location on an infill site and congruency with the surrounding residential land
uses, the proposed project would not result in a cumulatively considerable impact to scenic vistas.
Scenic Highways
State Scenic Highways are those highways that are either officially designated as state scenic highways by Caltrans
or are eligible for such designation. There are no officially designated or eligible highways within the City. The closest
designated State Scenic Highway is the portion of SR-125 between SR-94 and Interstate 8 near La Mesa, which is
approximately 17 miles south of the project site.
As mentioned, Espola Road is a local scenic roadway as designated by the City and the proposed project would
comply with the City’s setback requirements, except for parking behind an earthen berm and landscape, for
Espola Road. There are no cumulative projects along or in the vicinity of Espola Road. Further, since Espola
road is not a designated or eligible state scenic highway, and there are no designated or eligible state scenic
highways within the City, no cumulative impact to a state scenic highway would occur.
Policy Consistency
As discussed in Section 4.1.4, Impacts Analysis, the proposed project is in an urbanized area, per CEQA, so impacts
would only occur if the project would conflict with applicable zoning and other regulations governing scenic quality.
Since the proposed project would not conflict with applicable zoning, as amended by the project, or any other
regulations governing scenic quality, and because policy consistency is determined on a project-by-project basis,
no cumulative impact would occur.
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Light and Glare
The proposed project would have the potential to result in an incremental increase in light and glare associated
with the new development. However, the City’s Municipal Code, General Plan policies, and State Title 24
Regulations require new development to avoid glare impacts and minimize nighttime lighting. Specific Plan
requirements are also included to avoid nuisance nighttime lighting. Cumulative projects would also be required to
comply with these regulations, reducing cumulative impacts through collective regulatory compliance. Additionally,
the closest cumulative project to the proposed project is the Vista Maderas Subdivision project located
approximately 0.9 miles east of the proposed project and at a higher elevation. Due to the distance and topography,
any potential light and glare associated with this cumulative project would not result in considerable cumulative
impacts in conjunction with the proposed project. Therefore, impacts would be less than significant and the
proposed project would not result in a cumulatively considerable impact related to light and glare.
4.1.6 Mitigation Measures
Implementation of the proposed project would not result in significant impacts to aesthetics. Therefore, no
mitigation would be required.
4.1.7 Other Considerations
Recognizing there is a great deal of public interest and concern regarding changes in the visual environment resulting
from implementation of the proposed project, the following discussion provides a description of the visual simulations
prepared to help conceptualize views of the proposed project from surrounding public vantage points or Key Observation
Points (KOPs). An overview of KOP locations is included as Figure 4.1-1, KOP Locations. The following discussion is for
informational purposes only and is not required by CEQA for determination of environmental impacts. As a result, the
visual simulations and information provided below are for the benefit of the public and decision makers.
KOP and Visual Simulation 1
As depicted in Figure 4.1-2, Visual Simulation 1: Espola Rd. & Martincoit Rd., KOP 1 is located at the intersection
of Espola Road and Martincoit Road looking north at the main entrance of the proposed project. The proposed
project would improve this intersection into a signalized four-way intersection, as discussed in Chapter 3, Project
Description. The proposed project’s primary entrance, monument signs, proposed Event Barn, and some proposed
Residential Cottage (R-C) housing units would be visible from this location. Additionally, the proposed landscape
setback from Espola Road and nine foot decomposed granite trail can be seen along in the foreground. All on-site
trees seen in the existing view would be removed from the project site.
KOP and Visual Simulation 2
As depicted in Figure 4.1-3, Visual Simulation 2: Tam O’Shanter Dr., KOP 2 is located along Tam O’ Shanter Drive, looking
west towards the middle of the project site. As shown, the primary views of this location would be ornamental landscaping
and trees. The proposed Residential Twin (R-T) housing units located in the middle of the project site would be visible in
the background. The existing fence would be removed. The proposed multi-use trail and some internal roadways can
also be seen beyond the landscaping, which is adjacent to Tam O’ Shanter Drive. The proposed Club area would be
located beyond the Residential Twin units seen in this figure; however, due to the downward sloping topography of the
project site from this location, the proposed Club area would not be visible from Tam O’ Shanter Drive.
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KOP and Visual Simulation 3
As depicted in Figure 4.1-4, Visual Simulation 3: St. Andrews Dr. & Villamoura Dr., KOP 3 is located along Villamoura
Drive, approximately 210 feet southeast of St. Andrews Drive. This view is oriented towards the proposed agrifields,
looking east into the project site. As shown, some low-lying crops and a few trees associated with the proposed
agrifields would be visible from this location. Additionally, the existing fence would be removed and some existing
houses would be visible in the background.
KOP and Visual Simulation 4
As depicted in Figure 4.1-5, Visual Simulation 4: St. Andrews Dr. & Del Paseo Dr., KOP 4 is located at the intersection
of St. Andrews Drive and Del Paseo Drive, looking southwest into the project site. From this location, a proposed
pollinator garden can be seen in the foreground of the project site. The top of this garden is approximately 10 feet
above the grade of the road, as this was previously a Tee box associated with the former StoneRidge golf course. Due
to this grade, views of the proposed Residential Homestead (R-H) housing units beyond this garden would be limited.
However, the top of one proposed residence would be partially visible, as shown.
4.1.8 Level of Significance After Mitigation
As previously stated, all potential impacts to aesthetics as a result of the proposed project would be less than
significant, and no mitigation would be required.
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4.2 Air Quality
This section describes the existing air quality conditions of The Farm in Poway project (proposed project) site and
vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation
measures related to implementation of the proposed project. The analysis is based on the review of existing air
quality; technical data; applicable laws, regulations, and guidelines; and the air quality and greenhouse gas
technical report prepared by Dudek in January 2020. The Air Quality and Greenhouse Gas Emissions Analysis
Technical Report for The Farm in Poway is included in this Environmental Impact Report (EIR) as Appendix B.
A Notice of Preparation (NOP) was circulated from May 10, 2019, to June 10, 2019. During the NOP comment
period, comment letters related to air quality focused on the following topics:
Decreased air quality due to development
Increased vehicle emissions
These comments were considered during the preparation of this EIR. The Initial Study, NOP, and Public Scoping
comments are provided in Appendix A of this EIR.
4.2.1 Existing Conditions
Environmental Setting
The project site is located within the San Diego Air Basin (SDAB) and is subject to the SDAPCD guidelines and
regulations. The SDAB is one of 15 air basins that geographically divide the State of California. The weather of the
San Diego region, as in most of Southern California, is influenced by the Pacific Ocean and its semi-permanent
high-pressure systems that result in dry, warm summers and mild, occasionally wet winters. The average
temperature ranges (in °F) from the mid-40s to the high 90s. Most of the region’s precipitation falls from
November to April with infrequent (approximately 10 percent) precipitation during the summer. The average
seasonal precipitation along the coast is approximately 10 inches; the amount increases with elevation as moist
air is lifted over the mountains to the east.
The topography in the San Diego region varies greatly, from beaches on the west to mountains and desert on the
east. Along with local meteorology, the topography influences the dispersal and movement of pollutants in the
SDAB. The mountains to the east prohibit dispersal of pollutants in that direction and help trap them in inversion
layers as described in the next section.
The interaction of ocean, land, and the Pacific High Pressure Zone maintains clear skies for much of the year and
influences the direction of prevailing winds (westerly to northwesterly). Local terrain is often the dominant factor
inland, and winds in inland mountainous areas tend to blow through the valleys during the day and down the hills
and valleys at night.
Meteorological and Topographical Conditions
The SDAB lies in the southwest corner of California, comprises the entire San Diego region (covering
approximately 4,260 square miles), and is an area of high air pollution potential. The SDAB experiences warm
summers, mild winters, infrequent rainfalls, light winds, and moderate humidity. This usually mild climatological
pattern is interrupted infrequently by periods of extremely hot weather, winter storms, or Santa Ana winds.
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The climate also drives the pollutant levels. The climate of San Diego is classified as Mediterranean, but it is
incredibly diverse due to the topography. The climate is dominated by the Pacific High pressure system that
results in mild, dry summers and mild, wet winters. The Pacific High drives the prevailing winds in the SDAB.
The winds tend to blow onshore during the daytime and offshore at night. In the fall months, the SDAB is often
impacted by Santa Ana winds. These winds are the result of a high pressure system over the Nevada–Utah
region that overcomes the westerly wind pattern and forces hot, dry winds from the east to the Pacific Ocean
(SDAPCD 2015a). The winds blow the air basin’s pollutants out to sea. However, a weak Santa Ana can
transport air pollution from the South Coast Air Basin and greatly increase the San Diego ozone (O3)
concentrations. A strong Santa Ana also primes the vegetation for firestorm conditions.
The SDAB experiences frequent temperature inversions. Subsidence inversions occur during the warmer
months as descending air associated with the Pacific High Pressure Zone meets cool marine air. The
boundary between the two layers of air creates a temperature inversion that traps pollutants. Another type of
inversion, a radiation inversion, develops on winter nights when air near the ground cools by heat radiation
and air aloft remains warm. The shallow inversion layer formed between these two air masses can also trap
pollutants. As the pollutants become more concentrated in the atmosphere, photochemical reactions occur
that produce O3, commonly known as smog.
Light daytime winds, predominantly from the west, further aggravate the condition by driving air pollutants inland, toward
the mountains. During the fall and winter, air quality problems are created due to emissions of carbon monoxide (CO) and
oxides of nitrogen (NOx). CO concentrations are generally higher in the morning and late evening. In the morning, CO levels
are elevated due to cold temperatures and the large number of motor vehicles traveling. Higher CO levels during the late
evenings are a result of stagnant atmospheric conditions trapping CO in the area. Since CO is produced almost entirely
from automobiles, the highest CO concentrations in the basin are associated with heavy traffic. Nitrogen dioxide (NO2)
levels are also generally higher during fall and winter days when O3 concentrations are lower.
The local climate in the southern part of the County of San Diego (County) is characterized as semi-arid with
consistently mild, warmer temperatures throughout the year. The average summertime high temperature in the
region is approximately 86°F. The average wintertime low temperature is approximately 39°F. Average
precipitation in the local area is approximately 13.2 inches per year, with the bulk of precipitation falling between
November and March (WRCC 2017).
Pollutants and Effects
Criteria Air Pollutants
Criteria air pollutants are defined as pollutants for which the federal and state governments have established
ambient air quality standards (criteria) for outdoor concentrations to protect public health. The federal and state
standards have been set, with an adequate margin of safety, at levels above which concentrations could be
harmful to human health and welfare. These standards are designed to protect the most sensitive persons from
illness or discomfort. Pollutants of concern include O3, NO2, CO, sulfur dioxide (SO2), particulate matter with an
aerodynamic diameter less than or equal to 10 microns (PM10), particulate matter with an aerodynamic diameter
less than or equal to 2.5 microns (PM2.5), and lead. These pollutants, as well as toxic air contaminants (TACs), are
discussed in the following paragraphs.1 In California, sulfates, vinyl chloride, hydrogen sulfide, and visibility-
reducing particles are also regulated as criteria air pollutants.
1 The descriptions of each of the criteria air pollutants and associated health effects are based on the EPA’s (2016a) Criteria Air
Pollutants and the CARB (2016a) Glossary of Air Pollutant Terms.
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Ozone. O3 is a strong-smelling, pale blue, reactive, toxic chemical gas consisting of three oxygen atoms. It is a
secondary pollutant formed in the atmosphere by a photochemical process involving the sun’s energy and O3
precursors. These precursors are mainly NOx and volatile organic compounds (VOCs). The maximum effects of
precursor emissions on O3 concentrations usually occur several hours after they are emitted and many miles from
the source. Meteorology and terrain play major roles in O3 formation, and ideal conditions occur during summer and
early autumn on days with low wind speeds or stagnant air, warm temperatures, and cloudless skies. O3 exists in the
upper atmosphere O3 layer (stratospheric ozone) and at the Earth’s surface in the troposphere (ozone).2 The O3 that
the U.S. Environmental Protection Agency (EPA) and the California Air Resources Board (CARB) regulate as a criteria
air pollutant is produced close to the ground level, where people live, exercise, and breathe. Ground-level O3 is a
harmful air pollutant that causes numerous adverse health effects and is, thus, considered “bad” O3. Stratospheric,
or “good,” O3 occurs naturally in the upper atmosphere, where it reduces the amount of ultraviolet light (i.e., solar
radiation) entering the Earth’s atmosphere. Without the protection of the beneficial stratospheric O3 layer, plant and
animal life would be seriously harmed.
O3 in the troposphere causes numerous adverse health effects; short-term exposures (lasting for a few hours) to O3
at levels typically observed in Southern California can result in breathing pattern changes, reduction of breathing
capacity, increased susceptibility to infections, inflammation of the lung tissue, and some immunological changes
(EPA 2013). These health problems are particularly acute in sensitive receptors such as the sick, the elderly, and
young children.
Nitrogen Dioxide and Oxides of Nitrogen. NO2 is a brownish, highly reactive gas that is present in all urban
atmospheres. The major mechanism for the formation of NO2 in the atmosphere is the oxidation of the primary
air pollutant nitric oxide, which is a colorless, odorless gas. NO2 can irritate the lungs, cause bronchitis and
pneumonia, and lower resistance to respiratory infections (EPA 2016b).
NOx plays a major role, together with VOCs, in the atmospheric reactions that produce O3. NOx is formed from
fuel combustion under high temperature or pressure. In addition, NOx is an important precursor to acid rain and
may affect both terrestrial and aquatic ecosystems. The two major emissions sources of NOx are transportation
and stationary fuel combustion sources, such as electric utility and industrial boilers.
Carbon Monoxide. CO is a colorless, odorless gas formed by the incomplete combustion of hydrocarbon, or fossil
fuels. CO is emitted almost exclusively from motor vehicles, power plants, refineries, industrial boilers, ships, aircraft,
and trains. In urban areas, automobile exhaust accounts for the majority of CO emissions. CO is a nonreactive air
pollutant that dissipates relatively quickly; therefore, ambient CO concentrations generally follow the spatial and
temporal distributions of vehicular traffic. CO concentrations are influenced by local meteorological conditions—
primarily wind speed, topography, and atmospheric stability. CO from motor vehicle exhaust can become locally
concentrated when surface-based temperature inversions are combined with calm atmospheric conditions, which is
a typical situation at dusk in urban areas from November to February. The highest levels of CO typically occur during
the colder months of the year, when inversion conditions are more frequent.
In terms of adverse health effects, CO competes with oxygen, often replacing it in the blood, reducing the blood’s
ability to transport oxygen to vital organs. The results of excess CO exposure can include dizziness, fatigue, and
impairment of central nervous system functions.
2 The troposphere is the layer of the Earth’s atmosphere nearest to the surface of the Earth. The troposphere extends outward
about five miles at the poles and about 10 miles at the equator.
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Sulfur Dioxide. SO2 is a colorless, pungent gas formed primarily from incomplete combustion of sulfur-containing
fossil fuels. The main sources of SO2 are coal and oil used in power plants and industries; as such, the highest
levels of SO2 are generally found near large industrial complexes. In recent years, SO2 concentrations have been
reduced by the increasingly stringent controls placed on stationary source emissions of SO2 and limits on the
sulfur content of fuels.
SO2 is an irritant gas that attacks the throat and lungs and can cause acute respiratory symptoms and diminished
ventilator function in children. When combined with particulate matter, SO2 can injure lung tissue and reduce
visibility and the level of sunlight. SO2 can also yellow plant leaves and erode iron and steel.
Particulate Matter. Particulate matter pollution consists of very small liquid and solid particles floating in the air,
which can include smoke, soot, dust, salts, acids, and metals. Particulate matter can form when gases emitted
from industries and motor vehicles undergo chemical reactions in the atmosphere. PM2.5 and PM10 represent
fractions of particulate matter. Coarse particulate matter (PM10) consists of particulate matter that is 10 microns
or less in diameter (about 1/7 the thickness of a human hair). Major sources of PM10 include crushing or grinding
operations; dust stirred up by vehicles traveling on roads; wood-burning stoves and fireplaces; dust from
construction, landfills, and agriculture; wildfires and brush/waste burning; industrial sources; windblown dust
from open lands; and atmospheric chemical and photochemical reactions. Fine particulate matter (PM2.5)
consists of particulate matter that is 2.5 microns or less in diameter (roughly 1/28 the diameter of a human hair).
PM2.5 results from fuel combustion (e.g., from motor vehicles and power generation and industrial facilities),
residential fireplaces, and woodstoves. In addition, PM2.5 can be formed in the atmosphere from gases such as
sulfur oxides (SOx), NOx, and VOCs.
PM2.5 and PM10 pose a greater health risk than larger-size particles. When inhaled, these tiny particles can
penetrate the human respiratory system’s natural defenses and damage the respiratory tract. PM2.5 and PM10 can
increase the number and severity of asthma attacks, cause or aggravate bronchitis and other lung diseases, and
reduce the body’s ability to fight infections. Very small particles of substances such as lead, sulfates, and nitrates
can cause lung damage directly or be absorbed into the blood stream, causing damage elsewhere in the body.
Additionally, these substances can transport adsorbed gases such as chlorides or ammonium into the lungs, also
causing injury. Whereas PM10 tends to collect in the upper portion of the respiratory system, PM2.5 is so tiny that it
can penetrate deeper into the lungs and damage lung tissue. Suspended particulates also damage and discolor
surfaces on which they settle and produce haze and reduce regional visibility.
People with influenza, people with chronic respiratory and cardiovascular diseases, and the elderly may suffer
worsening illness and premature death as a result of breathing particulate matter. People with bronchitis can expect
aggravated symptoms from breathing in particulate matter. Children may experience a decline in lung function due to
breathing in PM10 and PM2.5 (EPA 2009).
Lead. Lead in the atmosphere occurs as particulate matter. Sources of lead include leaded gasoline; the
manufacturing of batteries, paints, ink, ceramics, and ammunition; and secondary lead smelters. Prior to 1978,
mobile emissions were the primary source of atmospheric lead. Between 1978 and 1987, the phaseout of leaded
gasoline reduced the overall inventory of airborne lead by nearly 95 percent. With the phaseout of leaded
gasoline, secondary lead smelters, battery recycling, and manufacturing facilities are becoming lead-emissions
sources of greater concern.
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Prolonged exposure to atmospheric lead poses a serious threat to human health. Health effects associated
with exposure to lead include gastrointestinal disturbances, anemia, kidney disease, and in severe cases,
neuromuscular and neurological dysfunction. Of particular concern are low-level lead exposures during infancy
and childhood. Such exposures are associated with decrements in neurobehavioral performance, including
intelligence quotient performance, psychomotor performance, reaction time, and growth. Children are highly
susceptible to the effects of lead.
Volatile Organic Compounds. Hydrocarbons are organic gases that are formed from hydrogen and carbon and
sometimes other elements. Hydrocarbons that contribute to formation of O3 are referred to and regulated as
VOCs (also referred to as reactive organic gases). Combustion engine exhaust, oil refineries, and fossil-fueled
power plants are the primary sources of hydrocarbons. Other sources of hydrocarbons include evaporation from
petroleum fuels, solvents, dry cleaning solutions, and paint.
The primary health effects of VOCs result from the formation of O3 and its related health effects. High levels of
VOCs in the atmosphere can interfere with oxygen intake by reducing the amount of available oxygen through
displacement. Carcinogenic forms of hydrocarbons, such as benzene, are considered TACs. There are no separate
health standards for VOCs as a group.
Sulfates. Sulfates are the fully oxidized form of sulfur, which typically occur in combination with metals or
hydrogen ions. Sulfates are produced from reactions of SO2 in the atmosphere. Sulfates can result in respiratory
impairment and reduced visibility.
Vinyl Chloride. Vinyl chloride is a colorless gas with a mild, sweet odor that has been detected near landfills, sewage
plants, and hazardous waste sites, due to the microbial breakdown of chlorinated solvents. Short-term exposure to
high levels of vinyl chloride in the air can cause nervous system effects such as dizziness, drowsiness, and headaches.
Long-term exposure through inhalation can cause liver damage, including liver cancer.
Hydrogen Sulfide. Hydrogen sulfide is a colorless and flammable gas that has a characteristic odor of rotten eggs.
Sources of hydrogen sulfide include geothermal power plants, petroleum refineries, sewers, and sewage
treatment plants. Exposure to hydrogen sulfide can result in nuisance odors, as well as headaches and breathing
difficulties at higher concentrations.
Visibility-Reducing Particles. Visibility-reducing particles are any particles in the air that obstruct the range
of visibility. Effects of reduced visibility can include obscuring the viewshed of natural scenery, reducing
airport safety, and discouraging tourism. Sources of visibility-reducing particles are the same as for PM2.5,
described above.
Non-Criteria Air Pollutants
Toxic Air Contaminants. A substance is considered toxic if it has the potential to cause adverse health effects in
humans, including increasing the risk of cancer upon exposure, or acute and/or chronic non-cancer health
effects. A toxic substance released into the air is considered a TAC. TACs are identified by federal and state
agencies based on a review of available scientific evidence. In the State of California, TACs are identified through
a two-step process that was established in 1983 under the Toxic Air Contaminant Identification and Control Act.
This two-step process of risk identification and risk management and reduction was designed to protect residents
from the health effects of toxic substances in the air. In addition, the California Air Toxics “Hot Spots” Information
and Assessment Act, Assembly Bill (AB) 2588, was enacted by the legislature in 1987 to address public concern
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over the release of TACs into the atmosphere. The law requires facilities emitting toxic substances to provide local
air pollution control districts with information that will allow an assessment of the air toxics problem, identification of
air toxics emissions sources, location of resulting hotspots, notification of the public exposed to significant risk,
and development of effective strategies to reduce potential risks to the public over five years.
Examples include certain aromatic and chlorinated hydrocarbons, certain metals, and asbestos. TACs are
generated by a number of sources, including stationary sources, such as dry cleaners, gas stations, combustion
sources, and laboratories; mobile sources, such as automobiles; and area sources, such as landfills. Adverse
health effects associated with exposure to TACs may include carcinogenic (i.e., cancer-causing) and
noncarcinogenic effects. Noncarcinogenic effects typically affect one or more target organ systems and may be
experienced on either short-term (acute) or long-term (chronic) exposure to a given TAC.
Diesel Particulate Matter. Diesel particulate matter (DPM) is part of a complex mixture that makes up diesel
exhaust. Diesel exhaust is composed of two phases, gas and particle, both of which contribute to health risks. More
than 90 percent of DPM is less than one micrometer in diameter (about 1/70th the diameter of a human hair) and,
thus, is a subset of PM2.5 (CARB 2016a). DPM is typically composed of carbon particles (“soot,” also called black
carbon) and numerous organic compounds, including over 40 known cancer-causing organic substances. Examples
of these chemicals include polycyclic aromatic hydrocarbons, benzene, formaldehyde, acetaldehyde, acrolein, and
1,3-butadiene (CARB 2016a). CARB classified “particulate emissions from diesel-fueled engines” (i.e., DPM) (17
CCR 93000) as a TAC in August 1998. DPM is emitted from a broad range of diesel engines, including on-road
diesel engines from trucks, buses, and cars; and off-road diesel engines from locomotives, marine vessels, and
heavy-duty construction equipment, among others. Approximately 70 percent of all airborne cancer risk in California
is associated with DPM (CARB 2000). To reduce the cancer risk associated with DPM, CARB adopted a diesel risk
reduction plan in 2000 (CARB 2000). Because it is part of PM2.5, DPM also contributes to the same non-cancer
health effects as PM2.5 exposure. These effects include premature death; hospitalizations and emergency
department visits for exacerbated chronic heart and lung disease, including asthma; increased respiratory
symptoms; and decreased lung function in children. Several studies suggest that exposure to DPM may also
facilitate development of new allergies (CARB 2016b). Those most vulnerable to non-cancer health effects are
children whose lungs are still developing and the elderly who often have chronic health problems.
Odorous Compounds. Odors are generally regarded as an annoyance rather than a health hazard. Manifestations
of a person’s reaction to odors can range from psychological (e.g., irritation, anger, or anxiety) to physiological
(e.g., circulatory and respiratory effects, nausea, vomiting, and headache). The ability to detect odors varies
considerably among the population and, overall, is quite subjective. People may have different reactions to the
same odor. An odor that is offensive to one person may be perfectly acceptable to another (e.g., coffee roaster).
An unfamiliar odor is more easily detected and is more likely to cause complaints than a familiar one. In a
phenomenon known as odor fatigue, a person can become desensitized to almost any odor, and recognition may
only occur with an alteration in the intensity. The occurrence and severity of odor impacts depend on the nature,
frequency, and intensity of the source; wind speed and direction; and the sensitivity of receptors.
Valley Fever. Coccidioidomycosis, more commonly known as “Valley Fever,” is an infection caused by inhalation of
the spores of the Coccidioides immitis fungus, which grows in the soils of the southwestern United States. The
fungus is very prevalent in the soils of California’s San Joaquin Valley, particularly in Kern County. Kern County is
considered a highly endemic county (i.e., more than 20 cases annually of Valley Fever per 100,000 people) based
on the incidence rates reported through 2016 (California Department of Public Health 2017). The ecologic factors
that appear to be most conducive to survival and replication of the spores are high summer temperatures, mild
winters, sparse rainfall, and alkaline, sandy soils.
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The County is not considered a highly endemic region for Valley Fever, as the latest report from the California
Department of Public Health indicated the County has 4.4 cases per 100,000 people (California Department
of Public Health 2017). Similarly, among the total reported incidents of Valley Fever from 2008 through
2017, only 0.8 percent of the cases reported in the County were in in the City’s zip code (92064) (County of
San Diego 2018).
Sensitive Receptors
Some land uses are considered more sensitive to changes in air quality than others, depending on the population
groups and the activities involved. People most likely to be affected by air pollution include children, the elderly,
athletes, and people with cardiovascular and chronic respiratory diseases. Facilities and structures where these
air pollution-sensitive people live or spend considerable amounts of time are known as sensitive receptors. Land
uses where air pollution-sensitive individuals are most likely to spend time include schools and schoolyards, parks
and playgrounds, daycare centers, nursing homes, hospitals, and residential communities (sensitive sites or
sensitive land uses) (CARB 2005). The SDAPCD identifies sensitive receptors as those who are especially
susceptible to adverse health effects from exposure to TACs, such as children, the elderly, and the ill. Sensitive
receptors include schools (grades Kindergarten through 12), day care centers, nursing homes, retirement homes,
health clinics, and hospitals within two kilometers of the facility (SDAPCD 2015b). The closest sensitive receptors to the
proposed project are residences adjacent to the property boundary.
4.2.2 Relevant Plans, Policies, and Ordinances
Federal
Criteria Air Pollutants
The federal Clean Air Act (CAA), passed in 1970 and last amended in 1990, forms the basis for the national air
pollution control effort. The EPA is responsible for implementing most aspects of the CAA, including the setting
of the National Ambient Air Quality Standards (NAAQS) for major air pollutants, hazardous air pollutant
standards, approval of state attainment plans, motor vehicle emission standards, stationary source emission
standards and permits, acid rain control measures, stratospheric O3 protection, and enforcement provisions.
Under the CAA, NAAQS are established for the following criteria pollutants: O3, CO, NO2, SO2, PM10, PM2.5, and
lead. The NAAQS describe acceptable air quality conditions designed to protect the health and welfare of the
citizens of the nation. The CAA requires the EPA to reassess the NAAQS at least every five years to determine
whether adopted standards are adequate to protect public health based on current scientific evidence. States
with areas that exceed the NAAQS must prepare a State Implementation Plan (SIP) that demonstrates how
those areas will attain the standards within mandated time frames.
Hazardous Air Pollutants
The 1977 federal CAA amendments required the EPA to identify national emission standards for hazardous air
pollutants to protect public health and welfare. Hazardous air pollutants include certain VOCs, pesticides,
herbicides, and radionuclides that present a tangible hazard, based on scientific studies of exposure to
humans and other mammals. Under the 1990 CAA amendments, which expanded the control program for
hazardous air pollutants, 189 substances and chemical families were identified as hazardous air pollutants.
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State
Criteria Air Pollutants
The federal CAA delegates the regulation of air pollution control and the enforcement of the NAAQS to the states.
In California, the task of air quality management and regulation has been legislatively granted to CARB, with
subsidiary responsibilities assigned to air quality management districts and air pollution control districts at the
regional and county levels. CARB, which became part of the California Environmental Protection Agency in 1991,
is responsible for ensuring implementation of the California Clean Air Act of 1988, responding to the CAA and
regulating emissions from motor vehicles and consumer products.
CARB has established California Ambient Air Quality Standards (CAAQS), which are generally more restrictive than
the NAAQS. The CAAQS describe adverse conditions; that is, pollution levels must be below these standards
before a basin can attain the standard. Air quality is considered “in attainment” if pollutant levels are
continuously below the CAAQS and violate the standards no more than once each year. The CAAQS for O3, CO, SO2
(one-hour and 24-hour), NO2, PM10, PM2.5, and visibility-reducing particles are values that are not to be exceeded.
All others are not to be equaled or exceeded. The NAAQS and CAAQS are presented in Table 4.2-1.
Table 4.2-1. Ambient Air Quality Standards
Pollutant Averaging Time
California Standardsa National Standardsb
Concentrationc Primaryc,d Secondaryc,e
O3 1 hour 0.09 ppm (180 g/m3) — Same as Primary
Standardf 8 hours 0.070 ppm (137 g/m3) 0.070 ppm (137
g/m3)f
NO2g 1 hour 0.18 ppm (339 g/m3) 0.100 ppm (188
g/m3)
Same as Primary
Standard
Annual Arithmetic
Mean 0.030 ppm (57 g/m3) 0.053 ppm (100
g/m3)
CO 1 hour 20 ppm (23 mg/m3) 35 ppm (40 mg/m3) None
8 hours 9.0 ppm (10 mg/m3) 9 ppm (10 mg/m3)
SO2h 1 hour 0.25 ppm (655 g/m3) 0.075 ppm (196
g/m3)
—
3 hours — — 0.5 ppm (1,300
g/m3)
24 hours 0.04 ppm (105 g/m3) 0.14 ppm (for certain
areas)g
—
Annual — 0.030 ppm (for certain
areas)g
—
PM10i 24 hours 50 g/m3 150 g/m3 Same as Primary
Standard Annual Arithmetic
Mean
20 g/m3 —
PM2.5i 24 hours — 35 g/m3 Same as Primary
Standard
Annual Arithmetic
Mean 12 g/m3 12.0 g/m3 15.0 g/m3
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Table 4.2-1. Ambient Air Quality Standards
Pollutant Averaging Time
California Standardsa National Standardsb
Concentrationc Primaryc,d Secondaryc,e
Leadj,k 30-day Average 1.5 g/m3 — —
Calendar Quarter — 1.5 g/m3 (for certain
areas)k
Same as Primary
Standard
Rolling 3-Month
Average
— 0.15 g/m3
Hydrogen
sulfide
1 hour 0.03 ppm (42 µg/m3) — —
Vinyl
chloridej
24 hours 0.01 ppm (26 µg/m3) — —
Sulfates 24 hours 25 µg/m3 — —
Visibility
reducing
particles
8 hour (10 a.m. to 6
p.m. PST)
Insufficient amount to
produce an extinction
coefficient of 0.23 per
kilometer due to the number
of particles when the relative
humidity is less than 70
percent
— —
Source: CARB 2016b; EPA 2016c.
Notes: O3 = ozone; ppm = parts per million by volume; g/m3 = micrograms per cubic meter; NO2 = nitrogen dioxide; CO = carbon
monoxide; mg/m3= milligrams per cubic meter; SO2 = sulfur dioxide; PM10 = particulate matter with an aerodynamic diameter less
than or equal to 10 microns; PM2.5 = particulate matter with an aerodynamic diameter less than or equal to 2.5 microns.
a California standards for O3, CO, SO2 (one-hour and 24-hour), NO2, suspended particulate matter (PM10, PM2.5), and visibility-
reducing particles are values that are not to be exceeded. All others are not to be equaled or exceeded. California Ambient Air
Quality Standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations.
b National standards (other than O3, NO2, SO2, particulate matter, and those based on annual averages or annual arithmetic
mean) are not to be exceeded more than once per year. The O3 standard is attained when the fourth highest eight-hour
concentration measured at each site in a year, averaged over three years, is equal to or less than the standard. For PM10, the
24-hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above
150 µg/m3 is equal to or less than one. For PM2.5, the 24-hour standard is attained when 98 percent of the daily
concentrations, averaged over 3 years, are equal to or less than the standard.
c Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based on a reference
temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference
temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant
per mole of gas.
d National Primary Standards: The levels of air quality necessary, with an adequate margin of safety, to protect the public health.
e National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated
adverse effects of a pollutant.
f On October 1, 2015, the national eight-hour O3 primary and secondary standards were lowered from 0.075 to 0.070 ppm.
g To attain the national one-hour standard, the three-year average of the annual 98th percentile of the one-hour daily maximum
concentrations at each site must not exceed 100 parts per billion (ppb). Note that the national one-hour standard is in units of
ppb. California standards are in units of ppm. To directly compare the national one-hour standard to the California standards,
the units can be converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 ppm.
h On June 2, 2010, a new one-hour SO2 standard was established, and the existing 24-hour and annual primary standards were
revoked. To attain the national one-hour standard, the three-year average of the annual 99th percentile of the one-hour daily
maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in
effect until one year after an area is designated for the 2010 standard, except that in areas designated nonattainment of the 1971
standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved.
i On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 g/m3 to 12 g/m3. The existing
national 24-hour PM2.5 standards (primary and secondary) were retained at 35 g/m3, as was the annual secondary standard of
15 μg/m3. The existing 24-hour PM10 standards (primary and secondary) of 150 g/m3 were also retained. The form of the
annual primary and secondary standards is the annual mean averaged over three years.
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j California Air Resources Board has identified lead and vinyl chloride as toxic air contaminants with no threshold level of exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below
the ambient concentrations specified for these pollutants.
k The national standard for lead was revised on October 15, 2008, to a rolling three-month average. The 1978 lead standard (1.5
μg/m3 as a quarterly average) remains in effect until one year after an area is designated for the 2008 standard, except that in
areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to
attain or maintain the 2008 standard are approved.
Toxic Air Contaminants
A TAC is defined by California law as an air pollutant that may cause or contribute to an increase in mortality or an
increase in serious illness, or which may pose a present or potential hazard to human health. Federal laws use
the hazardous air pollutants to refer to the same types of compounds that are referred to as TACs under state
law. California regulates TACs primarily through the Tanner Air Toxics Act (AB 1807) and the Air Toxics Hot Spots
Information and Assessment Act of 1987 (AB 2588).
AB 1807 sets forth a formal procedure for CARB to designate substances as TACs. This includes research,
public participation, and scientific peer review before CARB can designate a substance as a TAC. Pursuant to
AB 2588, existing facilities that emit air pollutants above specified levels were required to (1) prepare a TAC
emission inventory plan and report; (2) prepare a risk assessment if TAC emissions were significant; (3)
notify the public of significant risk levels; and (4) if health impacts were above specified levels, prepare and
implement risk reduction measures.
The following regulatory measures pertain to the reduction of DPM and criteria pollutant emissions from off-road
equipment and diesel-fueled vehicles.
Idling of Commercial Heavy Duty Trucks (13 CCR 2485)
In July 2004, CARB adopted an Airborne Toxic Control Measure (ATCM) to control emissions from idling trucks.
The ATCM prohibits idling for more than five minutes for all commercial trucks with a gross vehicle weight rating
over 10,000 pounds. The ATCM contains an exception that allows trucks to idle while queuing or involved in
operational activities.
In-Use Off-Road Diesel-Fueled Fleets (13 CCR 2449 et seq.)
In July 2007, CARB adopted an ATCM for in-use off-road diesel vehicles. This regulation requires that specific fleet
average requirements are met for NOx emissions and for particulate matter emissions. Where average
requirements cannot be met, best available control technology requirements apply. The regulation also includes
several recordkeeping and reporting requirements.
In response to AB 8 2X, the regulations were revised in July 2009 (effective December 3, 2009) to allow a partial
postponement of the compliance schedule in 2011 and 2012 for existing fleets. On December 17, 2010, CARB
adopted additional revisions to further delay the deadlines reflecting reductions in diesel emissions due to the
poor economy and overestimates of diesel emissions in California. The revisions delayed the first compliance date
until no earlier than January 1, 2014, for large fleets, with final compliance by January 1, 2023. The compliance
dates for medium fleets were delayed until an initial date of January 1, 2017, and final compliance date of
January 1, 2023. The compliance dates for small fleets were delayed until an initial date of January 1, 2019, and
final compliance date of January 1, 2028. Correspondingly, the fleet average targets were made more stringent in
future compliance years. The revisions also accelerated the phaseout of older equipment with newer equipment
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added to existing large and medium fleets over time, requiring the addition of Tier 2 or higher engines starting on
March 1, 2011, with some exceptions: Tier 2 or higher engines on January 1, 2013, without exception; and Tier 3
or higher engines on January 1, 2018 (January 1, 2023, for small fleets).
On October 28, 2011 (effective December 14, 2011), the Executive Officer approved amendments to the regulation.
The amendments included revisions to the applicability section and additions and revisions to the definition. The initial
date for requiring the addition of Tier 2 or higher engines for large and medium fleets, with some exceptions, was
revised to January 1, 2012. New provisions also allow for the removal of emission control devices for safety or visibility
purposes. The regulation also was amended to combine the particulate matter and NOx fleet average targets under
one, instead of two, sections. The amended fleet average targets are based on the fleet’s NOx fleet average, and the
previous section regarding particulate matter performance requirements was deleted completely. The best available
control technology requirements, if a fleet cannot comply with the fleet average requirements, were restructured and
clarified. Other amendments to the regulations included minor administrative changes to the regulatory text.
In-Use On-Road Diesel-Fueled Vehicles (13 CCR 2025)
On December 12, 2008, CARB adopted an ATCM to reduce NOx and particulate matter emissions from most in-
use on-road diesel trucks and buses with a gross vehicle weight rating greater than 14,000 pounds. The original
ATCM regulation required fleets of on-road trucks to limit their NOx and particulate matter emissions through a
combination of exhaust retrofit equipment and new vehicles. The regulation limited particulate matter emissions
for most fleets by 2011, and limited NOx emissions for most fleets by 2013. The regulation did not require any
vehicle to be replaced before 2012 and never required all vehicles in a fleet be replaced.
In December 2009, the CARB Governing Board directed staff to evaluate amendments that would provide additional
flexibility for fleets adversely affected by the struggling California economy. On December 17, 2010, CARB revised this
ATCM to delay its implementation along with limited relaxation of its requirements. Starting on January 1, 2015, lighter
trucks with a gross vehicle weight rating of 14,001 to 26,000 pounds with 20-year-old or older engines need to be
replaced with newer trucks (2010 model year emissions equivalent as defined in the regulation). Trucks with a gross
vehicle weight rating greater than 26,000 pounds with 1995 model year or older engines needed to be replaced as of
January 1, 2015. Trucks with 1996 to 2006 model year engines must install a Level 3 (85 percent control) diesel
particulate filter starting on January 1, 2012, to January 1, 2014, depending on the model year, and then must be
replaced after eight years. Trucks with 2007 to 2009 model year engines have no requirements until 2023, at which
time they must be replaced with 2010 model year emissions-equivalent engines, as defined in the regulation. Trucks
with 2010 model year engines would meet the final compliance requirements. The ATCM provides a phase-in option
under which a fleet operator would equip a percentage of trucks in the fleet with diesel particulate filters, starting at 30
percent as of January 1, 2012, with 100 percent by January 1, 2016. Under each option, delayed compliance is
granted to fleet operators who have or will comply with requirements before the required deadlines.
On September 19, 2011 (effective December 14, 2011), the Executive Officer approved amendments to the
regulations, including revisions to the compliance schedule for vehicles with a gross vehicle weight rating of
26,000 pounds or less to clarify that all vehicles must be equipped with 2010 model year emissions equivalent
engines by 2023. The amendments included revised and additional credits for fleets that have downsized;
implement early particulate matter retrofits; incorporate hybrid vehicles, alternative-fueled vehicles, and vehicles
with heavy-duty pilot ignition engines; and implement early addition of newer vehicles. The amendments included
provisions for additional flexibility, such as for low-usage construction trucks, and revisions to previous
exemptions, delays, and extensions. Other amendments to the regulations included minor administrative changes
to the regulatory text, such as recordkeeping and reporting requirements related to other revisions.
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California Health and Safety Code Section 41700
Section 41700 of the California Health and Safety Code states that a person shall not discharge from any source
whatsoever quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance
to any considerable number of persons or to the public, or that endanger the comfort, repose, health, or safety of
any of those persons or the public, or that cause, or have a natural tendency to cause, injury or damage to
business or property. This section also applies to sources of objectionable odors.
Local
San Diego Air Pollution Control District
While CARB is responsible for the regulation of mobile emission sources within the state, local air quality
management districts and air pollution control districts are responsible for enforcing standards and regulating
stationary sources. The proposed project area is located within the SDAB and is subject to the guidelines and
regulations of the SDAPCD.
In the County, O3 and particulate matter are the pollutants of main concern, since exceedances of state
ambient air quality standards for those pollutants have been observed in most years. For this reason, the
SDAB has been designated as a nonattainment area for the state PM10, PM2.5, and O3 standards. The SDAB
is also a federal O3 attainment (maintenance) area for 1997 eight-hour O3 standard, an O3 nonattainment
area for the 2008 eight-hour O3 standard, and a CO maintenance area (western and central part of the SDAB
only, including the proposed project area).
Federal Attainment Plans
In December 2016, the SDAPCD adopted an update to the Eight-Hour Ozone Attainment Plan for San Diego
County (2008 O3 NAAQS), which indicated that local controls and state programs would allow the region to reach
attainment of the federal eight-hour O3 standard (1997 O3 NAAQS) by 2018 (SDAPCD 2016a). In this plan,
SDAPCD relies on the Regional Air Quality Strategy (RAQS) to demonstrate how the region will comply with the
federal O3 standard. The RAQS details how the region will manage and reduce O3 precursors (NOx and VOCs) by
identifying measures and regulations intended to reduce these pollutants. The control measures identified in the
RAQS generally focus on stationary sources; however, the emissions inventories and projections in the RAQS
address all potential sources, including those under the authority of CARB and the EPA. Incentive programs for
reduction of emissions from heavy-duty diesel vehicles, off-road equipment, and school buses are also
established in the RAQS.
Currently, the County is designated as moderate nonattainment for the 2008 NAAQS and maintenance for the 1997
NAAQS. As documented in the 2016 Eight-Hour Ozone Attainment Plan for San Diego County, the County has a likely
chance of obtaining attainment due to the transition to low-emission cars, stricter new source review rules, and
continuing the requirement of general conformity for military growth and the San Diego International Airport. The
County will also continue emission control measures, including ongoing implementation of existing regulations in O3
precursor reduction to stationary and area-wide sources, subsequent inspections of facilities and sources, and the
adoption of laws requiring best available retrofit control technology for control of emissions (SDAPCD 2016a).
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State Attainment Plans
The SDAPCD and the San Diego Association of Governments (SANDAG) are responsible for developing and
implementing the clean air plan for attainment and maintenance of the ambient air quality standards in the
SDAB. The RAQS for the SDAB was initially adopted in 1991 and is updated on a triennial basis, most recently in
2016 (SDAPCD 2016b). The RAQS outlines SDAPCD’s plans and control measures designed to attain the state air
quality standards for O3. The RAQS relies on information from CARB and SANDAG, including mobile and area
source emissions, as well as information regarding projected growth in the County and the cities in the County, to
forecast future emissions and then determine from that the strategies necessary for the reduction of emissions
through regulatory controls. CARB mobile source emission projections and SANDAG growth projections are based
on population, vehicle trends, and land use plans developed by the County and the cities in the County as part of
the development of their general plans (SANDAG 2017a, 2017b).
In December 2016, the SDAPCD adopted the revised RAQS for the County. Since 2007, the San Diego region
reduced daily VOC emissions and NOx emissions by 3.9 percent and 7.0 percent, respectively; the SDAPCD
expects to continue reductions through 2035 (SDAPCD 2016b). These reductions were achieved through
implementation of six VOC control measures and three NOx control measures adopted in the SDAPCD’s 2009
RAQS (SDAPCD 2009a); in addition, the SDAPCD is considering additional measures, including three VOC
measures and four control measures to reduce 0.3 daily tons of VOC and 1.2 daily tons of NOx, provided they are
found to be feasible region-wide. In addition, SDAPCD has implemented nine incentive-based programs, has
worked with SANDAG to implement regional transportation control measures, and has reaffirmed the state
emission offset repeal.
In regards to particulate matter emissions-reduction efforts, in December 2005, the SDAPCD prepared a report
titled Measures to Reduce Particulate Matter in San Diego County to address implementation of Senate Bill (SB)
656 in the County (SB 656 required additional controls to reduce ambient concentrations of PM10 and PM2.5)
(SDAPCD 2005). In the report, SDAPCD evaluated implementation of source-control measures that would reduce
particulate matter emissions associated with residential wood combustion; various construction activities
including earthmoving, demolition, and grading; bulk material storage and handling; carry-out and track-out
removal and cleanup methods; inactive disturbed land; disturbed open areas; unpaved parking lots/staging
areas; unpaved roads; and windblown dust (SDAPCD 2005).
SDAPCD Rules and Regulations
As stated above, the SDAPCD is responsible for planning, implementing, and enforcing federal and state ambient
standards in the SDAB. The following rules and regulations apply to all sources in the jurisdiction of SDAPCD and
would apply to the proposed project.
SDAPCD Regulation II: Permits; Rule 20.2: New Source Review Non-Major Stationary Sources
This rule requires new or modified stationary source units (that are not major stationary sources) with the potential
to emit 10 pounds per day or more of VOC, NOx, SOx, or PM10 to be equipped with best available control technology.
For those units with a potential to emit above Air Quality Impact Assessments Trigger Levels, the units must
demonstrate that such emissions would not violate or interfere with the attainment of any national air quality
standard (SDAPCD 2016b).
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The proposed project does not propose specific stationary sources. If stationary sources were to be included as part
of the proposed project, or at a later date, those sources would be subject to Rule 20.2 and would require
appropriate operating permits from the SDAPCD. Because the SDAPCD has not adopted specific criteria air pollutant
thresholds for CEQA analyses, the thresholds identified in Rule 20.2 are utilized in this analysis as screening-level
thresholds to evaluate project-level impacts, as discussed in Section 4.2.3, Thresholds of Significance.
SDAPCD Regulation IV: Prohibitions; Rule 50: Visible Emissions
This rule prohibits discharge into the atmosphere from any single source of emissions whatsoever any air
contaminant for a period or periods aggregating more than three minutes in any period of 60 consecutive
minutes, which is darker in shade than that designated as Number 1 on the Ringelmann Chart, as published by
the United States Bureau of Mines, or of such opacity as to obscure an observer’s view to a degree greater than
does smoke of a shade designated as Number 1 on the Ringelmann Chart (SDAPCD 1997).
Construction of the proposed project may result in visible emissions, primarily during earth-disturbing activities,
which would be subject to SDAPCD Rule 50. Although visible emissions are less likely to occur during operation of
the proposed project, compliance with SDAPCD Rule 50 would be required during both construction and
operational phases.
SDAPCD Regulation IV: Prohibitions; Rule 51: Nuisance
This rule prohibits the discharge, from any source, of such quantities of air contaminants or other materials that
cause or have a tendency to cause injury, detriment, nuisance, annoyance to people and/or the public, or damage
to any business or property (SDAPCD 1969).
Any criteria air pollutant emissions, TAC emissions, or odors that would be generated during construction or
operation of the proposed project would be subject to SDAPCD Rule 51. Violations can be reported to the SDAPCD
in the form of an air quality complaint by telephone, email, and online form. Complaints are investigated by the
SDAPCD as soon as possible.
SDAPCD Regulation IV: Prohibitions; Rule 55: Fugitive Dust
This rule regulates fugitive dust emissions from any commercial construction or demolition activity capable of
generating fugitive dust emissions, including active operations, open storage piles, and inactive disturbed areas, as
well as track-out and carry-out onto paved roads beyond a project area (SDAPCD 2009b).
Construction of the proposed project, primarily during earth-disturbing activities, may result in fugitive dust
emissions that would be subject to SDAPCD Rule 55. Fugitive dust emissions are not anticipated during operation
of the proposed project.
SDAPCD Regulation IV: Prohibitions; Rule 67.0.1: Architectural Coatings
This rule requires manufacturers, distributors, and end users of architectural and industrial maintenance coatings to
reduce VOC emissions from the use of these coatings, primarily by placing limits on the VOC content of various coating
categories (SDAPCD 2015b). Construction and operation of the proposed project would include application of
architectural coatings (e.g., paint and other finishes), which are subject to SDAPCD Rule 67.0.1. Architectural coatings
used in the reapplication of coatings during operation of the proposed project would be subject to the VOC content
limits identified in SDAPCD Rule 67.0.1, which applies to coatings manufactured, sold, or distributed within the County.
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SDAPCD Regulation XII: Toxic Air Contaminants; Rule 1200: Toxic Air Contaminants - New Source Review
This rule requires new or modified stationary source units with the potential to emit TACs above rule threshold
levels to either demonstrate that they will not increase the maximum incremental cancer risk above one in 1
million at every receptor location; demonstrate that toxics best available control technology will be employed if
maximum incremental cancer risk is equal to or less than 10 in 1 million; or demonstrate compliance with the
SDAPCD’s protocol for those sources with an increase in maximum incremental cancer risk at any receptor
location of greater than 10 in 1 million but less than 100 in 1 million (SDAPCD 2017a).
The proposed project does not currently include specific stationary sources that would generate TACs that are not
commonly associated with residential and commercial development projects. If stationary sources with the
potential to emit TACs were to be included as part of the proposed project—or if they were added at a later date—
those sources would be subject to SDAPCD Rule 1200, and would be subject to new source review requirements.
SDAPCD Regulation XII: Toxic Air Contaminants; Rule 1210: Toxic Air Contaminant Public Health Risks –Public
Notification and Risk Reduction
This rule requires each stationary source required to prepare a public risk assessment to provide written public
notice of risks at or above the following levels: maximum incremental cancer risks equal to or greater than 10 in 1
million, cancer burden equal to or greater than 1.0, total acute non-cancer health hazard index equal to or greater
than 1.0, or total chronic non-cancer health hazard index equal to or greater than 1.0 (SDAPCD 2017b).
The proposed project does not currently include specific stationary sources that would generate TACs. If stationary
sources with the potential to emit TACs were to be included as part of the proposed project—or if they were added
at a later date—those sources would be subject to SDAPCD Rule 1210 and would be subject to public notification
and risk reduction requirements.
San Diego Association of Governments
SANDAG is the regional planning agency for the County and serves as a forum for regional issues relating to
transportation, the economy, community development, and the environment. SANDAG serves as the federally
designated metropolitan planning organization for the County. With respect to air quality planning and other
regional issues, SANDAG has prepared San Diego Forward: The Regional Plan (Regional Plan) for the San Diego
region (SANDAG 2015). The Regional Plan combines the big-picture vision for how the region will grow over the
next 35 years with an implementation program to help make that vision a reality. The Regional Plan, including its
Sustainable Communities Strategy (SCS), is built on an integrated set of public policies, strategies, and
investments to maintain, manage, and improve the transportation system so that it meets the diverse needs of
the San Diego region through 2050.
In regards to air quality, the Regional Plan sets the policy context in which SANDAG participates in and responds
to the air district’s air quality plans and builds off the air district’s air quality plan processes that are designed to
meet health-based criteria pollutant standards in several ways (SANDAG 2015). First, it complements air quality
plans by providing guidance and incentives for public agencies to consider best practices that support the
technology-based control measures in air quality plans. Second, the Regional Plan emphasizes the need for better
coordination of land use and transportation planning, which heavily influences the emissions inventory from the
transportation sectors of the economy. This also minimizes land use conflicts, such as residential development
near freeways, industrial areas, or other sources of air pollution.
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On September 23, 2016, SANDAG’s Board of Directors adopted the final 2016 Regional Transportation Improvement
Program, which is a multi-billion dollar, multi-year program of proposed major transportation projects in the San Diego
region. Transportation projects funded with federal, state, and TransNet (the San Diego transportation sales tax
program) must be included in an approved Regional Transportation Improvement Program. The programming of locally
funded projects also may be programmed at the discretion of the agency. The 2016 Regional Transportation
Improvement Program covers five fiscal years and incrementally implements the Regional Plan (SANDAG 2016).
Poway Comprehensive Plan: General Plan
The Poway Comprehensive Plan: General Plan (General Plan) includes the following policy and strategies to limit
air pollution (City of Poway 1991):
Policy E – Air, Water and Soil Pollution: The City shall work locally and at the regional level to reduce air, water,
and soil pollution within Poway.
Strategy 1: Work closely with regional agencies to help control all forms of pollution.
Strategy 2: Seek to promote a development pattern that reduces daily trips for shopping, school,
and recreation.
Strategy 3: Encourage ridesharing, the use of transit and other transportation systems management
programs to reduce the number of vehicle miles traveled and traffic congestion.
Strategy 4: Consider the use of clean fuel systems for new local government fleet vehicles.
Strategy 5: Implement plans and programs to phase-in energy conservation improvements.
Strategy 6: Investigate incentives and regulations to reduce emissions from swimming pools, residential
and commercial water heating and heaters.
4.2.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to air quality are based on Appendix G of the CEQA
Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to air quality would occur
if the project would:
1. Conflict with or obstruct implementation of the applicable air quality plan.
2. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is
non-attainment under an applicable federal or state ambient air quality standard.
3. Expose sensitive receptors to substantial pollutant concentrations.
4. Result in other emissions (such as those leading to odors) adversely affecting a substantial number
of people.
Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.) indicates that, where available, the significance
criteria established by the applicable air quality management district or air pollution control district may be relied
upon to determine whether the project would have a significant impact on air quality.
As part of its air quality permitting process, the SDAPCD has established thresholds in Rule 20.2 requiring the
preparation of Air Quality Impact Assessments for permitted stationary sources (SDAPCD 2016c). The SDAPCD
sets forth quantitative emissions thresholds below which a stationary source would not have a significant impact
on ambient air quality. Project-related air quality impacts estimated in this environmental analysis would be
considered significant if any of the applicable significance thresholds presented in Table 4.2-2 are exceeded.
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Table 4.2-2. San Diego Air Pollution Control District Air Quality Significance Thresholds
Construction Emissions
Pollutant Total Emissions (Pounds per Day)
Respirable Particulate Matter (PM10) 100
Fine Particulate Matter (PM2.5) 55
Oxides of Nitrogen (NOx) 250
Oxides of Sulfur (SOx) 250
Carbon Monoxide (CO) 550
Volatile Organic Compounds (VOCs) 75a
Operational Emissions
Pollutant
Total Emissions
Pounds per Hour Pounds per Day Tons per Year
PM10 — 100 15
PM2.5 — 55 10
NOx 25 250 40
SOx 25 250 40
CO 100 550 100
Operational Emissions
Pollutant
Total Emissions
Pounds per Hour Pounds per Day Tons per Year
Lead and Lead Compounds — 3.2 0.6
VOCs — 75a 13.7
Sources: SDAPCD 1995; SDAPCD 2016b.
Notes: — = not available.
a VOC threshold based on the threshold of significance for VOCs from the South Coast Air Quality Management District for the
Coachella Valley as stated in the San Diego County Guidelines for Determining Significance.
The thresholds listed in Table 4.2-2 represent screening-level thresholds that can be used to evaluate whether
project-related emissions could cause a significant impact on air quality. Emissions below the screening-level
thresholds would not cause a significant impact. For nonattainment pollutants, if emissions exceed the thresholds
shown in Table 4.2-2, the proposed project could have the potential to result in a cumulatively considerable net
increase in these pollutants and, thus, could have a significant impact on the ambient air quality.
With respect to odors, SDAPCD Rule 51 (Public Nuisance) prohibits emission of any material that causes nuisance
to a considerable number of persons or endangers the comfort, health, or safety of any person. A project that
proposes a use that would produce objectionable odors would be deemed to have a significant odor impact if it
would affect a considerable number of off-site receptors.
The SDAPCD document, Supplemental Guidelines for Submission of Air Toxics “Hot Spots” Program Health Risk
Assessments, provides guidance with which to perform health risk assessments (HRAs) within the SDAB. The
current SDAPCD thresholds of significance for TAC emissions from the operations of both permitted and non-
permitted sources are combined and are less than 10 in 1 million for cancer and less than one for the chronic
hazard index (SDAPCD 2015c).
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4.2.4 Impacts Analysis
Would the project conflict with or obstruct implementation of the applicable air quality plan?
The SDAPCD and SANDAG are responsible for developing and implementing the clean air plans for attainment
and maintenance of the ambient air quality standards in the basin—specifically, the SIP and RAQS.3 The federal
O3 maintenance plan, which is part of the SIP, was adopted in 2012. The most recent O3 attainment plan was
adopted in 2016. The SIP includes a demonstration that current strategies and tactics will maintain acceptable
air quality in the SDAB based on the NAAQS. The RAQS was initially adopted in 1991 and is updated on a triennial
basis (most recently in 2016). The RAQS outlines SDAPCD’s plans and control measures designed to attain the
state air quality standards for O3. The SIP and RAQS rely on information from CARB and SANDAG, including mobile
and area source emissions, as well as information regarding projected growth in the County as a whole and the
cities in the County, to project future emissions and determine the strategies necessary for the reduction of
emissions through regulatory controls. CARB mobile source emission projections and SANDAG growth projections
are based on population, vehicle trends, and land use plans developed by the County and the cities in the County
as part of the development of their general plans.
If a project proposes development that is greater than that anticipated in the local plan and SANDAG’s growth
projections, the project might be in conflict with the SIP and RAQS and may contribute to a potentially significant
cumulative impact on air quality. The project site is designated as “Open Space” in the City’s General Plan, and is
zoned as “Open Space – Recreation (OS-R)” (City of Poway 1991). Therefore, the proposed project would not be
consistent with the land use zoning for the site. However, a General Plan amendment and zoning amendment
would be processed concurrently with The Farm in Poway Specific Plan (Specific Plan) to re-designate the project
site as “Planned Community (PC-9)” (The Farm in Poway LLC 2020).
Implementation of the proposed project would result in an increase in 160 residential units, as well as additional
open space and amenities as described in the Specific Plan (The Farm in Poway LLC 2020). SANDAG’s 2050
Regional Growth Forecast, was adopted in October 2013 and is the current growth forecast; it estimates that the
City would have 16,855 units in 2020 and 17,685 units in 2035 (SANDAG 2013). This would equate to an
additional 55 units per year from 2020 to 2035. The proposed project is expected to bring 160 units to market in
2025. However, the units would be released to the public in phases as they are constructed and on average
would result in the addition of 40 units per year; thus falling within SANDAG’s growth projection for housing for
that year. Therefore, while the proposed project would not be consistent with the current land use designation for
the site, the proposed project would not conflict with SANDAG’s regional growth forecast for the City, which
accounts for residential growth in the City.
While the SDAPCD and City do not provide guidance regarding the analysis of impacts associated with air quality
plan conformance, the County’s Guidelines for Determining Significance and Report and Format and Content
Requirements – Air Quality does discuss conformance with the RAQS (County of San Diego 2007). The guidance
indicates that if a project, in conjunction with other projects, contributes to growth projections that would not
exceed SANDAG’s growth projections for the City, the project would not be in conflict with the RAQS (County of San
Diego 2007). As previously discussed, the proposed project would not contribute to growth in the region that is
not already accounted for. Therefore, impacts would be less than significant.
3 For the purpose of this discussion, the relevant federal air quality plan is the ozone maintenance plan (SDAPCD 2012). The
RAQS is the applicable plan for purposes of state air quality planning. Both plans reflect growth projections in the SDAB.
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Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project
region is non-attainment under an applicable federal or state ambient air quality standard?
Air pollution is largely a cumulative impact. The nonattainment status of regional pollutants is a result of past and
present development, and the SDAPCD develops and implements plans for future attainment of ambient air
quality standards. Based on these considerations, project-level thresholds of significance for criteria pollutants
are relevant in the determination of whether a project’s individual emissions would have a cumulatively significant
impact on air quality.
Emissions from the construction phase of the proposed project were estimated using the California
Emissions Estimator Model (CalEEMod) Version 2016.3.2 (CAPCOA 2017).
The proposed project would develop 160 single-family homes and a mix of open space and recreational uses. For
the purposes of modeling, it was assumed that construction of the proposed project would commence in January
20214 and would last approximately 48 months, ending in December 2024. The analysis contained herein is based
on the following subset area schedule assumptions (duration of phases is approximate):
Demolition – two months
Site Preparation – six months
Grading – 14 months
Building Construction – 34 months
Paving – 2.5 months
Architectural Coating – 3 months
The majority of the phases listed above would occur concurrently and would not occur sequentially in isolation.
The estimated construction duration was provided by the project applicant. Detailed construction equipment
modeling assumptions are provided in Appendix B.
Construction Emissions
Construction of the proposed project would result in the temporary addition of pollutants to the local airshed
caused by on-site sources (i.e., off-road construction equipment, soil disturbance, and VOC off-gassing) and off-
site sources (worker vehicle trips). Construction emissions can vary substantially day to day, depending on the
level of activity, the specific type of operation, and for dust, the prevailing weather conditions.
Criteria air pollutant emissions associated with construction activity were quantified using CalEEMod. Default
values provided by the program were used where detailed proposed project information was not available. A
detailed depiction of the construction schedule—including information regarding phasing, equipment used during
each phase, haul trucks, vendor trucks, and worker vehicles—is included in Appendix B.
Implementation of the proposed project would generate air pollutant emissions from entrained dust, off-road
equipment, vehicle emissions, asphalt pavement application, and architectural coatings. Entrained dust results
from the exposure of earth surfaces to wind from the direct disturbance and movement of soil, resulting in PM10
4 The analysis assumes a construction start date of January 2021, which represents the earliest date construction would initiate.
Assuming the earliest start date for construction represents the worst-case scenario for criteria air pollutant emissions because
equipment and vehicle emission factors for later years would be slightly less due to more stringent standards for in-use off-road
equipment and heavy-duty trucks, as well as fleet turnover replacing older equipment and vehicles in later years.
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and PM2.5 emissions. The proposed project would be subject to SDAPCD Rule 55, Fugitive Dust Control. This rule
requires that the proposed project take steps to restrict visible emissions of fugitive dust beyond the property line.
Compliance with Rule 55 would limit fugitive dust (PM10 and PM2.5) generated during grading and construction
activities. To account for dust control measures in the calculations, project design feature (PDF) AQ-1 would be
implemented at active sites. PDF AQ-1 would ensure that active sites be watered at least three times daily, a soil
stabilizer would be used, and unpaved road travel would be limited to 15 miles per hour.
Exhaust from internal combustion engines used by construction equipment and worker vehicles would result in
emissions of VOC, NOx, CO, SOx, PM10, and PM2.5. The application of asphalt pavement and architectural coatings
would also produce VOC emissions.
Table 4.2-3 shows the estimated maximum daily construction emissions associated with construction of the
proposed project without mitigation. Complete details of the emissions calculations are provided in Appendix B.
Table 4.2-3. Estimated Maximum Daily Construction Criteria Air Pollutant Emissions
Year
VOC NOx CO SOx PM10 PM2.5
Pounds per day
2021 12.22 264.41 563.41 14.58 27.83 7.40
2022 9.37 73.12 72.59 0.27 78.26 11.23
2023 6.80 51.12 53.64 0.24 75.25 10.27
2024 73.29 50.81 54.36 0.24 77.51 10.54
Maximum 73.29 264.41 563.41 14.58 78.26 11.23
SDAPCD Threshold 75 250 550 250 100 55
Threshold Exceeded? No Yes Yes No No No
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse
particulate matter; PM2.5 = fine particulate matter; SDAPCD = San Diego Air Pollution Control District; CalEEMod = California Emissions Estimator Model.
See Appendix B for complete results.
The values shown are the maximum summer or winter daily emissions results from CalEEMod. Although not considered mitigation,
these emissions reflect the CalEEMod “mitigated” output, which accounts for the required compliance with SDAPCD Rule 55
(Fugitive Dust) and Rule 67.0.1 (Architectural Coatings).
As shown in Table 4.2-3, daily construction emissions would exceed the significance thresholds for NOx and CO.
Therefore, impacts during construction would be potentially significant (Impact AQ-1) and mitigation would be required.
Operational Emissions
Operation of the proposed project would generate VOC, NOx, CO, SOx, PM10, and PM2.5 emissions from mobile
sources (vehicle trips), area sources (consumer products, landscape maintenance equipment), and energy
sources. Pollutant emissions associated with long-term operations were quantified using CalEEMod. Project-
generated mobile source emissions were estimated in CalEEMod based on project-specific trip rates and VMT.
CalEEMod default values were used to estimate emissions from the proposed project area and energy sources.
Table 4.2-4 presents the maximum daily area, energy, and mobile source emissions associated with
operation (Year 2025) of the proposed project. The values shown are the maximum summer or winter daily
emissions results from CalEEMod. Details of the emission calculations are provided in Appendix B.
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Table 4.2-4. Estimated Maximum Daily Operational Criteria Air Pollutant Emissions
Emission Source
VOC NOx CO SOx PM10 PM2.5
Pounds per day
Area 16.90 2.81 14.37 0.02 0.29 0.29
Energy 0.19 1.65 1.05 0.01 0.13 0.13
Mobile 3.51 13.63 41.70 0.16 15.66 4.27
Total 20.60 18.09 57.12 0.19 16.08 4.69
SDAPCD Threshold 75 250 550 250 100 55
Threshold Exceeded? No No No No No No
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse
particulate matter; PM2.5 = fine particulate matter; SDAPCD = San Diego Air Pollution Control District; CalEEMod = California
Emissions Estimator Model.
See Appendix B for complete results.
Negative values are presented in parentheses.
The values shown are the maximum summer or winter daily emissions results from CalEEMod. These emissions reflect the
CalEEMod “mitigated” output, which accounts for compliance with SDAPCD Rule 67.0.1 (Architectural Coatings).
As shown in Table 4.2-4, the combined daily area, energy, and mobile source emissions would not exceed the
SDAPCD’s operational thresholds for VOC, NOx, CO, SOx, PM10, and PM2.5. The SDAB is a nonattainment area for
O3 under the NAAQS and CAAQS. The poor air quality in the SDAB is the result of cumulative emissions from motor
vehicles, off-road equipment, commercial and industrial facilities, and other emission sources. Projects that emit
these pollutants or their precursors (i.e., VOCs and NOx for O3) potentially contribute to poor air quality. In
analyzing cumulative impacts from a project, the analysis must specifically evaluate the project’s contribution to
the cumulative increase in pollutants for which the SDAB is designated as nonattainment for the CAAQS and
NAAQS. If the project does not exceed thresholds and is determined to have less-than-significant project-specific
impacts, it may still contribute to a significant cumulative impact on air quality if the emissions from the project, in
combination with the emissions from other proposed or reasonably foreseeable future projects, are in excess of
established thresholds. However, a project would only be considered to have a significant cumulative impact if the
project’s contribution accounts for a significant proportion of the cumulative total emissions (i.e., it represents a
“cumulatively considerable contribution” to the cumulative air quality impact).
Additionally, for the SDAB, the RAQS serves as the long-term regional air quality planning document for the
purpose of assessing cumulative operational emissions in the basin to ensure the SDAB continues to make
progress toward NAAQS- and CAAQS-attainment status. As such, cumulative projects located in the San Diego
region would have the potential to result in a cumulative impact to air quality if, in combination, they would
conflict with or obstruct implementation of the RAQS. Similarly, individual projects that are inconsistent with the
regional planning documents upon which the RAQS is based would have the potential to result in cumulative
operational impacts if they represent development and population increases beyond regional projections.
The SDAB has been designated as a federal nonattainment area for O3 and a state nonattainment area for O3, PM10,
and PM2.5. The nonattainment status is the result of cumulative emissions from all sources of these air pollutants and
their precursors within the basin. As discussed previously, the proposed project would not exceed significance
thresholds during construction or operation.
Regarding long-term cumulative operational emissions in relation to consistency with local air quality plans, the
SIP and RAQS serve as the primary air quality planning documents for the state and SDAB, respectively. The SIP
and RAQS rely on SANDAG growth projections based on population, vehicle trends, and land use plans developed
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by the cities and the County as part of the development of their general plans. Therefore, projects that propose
development that is consistent with the growth anticipated by local plans would be consistent with the SIP and RAQS
and would not be considered to result in cumulatively considerable impacts from operational emissions. As stated
previously, the proposed project would be consistent with the existing zoning and land use designation for the site
and would not result in significant regional growth that is not accounted for within the RAQS. As a result, the
proposed project would not result in a cumulatively considerable contribution to regional O3 concentrations or other
criteria pollutant emissions. Cumulative impacts would be potentially significant during construction and less than
significant during operation.
Would the project expose sensitive receptors to substantial pollutant concentrations?
Air quality varies as a direct function of the amount of pollutants emitted into the atmosphere, the size and
topography of the air basin, and the prevailing meteorological conditions. Air quality problems arise when the rate
of pollutant emissions exceeds the rate of dispersion. Reduced visibility, eye irritation, and adverse health
impacts upon those persons termed “sensitive receptors” are the most serious hazards of existing air quality
conditions in the area. Some land uses are considered more sensitive to changes in air quality than others,
depending on the population groups and the activities involved. People most likely to be affected by air pollution,
as identified by CARB (2005), include children, the elderly, athletes, and people with cardiovascular and chronic
respiratory diseases. As such, sensitive receptors include residences, schools, playgrounds, childcare centers,
athletic facilities, long-term healthcare facilities, rehabilitation centers, convalescent centers, and retirement
homes. The closest sensitive receptors to the proposed project are residences adjacent to the property boundaries.
The proposed project would also introduce new on-site sensitive receptors (residences) to the area, although CEQA
does not require the analysis of the impacts of the existing environment on the project’s proposed residences.
Health Impacts of Toxic Air Contaminants
“Incremental cancer risk” is the net increased likelihood that a person continuously exposed to concentrations of
TACs resulting from a project over a 9-, 30-, and 70-year exposure period would contract cancer based on the use
of standard Office of Environmental Health Hazard Assessment risk-assessment methodology (OEHHA 2015). In
addition, some TACs have noncarcinogenic effects. TACs that would potentially be emitted during construction
activities would be DPM emitted from heavy-duty construction equipment and heavy-duty trucks. Heavy-duty
construction equipment and diesel trucks are subject to CARB ATCMs to reduce DPM emissions. According to the
Office of Environmental Health Hazard Assessment, HRAs should be based on a 30-year exposure duration based on
typical residency period; however, such assessments should be limited to the period/duration of activities
associated with the project (OEHHA 2015). Thus, the duration of proposed construction activities (approximately 48
months) would only constitute a small percentage of the total long-term exposure period and would not result in
exposure of proximate sensitive receptors to substantial TACs. After proposed construction is completed, there
would be no long-term source of TAC emissions during operation. The agrifields and community garden, which
would be professionally managed, would be considered a land use that is commonly associated with odors due to
the presence of fertilizers, pesticides, and herbicides. The agrifields and community garden would use minimal
amounts of pesticides and fertilizers.
However, as a precautionary measure to ensure the most informational and conservative analysis possible, an
HRA was performed to evaluate the risk from diesel exhaust emissions on existing sensitive receptors from
construction activities. The HRA methodology was described in detail in Section 2.4.2.1 of Appendix B. Table 4.2-
5 summarizes the results of the HRA for proposed project construction.
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Table 4.2-5. Construction Activity Health Risk Assessment Results
Impact Parameter Units Project Impact CEQA Threshold Level of Significance
Cancer Risk Per Million 27.6 10.0 Potentially Significant
HIC Not Applicable 0.01 1.0 Less than Significant
Source: Appendix B
Notes: CEQA = California Environmental Quality Act; HIC = Chronic Hazard Index.
The results of the HRA demonstrate that the TAC exposure from construction diesel exhaust emissions would result in
cancer risk on site above the 10 in 1 million threshold, as well as Chronic Hazard Index less than one. Therefore, TAC
emissions from construction of the proposed project may expose sensitive receptors to substantial pollutant
concentrations and would result in a potentially significant impact (Impact AQ-2).
Health Impacts of Carbon Monoxide
Mobile-source impacts occur on two basic scales of motion. Regionally, project-related travel would add to
regional trip generation and increase the VMT within the local airshed and the SDAB. Locally, project-related
traffic would be added to the City’s roadway system. If such traffic occurs during periods of poor atmospheric
ventilation, consists of a large number of vehicles “cold-started” and operating at pollution-inefficient speeds, and
operates on roadways already crowded with non-project traffic, there is a potential for the formation of microscale
CO “hotspots” in the area immediately around points of congested traffic. Because of continued improvement in
mobile emissions at a rate faster than the rate of vehicle growth and/or congestion, the potential for CO hotspots
in the SDAB is steadily decreasing.
Projects contributing to adverse traffic impacts may result in the formation of CO hotspots. To verify that the
proposed project would not cause or contribute to a violation of the CO standard, a screening evaluation of the
potential for CO hotspots was conducted. Linscott, Law & Greenspan prepared the Transportation Impact Analysis
for The Farm in Poway in January 2020, which evaluated the level of service (LOS) (i.e., increased congestion)
impacts at intersections affected by the proposed project (Appendix J). The potential for CO hotspots was
evaluated based on the results of the traffic report. As the City does not have CO hotspot guidelines, the County’s
CO hotspot screening guidance was followed to determine if the proposed project would require a site-specific
hotspot analysis (County of San Diego 2007). The County recommends that a quantitative analysis of CO hotspots
be performed for intersections operating at or below a LOS of “E” and have peak-hour trips exceeding 3,000 trips.
The proposed project’s transportation impact analysis determined that there would be seven intersections that
would operate at a LOS E or worse with five of the intersections have peak-hour trips exceeding 3,000 trips
(Appendix J). Therefore, a quantitative analysis is required for the proposed project.
For each scenario (horizon year plus total project), the screening evaluation presents LOS and whether a quantitative
CO hotspots analysis may be required. According to the CO Protocol, there is a cap on the number of intersections that
need to be analyzed for any one project. For a single project with multiple intersections, only the three intersections
representing the worst LOS ratings of the project, and, to the extent they are different intersections, the three
intersections representing the highest traffic volumes, need be analyzed. For each intersection failing a screening test
as described in this protocol, an additional intersection should be analyzed (Caltrans 2010).
4.2 – Air Quality
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Based on the CO hotspot screening evaluation (Appendix B), all of the five intersections that operate at LOS D
or worse and exceeded 3,000 peak-hour trips had similar geometries. Therefore, the three intersections with
the highest volumes were selected to represent that type of geometry. All intersections were evaluated in the
Horizon scenarios for CO Hotspots. For each intersection, the highest volume (AM or PM) was used in the
analysis as the worst-case scenario. The potential impact of the proposed project on local CO levels was
assessed at these intersections with the Caltrans CL4 interface based on the California LINE Source Dispersion
Model (CALINE4), which allows microscale CO concentrations to be estimated along each roadway corridor or
near intersections (Caltrans 1998).
The emissions factor represents the weighted average emissions rate of the County vehicle fleet expressed in grams
per mile per vehicle. Consistent with the traffic scenario, emissions factors for 2035 were used for the three
intersections. Emissions factors were predicted by EMFAC2017 based on an average speed of five miles per hour
for all of the intersections for approach and departure segments. The hourly traffic volume anticipated to travel on
each link, in units of vehicles per hour, was based on information provided by the transportation impact assessment
and modeling assumptions are outlined in Appendix B.
Four receptor locations were modeled at each intersection to determine CO ambient concentrations. A receptor was
assumed on the sidewalk at each corner of the modeled intersections, to represent the future possibility of extended
outdoor exposure. CO concentrations were modeled at these locations to assess the maximum potential CO
exposure that could occur in 2035. A receptor height of 5.9 feet (1.8 meters) was used in accordance with Caltrans
recommendations for all receptor locations (Caltrans 2010).
The Caltrans guidance recommends using the highest one-hour measurement in the last three years as the
projected future one-hour CO background concentration for the analysis. A CO concentration of 1.7 parts per million
(ppm) was recorded in 2016 for the Floyd Smith Drive monitoring station in El Cajon and was assumed in the
CALINE4 model for 2035 (CARB 2016b). To estimate an eight-hour average CO concentration, a persistence factor
of 0.6, as recommended for suburban locations in the Caltrans guidance (Caltrans 2010), was applied to the output
values of predicted concentrations in ppm at each of the receptor locations.
The results of the model are shown in Table 4.2-6, and model input and output data are provided in Appendix B.
Table 4.2-6. CALINE4 Predicted Carbon Monoxide Concentrations
Intersection
Maximum Modeled Impact (ppm)
1-hour 8-hour*
Pomerado Road at Twin Peaks Road 2.3 1.38
Pomerado Road at Rancho Bernardo Road 2.1 1.26
Pomerado Road at Bernardo Heights Pkwy Road 2.0 1.2
Source: Caltrans 1998 (CALINE4).
Notes: ppm = parts per million.
* Eight-hour concentrations were obtained by multiplying the one-hour concentration by a persistence factor of 0.6 (Caltrans 2010).
As shown in Table 4.2-6, the maximum CO concentration predicted for the one-hour averaging period at the
studied intersections would be 2.3 ppm, which is below the one-hour CO CAAQS of 20 ppm (CARB 2016b). The
maximum predicted eight-hour CO concentration of 1.38 ppm at the studied intersections would be below the
eight-hour CO CAAQS of 9.0 ppm (CARB 2016b). Neither the one-hour nor eight-hour CAAQS would be equaled or
exceeded at any of the intersections studied. Accordingly, the proposed project would not cause or contribute to
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violations of the CAAQS and would not result in exposure of sensitive receptors to localized high concentrations of
CO. As such, impacts would be less than significant to sensitive receptors with regard to potential CO hotspots
resulting from the proposed project’s contribution to cumulative traffic-related air quality impacts, and no
mitigation would be required.
Health Impacts of Other Criteria Air Pollutants
Construction and operation of the proposed project would not result in emissions that exceed the SDAPCD’s
emission thresholds for any criteria air pollutants. Regarding VOCs, some VOCs are associated with motor vehicles
and construction equipment, while others are associated with architectural coatings, the emissions of which
would not result in the exceedances of the SDAPCD’s thresholds. Generally, the VOCs in architectural coatings are
of relatively low toxicity. Additionally, SDAPCD Rule 67.0.1 restricts the VOC content of coatings for both
construction and operational applications.
In addition, VOCs and NOx are precursors to O3, for which the SDAB is designated as nonattainment with respect
to the NAAQS and CAAQS (the SDAB is designated by the EPA as an attainment area for the one-hour O3 NAAQS
standard and 1997 eight-hour NAAQS standard). The health effects associated with O3 are generally associated
with reduced lung function. The contribution of VOCs and NOx to regional ambient O3 concentrations is the result
of complex photochemistry. The increases in O3 concentrations in the SDAB due to O3 precursor emissions tend to
be found downwind from the source location to allow time for the photochemical reactions to occur. However, the
potential for exacerbating excessive O3 concentrations would also depend on the time of year that the VOC
emissions would occur, because exceedances of the O3 ambient air quality standards tend to occur between April
and October when solar radiation is highest.
The holistic effect of a single project’s emissions of O3 precursors is speculative due to the lack of quantitative
methods to assess this impact. Nonetheless, the VOC and NOx emissions associated with proposed project
construction and operations could minimally contribute to regional O3 concentrations and the associated health
impacts. Due to the minimal contribution during construction and operation, as well as the existing good air
quality in Coastal San Diego areas, health impacts would be considered less than significant.
Regarding NO2, according to the construction emissions analysis, construction of the proposed project would not
contribute to exceedances of the NAAQS and CAAQS for NO2. Health impacts from exposure to NO2 and NOx are
associated with respiratory irritation, which may be experienced by nearby receptors during the periods of
heaviest use of off-road construction equipment. However, these operations would be relatively short term.
Additionally, off-road construction equipment would operate at various portions of the site and would not be
concentrated in one portion of the site at any one time. Construction of the proposed project would not require
any stationary emission sources that would create substantial, localized NOx impacts. Therefore, health impacts
would be considered less than significant.
The VOC and NOx emissions, as described previously, would minimally contribute to regional O3 concentrations
and its associated health effects. In addition to O3, NOx emissions would not contribute to potential exceedances
of the NAAQS and CAAQS for NO2. The existing NO2 concentrations in the area are well below the NAAQS and
CAAQS standards. Thus, it is not expected that the proposed project’s operational NOx emissions would result in
exceedances of the NO2 standards or contribute to the associated health effects. CO tends to be a localized
impact associated with congested intersections. The associated CO “hotspots” were discussed previously as a
less-than-significant impact. Thus, the proposed project’s CO emissions would not contribute to significant health
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effects associated with this pollutant. Likewise, PM10 and PM2.5 would not contribute to potential exceedances of the
NAAQS and CAAQS for particulate matter, would not obstruct the SDAB from coming into attainment for these
pollutants, and would not contribute to significant health effects associated with particulates.
Based on the preceding considerations, health impacts associated with criteria air pollutants would be
less than significant.
Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial
number of people?
Section 41700 of the California Health and Safety Code and SDAPCD Rule 51 (Public Nuisance), prohibit
emissions from any source whatsoever in such quantities of air contaminants or other material that cause injury,
detriment, nuisance, or annoyance to the public health or damage to property. Projects required to obtain permits
from SDAPCD are evaluated by SDAPCD staff for potential odor nuisance, and conditions may be applied (or
control equipment required) where necessary to prevent occurrence of public nuisance.
SDAPCD Rule 51 (Public Nuisance) also prohibits emission of any material that causes nuisance to a
considerable number of persons or endangers the comfort, health, or safety of any person. A project that
proposes a use that would produce objectionable odors would be deemed to have a significant odor impact if it
would affect a considerable number of off-site receptors. Odor issues are very subjective by the nature of odors
themselves and due to the fact that their measurements are difficult to quantify. As a result, this guideline is
qualitative and will focus on the existing and potential surrounding uses and location of sensitive receptors.
The occurrence and severity of potential odor impacts depends on numerous factors: the nature, frequency, and
intensity of the source; the wind speeds and direction; and the sensitivity of receiving location each contribute to
the intensity of the impact. Although offensive odors seldom cause physical harm, they can be annoying, cause
distress among the public, and generate citizen complaints.
Odors would be potentially generated from vehicles and equipment exhaust emissions during construction of the
proposed project. Potential odors produced during proposed construction would be attributable to concentrations
of unburned hydrocarbons from tailpipes of construction equipment, architectural coatings, and asphalt
pavement application. Such odors would disperse rapidly from the project site and generally occur at magnitudes
that would not affect substantial numbers of people. Therefore, impacts associated with odors during
construction would be less than significant.
Land uses and industrial operations associated with odor complaints include agricultural uses, wastewater
treatment plants, food-processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass
molding (SCAQMD 1993). The proposed project includes residential and commercial uses, as well as an on-site
agrifields and a community garden. The agrifields and community garden, which would be professionally
managed, would be considered a land use that is commonly associated with odors due to the presence of
fertilizers, pesticides, and herbicides. The agrifields and community garden would be located as the furthest
amenity from planned and existing residents, providing a buffer from any potential odors. While organic and
biodynamic farming practices are preferred, as stated in the Specific Plan, limited use of pesticides may be
permitted when other Integrated Pest Management methods have proven to be ineffective. To ensure
compatibility of agricultural operations with residential uses, any chemical or pesticide use shall be in compliance
with the applicable permits and regulations enforced by the California Department of Agriculture and County of
San Diego Department of Agriculture (The Farm in Poway LLC 2020). Additionally, agricultural operations are
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addressed in the Priority Development Project – Stormwater Quality Management Plan prepared by Hunsaker and
Associates in January 2020 (Appendix G). These regulations and structural best management practices would
guide the use of these materials. As the agrifields and community garden would apply pesticides and fertilizers in
a limited and regulated manner, odors related to the agrifields and community garden would be minimal.
Therefore, proposed project operations would result in an odor impact that would be less than significant.
The proposed project’s impacts to air quality are listed as follows:
Impact AQ-1 The proposed project would result in daily construction emissions that would exceed the significance
thresholds for NOx and CO.
Impact AQ-2 The proposed project would result in TAC exposure from construction diesel exhaust emissions
that would result in cancer risk on site above the 10 in 1 million threshold, as well as Chronic
Hazard Index less than one. Therefore, TAC emissions from construction of the proposed project
may expose sensitive receptors to substantial pollutant concentrations.
4.2.5 Cumulative Impacts
In analyzing cumulative impacts from a project, the analysis must specifically evaluate a project’s contribution to
the cumulative increase in pollutants for which the SDAB is listed as nonattainment for the state and federal
ambient air quality standards. The project would have a cumulatively considerable impact if project-generated
emissions would exceed thresholds for PM10, PM2.5, NOx, and/or VOCs. If the project does not exceed thresholds
and is determined to have less than significant project-specific impacts, it may still have a cumulatively
considerable impact on air quality if the emissions from the project, in combination with the emissions from other
proposed or reasonably foreseeable future projects, are in excess of established thresholds. However, the project
would be considered to have a cumulative impact only if the project’s contribution accounts for a significant
proportion of the cumulative total emissions.
Background ambient air quality, as measured at the monitoring stations maintained and operated by SDAPCD,
measures the concentrations of pollutants from existing sources; therefore, impacts from other past and present
projects are included in the background ambient air quality data.
Geographic Extent
The geographic extent for the analysis of cumulative impacts related to air quality includes the northeastern
corner of the SDAB (San Diego County). However, localized cumulative effects may occur from fugitive dust,
CO, and NOx. Due to the nonattainment status of the SDAB, the primary air pollutants of concern would be
NOx and VOCs, which are O3 precursors, and PM10 and PM2.5. NOx and VOCs are primarily emitted from motor
vehicles and construction equipment, while PM10 and PM2.5 are emitted primarily as fugitive dust during
construction. Because of the nature of ozone as a regional air pollutant, emissions from the entire
geographic area for this cumulative impact analysis would tend to be important, although maximum ozone
impacts generally occur downwind of the area in which the ozone precursors are released. PM10 and PM2.5
impacts, on the other hand, would tend to occur locally; thus, projects occurring in the same general area
and in the same time period would tend to create cumulative air quality impacts.
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Existing Cumulative Conditions
Air quality management in the geographic area for the cumulative impact assessment is the responsibility of
SDAPCD. Existing levels of development in San Diego County have led to the nonattainment status for ozone
with respect to the CAAQS and NAAQS, and for PM10 and PM2.5 with respect to the CAAQS. The nonattainment
status is based on ambient air quality monitoring generally conducted in the urban portions of the County. No
monitoring stations exist in the geographic area for the cumulative impact assessment, but air quality would
generally be better than that in the urban areas in the western portion of the County due to the lack of major air
pollutant sources. The air quality plans prepared by SDAPCD reflect future growth under local development
plans but are intended to reduce emissions countywide to levels that would comply with the NAAQS an d CAAQS
through implementation of new regulations at the federal, state, and local levels.
Cumulative Analysis
Cumulatively Considerable Net Increase of Criteria Pollutants (Construction)
Air pollution is largely a cumulative impact. The nonattainment status of regional pollutants is a result of past and
present development, and SDAPCD develops and implements plans for future attainment of ambient air quality
standards. Based on these considerations, project-level thresholds of significance for criteria pollutants are relevant
in the determination of whether a project’s individual emissions would have a cumulatively significant impact on air
quality. Additionally, for the basin, the RAQS serves as the long-term regional air quality planning document for the
purpose of assessing cumulative operational emissions in the basin to ensure the SDAB continues to make progress
toward NAAQS- and CAAQS-attainment status. As such, cumulative projects located in the San Diego region would
have the potential to result in a cumulative impact to air quality if, in combination, they would conflict with or
obstruct implementation of the RAQS. Similarly, individual projects that are inconsistent with the regional planning
documents upon which the RAQS is based would have the potential to result in cumulative operational impacts if
they represent development and population increases beyond regional projections.
The SDAB has been designated as a federal nonattainment area for O3 and a state nonattainment area for O3,
PM10, and PM2.5. PM10 and PM2.5 emissions associated with construction generally result in near-field
impacts. The nonattainment status is the result of cumulative emissions from all sources of these air pollutants
and their precursors within the basin. As discussed previously, NOx and CO criteria air pollutant emissions from
construction of the proposed project would be potentially significant. Exposure of sensitive receptors to TACs from
construction diesel exhaust emissions would be considered a potentially significant impact of the proposed
project; however, TACs are not criteria pollutants and potential impacts to sensitive receptors associated with TAC
exposure would be specific to the sensitive receptors in direct proximity to the project site, including the
residences adjacent to the project site boundary. No cumulative projects identified in Table 3-2, Cumulative
Projects, are proximate enough to the proposed project to result in cumulative impacts to the same sensitive
receptors with regard to TAC emissions. Finally, TAC emissions from construction would be short term in nature
and would cease after construction of the proposed project. Therefore, cumulative impacts from criteria air
pollutant emissions would be potentially significant during construction and less than significant during operation.
The proposed project’s potential cumulative impacts to air quality are listed as follows:
Impact AQ-CU-1 The proposed project would result in a potentially significant cumulative impact from criteria air
pollutant emissions during construction.
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4.2.6 Mitigation Measures
The following mitigation measure is provided to reduce emissions of NOx and CO during construction. This
mitigation measure would also reduce the impacts to nearby sensitive receptors.
MM-AQ-1 During project construction, the City of Poway shall ensure that the project contractor adheres to
the following measures to reduce diesel particulate emissions, including, but not limited to:
1) All construction equipment greater than 75 horsepower shall be equipped with Tier 4 Interim
diesel engines or better.
2) The engine size of construction equipment shall be the minimum size suitable for the
required job.
3) The number of construction equipment operating simultaneously shall be minimized through
efficient management practices to ensure that the smallest number is operating at any one time.
4) Construction equipment shall be maintained in tune per the manufacturer’s specifications.
5) The prime contractor will provide the City of Poway verification of equipment type used
during construction.
4.2.7 Level of Significance After Mitigation
Table 4.2-7 shows the estimated maximum daily construction emissions associated with construction of the
proposed project with implementation of MM-AQ-1. Complete details of the emissions calculations are
provided in Appendix B.
Table 4.2-7. Estimated Maximum Daily Construction Criteria Air Pollutant Emissions – Mitigated
Year
VOC NOx CO SOx PM10 PM2.5
Pounds per day
2021 3.26 170.67 493.77 12.18 30.62 7.57
2022 7.43 67.34 76.81 0.27 77.01 10.07
2023 5.76 47.64 55.27 0.24 74.63 9.70
2024 72.22 48.12 56.08 0.24 76.93 9.99
Maximum 72.22 170.67 493.77 12.18 77.01 10.07
SDAPCD Threshold 75 250 550 250 100 55
Threshold Exceeded? No No No No No No
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse
particulate matter; PM2.5 = fine particulate matter; SDAPCD = San Diego Air Pollution Control District; CalEEMod = California
Emissions Estimator Model.
See Appendix B for complete results.
The values shown are the maximum summer or winter daily emissions results from CalEEMod. Although not considered mitigation,
these emissions reflect the CalEEMod “mitigated” output, which accounts for the required compliance with SDAPCD Rule 55 (Fugitive
Dust) and Rule 67.0.1 (Architectural Coatings).
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As shown in Table 4.2-7, daily construction emissions would not exceed the significance thresholds for any criteria
pollutant with incorporation of MM-AQ-1. Therefore, mitigation would be required to result in less-than-significant
impacts during construction. Furthermore, cumulative impacts would be less than significant as well with mitigation.
Construction of proposed project components would require use of heavy-duty construction equipment, which is
subject to a CARB ATCM for in-use diesel construction equipment to reduce diesel particulate emissions, and
would involve use of diesel trucks, which are also subject to an ATCM. The implementation of MM-AQ-1 would
reduce the emissions of DPM during construction. The results of the HRA during construction with mitigation are
provided in Table 4.2-8.
Table 4.2-8. Construction Activity Health Risk Assessment Results – Mitigated
Impact Parameter Units Project Impact CEQA Threshold Level of Significance
Cancer Risk Per Million 2.2 10.0 Less than Significant
HIC Not Applicable 0.001 1.0 Less than Significant
Source: Appendix B.
Notes: CEQA = California Environmental Quality Act; HIC = Chronic Hazard Index.
The results of the construction analysis demonstrate that the mitigated construction emissions exhibit cancer risk
below the 10 in 1 million threshold and below the Chronic Hazard Index threshold. The project construction TACs
impact from DPM emissions would be reduced to less than significant with mitigation.
4.3 – Biological Resources
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4.3 Biological Resources
This section describes the existing biological resources conditions of The Farm in Poway project (proposed project)
site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies
mitigation measures related to implementation of the proposed project. The analysis is based on the review of
existing biological resources; technical data; applicable laws, regulations, and guidelines; and the biological
technical report prepared by RECON Environmental in February 2020. The Biological Resources Report for The
Farm in Poway Project is included in this Environmental Impact Report (EIR) as Appendix C.
A Notice of Preparation (NOP) was circulated from May 10, 2019, to June 10, 2019. During the NOP comment
period, comment letters related to Biological Resources focused on the following topics:
Presence of sensitive species and habitat
Requests for biological survey and monitoring
These comments were considered during the preparation of this EIR. The Initial Study, NOP, and Public Scoping
comments are provided in Appendix A of this EIR.
4.3.1 Existing Conditions
Project Site
A majority of the vegetation on the project site is comprised of non-native ornamental plantings that line the former
golf course fairways and access roads. While the grasses that make up the golf course fairways and greens were
the most common vegetation while the course was active, the majority of the vegetation is now comprised of non-
native weed species. No sensitive plants occur on the project site. No sensitive wildlife species were detected during
the general survey (Appendix C). The project site is not directly adjacent to natural open space areas that support
sensitive wildlife species.
Four soil types—Fallbrook sandy loam, Placentia sandy loam, Vista rocky course sandy loam, and Cieneba coarse
sandy loam—as mapped by the U.S. Department of Agriculture (USDA 1973), occur within the survey area. The
Fallbrook series consists of well-drained, moderately deep to deep sandy loams that formed in material that was
weathered in place from granodiorite (USDA 1973). These soils are found in upland areas. The Placentia series
consists of moderately well-drained sandy loams that have sandy clay subsoil (USDA 1973). These soils are formed
in granitic alluvium. Vista series consists of well-drained to moderately well-drained sandy loams derived from
granodiorite or quartz diorite. The Cieneba series consist of excessively drained, very shallow to shallow coarse
sandy loams that formed in material weathered in place from granitic rock (Appendix C). Two sensitive vegetation
communities, freshwater marsh and open water, were identified within the survey area (Appendix C). In addition,
the freshwater marsh and open water are jurisdictional waters of the United States and the State of California. No
sensitive plant or wildlife species were found within the proposed project site and the project site is not located
within dedicated Mitigation Areas as indicated in the Poway Subarea Habitat Conservation Plan/Natural Community
Conservation Plan (Poway Subarea HCP/NCCP) (City of Poway 1996).
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Methodology
A biological survey was conducted by RECON biologists on February 7, 2019. The survey was conducted under clear
skies between 9:30 a.m. and 11:45 a.m., with the air temperature ranging from 52°F to 59°F, and wind speed
ranging from 0 to 2 miles per hour. Vegetation communities and land cover types were mapped on a 1-inch-equals-
150 feet aerial photograph of the survey area. Wildlife species were observed directly or detected from calls, tracks,
scat, nests, or other signs. Plant species observed within the survey area were also noted (Appendix C).
Floral nomenclature for common plants follows the Jepson Online Herbarium (Jepson Flora Project 2019), for
ornamental plants Brenzel (2001), and for sensitive plants California Rare Plant Rank (CNPS 2019). Vegetation
community classifications follow Oberbauer et al. (2008), which is based on Holland’s (1986) Preliminary
Descriptions of the Terrestrial Natural Communities of California. Zoological nomenclature for birds is in accordance
with the American Ornithological Society Checklist (Chesser et al. 2018) and Unitt (2004); for mammals with Baker
et al. (2003); and for reptiles with Crother (2008). Determination of the potential occurrence for listed, sensitive, or
noteworthy species is based upon known ranges and habitat preferences for the species (CNPS 2019; Jennings
and Hayes 1994; Reiser 2001; Unitt 2004) and species occurrence records from the California Natural Diversity
Database (CDFW 2018a) (Appendix C).
Botany
Three vegetation/land cover types were identified on the proposed project site, (1) freshwater marsh, (2) open
water, and (3) developed/disturbed land (see Table 4.3-1). Freshwater marsh and open water are considered
sensitive habitats, while developed/disturbed land is not considered sensitive habitat. Figure 4.3-1, Vegetation
Communities and Land Cover Types, shows all of the vegetation communities found within project site. The
full list of plants found on the project site are listed in Appendix C. No sensitive plant species were found on
the project site.
Table 4.3-1. Existing Vegetation Communities and Land Cover Types
Vegetation Communities/
Land Cover Types1 Sensitivity Type2 Acreage
Freshwater Marsh Sensitive 0.02
Open Water Sensitive 0.14
Developed/Disturbed Land Not Sensitive 117.04
Total 117.2
Source: Appendix C.
Notes:
1 Per Table 5-2 of the Poway Subarea HCP/NCCP.
2 Per the Poway Subarea HCP/NCCP.
Freshwater Marsh
Freshwater marsh communities comprise perennial emergent monocots typically forming a closed canopy. This
habitat occurs in open bodies of fresh water with little current flow, such as ponds, and to a lesser extent around
seeps and springs. Freshwater marshes occur in areas of permanent inundation by freshwater without active
stream flow (Oberbauer et al. 2008). Freshwater marsh is sensitive per the Poway Subarea HCP/NCCP and
regulated by the U.S. Army Corps of Engineers (ACOE), California Department of Fish and Wildlife (CDFW), and
Regional Water Quality Control Board (RWQCB) (Appendix C).
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A small patch of freshwater marsh vegetation occurs around the banks of the pond located in the southwest
portion of the proposed project site. Broadleaf cattail (Typha latifolia) is the most common plant species along
with a couple of mulefat shrubs (Baccharis salicifolia) and individuals of Washington fan palm (Washingtonia
robusta) and eucalyptus trees (Eucalyptus spp.). There are three other former ponds on the proposed project
site, but these no longer hold water and do not support vegetation (Appendix C). Photographs of the site can be
found in Appendix C.
Open Water
One freshwater pond is located in the southwest portion of the project site, downstream of the freshwater marsh
area. This pond continues to hold water seasonally, but does not support a predominance of wetland vegetation,
and is therefore categorized as open water (Appendix C). Photographs of the site can be found in Appendix C.
Developed/Disturbed Land
Developed/disturbed land consist of all buildings, parking lots, access roads, and former golf course fairways and
greens. The majority of the vegetation on the project site is comprised of non-native ornamental plantings that line
the former golf course fairways and access roads. The grasses that make up the golf course fairways and greens
were the most common vegetation while the course was active; however, the majority of the vegetation is now
comprised of non-native weed species. Various trees remain on the property, including species of eucalyptus and
pine (Pinus spp.) along with specimen of Washington fan palm, date palm (Phoenix dactylifera), Peruvian peppertree
(Schinus molle), and Brazilian peppertree (Schinus terebinthifolius) (Appendix C). Photographs of the site can be
found in Appendix C.
Zoology
No sensitive wildlife species were observed on the project site. Common wildlife species detected during the survey
include mule deer (Odocoileus hemionus), Anna’s hummingbird (Calypte anna), song sparrow (Melospiza melodia),
and black phoebe (Sayornis nigricans). A full list of all wildlife species observed is listed in Appendix C.
Sensitive Biological Resources
Sensitive Vegetation Communities
Two sensitive vegetation communities, freshwater marsh and open water, occur within the survey area. These
habitats are sensitive habitats under the Poway Subarea HCP/NCCP and are federal and state jurisdictional waters
under the jurisdiction of the ACOE, CDFW, and RWQCB. The location of these sensitive vegetation communities on
the site are shown on Figure 4.3-1.
Sensitive Plants
No sensitive plants were found on the project site and none are expected to occur. An evaluation of sensitive plant
species known to occur within one mile of the project site, based on a review of the California Natural Diversity Data
Base, and their potential for their occurrence on the site can be found in Appendix C.
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Sensitive Wildlife Species
No sensitive wildlife species were found on the project site. Although not observed, Cooper’s hawk (Accipiter
cooperii) has moderate potential to nest within the mature trees on site. An evaluation of sensitive wildlife species
known to occur within one mile of the project site that are federally listed threatened or endangered, or have the
potential to occur based on species range, can be found in Appendix C.
While Coastal California gnatcatcher (Polioptila californica californica) is known to occur in open space areas to the
east and north of the project site, these open space areas are separated from the project site by development and
the project site is not directly adjacent to habitat for this species. No coastal sage scrub habitat occurs on the
project site and no coastal California gnatcatchers were observed on the site (Appendix C).
Wildlife Movement Corridor
Wildlife movement corridors are defined as areas that connect suitable wildlife habitat areas in a region
otherwise fragmented by rugged terrain, changes in vegetation, or human disturbance. Natural features such
as canyon drainages, ridgelines, or areas with vegetation cover provide corridors for wildlife travel. Wildlife
movement corridors are important, because they provide access to mates, food, and water; allow the dispersal
of individuals away from high population density areas; and facilitate the exchange of genetic traits between
populations (Beier and Loe 1992). Wildlife movement corridors are considered sensitive by resources and
conservation agencies (Appendix C).
The survey area does not currently function as a significant wildlife movement corridor. It is surrounded by residential
development and is fenced around the perimeter, which ultimately restricts its use by wildlife. While there may be
some wildlife movement within the open areas and trees within the site, the property, as a whole, does not provide a
major movement corridor for wildlife species to other adjacent native habitat area (Appendix C).
Jurisdictional Waters
A formal jurisdictional waters delineation was not conducted as part of this study. The jurisdictional status of
features on the proposed project site were preliminarily assessed based on connectivity to a natural watercourse
and presence of hydrophytic vegetation.
The concrete-lined drainage located in the southwest corner of the project site conveys stormwater runoff from the
golf course and adjacent development through the freshwater marsh and associated pond, and then to a large
culvert under Espola Road (see Figure 4.3-1). Photographs of this concrete culvert can be found in Appendix C.
Historically, this portion of the project site supported a “blue-line” stream course, as shown on Figure 4.3-2, Project
Location on USGS Map. The development and subsequent contouring of the property into the golf course re-directed
this “blue-line” stream course into the alignment of the concrete lined drainage. The flows from this drainage are
conveyed off site to the south where they connect to a natural watercourse. This lined drainage and associated
ponds would likely be considered a water of the United States and water of the state due to the presence of
hydrophytic vegetation and connectivity to a natural watercourse located off site. The total jurisdictional area equals
0.23 acres (0.02 acres of freshwater marsh, 0.14 acres of open water, and 0.07 acres of concrete-lined channel).
There are a number of other concrete-lined drainage features spread out over the former golf course, usually
in low-lying areas where localized stormwater runoff collect. All but one of these lined drainages appear to
convey water to areas on site (e.g., to brow ditches, and/or to storm drain connections to the adjacent
developed areas). These lined drainages do not support hydrophytic vegetation, and do not connect to a natural
drainage system off site.
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Three abandoned, un-vegetated golf course ponds occur to the west of the clubhouse complex in the center of the property.
These ponds are isolated features that were used to store irrigation water for the golf course. The smaller pond is concrete
lined. These three ponds are not likely jurisdictional waters of the United States or waters of the state as they were excavated
in an upland area, do not support hydrophytic vegetation, and do not connect to any natural drainage course (Appendix C).
Photographs of the concrete-lined drainages, channels, and culverts can be found in Appendix C.
4.3.2 Relevant Plans, Policies, and Ordinances
Federal
Federal Endangered Species Act
The federal Endangered Species Act of 1973 (ESA), as amended (16 USC 1531 et seq.), provides for listing of
endangered and threatened species of plants and animals and designation of critical habitat for listed animal
species. The ESA also prohibits all persons subject to United States jurisdiction from “taking” endangered species,
which includes any harm or harassment. Section 7 of the ESA requires that federal agencies, prior to project
approval, consult the U.S. Fish and Wildlife Service (USFWS) and/or the National Marine Fisheries Service to ensure
adequate protection of listed species that may be affected by the project.
Migratory Bird Treaty Act
All migratory bird species that are native to the United States or its territories are protected under the federal
Migratory Bird Treaty Act (MBTA), as amended under the Migratory Bird Treaty Reform Act of 2004 (Senate Bill
2547). The MBTA is generally protective of migratory birds, but does not actually stipulate the type of protection
required. In common practice, MBTA is used to place restrictions on disturbance of active bird nests during the
nesting season (generally February 1 through August 31). In addition, the USFWS commonly places restrictions on
disturbances allowed near active raptor nests.
Clean Water Act
The federal Water Pollution Control Act Amendments of 1972 (Clean Water Act) (33 USC 1251 et seq.), as amended
by the Water Quality Act of 1987 (PL 1000-4), is the major federal legislation governing water quality. The purpose
of the Clean Water Act is to “restore and maintain the chemical, physical, and biological integrity of the nation’s
waters.” Discharges into waters of the United States are regulated under Section 404. Waters of the United States
include (1) all navigable waters (including all waters subject to the ebb and flow of tides); (2) all interstate waters
and wetlands; (3) all other waters, such as intrastate lakes, rivers, streams (including intermittent streams),
mudflats, sand flats, wetlands, sloughs, or natural ponds; (4) all impoundments of waters mentioned above; (5) all
tributaries to waters mentioned above; (6) the territorial seas; and (7) all wetlands adjacent to waters mentioned
above. In California, the State Water Resources Control Board and the nine RWQCBs are responsible for
implementing the Clean Water Act. Important applicable section of the Clean Water Act include the following:
Section 303 requires states to develop water quality standards for inland surface and ocean waters and
submit to the U.S. Environmental Protection Agency for approval. Under Section 303(d), the state is required
to list waters that do not meet water quality standards and to develop action plans, called total maximum
daily loads, to improve water quality.
Section 304 provides for water quality standards, criteria, and guidelines.
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Section 401 requires an applicant for any federal permit that proposes an activity that may result in a
discharge to waters of the United States to obtain certification from the state that the discharge will comply
other provisions of the Clean Water Act. Certification is provided by the respective RWQCB.
Section 402 establishes the National Pollutant Discharge Elimination System, a permitting system for the
discharge of any pollutant (except for dredge or fill material) into waters of the United States. The National
Pollutant Discharge Elimination System program is administered by the RWQCB. Conformance with Section
402 is typically addressed in conjunction with water quality certification under Section 401.
Section 404 provides for issuance of dredge/fill permits by the ACOE. Permits typically include conditions
to minimize impacts on water quality. Common conditions include (1) ACOE review and approval of
sediment quality analysis before dredging, (2) a detailed pre- and post-construction monitoring plan that
includes disposal site monitoring, and (3) required compensation for loss of waters of the United States.
State
California Endangered Species Act
Similar to the federal ESA, the California ESA of 1970 provides protection to species considered threatened or
endangered by the State of California (California Fish and Game Code, Section 2050 et seq.). The California ESA
recognizes the importance of threatened and endangered fish, wildlife, and plant species and their habitats; it also
prohibits the taking of any endangered, threatened, or rare plant and/or animal species unless specifically
permitted for education or management purposes.
California Fish and Game Code
The California Fish and Game Code regulates the handling and management of the state’s fish and wildlife. Most
of the code is administered or enforced by the CDFW. One section of the code generally applies to public
infrastructure projects such as the proposed project:
Section 1602 regulates activities that would divert or obstruct the natural flow or substantially change the
bed, channel, or bank of any river, stream, or lake that supports fish or wildlife. CDFW has jurisdiction over
riparian habitats associated with watercourses. Jurisdictional waters are delineated by the outer edge of
riparian vegetation or at the top of the bank of streams or lakes, whichever is wider. CDFW jurisdiction does
not include tidal areas or isolated resources.
California Environmental Quality Act
The California Environmental Quality Act (CEQA) (California Public Resources Code, Section 21000 et seq.) and
CEQA Guidelines (14 CCR 15000 et seq.) are primary sources for environmental legislation in California; they
require projects with potential adverse environmental effects (or impacts) undergo environmental review. Adverse
environmental impacts are typically mitigated as a result of the environmental review process in accordance with
existing laws and regulations.
California Native Plant Society
The California Native Plant Society maintains a list of special-status plant species based on collected scientific
information. Designation of these species by the California Native Plant Society does not constitute legal status or
protection under federal or state endangered species legislation. The California Native Plant Society’s California
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Rare Plant Ranks (CRPRs) are defined as follows: CRPR 1A (plants presumed extinct), CRPR 1B (plants rare,
threatened, or endangered in California and elsewhere), CRPR 2 (plants rare, threatened, or endangered in
California, but more numerous elsewhere), CRPR 3 (plants about which more information is needed—a review list),
and CRPR 4 (plants of limited distribution—a watch list). In general, substantial adverse effects to plants designated
as CRPR 1A, 1B, or 2 would be considered significant.
California Natural Community Conservation Planning Act of 1991
The Natural Community Conservation Planning Act of 1991 provides a framework for state and local government,
as well as private interest efforts, for the protection of regional biodiversity and the ecosystems upon which they
depend. Natural community conservation plans allow for the appropriate, compatible economic activity to occur
while ensuring the long-term conservation of multiple species.
California Fish and Game Code
The California Fish and Game Code provides specific protection and listing for several types of biological
resources. Section 1600 et seq. of the California Fish and Game Code require notification and, if required, a
Streambed Alteration Agreement for any activity that would alter the flow, change, or use any material from
the bed, channel, or bank of any perennial, intermittent, or ephemeral river, stream, and/or lake. Typical
activities that require notification include excavation or fill placed within a channel, vegetation clearing,
structures for diversion of water, installation of culverts and bridge supports, cofferdams for construction
dewatering, and bank reinforcement.
Pursuant to California Fish and Game Code Section 3503, it is unlawful to take, possess, or needlessly destroy the
nest or eggs of any bird, except as otherwise provided by this code or any regulation made pursuant thereto. Raptors
and owls and their active nests are protected by California Fish and Game Code Section 3503.5, which states that it
is unlawful to take, possess, or destroy any birds of prey or to take, possess, or destroy the nest or eggs of any such
bird unless authorized by CDFW. Section 3513 states that it is unlawful to take or possess any migratory non-game
bird as designated in the MBTA. These regulations could require that construction activities (particularly vegetation
removal or construction near nests) be reduced or eliminated during critical phases of the nesting cycle unless surveys
by a qualified biologist demonstrate that nests, eggs, or nesting birds would not be disturbed, subject to approval by
CDFW and/or USFWS.
Local
Poway Municipal Code – Chapter 12.32 – Urban Forestry, Article 3 – Removal of Trees on Private Property
Chapter 12.32 of the City of Poway Municipal Code (City of Poway 2000) sets all tree-related policies, standards, and
regulations. Removal of trees on private property, such as the proposed project site, requires the property owner to acquire
a permit from the Director of Development Services that authorizes the removal of a native tree or a heritage tree.
Chapter 12.32.150 – Private Tree Removal Permit
A. The Director of Development Services shall maintain the City of Poway’s private tree removal permit records
and issue such permits.
B. A property owner shall first obtain a private tree removal permit authorizing the removal of a private tree
that is a native tree or a heritage tree subject to terms and conditions deemed appropriate by the Director
of Development Services or his/her designee. On commercial and industrial property, a permit shall be
required for the removal of any living tree greater than three inches in diameter.
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C. Applicants shall be expected to replace these types of trees in accordance with PMC [Poway Municipal
Code] 12.32.170: “Replacement of Trees.” The Director of Development Services, or his/her designee shall
review each private tree removal permit application and make a recommendation as to whether the permit
shall be issued or denied. The decision to issue or deny the permit and any terms and conditions of the
permit shall be based on the following criteria:
1. The condition of the tree with respect to disease, general health, damage, public nuisance, danger of falling,
proximity to existing or proposed structures and interference with utility services, age or remaining life span,
and whether or not the tree acts as a host for a plant which is parasitic to other species of trees which are
in danger of being infested or exterminated by the parasite;
2. The necessity of the requested action to construct improvements, or allow economic or other enjoyment
of the property;
3. The topography of the land and the effect of the requested action on erosion, soil retention, water
retention, and diversion or increased flow or surface water;
4. The number, species, size, and location of existing trees in the area and the effect of the requested
action in terms of providing shade, protection from wind, air pollution reduction, historic or cultural
value, and scenic beauty upon the health, safety, aesthetics, and general welfare of the City as a whole;
5. Generally accepted International Society of Arboriculture practices addressing topics such as, but not
limited to, the number of healthy trees a given parcel of land will support;
6. Native trees shall be retained unless their removal is absolutely necessary. (Ordinance 521, Section
1[B], 2000)
Chapter 12.32.170 – Replacement of Trees
Any person removing a live tree pursuant to a permit issued by the Director of Development Services or his/her designee
shall replace such tree on a one-for-one basis with a tree of the same size of a species and in a location approved by the
Director of Development Services or his/her designee. Where the tree to be removed exceeds the size of a 72-inch-box
specimen (approximately eight inches in diameter), two 48-inch box specimen trees shall be used as replacements.
These requirements may be waived or modified by the Director of Development Services if it is determined that the
requirements impose an unreasonable hardship. (Ordinance 521, Section 1[B], 2000)
Chapter 12.32.180 – Commercial, Industrial, and Residential Development Projects
For commercial, industrial, or residential projects requiring City approval, existing on-site trees shall be retained
wherever possible and shall be trimmed and maintained in accordance with the adopted “City of Poway Guidelines
to Landscape Requirements.” A master plan of the existing on-site trees shall be provided to the Development
Services Department prior to the issuance of building and grading permits, to determine which trees shall be
retained. Any dead, decaying, or potentially dangerous trees shall be approved for removal at the discretion of the
Director of Development Services during review of the master plan of existing on-site trees. All trees that are
removed shall be replaced on a one-for-one basis as described in PMC [Poway Municipal Code] 12.32.170, and
replacements should be one of the species contained in the adopted “City of Poway Guidelines to Landscape
Requirements.” (Ordinance 521, Section 1[B], 2000)
Poway Comprehensive Plan: General Plan – Resources Element
The Poway Comprehensive Plan: General Plan (General Plan) includes the following policies regarding biological
resources (City of Poway 1991):
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Goal IV: It is the goal of the city of Poway to preserve its natural, scenic and cultural resources for the future benefit
and enjoyment of its residents and to protect biological and ecological diversity.
Strategy 1: Significant open space areas and scenic vistas along local scenic roadways should be protected.
Strategy 2: The mountains, hillsides and prominent ridgelines are a valuable natural resource and should
be preserved through appropriate land use policies.
Policy C – Biological Resources: Wildlife and natural plants are a valuable natural resource and should be preserved
and protected.
Strategy 1: The acquisition and dedication of undeveloped land adjacent to and between existing dedicated
open space areas is encouraged to promote large contiguous areas necessary for watershed, habitat and
viewshed protection. If private development is required to purchase and dedicate land to mitigate environmental
impacts, the acquisition of areas adjacent to existing large permanent open space areas is preferred.
Strategy 2: Biological corridors shall be preserved in order to provide linkages for vegetative and wildlife
communities between nonconnective open space areas. Special efforts shall be made to acquire and
preserve the two major wildlife corridors identified in the Detailed Biological Assessment and lands linking
open space areas in Poway to open space areas in the region, such as the Sycamore Canyon County Park
and San Dieguito Regional Park.
Strategy 3: Development should not disrupt habitats considered to be sensitive, or the habitat of
sensitive, declining, threatened, rare or endangered species. An assessment, performed by a qualified
biologist, shall be required in areas where the existence of a sensitive species is known or reasonably
expected to be present.
Strategy 4: Off-road vehicle use is prohibited.
Strategy 5: Access of humans and domestic animals to preserved biological habitats and sensitive
biological areas shall be limited as deemed necessary to preserve the integrity of the areas.
Strategy 6: Confinement of horses, cattle and other livestock shall not be permitted in natural open space
areas or sensitive biological areas.
Strategy 7: Mitigation for significant impacts for biological resources in the form of preservation (on site
and off site) or restoration shall be required. All preservation and restoration areas shall be dedicated as
permanent biological open space.
Strategy 8: The City and development community should use the important biological resource areas, as
identified in the Detailed Biological Assessment, as the foundation for a City-wide system of reserves and
wildlife corridors. Efforts should be made to acquire unprotected lands within and adjacent to these areas,
through mitigation banking programs or other land transfer and acquisition programs for the purposes of
biological resource preservation and natural open space management.
Strategy 9: Require biological monitoring during construction where there is the potential to impact
sensitive biological resources. Construction monitoring shall be conducted by a qualified biologist and
follow the guidelines outlined in the Detailed Biological Assessment to ensure that all construction practices
consider the protection of sensitive biological resources both on and off site.
Strategy 10: Long-term biological management plans for open space areas within a proposed development
should be developed by a qualified biologist and implemented by the developer.
Strategy 11: Habitat conservation plans should be developed for endangered resources.
Strategy 12: The hunting of wildlife shall be prohibited in Poway.
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Strategy 13: Development proposals shall consider areas determined to be particularly valuable to wildlife
as identified for each quadrant of the City in the Detailed Biological Assessment. Efforts shall be made to
minimize encroachment into these areas.
Strategy 14: Plant resources, particularly large expanses of undisturbed natural areas, oak woodlands,
riparian corridors, significant tree stands and sensitive declining, threatened and endangered species
should be preserved through appropriate means such as buffering and dedicated open space.
Strategy 15: Large tree stands comprised of oaks, sycamores or eucalyptus should be retained and
integrated into project designs. The understory in these stands should also be retained or enhanced with
native species as deemed appropriate by a qualified biologist or native plant horticulturalist. Areas
preserved shall be designated as permanent natural open space.
The biological resources report can be found in Appendix C.
Poway Subarea Habitat Conservation Plan/Natural Community Conservation Plan
The Poway Subarea HCP/NCCP (City of Poway 1996) lists general development requirements that apply to all
parcels of land in the City that may contain native or natural vegetation and wildlife. Section 7.3.2, Specific
Development Requirements, in the Poway Subarea HCP/NCCP is not applicable to the proposed project because
the project site is not located within the Mitigation Area. The following are applicable requirements that haven’t
already been discussed in this section.
7.3.1 General Development Requirements
8. The potential adverse effects of development and associated human activity (for example, noise, light, and
encroachment by people or domestic animals) on adjacent open space, natural habitat, biological core areas,
habitat linkages, and wildlife movement corridors shall be limited as deemed necessary to preserve the
integrity of these areas. In some cases, a buffer of protected natural habitat surrounding the development
area may be required (Poway Municipal Code, General Plan, and CEQA Implementation Procedures).
23. Important and sensitive biological resources, significant archaeological resources, and historical sites shall
be protected and integrated into the design of a development project where feasible (Poway General Plan).
28. Monitoring by a qualified biologist during vegetation clearing, grading, construction, and land development
activities shall be required where there is the potential to impact sensitive biological resources both on and
off site (Poway General Plan).
7.4 Compensation Mitigation
Impacts to vegetation communities and wildlife habitats in the City of Poway, either inside or outside of the Mitigation
Area, shall require compensating mitigation, restoration, or revegetation, or a combination thereof, inside the
Mitigation Area. Compensating mitigation can consist either of 1) outright purchase or dedication of lands inside the
Mitigation Area as biological open space or 2) payment of in-lieu fees into a mitigation bank administered by the City
of Poway or a land trust acting as an agent of the City of Poway. Mitigation lands should be selected according to the
priority ratings for the Proposed Resource Protection Areas (PRPAs) outlined in Section 5.5.
The compensation strategy applies to planned public and private development projects within the City or within
other jurisdictions that choose to mitigate within Poway. It includes provisions for “in-kind/out-of-kind” and “on-
site/off-site” compensation mitigation. The specific mitigation strategy for a development project will be based on
the result of a biological resource survey technical report prepared by a qualified biologist.
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7.4.1 Compensation for Impacts Outside Mitigation Area
Biological impacts for projects outside of the Mitigation Area will be mitigated primarily by in-kind habitat acquisition
within the Mitigation Area. In the event that there is insufficient inventory, of in-kind habitat available for acquisition
within the Mitigation Area, or if out-of-kind habitat is available that better serves overall preserve design, mitigation
will be satisfied by purchase of a sufficient combination of in- and out-of-kind habitat. In all cases, mitigation
purchases must be within the Mitigation Area unless biological information indicates that habitat available for
acquisition outside of the Mitigation Area would add greater value to the preserve than would acquisitions within
the Mitigation Area. A reduction in the mitigation requirement of up to ten (10) percent will be granted for
compensation acreage acquired within high priority PRPAs (“PRPA Bonus”). If insufficient acreage is available within
high priority PRPAs, the 10 percent bonus may be applied to other selected parcels at the discretion of the City.
Optionally, mitigation compensation may be satisfied by the payment of a fee pursuant to the City’s Mitigation
Compensation In-lieu Fee Schedule and Process (Section 7.6). Such fees will be deposited in the City’s Mitigation
Area Acquisition Fund for purchase of preserve land within the Mitigation Area.
7.4.3 Compensation Mitigation Ratios
The following mitigation ratios shall apply to all projects resulting in removal of natural vegetation or wildlife habitat
within the City of Poway and that are subject to the HCP, whether inside or outside of the Mitigation Area.
Wetlands
Given the “no net loss” policy for wetland habitats of the City and the resources agencies (ACOE, USFWS, CDFW)
impacts to all wetland habitats shall be avoided or minimalized where alternatives exist. Any unavoidable impacts
to wetlands may require a permit from the ACOE under Section 404 of the Clean Water Act and will require a
Streambed Alteration Agreement with the CDFW. Unavoidable impacts to wetlands will be mitigated by
replacement or enhancement of a minimum of 3:1 for woodland types and 2:1 for shrub-dominated types.
Mitigation for disturbed wetlands will generally be mitigated in-kind at no less than 1:1 ratio as determined by a
case-by-case basis.
Oak Woodlands
Impacts to oak-dominated habitats shall require mitigation by in-kind habitat creation, restoration or enhancement
as determined by the City and the project biologist. Impacts shall require a minimum of a 3:1 replacement ratio,
depending on the quality and maturity of the habitat as determined by the project biologist.
To achieve 2:1 replacement of individual oak trees outside of woodland habitats in the long term, impacts to
individual oak specimens shall be replaced (linear stock) as follows:
10 oaks shall be planted for each oak directly impacted; and
Five oaks shall be planted for each oak indirectly impacted.
The oaks should be planted in appropriate habitat to create a comparable area of woodland value within the
Mitigation Area to that removed by the action.
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4.3.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to biological resources are based on Appendix G of
the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to biological
resources would occur if the proposed project would:
1. Have a substantial adverse effect, either directly or through habitat modifications, on any species identified
as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by
the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.
2. Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in
local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish
and Wildlife Service.
3. Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to,
marsh, vernal pool, coastal, etc.) through direct removal, filling, interruption, or other means.
4. Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with
established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.
5. Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation
policy or ordinance.
6. Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation
Plan, or other approved local, regional, or state habitat conservation plan.
4.3.4 Impacts Analysis
Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species
identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or
by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
As stated in Section 4.3.1, Existing Conditions, a majority of the vegetation on the site is comprised of non-native
ornamental plantings that line the former golf course fairways and access roads. While the grasses that make up
the golf course fairways and greens were the most common vegetation while the course was active, the majority of
the vegetation is now comprised of non-native weed species. No sensitive plants occur on the project site or in the
surrounding areas where off-site improvements are proposed, therefore the proposed project would have no impact
on sensitive plant species. No sensitive wildlife species were detected during the general survey (Appendix C).
The proposed project may result in direct impacts to small mammals and reptiles. Large mammal species and most
birds would be able to avoid impacts due to grading. Therefore, impacts to general wildlife are considered less than
significant and would not require mitigation.
The proposed project has potential to result in direct impacts to migratory or nesting birds, including Cooper’s hawk,
and other raptors within the survey area if vegetation removal occurs during the typical bird breeding season
(February 1 to September 15). There would be a potentially significant impact (Impact BR-1) on migratory or nesting
birds, which would require mitigation measures (MM-BR-1).
The project site is not directly adjacent to natural open space areas that support sensitive wildlife species.
Therefore, potential significant indirect impacts to sensitive wildlife species from lighting, noise, and human activity
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is not anticipated, both during and after project construction. Indirect impacts to any species identified as a
candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the CDFW or
USFWS are considered less than significant and would not require mitigation.
Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community
identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S.
Fish and Wildlife Service?
The large majority of the site is considered developed/disturbed habitat. However, on the southwestern end of the
project site, two sensitive natural communities were identified: 0.02 acres of freshwater marsh and 0.14 acres of
open water. Freshwater marshes are considered sensitive in accordance with the Poway Subarea HCP/NCCP (City
of Poway 1996), the ACOE, CDFW, and RWQCB (Appendix C). Open waters are considered sensitive in accordance
with the Poway Subarea HCP/NCCP (City of Poway 1996).
The proposed project would develop approximately 117.2 acres of the decommissioned StoneRidge Country Club
and associated 18-hole golf course into 160 residential buildings, non-residential buildings for recreational use, tot
lots, gardens, water quality basins, multi-use trails, and private streets. As shown on Figure 1-1, Site plan, the
freshwater marsh and the open water habitat spaces would be filled in order to build Private Street B, residential
homes, open spaces, multi-use trails, and water quality basins. Therefore, the project would have a potentially
significant impact (Impact BR-2) and would require mitigation measures (MM-BR-2).
Would the project have a substantial adverse effect on state or federally protected wetlands (including, but
not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or
other means?
A concrete-lined drainage collects stormwater runoff from the golf course and adjacent developments through
the freshwater marsh and open water freshwater pond; refer above to discussion regarding potential impacts
to those two sensitive natural communities. The drainage supports hydrophytic vegetation and flows south into
a natural watercourse, and as a result the concrete-lined drainage and associated water bodies (freshwater
marsh and open water freshwater pond) are considered jurisdictional waters of the United States and the
state. The total jurisdictional area equals 0.23 acres (0.02 acres freshwater marsh, 0.14 acres open water,
and 0.07 acres of concrete-lined channel) (Appendix C).
Additional concrete-lined drainages were found on the project site, but they were not found to flow into a natural
watercourse nor did they predominantly support hydrophytic vegetation. Therefore, they are not considered
jurisdictional waters of the United States and the state. Three abandoned, un-vegetated, concrete-lined golf course
ponds were found within the project site, but are not considered jurisdictional waters because they do not connect
to a natural drainage source and do they support hydrophytic vegetation.
The project’s potential impacts to the southerly concrete-lined drainage, freshwater marsh and open water habitat
(a total of 0.23 acres) found on the project site results in the impact to jurisdictional waters of the United States
and waters of the state. The proposed project would have a potentially significant impact (Impact BR-3) and would
require mitigation measures (MM-BR-2).
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Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife
species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife
nursery sites?
The project site is home to many mature trees that can be used as perching spots for migratory birds, including
raptors. Although there were no sensitive species surveyed on site, the habitat could potentially support migratory
or nesting birds, including species of special concern Cooper’s hawk. Therefore, the proposed project would have
a potentially significant impact on the movement of migratory wildlife species, such as migratory nesting birds (see
Impact BR-1), and would require mitigation measures (MM-BR-1).
Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree
preservation policy or ordinance?
As listed in Appendix C, Attachment 1, various trees were observed on the project site, such as species of eucalyptus
and pine (Pinus spp.) along with specimens of Mexican fan palm, date palm (Phoenix dactylifera), Peruvian pepper
tree (Schinus molle), Brazilian pepper tree (Schinus terebinthifolius) as well as coast live oak (Quercus agrifolia)
(Appendix C). Furthermore, as stated in the City of Poway Municipal Code, Chapter 12.32, all existing on-site trees
shall be retained wherever possible and shall be trimmed and maintained in accordance with the City of Poway
Guidelines to Landscape Requirements (City of Poway 2000). However, permits to remove trees are issued based
on criteria in Chapter 12, Urban Forestry, of the City of Poway Municipal Code. One of the criteria considered for
approval of a permit to remove trees includes “the condition of the tree with respect to disease, general health,
damage, public nuisance, danger of falling, proximity to existing or proposed structures and interference with utility
services, age or remaining life span, and whether or not the tree acts as a host for a plant which is parasitic to other
species of trees which are in danger of being infested or exterminated by the parasite” (City of Poway 2000).
Development of the project site would result in removal of trees. Based on Figure 1-1, it is assumed that at least
three coast live oaks and potentially other trees such as, but not limited to, eucalyptus, would be removed due to
placement of development such as parking lots or structures. According to the Farm in Poway Specific Plan (The
Farm in Poway LLC 2020), most of the existing trees on site are in poor health or represent a safety hazard.
Strategy 3 of the City’s General Plan Resources Element states that development should not disrupt habitats
considered to be sensitive (City of Poway 1991). Two sensitive habitats were found on site: freshwater marsh
and open water. The proposed project would develop approximately 117.2 acres of the decommissioned
StoneRidge Country Club and associated 18-hole golf course into 160 residential buildings, non-residential
buildings for recreational use, tot lots, gardens, water quality basins, multi-use trails, and private streets. As
shown on Figure 1-1, the freshwater marsh and the open water habitat spaces would be filled in order to build
Private Street B, residential homes, open spaces, multi-use trails, and water quality basins.
Therefore, due to the removal of trees and impacts to two sensitive habitats, the proposed project would result in
potentially significant impacts related to potential conflicts with local policies or ordinances protecting biological
resources (Impact BR-4) and would require mitigation measures (MM-BR-2, MM-BR-3).
Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local, regional, or state habitat conservation plan?
The project site is located within the Poway Subarea HCP/NCCP. The Poway Subarea HCP/NCCP was adopted in
1996, and serves as the project document for the protection and management of biologically effective,
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interconnected spaces in the City. A preserve system within the City has been designated as the Poway Mitigation
Area as part of the Poway Subarea HCP/NCCP (City of Poway 1996).
The project site is not located within the Poway Mitigation Area (see Figure 4.3-3, Project Location in Relation to City
of Poway HCP Mitigation Area). This is due to the highly developed setting of the property and its isolation from adjacent
undeveloped habitat areas by residential development. Therefore, implementation of the proposed project would not
conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other
approved local, regional, or state habitat conservation plan, and impacts would be less than significant.
The proposed project’s impacts to biological resources are listed as follows:
Impact BR-1 The proposed project would result in significant impacts to nesting birds if suitable nesting
habitats, such as mature trees, are removed during the general bird breeding season from
February 1 to September 15.
Impact BR-2 The proposed project would impact 0.16 acres of wetland/riparian and other sensitive
natural communities.
Impact BR-3 The proposed project would impact 0.23 acres of jurisdictional waters and wetlands.
Impact BR-4 The proposed project would result in the unavoidable impact of trees and sensitive habitats on the
project site, therefore being in conflict with local regulations.
4.3.5 Cumulative Impacts
A cumulative study area for biological resources was identified based on the local environment setting and areas
that share similar biological resources as those determined to occur on the proposed project site. The geographic
scope of cumulative impacts are limited to other projects within the City (see Table 3-2, Cumulative Projects).
4.3.5.1 Special-Status Plant and Wildlife Species
The proposed project site is heavily disturbed due to its prior use as a golf course and recreational site. No special-status
plants or wildlife were observed on site. Although no special-status wildlife were recorded on site, it is possible that
special-status wildlife, such as Cooper’s hawk, could occur and nest on site because of the presence of mature trees.
Avoidance of nesting birds is a regulatory requirement for any project occurring within the cumulative study area. Nesting
birds are protected under federal and state policy, including the MBTA and California Fish and Game Code, respectively.
Without the appropriate mitigation, in combination with other cumulative projects, the proposed project would potentially
contribute to a cumulatively considerable impact to nesting birds (Impact BR-CU-1); see MM-BR-1.
4.3.5.2 Riparian Habitat or Other Sensitive Natural Communities
As discussed in Section 4.3.4, Impacts Analysis, 0.02 acres of freshwater marsh and 0.14 acres of open water
would be impacted by the proposed project. Freshwater marshes are considered sensitive in accordance with the
Poway Subarea HCP/NCCP (City of Poway 1996), the ACOE, CDFW, and RWQCB (Appendix C). Open waters are
considered sensitive in accordance with the Poway Subarea HCP/NCCP (City of Poway 1996). Without appropriate
mitigation, the proposed project in combination with cumulative projects would potentially contribute to the
cumulative impact to riparian habitat or other sensitive natural communities (Impact BR-CU-2); see MM-BR-2.
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4.3.5.3 Jurisdictional Waters and Wetlands
As discussed in Section 4.3.4, Impacts Analysis, 0.23 acres of jurisdictional waters and wetlands would be impacted
by the proposed project. In accordance with regulatory requirements, projects are required to notify the appropriate
regulatory agencies and obtain the appropriate permits to demonstrate compliance with existing regulations
protecting jurisdictional resources. The regulatory permitting process ensures that every project with unavoidable
impacts on jurisdictional resources implements required avoidance, minimization, and compensatory mitigation
measures and obtains the appropriate permits. Projects in the City of Poway are required to meet a no-net-loss
standard for both function and spatial area of wetland and non-wetland resources. Without appropriate mitigation,
the proposed project in combination with cumulative projects would potentially contribute to the cumulative impact
to jurisdictional waters and wetlands (Impact BR-CU-3); see MM-BR-2.
4.3.5.4 Conflict with Local Policies or Ordinances Protecting Biological Resources
As discussed in Section 4.3.4, trees on the project site would be impacted by the proposed project. Pursuant to
regulatory requirements, projects in the City are required to compensate the loss of mature and protected trees.
Without the appropriate mitigation, the proposed project in combination with other cumulative projects would
potentially contribute to the cumulative impact to mature and protected trees (Impact BR-CU-4); see MM-BR-3.
The proposed project’s potential cumulative impacts to biological resources are listed as follows:
Impact BR-CU-1 The proposed project would potentially contribute to a cumulatively considerable impact to
nesting birds.
Impact BR-CU-2 The proposed project would potentially contribute to a cumulatively considerable impact
to wetland/riparian and other sensitive natural communities.
Impact BR-CU-3 The proposed project would potentially contribute to a cumulatively considerable impact to
jurisdictional waters and wetlands.
Impact BR-CU-4 The proposed project would potentially contribute to a cumulatively considerable impact to
mature and protected trees.
4.3.6 Mitigation Measures
The following mitigation measures would be implemented to reduce potentially significant impacts to less than significant.
MM-BR-1 Removal of habitat that supports active nests in the proposed project area of disturbance shall occur
outside of the breeding season for nesting birds (February 1 to September 15). If removal of the habitat
in the proposed area of disturbance must occur during the breeding season, a qualified biologist shall
conduct a pre-construction survey to determine the presence or absence of nesting birds or raptors
protected under the Migratory Bird Treaty Act and California Fish and Game Code. The pre-construction
survey shall be conducted within 10 3 calendar days prior to the start of construction activities (including
removal of vegetation) and shall include the limits of disturbance as well as 300 feet (500 feet for
raptors) from the area of disturbance. The applicant shall submit the results of the pre-construction
survey to the City of Poway (City) for review and approval prior to initiating any construction activities.
1. If nesting birds are detected, a letter report or mitigation plan (pre-construction survey) in
conformance with applicable state and federal law (e.g., appropriate follow-up surveys,
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monitoring schedules, construction, noise barriers, and/or buffers up to 300 feet) shall be
prepared and include proposed measures to be implemented to ensure that take of birds or
eggs, or disturbance of breeding activities, is avoided. The report or mitigation plan shall be
submitted to the City for review and approval. The recommendations contained in the
mitigation plan shall be implemented to the satisfaction of the City.
2. If nesting birds are not detected during the pre-construction survey, no further mitigation
is required.
3. If nesting birds are detected and construction activities are to occur during the breeding season
the following mitigation measures shall be implemented:
a) No vegetation clearing shall occur within 300 feet of an active raptor nest and 100 feet of
an active nest of a non-listed bird species until a biologist has determined that the young
have fledged from the nest or that the nest is inactive (i.e., abandoned).
b) A mitigation plan outlining active nest avoidance measures in conformance with
applicable state and federal law shall be prepared and submitted to the City of Poway
for review and approval.
c) During construction, active nests shall be monitored on a daily basis to determine the
effectiveness of the avoidance measures being implemented. The biologist shall monitor
all active nests until all young have fledged or until the nest is determined inactive.
d) A minimum 300-foot buffer between the location of an active raptor nest and the
nearest construction activity shall be maintained until the young have fledged from the
nest or until the nest is determined inactive. For nests of non-raptor birds, a buffer of
100 feet shall be maintained.
4. While no specific noise level thresholds have been established for raptors or other non-listed
bird species, construction activities that are expected to generate noise levels above the
ambient noise level shall be measured by an acoustician technician. The active nest shall also
be monitored by a biologist to determine if there is any effect on the breeding behavior of the
particular species from the elevated noise levels. If it is determined that the elevated noise
level is having an effect on the breeding behavior of the nesting bird species, then the noise
generating construction activity shall be suspended in the vicinity of the active nest until such
time as all of the young birds have fledged or until the nest is determined inactive.
MM-BR-2 Impacts to jurisdictional waters require a 404 permit from the U.S. Army Corps of Engineers, a 401
state water quality certification from the Regional Water Quality Control Board, and a 1602
streambed alteration agreement from the California Department of Fish and Wildlife. Impacts to
the sensitive habitat, including jurisdictional waters, within the project site require compensating
mitigation, restoration, or revegetation, or a combination thereof, inside a priority Mitigation Area
as defined by the Poway Subarea Habitat Conservation Plan/Natural Community Conservation Plan
(Poway Subarea HCP/NCCP), Section 5.5. This can be achieved by one of the following:
1) Purchase or dedication of lands inside the City of Poway’s Mitigation Area as a biological open space.
2) Payment of in-lieu fees into a mitigation bank administered by the City of Poway or a land trust
acting as an agent of the City of Poway.
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Applicable permits necessary to develop over the wetland habitat features in the project site
require a no-net-loss ratio. The Poway Subarea HCP/NCCP states that mitigation ratios of 2:1 would
be required for impacts to fresh water marsh and open water. As described in the following table,
the total mitigation for jurisdictional waters impacts is estimated to total 0.39 acres, but requires
approval by the aforementioned resource agencies through their respective permit processes,
which would occur before project development.
Mitigation Requirements
Vegetation Community Impact Mitigation Ratio Total Mitigation Required
Freshwater Marsh 0.02 2:1 0.04
Open Water 0.14 2:1 0.28
Concrete-Lined Channel 0.07 1:1 0.07
Total 0.16 — 0.39
Source: Appendix C.
MM-BR-3 If it is not feasible to avoid trees on the project site, the project applicant shall replace all impacted
trees as follows:
1) Native coast live oaks (Quercus agrifolia) will be mitigated at minimum ratios of 10:1 for directly
impacted oak trees and 5:1 for indirectly impacted oak trees, as required by the City’s
HCP/NCCP, 4:1 ratio and shall use 24-inch box specimen trees to be located on site.
2) Any non-native trees removed will be replaced with one 15-gallon tree per 750 square feet of
ornamental landscape (20 percent of which shall be 24-inch box specimen trees).
4.3.7 Level of Significance After Mitigation
MM-BR-1 would reduce Impact BR-1 and Impact BR-CU-1 by ensuring that if an active migratory bird or raptor nest is
identified, a letter report or mitigation plan (pre-construction survey) in conformance with applicable state and federal law
(e.g., appropriate follow-up surveys, monitoring schedules, construction, noise barriers, and/or buffers up to 300 feet) shall
be prepared and include proposed measures to be implemented to ensure that take of birds or eggs, or disturbance of
breeding activities, is avoided, including, but not limited to, the specific performance criteria expressly listed in MM-BR-1.
The report or mitigation plan shall be submitted to the City for review and approval. The recommendations contained in the
mitigation plan shall be implemented to the satisfaction of the City. Additionally, the proposed project would incorporate
open space such as agrifields, basins, and gardens that could function as foraging habitat for raptors and other species. By
avoiding migratory bird, raptor nests, and functional foraging habitats for raptors and other species, Impact BR-1 and Impact
BR-CU-1 would be reduced to less than significant.
MM-BR-2 would reduce Impact BR-2, Impact BR-3, Impact BR-4, Impact BR-CU-2, and Impact BR-CU-3 by ensuring
that the impacts to the 0.16 acres of sensitive biological resources (open water and freshwater marsh) and 0.23
acres of jurisdictional waters and wetlands would be mitigated. Additionally, the collection of appropriate permits
would mitigate impacts. Implementation of MM-BR-2 would reduce Impact BR-2, Impact BR-3, Impact BR-4, Impact
BR-CU-2, and Impact BR-CU-3 to less than significant.
MM-BR-3 would reduce Impact BR-4 and Impact BR-CU-4 to less than significant by replacing any removed trees
as described above.
With the implementation of MM-BR-1 through MM-BR-3, all impacts to biological resources would be reduced to
less-than-significant levels.
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Vegetation Communities and Land Cover Types
The Farm in Poway
SOURCE: RECON 2019; SANGIS 2017, 2019
0 500250Feet
Project Boundary
Vegetation Communities/Land Cover Types
Freshwater Marsh
Open Water (Pond)
Concrete Channel
Developed Land
FIGURE 4.3-1
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Date: 6/14/2019 - Last saved by: agreis - Path: Z:\Projects\j1187201\MAPDOC\EIR\Figure4-3-2_ProjectLocation_USGS.mxdProject Location on USGS Map
The Farm in Poway
SOURCE: USGS 7.5-Minute Series Escondido Quadrangle; SANGIS 2019
0 2,0001,000 Feet
Project Boundary
FIGURE 4.3-2
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Project Location in Relation to City of Poway HCP Mitigation Area
The Farm in Poway
FIGURE 4.3-3SOURCE: RECON 2019Z:\Projects\j1187201\MAPDOC\PD
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4.4 – Cultural and Tribal Cultural Resources
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4.4 Cultural and Tribal Cultural Resources
This section describes the existing cultural resources conditions of The Farm in Poway project (proposed
project) site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and
identifies mitigation measures related to implementation of the proposed project. The information provided in
this section was incorporated from the Cultural Resources Study for The Farm in Poway Project prepared by
Brian F. Smith and Associates Inc. in February 2020. A copy of this report is included in this Environmental
Impact Report (EIR) as Appendix D.
A Notice of Preparation (NOP) was circulated from May 10, 2019, to June 10, 2019. During the NOP comment
period, comment letters related to cultural and tribal cultural resources focused on the following topics:
Presence of cultural resources
Acknowledgment of tribal history
Requests for formal tribal consultation
These comments were considered during the preparation of this EIR. The Initial Study, NOP, and Public Scoping
comments are provided in Appendix A of this EIR.
4.4.1 Existing Conditions
Cultural Setting
Prehistoric Period
The prehistoric cultural sequence in the County of San Diego (County) is generally conceived as comprising three
basic periods: (1) the Paleoindian, dated between about 11,500 and 8,500 years ago and manifested by the
artifacts of the San Dieguito Complex; (2) the Archaic, lasting from about 8,500 to 1,500 years ago (AD 500) and
manifested by the cobble and core technology of the La Jollan Complex; and (3) the Late Prehistoric, lasting from
about 1,500 years ago to historic contact (i.e., AD 500 to 1769) and represented by the Cuyamaca Complex. The
latest complex is marked by the appearance of ceramics, small arrow points, and cremation burial practices.
The Paleoindian Period in the County is most clearly associated with the San Dieguito Complex, as identified by
Rogers (1938, 1939, 1945, as cited in Appendix D). The San Dieguito assemblage consists of well-made scraper
planes, choppers, scraping tools, crescentics, elongated bifacial knives, and leaf-shaped points. The San Dieguito
Complex is thought to represent an early emphasis on hunting (Warren et al. 1993, as cited in Appendix D).
The Archaic Period brings an apparent shift toward a more generalized economy and an increased emphasis on seed
resources, small game, and shellfish. The local cultural manifestations of the Archaic Period are called the La Jollan Complex
along the coast and the Pauma Complex inland. Pauma Complex sites lack the shell that dominates many La Jollan sites.
Along with an economic focus on gathering plant resources, the settlement system appears to have been more sedentary.
The La Jollan assemblage is dominated by rough cobble-based choppers and scrapers, and slab and basin metates. Large
side-notched and Elko series projectile points appeared during this period. Large deposits of marine shell at coastal sites
argue for the importance of shellfish gathering to the coastal Archaic Period economy.
Near the coast and in the Peninsular Mountains beginning approximately 1,500 years ago, patterns began to emerge
that suggest the ethnohistoric Kumeyaay. This period is characterized by higher population densities and elaborations in
social, political, and technological systems. Economic systems diversify and intensify during this period, with the
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continued elaboration of trade networks, the use of shell-bead currency, and the appearance of more labor-intensive,
but effective technological innovations. The late prehistoric archaeology of the San Diego coast and foothills is
characterized by the Cuyamaca Complex. It is primarily known from the work of D. L. True at Cuyamaca Rancho State
Park (True 1970, as cited in Appendix D). The Cuyamaca Complex is characterized by the presence of steatite arrow shaft
straighteners, steatite pendants, steatite comales (heating stones), Tizon Brownware pottery, ceramic figurines
reminiscent of Hohokam styles, ceramic “Yuman bow pipes,” ceramic rattles, miniature pottery, various cobble-based
tools (e.g., scrapers, choppers, hammerstones), bone awls, manos and metates, mortars and pestles, and Desert side-
notched (more common) and Cottonwood Series projectile points (Appendix D).
Ethnohistory
The Kumeyaay (also known as Kamia, Ipai, Tipai, and Diegueño) occupied the southern two-thirds of the County.
The Kumeyaay lived in semi-sedentary, politically autonomous villages or rancherias. Settlement systems typically
consisted of two or more seasonal villages with temporary camps radiating away from these central places (Cline
1984a, 1984b, as cited in Appendix D). The Kumeyaay economic system consisted of hunting and gathering with
a focus on small game, acorns, grass seeds, and other plant resources. The most basic social and economic unit
was the patrilocal extended family. A wide range of tools were made of locally available and imported materials. A
simple shoulder-height bow was used for hunting. Numerous other flaked stone tools were made including scrapers,
choppers, flake-based cutting tools, and biface knives. Preferred stone types were locally available metavolcanics,
cherts, and quartz. Obsidian was imported from the deserts to the north and east. Ground stone objects include
mortars and pestles typically made of locally available, fine-grained granite. Both portable and bedrock types are
known. The Kumeyaay made fine baskets, employing either coiled or twined construction. The Kumeyaay also made
pottery, using the paddle-and-anvil technique. Most were a plain brown utility ware called Tizon Brownware, but
some were decorated (Meighan 1954, as cited in Appendix D; May 1976, 1978, as cited in Appendix D). Primary
ethnographic sources on traditional Kumeyaay lifeways are provided in the ethnographic work of Cline (1984a,
1984b, as cited in Appendix D), Gifford (1918, 1931, as cited in Appendix D), Kroeber (1925, as cited in Appendix
D), and Spier (1923, as cited in Appendix D).
Spanish, Mexican, and American Periods
The Spanish Period (1769–1821) represents a time of European exploration and settlement. Military and naval
forces along with a religious contingent founded the San Diego Presidio, the pueblo of San Diego, and the San Diego
Mission in 1769 (Rolle 1998, as cited in Appendix D). Native American culture in the coastal strip of California
rapidly deteriorated despite repeated attempts to revolt against the Spanish invaders (Cook 1976, as cited in
Appendix D). One of the hallmarks of the Spanish colonial scheme was the rancho system. In an attempt to
encourage settlement and development of the colonies, large land grants were made to meritorious or well-
connected individuals.
In 1821, Mexico declared its independence from Spain. During the Mexican Period (1822–1848), the mission
system was secularized by the Mexican government and these lands allowed for the dramatic expansion of the
rancho system. The southern California economy became increasingly based on cattle ranching.
The Mexican Period ended when Mexico signed the Treaty of Guadalupe Hidalgo on February 2, 1848, concluding
the Mexican–American War (1846–1848) (Rolle 1998, as cited in Appendix D). The great influx of Americans and
Europeans resulting from the California Gold Rush in 1848–1849 eliminated many remaining vestiges of Native
American culture.
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The first recorded Anglo-European settler in the Poway area was Philip Crosthwaite, who began ranching there in
1859. By 1870, the number of settlers in the area had increased to the point that resident Castanos Paine applied
for and was granted the position of postmaster. Paine ran a ranch that also served as a way station for the stage
running to and from San Diego. The population of the Poway area continued to grow through the 1880s, reaching
approximately 800 by 1887. Farming was the main occupation, with numerous orchards and vineyards established
and grains being farmed. Dairy ranching and beekeeping were also common. The chance of a railroad line running
through the Poway area led to some land speculation in the 1880s, but the line did not materialize and land
speculation dried up. By 1900, there were still less than 1,000 people living in the Poway area and it remained
basically rural through the early to mid-1950s. The first subdivision built in Poway in the late 1950s was a result of
the post-World War II boom affecting much of the County. Lake Poway was constructed in 1971, establishing a
more stable and permanent water supply for the growing population. Poway incorporated in 1980, establishing a
Council/Manager form of government (City of Poway 2016, as cited in Appendix D).
Methodology
A record search was conducted through the California Historical Resources Information System and the South
Coastal Information Center (SCIC) at San Diego State University to determine if there are any cultural resources on
the project site. On January 11, 2019, a letter requesting a search of the Sacred Lands Files was sent to the Native
American Heritage Commission (NAHC) in Sacramento, California.
RECON archaeologist, Richard Shultz, and Native American monitors, Banning Taylor, Jr., and Alyssa Soto, surveyed
the project site on September 22, 2017. The surveying team inspected the site for evidence of archaeological
materials such as flaked and ground stone tools, ceramics, milling features, and human remains. A sub-meter GPS
unit provided the team sub-meter accuracy and real-time position correction and recording capability. Photographs
of the existing conditions on site can be found in Appendix D.
Record Search
A record search of the project site with a one-mile-radius buffer was conducted at the SCIC at San Diego State
University on September 25, 2017. The search included a review of the National Register of Historic Places (NRHP)
for the County, National Historic Landmarks, California Register of Historical Resources (CRHR), California
Registered Landmarks, California Points of Historical Interests, historic resources inventory files, archaeological
inventory files, a bibliography of previous cultural resources investigations, and various historic maps.
No cultural resources are recorded within the project site or within one mile of the project site. The SCIC identified
one historic-era site, two historic structures, one multi-component site (both prehistoric and historic), 42 prehistoric
sites, and one prehistoric isolated artifact within a one-mile radius (Table 4.4-1). The historic site consisted of
masonry wall remnants. The historic structures were two utility poles. The prehistoric sites included bedrock milling
features, bedrock milling features with artifacts, lithic scatters, ceramic scatters, ground stone, faunal remains
(shellfish and bone), and pictographs.
Table 4.4-1. Cultural Resources within One Mile of the Project Site
Primary # Trinomial # Site Type Period Date Recorded
P-37-000007 CA-SDI-000007 Rock art: petroglyphs, pictographs Prehistoric 1957
P-37-000008 CA-SDI-000008 Rock art: pictographs, bedrock milling,
ceramic scatter, ground stone
Prehistoric 1957
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Table 4.4-1. Cultural Resources within One Mile of the Project Site
Primary # Trinomial # Site Type Period Date Recorded
P-37-000010 CA-SDI-000010 Bedrock milling, lithic scatter; wall remnants Multicompo
nent
1981
P-37-000160 CA-SDI-000160 Masonry wall remnants Historic 1957
P-37-000576 CA-SDI-000576 Bedrock milling, lithic scatter, ground stone Prehistoric n/a
P-37-000578 CA-SDI-000578 Lithic scatter, ground stone Prehistoric n/a
P-37-000581 CA-SDI-000581 Lithic scatter, ground stone Prehistoric n/a
P-37-000582 CA-SDI-000582 Lithic scatter, ground stone Prehistoric n/a
P-37-000590 CA-SDI-000590 Bedrock milling, lithic scatter, ground stone Prehistoric n/a
P-37-000807 CA-SDI-000807 Lithic scatter Prehistoric 1960
P-37-000808 CA-SDI-000808 Bedrock milling, ceramic scatter Prehistoric 1960
P-37-004561 CA-SDI-004561 Bedrock milling, lithic scatter Prehistoric 1971
P-37-004565 CA-SDI-004565 Bedrock milling, lithic scatter, ceramic scatter,
ground stone
Prehistoric 1973
P-37-004566 CA-SDI-004566 Lithic scatter Prehistoric 1973
P-37-004567 CA-SDI-004567 Lithic scatter Prehistoric 1973
P-37-004568 CA-SDI-004568 Lithic scatter, ground stone Prehistoric 1973
P-37-004569 CA-SDI-004569 Lithic scatter, ground stone Prehistoric 1973
P-37-007858 CA-SDI-007858 Bedrock milling, lithic scatter, ceramic scatter,
ground stone
Prehistoric 1980
P-37-007859 CA-SDI-007859 Bedrock milling, lithic scatter, ground stone Prehistoric 1980
P-37-007860 CA-SDI-007860 Bedrock milling, ground stone Prehistoric 1980
P-37-007862 CA-SDI-007862 Lithic scatter Prehistoric 1980
P-37-008745 CA-SDI-008745 Ceramic scatter, lithic scatter Prehistoric 1981
P-37-008746 CA-SDI-008746 Bedrock milling Prehistoric 1981
P-37-011153 CA-SDI-011153 Bedrock milling Prehistoric 1989
P-37-011154 CA-SDI-011154 Lithic scatter Prehistoric 1989
P-37-011155 CA-SDI-011155 Lithic scatter, ground stone Prehistoric 1989
P-37-011516 CA-SDI-011516 Lithic scatter, ground stone Prehistoric 1989
P-37-011517 CA-SDI-011517 Bedrock milling Prehistoric 1989
P-37-011520 CA-SDI-011520 Lithic scatter, ground stone Prehistoric 1989
P-37-011521 CA-SDI-011521 Bedrock milling, lithic scatter, ceramic scatter,
ground stone, faunal remains
Prehistoric 1989
P-37-011522 CA-SDI-011522 Bedrock milling, rock features, lithic scatter,
faunal remains
Prehistoric 1989
P-37-011523 CA-SDI-011523 Bedrock milling, lithic scatter, ceramic scatter,
ground stone, faunal remains
Prehistoric 1989
P-37-011524 CA-SDI-011524 Bedrock milling Prehistoric 1989
P-37-011529 CA-SDI-011529 Bedrock milling, rock features, lithic scatter,
faunal remains
Prehistoric 1989
P-37-011532 CA-SDI-011532 Bedrock milling Prehistoric 1989
P-37-014683 CA-SDI-014286 Bedrock milling, lithic scatter, ground stone Prehistoric 1996
P-37-014746 — Isolate: flake Prehistoric 1979
P-37-016197 CA-SDI-014736 Bedrock milling, lithic scatter, ceramic scatter Prehistoric 1998
P-37-017105 CA-SDI-015119 Bedrock milling Prehistoric 2008
P-37-018384 CA-SDI-015587 Bedrock milling Prehistoric 1999
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Table 4.4-1. Cultural Resources within One Mile of the Project Site
Primary # Trinomial # Site Type Period Date Recorded
P-37-019020 CA-SDI-013714 Possible hearths, lithic scatter, ceramic
scatter, ground stone
Prehistoric 1994
P-37-019022 CA-SDI-013716 Bedrock milling Prehistoric 1994
P-37-024332 CA-SDI-016141 Bedrock milling, lithic scatter, ceramic scatter,
ground stone, faunal remains
Prehistoric 2017
P-37-024333 CA-SDI-016142 Lithic scatter, ceramic scatter, ground stone,
faunal remains
Prehistoric 2001
P-37-026992 CA-SDI-017671 Bedrock milling Prehistoric 2005
P-37-030247 — Utility pole Historic 2008
P-37-030290 — Utility pole Historic 2008
Source: Appendix D.
The record search indicated that five previous investigations intersect with the project site.
The 1968 Escondido 7.5-minute quadrangle illustrated sewage disposal ponds in the southern part of the project
site near the existing ponds. Additionally, the San Diego Aqueduct runs underground in a northwest–southwest
direction through the center of the project site. The first pipeline was completed in 1947 and brings water to the
County from the Colorado River. Three additional pipelines were constructed between 1954 and 1973 (Crawford
2010, as cited in Appendix D). Air photographs available online show the project site in agriculture in 1946, 1947,
and 1953 (Nationwide Environmental Title Research LLC 2015, as cited in Appendix D). By 1964 the roads
surrounding the project site had been completed, but grading for the golf course had not begun, and subsequent
photographs from the 1960s also showed the golf course undeveloped. The houses surrounding the golf course
has not been constructed in the 1960s. A 1980 photograph shows the golf course, clubhouse, and surrounding
houses in place. A 1989 photograph shows substantial alteration to the clubhouse. Subsequent photographs from
the 1990s and 2000s show little change (Appendix D).
Tribal Resources
A letter was sent to the NAHC in Sacramento, California, on January 17, 2019, requesting a search of their Sacred
Lands Files. A reply was received from the NAHC on January 22, 2019, stating that a search of the Sacred Lands
Files produced negative results. Contact letters were sent out to all groups and individuals on the NAHC contact list
on February 19, 2019. On February 20, 2019, an email response was received from Mr. Clint Linton representing
the Iipay Nation Santa Ysabel. Mr. Linton requested additional information regarding the proposed project. On
February 20, 2019, RECON Archaeologist Harry Price called Mr. Linton and the two discussed the proposed project.
Mr. Linton’s email was forwarded to the City. On February 21, 2019, another response was received—from Mr.
Ralph Goff of the Campo Band of Mission Indians. Mr. Goff requested a copy of the survey report and requested
that a qualified Kumeyaay monitor be present for all future surveys and ground-disturbing activities. Mr. Goff’s reply
was forwarded to the City on February 26, 2019 (Appendix D).
On March 20, 2019, a response was received by Ray Teran of the Viejas Band of Kumeyaay Indians. Mr. Teran
requested that a Kumeyaay Cultural Monitor be present on the project site for all ground disturbing activities (Teran,
pers. comm. 2019).
On March 25, 2019, a response was received by Lisa Cumper of the Jamul Indian Village of California requesting
consultation. This consultation resulted in minor changes, clarifications, and reorganization of the mitigation
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measures; see Section 4.4.6. The changes do not raise important new issues about significant effects on the
environment. Such changes are insignificant as the term is used in Section 15088.5(b) of the California
Environmental Quality Act (CEQA) Guidelines. This consultation concluded with an email from Lisa Cumper dated
March 30, 2020, stating that she accepted the mitigation measures, as revised is currently ongoing. (Cumper, pers.
comm. 2019 2020).
On August 6, 2019, another request was received by Harry P. Cuero Jr. of the Campo Band of Mission Indians in a
letter dated July 25, 2019. Mr. Cuero requested AB-52 and SB-18 Consultation with the City for the proposed project
(Cuero, pers. comm. 2019). The City responded to set up the requested consultation on August 22, 2019, October
10, 2019, and again on October 21, 2019. The City did not hear back from Mr. Cuero about setting up a
consultation. In the last correspondence on October 21, 2019, the City indicated “I will consider this consultation
closed if I do not hear from you within 30 days of this email.” No further replies or requests have been received by
Mr. Cuero, the Campo Band of Mission Indians, or other tribes.
Survey Results
On September 22, 2017, a field survey of the project site was conducted by RECON Archaeologist Richard Shultz
and by Native American monitors Banning Taylor, Jr., and Alyssa Soto. The survey was conducted to identify
previously unrecorded cultural resources and assess the potential for the proposed project to affect any potentially
significant cultural resources found on the project site.
The majority of the project site had zero ground visibility due to the dense grass on the fairways and greens.
The areas outside the fairways and greens varied in visibility. Some areas were covered in leaf duff with 10
percent visibility, whereas other areas had excellent visibility. The survey team focused on the bedrock lining
the fairways and greens. The entire project site has been disturbed by the construction of the golf course and
associated clubhouse, ancillary buildings, tennis courts, and roads. The areas outside the fairways and greens
may have limited disturbance. Photographs of the varying conditions of the project site during the survey can
be found in Appendix D.
Two previously unrecorded cultural resources were identified during the field survey. The first resource (Resource
8858-RDS-001) consists of bedrock milling feature. A single amorphous slick is located on a prominent vertical
boulder between the ninth hole tee and eighth hole green, and surrounded by palm and eucalyptus trees. The
slick measures approximately 39.3 by 23.6 inches. The second resource (Resource 8858-RDS-002) consists of
two bedrock milling features. The first bedrock milling feature contains one slick, measuring approximately 7.9
by 11.8 inches. It is located on a low triangular boulder surrounded by in situ outcrops and a push-pile of boulders,
approximately 200 feet south of the first resource and 230 feet south of the eighth hole green. The second
bedrock milling feature contains a basin/slick on a low embedded boulder, approximately 230 feet south of the
above slick. The basin/slick measures approximately 11.8 by 15.7 inches. Both features are located west of
StoneRidge Country Club Lane and surrounded by palm trees. No surface artifacts were noted at either resource
location. The level of disturbance was difficult to determine; however, the bedrock milling features appear to be
at their original elevations implying minimal disturbances surrounding these features. California Department of
Parks and Recreation primary site forms were filled out for the two milling features and will be submitted to the
SCIC. These forms can be found in Appendix D.
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4.4.2 Relevant Plans, Policies, and Ordinances
Federal
National Historic Preservation Act
The National Historic Preservation Act (16 USC 470 et seq.) establishes the nation’s policy for historic preservation
and sets in place a program for the preservation of historic properties by requiring federal agencies to consider
effects to significant cultural resources (e.g., historic properties) prior to undertakings.
Section 106 of the National Historic Preservation Act requires federal agencies to take into account the effects of
projects on historic properties (resources included in or eligible for the NRHP). It also gives the Advisory Council on
Historic Preservation and the state historic preservation offices an opportunity to consult. Federal agencies issuing
permits for the proposed project would be required to comply with National Historic Preservation Act requirements.
Antiquities Act
The Antiquities Act of 1906 (16 USC 431–433) protects any historic or prehistoric ruin or monument, or any object
of antiquity, situated on lands owned or controlled by the government of the United States from appropriation,
excavation, injury, or destruction without the permission of the secretary of the department of the government
having jurisdiction over the lands on which the antiquities are situated. The California Department of Transportation,
National Park Service, Bureau of Land Management, U.S. Forest Service, and other federal agencies have
interpreted objects of antiquity to include fossils. The Antiquities Act provides for the issuance of permits to collect
fossils on lands administered by federal agencies and requires projects involving federal lands to obtain permits
for both paleontological resources evaluation and mitigation efforts.
American Indian Religious Freedom Act
The American Indian Religious Freedom Act (42 USC 1996) protects Native American religious practices, ethnic
heritage sites, and land uses.
Native American Graves Protection and Repatriation Act
Enacted in 1990, the Native American Graves Protection and Repatriation Act conveys to American Indians of
demonstrated lineal decent the human remains and funerary or religious items that are held by federal agencies
and federally supported museums, or that have been recovered from federal lands. It also makes the sale or
purchase of American Indian remains illegal, whether or not they derive from federal or Indian lands.
Secretary of the Interior Standards
The Secretary of the Interior is the head of the U.S. Department of the Interior, which is the nation’s principal
conservation agency. The department oversees agencies including the Bureau of Land Management, the Bureau
of Indian Affairs, and the National Park Service.
The Secretary of the Interior’s Standards and Guidelines for Archaeology and Historic Preservation
The purpose of the Secretary of the Interior’s Standards and Guidelines for Archaeology and Historic Preservation
of 1983 is to (1) organize the information gathered about preservation activities; (2) describe results to be achieved
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by federal agencies, states, and others when planning for the identification, evaluation, registration and treatment
of historic properties; and (3) integrate the diverse efforts of many entities performing historic preservation into a
systematic effort to preserve the nation’s culture heritage.
The Secretary of the Interior’s Standards for Rehabilitation
Developed in 1986, the Secretary of the Interior’s Standards for Rehabilitation are 10 basic principles created to
help preserve the distinctive character of a historic building and its site, while allowing for reasonable change to
meet new needs.
The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving,
Rehabilitating, Restoring, and Reconstructing Historic Buildings
The Secretary of the Interior’s Standards for the Treatment of Historic Properties were developed to help protect
the nation’s irreplaceable cultural resources by promoting consistent preservation practices. The standards are a
series of concepts about maintaining, repairing, and replacing historic materials, as well as designing new additions
or making alterations; thus, they cannot, in and of themselves, be used to make essential decisions about which
features of a historic property should be saved and which be changed. But once an appropriate treatment is
selected, the standards provide philosophical consistency to the work.
State
Assembly Bill 52 (Chapter 532, Statute of 2014)
Assembly Bill (AB) 52 (Chapter 532, Statute of 2014) establishes a formal consultation process for California Native
American tribes as part of the California Environmental Quality Act (CEQA) and equates significant impacts on tribal
cultural resources with significant environmental impacts (California Public Resources Code, Section 21084.2).
California Public Resources Code, Section 21074 defines tribal cultural resources as follows:
Sites, features, places, sacred places, and objects with cultural value to descendant communities or
cultural landscapes defined in size and scope that are:
o Included in or eligible for listing in the California Register of Historical Resources (CRHR); or
o Included in a local register of historic resources.
A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant
pursuant to criteria set forth in subdivision (c) of PRC [California Public Resources Code] Section 5024.1.
Sacred places can include Native American sanctified cemeteries, places of worship, religious or ceremonial sites,
and sacred shrines. In addition, both unique and non-unique archaeological resources, as defined in California
Public Resources Code, Section 21083.2, can be tribal cultural resources if they meet the criteria detailed above.
The lead agency relies upon substantial evidence to make the determination that a resource qualifies as a tribal
cultural resource when it is not already listed in the CRHR or a local register.
AB 52 defines a “California Native American Tribe” (Tribe) as a Native American tribe located in California that is on
the contact list maintained by the NAHC (California Public Resources Code, Section 21073). Under AB 52, formal
consultation with the Tribes is required prior to determining the level of environmental document if a Tribe has
requested to be informed by the lead agency of proposed projects and if the Tribe, upon receiving notice of the
project, accepts the opportunity to consult within 30 days of receipt of the notice. AB 52 also requires that
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consultation, if initiated, address project alternatives and mitigation measures for significant effects, if specifically
requested by the Tribe. AB 52 states that consultation is considered concluded when either the parties agree to
measures to mitigation or avoid a significant effect on tribal cultural resources, or when either the Tribe or the
agency concludes that mutual agreement cannot be reached after making a reasonable, good-faith effort. Under
AB 52, any mitigation measures recommended by the agency or agreed upon with the Tribe may be included in the
final environmental document and in the adopted mitigation monitoring program if they were determined to avoid
or lessen a significant impact on a tribal cultural resource. If the recommended measures are not included in the
final environmental document, then the lead agency must consider the four mitigation methods described in
California Public Resources Code, Section 21084.3. Any information submitted by a Tribe during the consultation
process is considered confidential and is not subject to public review or disclosure. It will be published in a
confidential appendix to the environmental document unless the Tribe consents to disclosure of all or some of the
information to the public.
California Historical Landmarks
The State Historical Landmarks Program places an emphasis on well-known places and events in California history.
The goals of the program include the preservation and maintenance of registered landmarks, most of which include
missions, early settlements, battles, and golf rush sites.
California Native American Graves Protection and Repatriation Act
The California Native American Graves Protection and Repatriation Act of 2001 conveys to American Indians of
demonstrated lineal descent the human remains and funerary items that are held by state agencies and museums.
California Points of Historical Interest Program
The State Points of Historical Interest Program was established in the effort to accommodate local historic properties not
able to meet the restrictive criteria of the State Historical Landmarks Program. The program requires the participation of
local governmental officials, such as the chairperson of the Board of Supervisors, in the approval process.
California Health and Safety Code, Section 7050.5 – Human Remains
Section 7050.5(b) of the California Health and Safety Code specifies protocol when human remains are discovered.
The code states the following:
In the event of discovery or recognition of any human remains in any location other than a dedicated
cemetery, there shall be no further excavation or disturbance of the site or any nearby area reasonably
suspected to overlie adjacent remains until the [County of San Diego Coroner’s office] in which the
human remains are discovered has determined, in accordance with Chapter 10 (commencing with
section 27460) of Part 3 of Division 2 of Title 3 of the Government Code, that the remains are not
subject to the provisions of section 27492 of the Government Code or any other related provisions of
law concerning investigation of the circumstances, manner and cause of death, and the
recommendations concerning treatment and disposition of the human remains have been made to the
person responsible for the excavation, or to his or her authorized representative, in the manner provided
in section 5097.98 of the PRC [California Public Resources Code].
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California Public Resources Code
Section 5097–5097.6 – Archaeological, Paleontological, and Historical Sites
California Public Resources Code, Section 5097–5097.6, outlines the requirements for cultural resource analysis
before the start of any construction project on state lands. This section identifies that the unauthorized disturbance
or removal of archaeological, historical, or paleontological resources located on public lands is a misdemeanor. It
prohibits the knowing destruction of objects of antiquity without a permit (expressed permission) on public lands, and
provides for criminal sanctions. This section was amended in 1987 to require consultation with the NAHC whenever
Native American graves are found. Violations for the taking or possessing remains or artifacts are felonies.
Section 5097.9–5097.991 – Native American Heritage
California Public Resources Code, Section 5097.9–5097.991, identifies that no public agency, and no private party
using or occupying public property, or operating on public property, under a public license, permit, grant, lease, or
contract made on or after July 1, 1977, shall in any manner whatsoever interfere with the free expression or exercise
of Native American religion as provided in the U.S. Constitution and the California Constitution; nor shall any such
agency or party cause severe or irreparable damage to any Native American sanctified cemetery, place of worship,
religious or ceremonial site, or sacred shrine located on public property, except on a clear and convincing showing
that the public interest and necessity so require it. In addition, this section details the composition and
responsibilities of NAHC. NAHC strives for the preservation and protection of Native American human remains,
associated grave goods, and cultural resources. NAHC has developed a strategic plan to assist the public,
development community, local and federal agencies, education institutions, and California Native Americans to
better understand problems relating to the protection and preservation of cultural resources and to serve as a tool
to resolve these problems and create an awareness among lead agencies and developers of the importance of
working with Native American (NAHC 2008, as cited in Appendix D). California Public Resources Code, Sections
5097.91 and 5097.98, were amended by AB 2641 in 2006. AB 2641 authorizes the NAHC to bring an action to
prevent damage to Native American burial grounds or places of worship and establishes more specific procedures
to be implemented in the event that Native American remains are discovered.
Senate Bill 18 – Traditional Tribal Cultural Places
As of March 1, 2005, Senate Bill 18 (California Code, Sections 65352.3 and 65352.4) requires that, before the
adoption or amendment of a general plan proposed on or after March 1, 2005, a city or county must consult with
Native American tribes with respect to the possible preservation of, or the mitigation of impacts to, specified Native
American places, features, and objects located within that jurisdiction. The consultation intends to establish a
meaningful dialogue regarding potential means to preserve Native American places of importance. It allows for
tribes to hold conservation easements and for tribal cultural places to be included in open space planning.
California Register of Historical Resources
The California Office of Historic Preservation maintains the CRHR, which is the authoritative guide to the state’s
significant historic and archaeological resources. The program provides for the identification, evaluation,
registration, and protection of California’s historic resources. The CRHR encourages public recognition and
protection of resources of architectural, historic, archaeological, and cultural significance; identifies historic
resources for state and local planning purposes; determines eligibility for state historic preservation grant funding;
and affords certain protection to resources under CEQA.
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The CRHR also has established context types to be used when evaluating the eligibility of a property or resources
for listing. The four criteria are as follows:
The property or resource is associated with events that have made a significant contribution to the broad
patterns of local or regional history, or the cultural heritage of California or the United States.
The property or resource is associated with the lives of persons important to local, California, or national history.
The property or resource represents the work of a master, or possesses high artistic values.
The property or resource has yielded, or is likely to yield, information important to prehistory or history of
the local area, California, or the nation.
Similar to the NRHP, eligibility for the CRHR requires an establishment of physical integrity, including the aspects
previously described. The CRHR’s list of special considerations is less stringent than that of the NRHP, providing
allowances for relocated buildings, structures, or objectives as reduced requirements for physical integrity.
California Environmental Quality Act
CEQA (California Public Resources Code, Section 21000 et seq.) and the CEQA Guidelines (14 CCR 15000 et seq.)
are primary sources for environmental legislation in California; they require projects with potential adverse
environmental effects (or impacts) undergo environmental review. Adverse environmental impacts are typically
mitigated as a result of the environmental review process in accordance with existing laws and regulations.
Resource importance is assigned to districts, sites, buildings, structures, and objects that possess exceptional value
or quality illustrating or interpreting the heritage of the County in history, architecture, archaeology, engineering,
and culture. A number of criteria are used in demonstrating resource importance. Specifically, criterial outlined in
CEQA provide the guidance for making such a determination. The following CEQA and Public Resources Code
Sections detail the criteria that a resource must meet in order to be determined important.
According to CEQA (14 CCR 15064.5a), the term “historical resource” includes the following:
1) A resource listed in, or determined to be eligible by the State Historical Resources Commission, for
listing in the California Register of Historical Resources (CRHR) (California Public Resources Code,
Section 5024.1; 14 CCR 4850 et seq.).
2) A resource included in a local register of historical resources, as defined in Section 5020.1(k) of the
PRC [California Public Resources Code] or identified as significant in a historical resource survey
meeting the requirements of Section 5024.1(g) of the PRC, shall be presumed to be historically or
culturally significant. Public agencies must treat any such resource as significant unless the
preponderance of evidence demonstrates that is not historically or culturally significant.
3) Any object, building, structure, site, area, place, record, or manuscript, which a lead agency
determines to be historically significant or significant in the architectural, engineering, scientific,
economic, agricultural, educational, social, political, military, or cultural annals of California may be
considered to be a historical resource, provided the lead agency’s determination is supported by
substantial evidence in light of the whole record. Generally, a resource shall be considered by the
lead agency to be “historically significant” if the resource meets the criteria for listing on the CRHR
(California Public Resources Code, Section 5024.1; 14 CCR 4852), including the following:
a. Is associated with events that have made a significant contribution to the broad patterns of
California’s history and cultural heritage;
b. Is associated with the lives of persons important in our past;
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c. Embodies the distinctive characteristics of a type, period, region, or method of construction, or
represents the work of an important creative individual, or possesses high artistic values; or
d. Has yielded, or may be likely to yield, information important in prehistory or history.
4) The fact that a resource is not listed on, or determined eligible for listing on the CRHR, not included
in a local register of historical resources (pursuant to Section 5020.1(k) of the PRC), or identified
in an historical resources survey (meeting the criteria in Section 5024.1(g) of the PRC) does not
preclude a lead agency from determining that the resource may be an historical resource as
defined in PRC Section 5020.1(j) or 5024.1.
According to CEQA (14 CCR 15064.5b), a project with an effect that may cause a substantial adverse change in the
significance of an historical resource is a project that may have a significant effect on the environment. CEQA
defines a substantial adverse change as:
1) Substantial adverse change in the significant of a historical resource means physical demolition,
destruction, relocation, or alteration of the resource or its immediate surroundings such that the
significance of an historical resource would be materially impaired.
2) The significance of a historical resource is materially impaired when a project:
a. Demolishes or materially alters in an adverse manner those physical characteristics of an
historical resource that convey its historical significance and that justify its inclusion in, or
eligibility for, including in the CRHR; or
b. Demolishes or materially alters in an adverse manner those physical characteristics that account
for its inclusion in a local register of historical resources pursuant to Section 5020.1(k) of the PRC
or its identification in an historical resources survey meeting the requirements of Section 5024.1(g)
of the PRC, unless the public agency reviewing the effects of the project establishes by a
preponderance of evidence that the resources is not historically or culturally significant; or
c. Demolishes or materially alters in an adverse manner those physical characteristics of an
historical resource that convey its historical significance and that justify its eligibility for
inclusion on the CRHR as determined by a lead agency for purposes of CEQA.
Section 15064.5(c) of the CEQA Guidelines applies to effects on archaeological sites and contains the following
additional provisions regarding archaeological sites:
1) When a project will impact an archaeological site, a lead agency shall first determine whether the
site is an historical resource, as defined in subsection (a).
2) If a lead agency determines that the archaeological site is an historical resource, it shall refer to
the provisions of Section 21084.1 of PRC, Section 15126.4 of the guidelines, and the limits
contained in Section 21083.2 of the PRC do not apply.
3) If an archaeological site does not meet the criteria defined in subsection (a) but does meet the definition
of a unique archaeological resource in Section 21803.2 of the PRC, the site shall be treated in
accordance with the provisions of Section 21083.2. The time treated in accordance with the provisions
of Section 21083.2 (c–f) do not apply to surveys and site evaluation activities intended to determine
whether the project location contains unique archaeological resources.
4) If an archaeological resource is neither a unique archaeological nor historical resource, the effects
of the project on those resources shall not be considered a significant effect on the environment.
It shall be sufficient that both the resource and the effect on the environment. It shall be sufficient
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that both the resource and the effect on it are noted in the Initial Study or Environmental Impact
Report, if one is prepared to address impacts on other resources, but they need not be considered
further in the CEQA process.
Section 15064.5 (d) and (e) contain additional provisions regarding human remains.
Regarding Native American human remains, paragraph (d) provides the following:
When an Initial Study identifies the existence of, or the probable likelihood of, Native American
human remains within the project, a lead agency shall work with the appropriate Native Americans
as identified by the NAHC as provided in PRC Section 5097.98. The applicant may develop an
agreement for treating or disposing of with appropriate dignity the human remains and any items
associated with Native American burials with the appropriate Native Americans as identified by the
NAHC. Action implementing such an agreement is exempt from:
1) The general prohibition on disinterring, disturbing, or removing human remains from any
location other than a dedicated cemetery (Healthy and Safety Code Section 7050.5).
2) The requirements of CEQA and the Coastal Act.
Regarding tribal cultural resources, California Public Resources Code, Section 21074(a) and (b) provides the following:
A “tribal cultural resource” is defined as any of the following under its subsections (a)–(c):
a) (1) Sites, features, places, and objects with cultural value to descendant communities or
cultural landscapes that are any of the following:
A. Included in the California Register of Historical Resources.
B. Included in a local register of historical resources as defined in subdivision (k) of
Section 5020.1.
C. Deemed to be significant pursuant to criteria set forth in subdivision (c) of Section 5024.1.
b) A cultural landscape that meets the criteria of subdivision (a) is a tribal cultural resource
to the extent that the landscape is geographically defined in terms of the size and scope
of the landscape.
c) A historical resource described in Section 21084.1, a unique archaeological resource as
defined in subdivision (g) of Section 21083.2, or a “nonunique archaeological resource”
as defined in subdivision (h) of Section 21083.2 may also be a tribal cultural resource if it
conforms with the criteria of subdivision (a).
Additionally, an EIR, mitigated negative declaration, or negative declaration for a project with a significant impact
on an identified tribal cultural resource cannot be certified or adopted unless one of the following occurs:
1) The consultation process between the tribe and the lead agency has concluded;
2) The tribe requested consultation but failed to provide comments or otherwise failed to engage in
consultation; or
3) The lead agency provided notice of the project to a tribe and the tribe failed to request consultation within
the 30 day deadline.
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Local
City of Poway Municipal Code
Chapter 17.45 of the City’s Municipal Code discusses Historical Structure. Its purpose is to “protect, enhance and
perpetuate historic/cultural resources, sites, and districts that represent or reflect elements of the City’s cultural,
social, economic, political and architectural history for the public health, safety and welfare of the people of the
City,” amongst other purposes (City of Poway 2019). Definitions, process of designation, and criteria for historic
landmarks in the City are detailed in Sections 17.45.020, 17.45.040, and 17.45.050 the City’s Municipal Code,
respectively. Permits must be issued for the demolition of historic landmarks. Historic landmarks shall be kept in
good repair, in accordance to Section 17.45.120 (City of Poway 2019).
Section 17.45.030 describes the four historical categories that a site can fall under in the City. The City has
conducted a preliminary historic/cultural resources inventory covering 33 sites in the City. In order to change the
categorization of an identified resource, or to add a building, structure, place or object to the inventory, the following
criteria for evaluating historic/cultural resources have been established (City of Poway 2019):
A. Description of Categories. Four categories of resources are identified and classified A through D.
a. Category A: This category is reserved for those structures, buildings, sites, or objects of major
significance. The resource must meet one or more of the following criteria:
i. It is the site of, or reflects special elements or events of the City’s cultural, social,
economic, political, aesthetic, engineering or architectural history; or
ii. It is associated with persons or events important in regional, State or national history; or
iii. It is a rare or particularly fine example of a certain architectural style or construction
technique associated with a particular period of history; or
iv. It is the work of an architect, engineer, or designer who has substantially influenced
regional, State, or national trends or the development of the North County region; or
v. Owing its unique location or singular physical characteristics, it represents an
established feature of the neighborhood or City whose removal would adversely affect
the appearance or spatial and design relationships of the area.
b. Category B: Structures, buildings, sites, or objects in this category must have one of the
following characteristics:
i. It is associated with important persons, events, or eras in the City, regional, or State history;
ii. Its original design, architecture, aspect of function of the resource is significant but has
been altered, affecting its integrity;
iii. It is a good (but not rare or particularly outstanding) example of certain style or
construction technique, or of the work of a prominent architect, engineer, or designer.
c. Category C: Structures, buildings, sites or objects in this category are:
i. It is a good example of a period of architecture design or construction; however, the
design is more commonplace and there are many similar structures, buildings, sites or
objects in the City;
ii. It is an important resource; however, substantial alterations have severely compromised
its historic, cultural, or architectural significance.
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d. Category D: Structures, buildings, sites, or objects in this category are:
i. Built prior to 1940, and clearly not significant terms of architectural style, appearance,
design, construction, or association with important persons or events in City history.
B. Change in Category. Further research on any building, structure, site or object may yield information
on their roles in history. This information may warrant their inclusion in a different category.
Applications to change in categorization of an identified resources or to add a resource to the
survey shall be submitted to the City Development Services Department. The application should
contain information which provides justification for adding a historic/cultural resource to the survey
or changing its category designation (Ord. 518, 1999; Ord. 296 Section 1, 1989)
Poway Comprehensive Plan: General Plan
The Poway Comprehensive Plan: General Plan (General Plan) includes the following policies and strategies
regarding cultural and tribal resources (City of Poway 1991):
Goal I, Policy B – Subdivisions Design: Subdivisions should be designed to ensure that future land development
supports the goals of the General Plan.
Strategy 11: Significant existing natural resources shall be incorporated into the design of new projects rather
than removed. These shall include, but are not limited to, large mature trees, sensitive biological habitat and
vegetation, streams, steep hillsides, major rock outcroppings and archaeological and historical structures.
Strategy 17: Development should be concentrated in the least environmentally sensitive locations in order
to preserve open space, retain natural vegetation and protect natural, cultural and historic features.
Goal IV, Policy D – Archaeological Sites: Archaeological resources are an important part of our heritage and should
be preserved and protected.
Strategy 1: Archaeological guidelines for the treatment of archaeological resources discovered during the
environment review process shall be implemented.
Strategy 2: The City shall require that all artifacts recovered from sites within Poway during environmental impacts
studies be presented to the City for permanent curation. This also recommended for the sphere of influence. The
City shall designate the repository (i.e., a museum) for the artifacts or direct that a suitable structure be built or
converted within the city boundaries to house the collections. The City shall ensure the proper treatment of the
artifacts by selecting an archaeologist/historian to define the necessary elements for curation of specimens as
outlined by the National Park Service. If the City cannot designate a facility as outlined by the National Park Service.
If the City cannot designate a facility to curate the artifacts, then an agreement could be reached with the Poway
Historical Society or the San Diego Archaeological Society to temporarily curate the artifacts.
Strategy 3: Consider mitigation alternatives which include “in kind” measures that provide unusual or more
beneficial results than the mitigation measures listed in the City archaeological/historical guidelines.
Strategy 4: Maintain a listing of significant prehistoric sites and document the locations of all open space
easement that include archaeological sites. These easements have been granted to protect resources;
however, without acknowledging the locations of such easements, the success of the use of such
easements for resource protection cannot be assured. The City should conduct a research effort to
determine where easements for archaeological sites are located, especially those easements where
“inherited” from the County of San Diego when the city was incorporated.
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Goal IV, Policy E – Historical Sites: The historical structures which remain in Poway contribute significantly to the
rural small town character of the community and should be preserved.
Strategy 1: Complete a comprehensive survey to identify and evaluate historic structures and sites in Poway.
Strategy 2: Maintain a Historic Sites List that will include a register of locations, photographs, and
historically relevant information regarding each site, structure or feature recognized as historically sensitive
or significant to the city’s heritage. The Historic Sites List will include as its foundation, the criteria for
relative categories of significance included in the City’s Ordinance 296. The method to be used for adding
structures to the Historic Sites List is also provided in Ordinance 296. Prehistoric sites should not be
included on this list, as it will be available to the public and the locations of significant prehistoric sites
should not be made publicly known.
Strategy 3: Support community efforts to register local prehistoric and historic features that fulfill state
or federal requirements. The basis for the registration of local sites of historic and prehistoric
significance will be the Historic Sites List. The City shall consider funding a periodic review of the
Historic Sites List by a qualified historian for the purpose of completing nomination forms for the
National Register and state landmarks list.
Strategy 4: Maintain appropriate legislation to apply alternative building code requirements as deemed
necessary on an individual basis to preserve historic structure. The City shall also maintain appropriate
legislation prohibiting the demolition of an historic structure without an evaluation of the condition of the
structure and the costs of rehabilitation.
Strategy 5: Study the feasibility of securing contracts with the owners of historic structures or places to restrict
the use or alteration of the property or structure as defined in Government Code Section 50280 et seq. for tax
advantages in the form of an historic easement. In the event that a contract or historic easement is executed,
the City shall inform the County Assessor of any agreement reached for the purpose of historic preservation and
encourage the Assessor to re-examine the assessment of the property based upon the agreement.
Strategy 6: Prior to the demolition of any historic structure (for a definition of a historic structure, see
Ordinance 296 and the archaeological guidelines filed at the City of Poway Planning Services Department),
that structure shall be fully documented with plans, photographs, and an archaeological/architectural
assessment. In the event that demolition is permitted for any historic structure within Categories A, B or C
as described in Ordinance 296, mitigation may be accomplished through the payment of a fee which would
be applied to the improvement of Old Poway Park. The City shall determine an equitable mitigation fee for
the demolition of historic structures.
Strategy 7: Mitigation of impacts to significant or sensitive historic structures may be accomplished by
moving the structure to a new location within the city. This location should be similar in setting to the original
site, depending upon the uniqueness of the original site.
Strategy 8: Historic structures or places should not be designated for land uses that would lead to their
demolition or to a depreciation in their value. Adjacent land uses should not conflict with the preservation
of an historic structure or place.
Strategy 9: Standards should be developed for community design adjacent to historic structures to preserve
the integrity of the structure and its surroundings.
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4.4.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to cultural resources are based on Appendix G of the
CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to cultural and tribal
cultural resources would occur if the project would:
1. Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5.
2. Cause a substantial adverse change in the significance of an archaeological resource pursuant to
Section 15064.5d.
3. Disturb any human remains, including those interred outside of dedicated cemeteries.
4. Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public
Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically
defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a
California Native American tribe, and that is listed or eligible for listing in the California Register of Historical
Resources, or in a local register of historical resources defined in Public Resources Code section 5020.1(k).
5. Cause a substantial adverse change in the significance of a tribal cultural resources, defined in Public
Resources Code section 21704 as either a site, feature, place cultural landscape that is geographically
defined in terms of the size and scope of the landscape, sacred place, or objective with cultural value
to a California Native America tribe, and that is a resource determined by the lead agency, in its
discretion and supported by substantial evidence, to be significant pursuant to criteria set for in
subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision
(c) of Public Resources Code Section 5024.1, the lead agency shall consider the significance of the
resource to a California Native American Tribe.
4.4.4 Impacts Analysis
Would the project cause a substantial adverse change in the significance of a historical resource pursuant
to Section 15064.5?
The record search performed at the SCIC at San Diego State University and by the NAHC of their Sacred Land Files
yielded no historical resources within or immediately adjacent to the project site. Additionally, the field survey found
no historical resources on site. As such, with no known or identified historical resources on the project site, no
impacts would occur.
Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant
to Section 15064.5?
A survey of the project site found two bedrock milling features, Resource 8858-RDS-001 and Resource 8858-RDS-
002, also referred to as Temp-1 and Temp-2 in Appendix D. As currently designed, these two bedrock milling
features would be demolished or relocated during grading and/or site preparation. Information from the
archeological testing program conducted by Brian F. Smith and Associates Inc. determined that neither bedrock
milling feature represented a significant resource, as defined by CEQA (refer to Appendix D for further details).
Additionally, both sites retain no additional research potential and the milling features represent the most common
type of prehistoric resource in the City and County. Therefore, while implementation of the proposed project would
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result in the removal of these bedrock milling features, this would not represent a significant impact to cultural
resources under CEQA and site-specific mitigation would not be required.
However, because the project site was graded before CEQA regulations were adopted in 1975, the potential exists
that other cultural resources were present on the property prior to grading. Because cultural resources could be
masked or buried beneath the graded golf course, monitoring of grading is recommended to locate and record any
resources that may be exposed by grading. Therefore, impacts to significant archeological resources are potentially
significant (Impact CUL-1) and mitigation measures are required (MM-CUL-1).
Would the project disturb any human remains, including those interred outside of dedicated cemeteries?
No evidence of human remains were discovered during the records search nor the field survey. The project site was not
tested or evaluated for human remains; however, it is unlikely that the project site was used as a burial ground or
cemetery. There is no indication that the project site was used by Native Americans for religious, ritual, or other special
activities. However, in the unlikely event that human remains are discovered on site during construction of the proposed
project, impacts would be potentially significant (Impact CUL-2) and would require mitigation measures (MM-CUL-12).
Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in
Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically
defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California
Native American tribe, and that is listed or eligible for listing in the California Register of Historical Resources, or
in a local register of historical resources defined in Public Resources Code section 5020.1(k)?
A records search of the proposed project area with a one-mile radius was conducted at the SCIC in September
2017. The search included a review of the NRHP for the County, National Historic Landmarks, California Register
or Historical Resources, California Registered Historical Landmarks, California Points of Historical Interest, historic
resources inventory files, archaeological inventory files, a bibliography of previous cultural resources investigations,
and various maps. The records search yielded no tribal cultural resources within or immediately adjacent to the
project site. Impacts would be less than significant.
Would the project cause a substantial adverse change in the significance of a tribal cultural resources, defined in
Public Resources Code section 21704 as either a site, feature, place cultural landscape that is geographically
defined in terms of the size and scope of the landscape, sacred place, or objective with cultural value to a California
Native America tribe, and that is a resource determined by the lead agency, in its discretion and supported by
substantial evidence, to be significant pursuant to criteria set for in subdivision (c) of Public Resources Code
Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the
lead agency shall consider the significance of the resource to a California Native American Tribe?
As discussed in Section 4.1.1, Existing Conditions, a NAHC record search of the Sacred Lands Files produced
negative results and contact letters were sent to all groups and individuals on the NAHC contact list. Responses
were received from the Iipay Nation of Santa Ysabel, Campo Band of Mission Indians, Viejas Band of Kumeyaay
Indians, and Jamul Indian Village of California. As described above, because the project site was graded before
CEQA regulations were adopted in 1975, the potential exists that other cultural resources, such as tribal cultural
resources, were present on the property prior to grading. Therefore, if unknown tribal resources were unearthed
during grading activities a potential significant impact may result (Impact CUL-3) and would require mitigation (MM-
CUL-1). As requested in correspondence, Native American monitors/representatives from the Kumeyaay nation
shall be invited to participate in the monitoring program provided in MM-CUL-1.
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The proposed project’s impacts to cultural and tribal resources are listed as follows:
Impact CUL-1 The proposed project has the potential to unearth subsurface prehistoric archaeological materials
during ground-disturbing activities, resulting in a potentially significant impact.
Impact CUL-2 In the event of accidental discovery of any human remains during construction of the proposed
project, impacts associated with the disturbance of human remains would be potentially significant.
Impact CUL-3 If unknown tribal resources were unearthed during grading activities, then implementation of the
proposed project has the potential to cause a substantial adverse change in the significance of a
tribal cultural resource, as defined in Section 21074 of the California Public Resources Code.
4.4.5 Cumulative Impacts
A cumulative impact, in terms of cultural resources, refers to the mounting aggregate effect upon the cultural,
archaeological, historical, or tribal resources due to modern or recent historic land use (e.g., residential
development) and natural processes (e.g., erosion) that result from acts of humans. The issue that must be explored
in a cumulative impact analysis is the aggregate loss of information as well as the loss of recognized cultural
landmarks and vestiges of our community cultural history. Table 3-2, Cumulative Projects, lists projects within the
proposed project area that would have the potential for a cumulative impact.
Historic Resources
Cumulative projects located in the region would have the potential to result in a cumulative impact associated with the
loss of historical resources through physical demolition, destruction, relocation, or alteration of a resource or its
immediate surroundings such that the significance of a historical resource would be materially impaired. Cumulative
projects, such as the Aria Estates in the City of Poway, the Chalice Unitarian Universalist Congregation project in the City
of Escondido, and the Del Prado Planned Development in the City of Escondido, within the City and in nearby areas
determined no impacts or less-than-significant impacts with mitigation to historical resources within their respective
project sites. The records search determined that there are no designated historical resources found within the project
site (City of Escondido 2016, 2017; City of Poway 2018). As such, with no known or identified historical resources on the
project site, no impacts would occur. Therefore, no cumulative impacts would occur.
Archaeological Resources
Cumulative projects located in the region would have the potential to result in a cumulative impact associated with the
loss of archaeological resources through development activities that could cause a substantial adverse change in the
significance of an archaeological resource. Any cumulative projects that involve ground-disturbing activities, including
the development of land uses as designated under the General Plan, infrastructure projects, and/or private
developments would have the potential to result in significant impacts to archaeological resources. These projects would
be regulated by applicable federal, state, and local regulations. The loss of archaeological resources on a regional level
may be adequately mitigated through the data recovery and collection methods specified in the regulations.
The records search determined that no archaeological resources were on the project site; however, the field survey
found two bedrock milling features. These milling features were subsequently tested for significance under CEQA
criteria and it was determined that neither represented a significant resources, as defined by CEQA. Cumulative
projects within the City and in nearby areas have been determined to have no impacts or less than significant
impacts with mitigation. For example, the Aria Estates project in the City found no historic of prehistoric resources
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within their project site, however the potential to encounter buried or masked archaeological resources during
grading was possible due to the moderate frequency of prehistoric archaeological sites surrounding the project
area (City of Poway 2018). The potential impacts for the Aria project in the City would be less than significant with
mitigation (City of Poway 2018). Similarly, the Chalice Universalist Congregation project in the City of Escondido
found no archaeological resources during their survey but recognized the potential to encounter buried or masked
resources, and therefore would lessen the potential impact to less than significant with mitigation (City of Escondido
2017). The proposed project would also have the potential to encounter buried or masked resources. However, an
archaeological resources monitoring program would be implemented (MM-CUL-1) which would ensure that project-
specific impacts would be less than significant. Since other cumulative projects within the City would be required
to implement similar mitigation, as necessary, to avoid or reduce potential impacts to previously unknown
archaeological resources, cumulative impacts would be less than significant.
Human Remains
Cumulative projects located in the region may have the potential to result in impacts associated with human remains
due to grading, excavation, or other ground-disturbing activities. Projects that may result in significant impacts due to
ground-disturbing activities include the development of land uses as designated under the General Plan, infrastructure
projects, and/or private development. As discussed in Section 4.4.4, Impacts Analysis, the proposed project may have
the potential to accidentally uncover human remains during ground-disturbing activities. In the event that any project,
including the proposed project, encounters unknown human remains during construction or during archaeological work,
compliance with California Health and Safety Code, Section 7050.5 would be required. Compliance with mandatory
regulations during site preparation for all cumulative projects would prevent a cumulative impact from occurring to
unknown human remains. As such, cumulative impacts would be less than significant.
Tribal Resources
For the proposed project, reasonably foreseeable projects within the cumulative impact study area are capable
of collectively contributing, along with the proposed project’s area of potential effect, to impacts on prehistoric
resources associated with ancestral Native American lifestyles. In the cumulative study area, prehistoric and
historic settlement patterns can be very broad; therefore it is prudent to consider a large study area when
evaluating cumulative impacts.
Prehistoric site types that have been identified in the cumulative project area include small artifact scatters,
bedrock milling features, temporary camps, rock shelters, and habitation sites. Prehistoric sites that have been
determined to be significant are all habitation sites and/or sites with human remains. Historic period sites are
predominantly refuse deposits consisting of food and beverage containers; building and/or structure foundations;
buildings; mining-related features (e.g., pits, adits); and ranching-related features (e.g., fences) and transportation
corridors (e.g., roads, railroads).
The proposed project’s impacts to tribal cultural resources would be reduced to less than significant through mitigation
measures that include Native American monitoring of grading activities, evaluation of any new discoveries, avoidance or
data recovery at new discoveries, the placement of significant sites within an avoidance area, and the curation of all
artifacts obtained during any testing and data recovery programs. Significant sites that are not placed within open space
easements preserve the information through recordation, test excavations, and data recovery programs that would be
presented in reports and filed with the appropriate agency and regional Information Center. The artifact collections from
any potentially significant site would also be curated at an appropriate curation facility. Cultural resources located within
the cumulative impact study area would be mitigated through similar measures.
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Because the proposed project and those projects identified within the cumulative impact study area are primarily
mitigated by the collection and curation of information and the preservation of the most important resources,
adequate mitigation has occurred for in situ appreciation of and access to information regarding those sites for
future generations. This reduces the potential for cumulative effects, and the proposed project would not contribute
to a cumulatively significant impact to cultural resources. Impacts would be less than significant.
4.4.6 Mitigation Measures
The following mitigation measures would be implemented to reduce potentially significant impacts to less than significant.
MM-CUL-1 An archaeological resources monitoring program to mitigate potential impacts to undiscovered, buried,
or previously undetected elements of any archaeological resources within the project site shall be
implemented to the satisfaction of the Lead Agency. The program shall and include the following:
1) Prior to issuance of a grading permit, the applicant shall provide written verification that a
qualified archaeologist has been retained to implement the monitoring program. This
verification shall be presented in a letter from the project archaeologist to the Lead Agency.
The qualified archaeologist (project archaeologist) shall engage a Native American
Kumeyaay representative to participate in the monitoring program. The Native American
Kumeyaay monitor will be responsible to advise the project archaeologist regarding
culturally sensitive artifacts or landforms within the project.
2) The certified project archaeologist and Kumeyaay representative shall attend the pre-
grading meeting with the contractors to explain and coordinate the requirements of the
monitoring program.
3) Archaeological and Native American monitoring shall be required during grading, unless
the project archaeologist determines that the potential for cultural resources has been
exhausted. The Native American monitor shall coordinate on-site monitoring with the
project archaeologist. Full- or- part-time inspections may be considered depending upon
the rate of excavation, the materials excavated, and the presence and abundance of
artifacts and features. The project archaeologist, in consultation with the Kumeyaay
representative, shall provide the City of Poway with any recommendations for reduced
monitoring protocol. The consulting archaeologist shall direct the field monitor during
grading of all areas identified for development.
Native American monitoring will be required during grading, unless the certified
archaeologist determines that the potential for cultural resources has been exhausted. The
Native American monitors will be directed by the project archaeologist. Native American
monitors/representatives from the Kumeyaay nation and The Jamul Indian Village of
California shall be invited to participate in the monitoring program.
During the original cutting of previously undisturbed deposits, the archaeological monitor
and Native American representative shall be on site, as determined by the consulting
archaeologist, to perform inspections of the excavations. Full- or part-time inspections may
be needed depending upon the rate of excavation, the materials excavated, and the
presence and abundance of artifacts and features.
Isolates and clearly non-significant deposits will be minimally documented in the field so
the monitored grading can proceed.
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4) In the event that previously unidentified cultural resources are discovered during the
monitoring program, the project archaeologist and Kumeyaay representative shall have the
authority to divert or temporarily halt ground-disturbance operation in the area of discovery
to allow for the evaluation of potentially significant cultural resources. The project
archaeologist shall contact the Lead Agency at the time of discovery. All discovered cultural
resources shall be recorded and tested using standard archaeological protocols. Any
resources determined to not be CEQA-significant shall be released to the grading program.
For any resources that are determined to be CEQA-significant and eligible for the California
Register of Historical Resources, the project archaeologist, in consultation with the lead
agency and the Kumeyaay representative, shall determine the appropriate measures to be
implemented in order to mitigate adverse impacts to the significant site. The applicant, at
their sole discretion, shall consider the possibility of preserving the significant site, if
feasible. If preservation is not feasible, a Research Design and Data Recovery Program to
mitigate impacts shall be prepared by the project archaeologist, in consultation with the
Kumeyaay representative, and approved by the lead agency. Data recovery mitigation shall
be completed at the location of a significant discovery before grading can resume at that
location. The archaeologist, in consultation with the Lead Agency, shall determine the
significance of the discovered resources. The Lead Agency must concur with the evaluation
before construction activities will be allowed to resume in the affected area. For significant
cultural resources that are discovered and that will be destroyed by grading, a Research
Design and Data Recovery Program to mitigate impacts shall be prepared by the consulting
archaeologist and approved by the Lead Agency before being carried out using professional
archaeological methods. If any human remains are discovered, all grading at that location
must stop and the County of San Diego Coroner’s office and Lead Agency shall be
contacted. In the event that the remains are determined to be of Native American origin,
the Most Likely Descendant, as identified by the Native American Heritage Commission,
shall be contacted in order to determine proper treatment and disposition of the remains.
Before construction activities are allowed to resume in the location of any discovered
significant cultural deposits, the artifacts shall be recovered and features recorded using
professional archaeological methods. The archaeological monitor(s) shall determine the
amount of material to be recovered for an adequate artifact sample for analysis.
5) Human Remains: If human remains are encountered during grading, California Health and
Safety Code Section 7050.5 states that no further disturbance shall occur until the San
Diego County Medical Examiner’s Office has made the necessary findings as to origin. The
City of Poway, the Native American Kumeyaay representative, and the applicant shall be
immediately notified of the discovery of any possible human remains. Further, pursuant to
California Public Resources Code Section 5097.98(b), remains shall be left in place and
free from disturbance until a final decision as to their treatment and disposition has been
made. If the medical examiner determines that the remains are of Native American origin,
the NAHC must be contacted within 24 hours. The NAHC must then immediately identify
the Most Likely Descendant(s) (MLD) for purposes of receiving notification of discovery.
The MLD shall then make recommendations within 48 hours and engage in consultation
concerning the treatment of the remains as provided in Public Resources Code Section
5097.98. The Kumeyaay monitor for grading will not necessarily be named as the MLD,
and therefore, cannot provide direction until the MLD is determined.
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6) All cultural material collected during the grading monitoring program shall be cataloged,
analyzed, and subsequently processed and curated according to the current professional
laboratory and repository standards. The collections and associated records shall be
transferred, including title, to an appropriate curation facility, to be accompanied by
payment of the fees necessary for permanent curation.
7) A report documenting the monitoring program, any field investigations, and results of any
data recovery programs or site evaluations field and analysis results and interpreting the
artifact and research data within the research context shall be completed and submitted
to the satisfaction of the Lead Agency prior to the issuance of any building permits. The
report will include DPR Primary and Archaeological Site Forms.
MM-CUL-2 As specified by California Health and Safety Code, Section 7050.5, if human remains are found on
the project site during construction or during archaeological work, the person responsible for the
excavation, or his or her authorized representative, shall immediately notify the County of San Diego
Coroner’s office and the City of Poway Development Services Division. Determination of whether
the remains are human shall be conducted on site and in situ (where they are discovered) by a
forensic anthropologist, unless the forensic anthropologist and the Native American monitor agree
to remove the remains to an off-site location for examinations. No further excavation or disturbance
of the site or any nearby area reasonably suspected to overlie adjacent remains shall occur until
the County of San Diego Coroner’s office has made the necessary findings as to origin and
disposition. A temporary construction exclusion zone may be established surrounding the area of
the discovery so that the area would be protected, and consultation and treatment shall occur as
prescribed by law or as otherwise recommended by a qualified professional in concurrence with
Tribal representatives or other represented entities. In the event that the remains are determined
to be of Native American origin, the most likely descendant, as identified by the Native American
Heritage Commission, shall be contacted in order to determine proper treatment and disposition
of the remains in accordance with California Public Resources Code, Section 5097.98. The Native
American remains shall be kept in situ, or in a secure location in close proximity to where they were
found, and the analysis of the remains shall only occur on site and in the presence of a Native
American monitor.
4.4.7 Level of Significance After Mitigation
Implementation of MM-CUL-1 would reduce Impact CUL-1 and Impact CUL-3 to a level below significance by setting
forth procedures for handling an accidental discovery of prehistoric archaeological resources or tribal cultural
resources during site preparation, should they be encountered, including not but limited to, requiring the presence
of archeological and Native American monitors during certain project construction activities.
Implementation of MM-CUL-12 would also reduce Impact CUL-2 to a level less than significant by setting forth
procedures for handling human remains as consistent with California Health and Safety Code Section 7050.5.
After mitigation, the proposed project would not represent a significant adverse impact to cultural resources or
tribal cultural resources.
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4.5 – Energy
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4.5 Energy
This section describes the existing energy conditions of The Farm in Poway project (proposed project) site and
vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation
measures related to implementation of the proposed project. The analysis is based on the review of existing
conditions; technical data; applicable laws, regulations, and guidelines; and the air quality and greenhouse gas
technical report prepared by Dudek in January 2020. The Air Quality Report for The Farm in Poway Project is
included in this Environmental Impact Report (EIR) as Appendix B.
A Notice of Preparation (NOP) was circulated from May 10, 2019, to June 10, 2019. During the NOP comment
period, comment letters related to Energy focused on the following topics:
Increased energy usage
Increased cost of energy
These comments were considered during the preparation of this EIR. The Initial Study, NOP, and Public Scoping
comments are provided in Appendix A of this EIR.
4.5.1 Existing Conditions
Environmental Setting
The environmental setting for the proposed project related to electricity, natural gas, and petroleum—including
associated service providers, supply sources, and estimated consumption—is discussed below. In summary, in
2018 (the latest calendar year for which data is uniformly available for all three types of energy sources),
California’s estimated annual energy use included the following:
Approximately 284,436 gigawatt hours of electricity (CEC 2019a)
Approximately 13 billion therms of natural gas (CEC 2019b)
Approximately 16 billion gallons of gasoline (CARB 2019)
Electricity
Electricity usage in California for different land uses varies substantially by the types of uses in a building, types of
construction materials used in a building, and the efficiency of all electricity-consuming devices within a building.
Due to the state’s energy efficiency building standards and efficiency and conservation programs, California’s
electricity use per capita has remained stable for more than 30 years, and the national average has steadily
increased (CEC 2016).
San Diego Gas & Electric (SDG&E) provides electric services to 3.6 million customers through 1.4 million electric
meters located in a 4,100-square-mile service area that includes San Diego County and southern Orange County
(SDG&E 2020). SDG&E is a subsidiary of Sempra Energy and would provide electricity to the proposed project.
According to the California Public Utilities Commission (CPUC), SDG&E customers consumed approximately
19,169 million kilowatt-hours (kWh) of electricity in 2015 (CPUC 2016).
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SDG&E receives electric power from a variety of sources. In 2017, 44 percent of SDG&E’s power came from
eligible renewable energy sources, including biomass/waste, geothermal, small hydroelectric, solar, and wind
sources. This is an improvement of 9 percent over the 2015 mix (CPUC 2016, 2020).
Based on recent energy supply and demand projections in California, statewide annual peak electricity demand is
projected to grow an average of 890 megawatts per year for the next decade, or 1.4 percent annually, and
consumption per capita is expected to remain relatively constant at 7,200 to 7,800 kWh per person (CEC 2016).
In San Diego County, the California Energy Commission (CEC) reported an annual electrical consumption of
approximately 6 billion kWh in 2018 for residential use (CEC 2019a).
Natural Gas
The CPUC regulates natural gas utility service for approximately 10.8 million customers who receive natural gas
from Pacific Gas & Electric, Southern California Gas (SoCalGas), SDG&E, Southwest Gas, and several smaller
natural gas utilities. The CPUC also regulates independent storage operators Lodi Gas Storage, Wild Goose
Storage, Central Valley Storage, and Gill Ranch Storage (CPUC 2020). SDG&E provides natural gas service to San
Diego and Orange Counties. SDG&E is a wholesale customer of SoCalGas and currently receives all of its natural
gas from the SoCalGas system (CPUC 2020).
The CPUC regulates California natural gas rates and natural gas services, including in-state transportation over
transmission and distribution pipeline systems, storage, procurement, metering, and billing. Most of the natural
gas used in California comes from out-of-state natural gas basins. California gas utilities may soon also begin
receiving biogas into their pipeline systems (CPUC 2020).
In 2012, California customers received 35 percent of their natural gas supply from basins located in the Southwest,
16 percent from Canada, 40 percent from the Rocky Mountains, and 9 percent from basins located within California
(CPUC 2020). Natural gas from out-of-state production basins is delivered into California through the interstate
natural gas pipeline system. The major interstate pipelines that deliver out-of-state natural gas to California are the
Gas Transmission Northwest Pipeline, Kern River Pipeline, Transwestern Pipeline, El Paso Pipeline, Ruby Pipeline,
Southern Trails, and Mojave Pipeline. The North Baja–Baja Norte Pipeline takes gas off the El Paso Pipeline at the
California/Arizona border and delivers it through California into Mexico. The Federal Energy Regulatory Commission
regulates the transportation of natural gas on interstate pipelines, and CPUC often participates in Federal Energy
Regulatory Commission proceedings to represent the interests of California natural gas consumers (CPUC 2020).
Most of the natural gas transported through interstate pipelines, and some California-produced natural gas, is
delivered through the Pacific Gas & Electric and SoCalGas intrastate natural gas transmission pipeline systems
(commonly referred to as California’s “backbone” natural gas pipeline system). Natural gas on the backbone
pipeline system is then delivered into local transmission and distribution pipeline systems or to natural gas
storage fields. Some large noncore customers take natural gas directly off the high-pressure backbone pipeline
system, and some core customers and other noncore customers take natural gas off the utilities’ distribution
pipeline systems. CPUC has regulatory jurisdiction over 150,000 miles of utility‐owned natural gas pipelines,
which transported 82 percent of the natural gas delivered to California’s gas consumers in 2012 (CPUC 2020).
Pacific Gas & Electric and SoCalGas own and operate several natural gas storage fields that are located in
Northern and Southern California. These storage fields and four independently owned storage utilities—Lodi Gas
Storage, Wild Goose Storage, Central Valley Storage, and Gill Ranch Storage—help meet peak-season natural gas
demand and allow California natural gas customers to secure natural gas supplies more efficiently (CPUC 2020).
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California’s regulated utilities do not own any natural gas production facilities. All natural gas sold by these
utilities must be purchased from suppliers or marketers. The price of natural gas sold by suppliers and marketers
was deregulated by the Federal Energy Regulatory Commission in the mid-1980s and is determined by market
forces. However, CPUC decides whether California’s utilities have taken reasonable steps to minimize the cost of
natural gas purchased on behalf of its core customers (CPUC 2020).
As indicated in the preceding discussion, natural gas is available from a variety of in-state and out-of-state
sources, and is provided throughout the state in response to market supply and demand. Complementing
available natural gas resources, biogas may soon be available through existing delivery systems, thereby
increasing the availability and reliability of resources.
Petroleum
There are more than 35 million registered vehicles in California, and those vehicles consume an estimated 18
billion gallons of fuel each year (CEC 2017). Gasoline and other vehicle fuels are commercially provided
commodities and would be available to the proposed project through commercial outlets.
Petroleum currently accounts for approximately 92 percent of California’s transportation energy consumption
(CEC 2017). However, technological advances, market trends, consumer behavior, and government policies could
result in significant changes in fuel consumption by type and in total. At the federal and state levels, various
policies, rules, and regulations have been enacted to improve vehicle fuel efficiency, promote the development
and use of alternative fuels, reduce transportation‐source air pollutants and greenhouse gas (GHG) emissions,
and reduce vehicle miles traveled (VMT). Market forces have driven the price of petroleum products steadily
upward over time, and technological advances have made use of other energy resources or alternative
transportation modes increasingly feasible.
Largely as a result of and in response to these multiple factors, gasoline consumption within the state has declined
in recent years, and availability of other alternative fuels and energy sources has increased. The quantity, availability,
and reliability of transportation energy resources have increased in recent years, and this trend may likely continue
and accelerate (CEC 2017). Increasingly available and diversified transportation energy resources act to promote
continuing reliable and affordable means to support vehicular transportation within the state.
Existing Infrastructure
The proposed project is located on the site of a currently vacant and abandoned golf course, and falls within the
SDG&E service area.
4.5.2 Relevant Plans, Policies, and Ordinances
Federal, state, and local agencies regulate energy use and consumption through various means and programs.
On the federal level, the U.S. Department of Transportation, the U.S. Department of Energy, and the U.S.
Environmental Protection Agency are three federal agencies with substantial influence over energy policies and
programs. On the state level, the CPUC and CEC are two agencies with authority over different aspects of energy.
Relevant federal, state, and local energy-related regulations are summarized below.
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Federal
Federal Energy Policy and Conservation Act
In 1975, Congress enacted the Federal Energy Policy and Conservation Act, which established the first fuel
economy standards for on-road motor vehicles in the United States. Pursuant to the act, the National Highway
Traffic Safety Administration is responsible for establishing additional vehicle standards. In 2012, new fuel
economy standards for passenger cars and light trucks were approved for model years 2017 through 2021 (77
FR 62624–63200). Fuel economy is determined based on each manufacturer’s average fuel economy for the
fleet of vehicles available for sale in the United States.
Energy Independence and Security Act of 2007
On December 19, 2007, the Energy Independence and Security Act of 2007 (EISA) was signed into law. In
addition to setting increased Corporate Average Fuel Economy standards for motor vehicles, the EISA includes the
following other provisions related to energy efficiency:
Renewable Fuel Standard (RFS) (Section 202)
Appliance and Lighting Efficiency Standards (Sections 301–325)
Building Energy Efficiency (Sections 411–441)
This federal legislation requires ever-increasing levels of renewable fuels (the RFS) to replace petroleum (EPA
2013). The U.S. Environmental Protection Agency is responsible for developing and implementing regulations to
ensure that transportation fuel sold in the United States contains a minimum volume of renewable fuel. The
RFS program regulations were developed in collaboration with refiners, renewable fuel producers, and many
other stakeholders.
The RFS program was created under the Energy Policy Act of 2005 and established the first renewable fuel
volume mandate in the United States. As required under the act, the original RFS program (RFS1) required 7.5
billion gallons of renewable fuel to be blended into gasoline by 2012. Under the EISA, the RFS program was
expanded in several key ways that lay the foundation for achieving significant reductions in GHG emissions
from the use of renewable fuels, reducing imported petroleum, and encouraging the development and
expansion of the renewable fuels sector in the United States. The updated program is referred to as “RFS2”
and includes the following:
EISA expanded the RFS program to include diesel, in addition to gasoline.
EISA increased the volume of renewable fuel required to be blended into transportation fuel from 9 billion
gallons in 2008 to 36 billion gallons by 2022.
EISA established new categories of renewable fuel and set separate volume requirements for each one.
EISA required the U.S. Environmental Protection Agency to apply lifecycle GHG performance
threshold standards to ensure that each category of renewable fuel emits fewer GHGs than the
petroleum fuel it replaces.
Additional provisions of the EISA address energy savings in government and public institutions, research for
alternative energy, additional research in carbon capture, international energy programs, and the creation of
“green” jobs.
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State
The discussion below focuses primarily on those policies, regulations, and laws that directly pertain to energy-
related resources. Refer to Section 4.7, Greenhouse Gas Emissions, of this EIR for a discussion of various
policies, regulations, and laws targeted to the reduction of GHG emissions that are expected to achieve co-
benefits in the form of reduced demand for energy-related resources and enhanced efficiencies in the
consumption of energy-related resources.
Warren-Alquist Act
The California Legislature passed the Warren-Alquist Act in 1974. The Warren-Alquist Act created the CEC, and
also incorporated the following three key provisions designed to address the demand side of the energy equation:
It directed the CEC to formulate and adopt the nation’s first energy conservation standards for both
buildings constructed and appliances sold in California.
The act removed the responsibility of electricity demand forecasting from the utilities, which had a
financial interest in high-demand projections, and transferred it to a more impartial CEC.
The CEC was directed to embark on an ambitious research and development program, with a particular focus
on fostering what were characterized as non-conventional energy sources.
State of California Energy Action Plan
The CEC and CPUC approved the first State of California Energy Action Plan in 2003. The plan established shared
goals and specific actions to ensure that adequate, reliable, and reasonably priced electrical power and natural
gas supplies are provided to consumers. The plan also identified policies, strategies, and actions that are cost-
effective and environmentally sound for California’s consumers and taxpayers. In 2005, a second Energy Action
Plan was adopted by the CEC and CPUC to reflect various policy changes and actions of the prior two years.
At the beginning of 2008, the CEC and CPUC determined that it was not necessary or productive to prepare a new
energy action plan. This determination was based, in part, on a finding that the state’s energy policies have been
significantly influenced by the passage of Assembly Bill (AB) 32, the California Global Warming Solutions Act of
2006 (discussed below). Rather than produce a new energy action plan, the CEC and CPUC prepared an update
that examines the state’s ongoing actions in the context of global climate change.
Senate Bill 1078 (2002)
Senate Bill (SB) 1078 established the California Renewables Portfolio Standard (RPS) Program, and required that
a retail seller of electricity purchase a specified minimum percentage of electricity generated by eligible
renewable energy resources as defined in any given year, culminating in a 20 percent standard by December 31,
2017. These retail sellers include electrical corporations, community choice aggregators, and electric service
providers. The bill relatedly required the CEC to certify eligible renewable energy resources, design and implement
an accounting system to verify compliance with the RPS by retail sellers, and allocate and award supplemental
energy payments to cover above-market costs of renewable energy.
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Senate Bills 107 (2006), X1-2 (2011), 350 (2015), and 100 (2018)
SB 107 (2006) accelerated the RPS established by SB 1078 by requiring that 20 percent of electricity retail sales
be served by renewable energy resources by 2010 (not 2017). Additionally, SB X1-2 (2011) requires all California
utilities to generate 33 percent of their electricity from eligible renewable energy resources by 2020. Specifically,
SB X1-2 sets a three-stage compliance period: by December 31, 2013, 20 percent had to come from renewables;
by December 31, 2016, 25 percent had to come from renewables; and by December 31, 2020, 33 percent will
come from renewables.
SB 350 (2015) requires retail seller and publicly owned utilities to procure 50 percent of their electricity from
eligible renewable energy resources by 2030, with interim goals of 40 percent by 2024 and 45 percent by 2027.
SB 100 (2018) increased the standards set forth in SB 350 by establishing targets for the total electricity sold to
retail customers in California per year be secured from qualifying renewable energy sources on the following
schedule: 44 percent by December 31, 2024; 52 percent by December 31, 2027; and 60 percent by December
31, 2030. SB 100 states that it is the policy of the state that eligible renewable energy resources and zero-carbon
resources supply 100 percent of the retail sales of electricity to California. This bill requires that the achievement
of 100 percent zero-carbon electricity resources do not increase the carbon emissions elsewhere in the western
grid and that the achievement not be achieved through resource shuffling.
Consequently, utility energy generation from non-renewable resources is expected to be reduced based on
implementation of the 60 percent RPS in 2030. Therefore, any project’s reliance on non-renewable energy
sources would also be reduced.
Assembly Bill 1007 (2005)
AB 1007 (2005) required the CEC to prepare a statewide plan to increase the use of alternative fuels in California
(State Alternative Fuels Plan). The CEC prepared the plan in partnership with the California Air Resources Board
(CARB) and in consultation with other state agencies, plus federal and local agencies. The State Alternative Fuels
Plan assessed various alternative fuels and developed fuel portfolios to meet California’s goals to reduce
petroleum consumption, increase alternative fuels use, reduce GHG emissions, and increase in-state production
of biofuels without causing a significant degradation of public health and environmental quality.
Assembly Bill 32 (2006) and Senate Bill 32 (2016)
In 2006, the State Legislature enacted AB 32, the California Global Warming Solutions Act of 2006. AB 32
requires California to reduce its GHG emissions to 1990 levels by 2020. In 2016, the Legislature enacted SB 32,
which extended the horizon year of the state’s codified GHG-reduction planning targets from 2020 to 2030,
requiring California to reduce its GHG emissions to 40 percent below 1990 levels by 2030. In accordance with AB
32 and SB 32, CARB prepares scoping plans to guide the development of statewide policies and regulations for
the reduction of GHG emissions. Many of the policy and regulatory concepts identified in the scoping plans
focused on increasing energy efficiencies, using renewable resources, and reducing the consumption of
petroleum-based fuels (e.g., gasoline and diesel). As such, the state’s GHG emissions-reduction planning
framework creates co-benefits for energy-related resources. Additional information on AB 32 and SB 32 is
provided in Section 4.7.2 of this EIR.
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California Building Standards
Part 6 of Title 24 of the California Code of Regulations was established in 1978 and serves to enhance and
regulate California’s building standards. Part 6 establishes energy efficiency standards for residential and non-
residential buildings constructed in California to reduce energy demand and consumption. Part 6 is updated
periodically to incorporate and consider new energy efficiency technologies and methodologies.
Title 24 also includes Part 11, the California Green Building Standards (CALGreen). The CALGreen standards
took effect in January 2011 and instituted mandatory minimum environmental performance standards for all
ground-up, new construction of commercial, low-rise residential, and state-owned buildings, as well as schools
and hospitals.
In general, single-family residences built to the 2019 Title 24 standards are anticipated to use approximately 7
percent less energy due to energy efficiency measures than those built to the 2016 standards; once rooftop solar
electricity generation is factored in, single-family residences built under the 2019 standards will use
approximately 53 percent less energy than those under the 2016 standards (CEC 2018). Nonresidential buildings
built to the 2019 standards are anticipated to use an estimated 30 percent less energy than those built to the
2016 standards (CEC 2018).
Integrated Energy Policy Report
The CEC is responsible for preparing integrated energy policy reports that identify emerging trends related to
energy supply, demand, conservation, public health and safety, and maintenance of a healthy economy. The
CEC’s 2015 Integrated Energy Policy Report discusses the state’s policy goal to require that new residential
construction be designed to achieve zero net energy standards by 2020, and that new non-residential
construction be designed to achieve zero net energy standards by 2030 (CEC 2016), which is relevant to this EIR.
Refer to Section 4.7 of this EIR for additional information on the state’s zero net energy objectives and how the
state’s achievement of its objectives would serve to beneficially reduce the proposed project’s GHG emissions
profile and energy consumption.
State Vehicle Standards
In response to the transportation sector accounting for more than half of California’s carbon dioxide (CO2)
emissions, AB 1493 was enacted in 2002. AB 1493 required CARB to set GHG emissions standards for
passenger vehicles, light-duty trucks, and other vehicles determined by the state board to be vehicles whose
primary use is noncommercial personal transportation in the state. The bill required that CARB set GHG emissions
standards for motor vehicles manufactured in 2009 and all subsequent model years. The 2009 through 2012
standards resulted in a reduction in approximately 22 percent of GHG emissions compared to emissions from the
2002 fleet, and the 2013 through 2016 standards resulted in a reduction of approximately 30 percent.
In 2012, CARB approved a new emissions-control program for model years 2017 through 2025. The program
combines the control of smog, soot, and global-warming gases with requirements for greater numbers of zero-
emissions vehicles into a single package of standards called Advanced Clean Cars. By 2025, when the rules would
be fully implemented, new automobiles would emit 34 percent fewer global-warming gases and 75 percent fewer
smog-forming emissions (CARB 2012).
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Although the focus of the state’s vehicle standards is on the reduction of air pollutants and GHG emissions, one
co-benefit of implementation of these standards is a reduced demand for petroleum-based fuels.
Sustainable Communities Strategy
The Sustainable Communities and Climate Protection Act of 2008, or SB 375, coordinates land use planning,
regional transportation plans, and funding priorities to help California meet its GHG emissions-reduction
mandates. As codified in California Government Code Section 65080, SB 375 requires metropolitan planning
organizations (e.g., San Diego Association of Governments) to include a Sustainable Communities Strategy in their
regional transportation plan. The main focus of the Sustainable Communities Strategy is to plan for growth in a
fashion that will ultimately reduce GHG emissions, but the strategy is also part of a bigger effort to address other
development issues, including transit and VMT, which influence the consumption of petroleum-based fuels.
Local
SDG&E Individual Integrated Resource Plan
SDG&E’s Conforming Portfolio identifies a need for approximately 700 gigawatt-hours of incremental renewable
power in addition to the assumed increases in energy efficiency and behind-the-meter solar, to meet the 2030
planning target (approximately 4 percent of the total energy in the portfolio) (SDG&E 2020). SDG&E’s Conforming
Portfolio demonstrates that the utility has reduced its GHG emissions in the early years of the planning period,
reflecting its current position in relation to its RPS targets—in 2018, approximately 45 percent of its energy mix
came from delivering renewable resources (compared to an RPS requirement of 29 percent), it has aggressively
adopted energy storage, and does not utilize coal resources. SDG&E is fully compliant with RPS and long-term
contracting requirements. SDG&E continues to procure to meet resource-specific renewable procurement
mandates, as required, but does not expect to procure additional resources for RPS compliance purposes until
after 2030. SDG&E is forecasted to reach 49 percent renewable energy in 2021, 98 percent of which will be from
long-term contracts (SDG&E 2020).
Poway Comprehensive Plan: General Plan
The Poway Comprehensive Plan: General Plan (General Plan) includes the following policy and strategies to limit
energy use (City of Poway 1991):
Policy E – Air, Water and Soil Pollution: The City shall work locally and at the regional level to reduce air, water,
and soil pollution within Poway.
Strategy 2: Seek to promote a development pattern that reduces daily trips for shopping, school ,
and recreation.
Strategy 3: Encourage ridesharing, the use of transit and other transportation systems management
programs to reduce the number of vehicle miles traveled and traffic congestion.
Strategy 5: Implement plans and programs to phase-in energy conservation improvements.
Strategy 6: Investigate incentives and regulations to reduce emissions from swimming pools, residential
and commercial water heating and heaters.
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4.5.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to energy are based on Appendix G of the CEQA
Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to energy would occur if
the project would:
1. Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project construction or operation.
2. Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
4.5.4 Impacts Analysis
Would the project result in potentially significant environmental impact due to wasteful, inefficient, or
unnecessary consumption of energy resources, during project construction or operation?
Implementation of the proposed project would increase the demand for electricity and natural gas at the project
site and gasoline consumption in the region during construction and operation.
Electricity
Construction Use
Temporary electric power for as-necessary lighting and electronic equipment, such as computers, may be needed
inside temporary construction trailers. However, the electricity used for such activities would be temporary and
would be substantially less than that required for project operation and would have a negligible contribution to the
proposed project’s overall energy consumption.
Operational Use
The operational phase would require electricity for multiple purposes including, but not limited to, building heating
and cooling, lighting, appliances, and electronics. These types of uses would be similar to those currently
occurring on site in the clubhouse.
California Emissions Estimator Model (CalEEMod) (version 2016.3.2) was used to estimate project emissions
from energy uses (see Appendix B for calculations). Default electricity generation rates in CalEEMod were used
(based on the proposed land use and climate zone) based on compliance with 2019 Title 24 for their respective
land uses. It was estimated that the proposed project would consume approximately 1,305,502 kWh per year.
This equates to approximately 0.8 gigawatt-hours per year. In 2018, the total electricity demand for San Diego
County was 19,749 gigawatt-hours (CEC 2019a).
As described above, the electricity demand calculation for the proposed project assumes compliance with Title
24 standards for 2019. The proposed project would be required to meet the California Building Energy Efficiency
Standards (24 CCR 6), which improve the energy efficiency of residential and non-residential buildings. The Title
24, Part 6, standards are updated every three years.
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The proposed project is subject to statewide mandatory energy requirements as outlined in Title 24, Part 6, of the
California Code of Regulations. Title 24, Part 11, contains voluntary energy measures that are applicable to the
proposed project under the CALGreen Code. Prior to project approval, the project applicant would ensure that the
proposed project meets Title 24 requirements applicable at that time, as required by state regulations through
their plan review process. For these reasons, the electricity consumption of the proposed project would not be
inefficient or wasteful, and impacts would be less than significant.
Natural Gas
Construction Use
Natural gas is not anticipated to be required during construction of the proposed project. Fuels used for
construction would primarily consist of diesel and gasoline, which are discussed below under the “petroleum”
subsection. Any minor amounts of natural gas that may be consumed as a result of project construction would be
substantially less than that required for project operation and would have a negligible contribution to the
proposed project’s overall energy consumption.
Operational Use
Natural gas consumption during operation would be required for various purposes, including, but not limited to,
building heating and cooling.
Default natural gas generation rates in CalEEMod for the proposed land use and climate zone were used and
adjusted based on compliance with 2019 Title 24 (see Appendix B for calculations). According to these estimations,
the proposed project would consume approximately 63,275 therms per year. In comparison, the total natural gas
demand for San Diego County in 2018 was 482,524,487 therms (CEC 2019b).
Although natural gas consumption would increase due to the implementation of the proposed project, it would be
designed to maximize energy performance. The proposed project is subject to statewide mandatory energy
requirements as outlined in Title 24, Part 6, of the California Code of Regulations. Title 24, Part 11, contains voluntary
energy measures that are applicable to the proposed project under the CALGreen Code. Prior to project approval, the
project applicant would ensure that the proposed project meets Title 24 requirements applicable at that time, as
required by state regulations through their plan review process. For these reasons, the natural gas consumption of the
proposed project would not be inefficient or wasteful, and impacts would be less than significant.
Petroleum
Construction Use
Petroleum would be consumed throughout construction of the proposed project. Fuel consumed by construction
equipment would be the primary energy resource expended over the course of construction, and VMT associated
with the transportation of construction materials and construction worker commutes would also result in
petroleum consumption. Heavy-duty construction equipment associated with construction activities, and haul
trucks involved in relocating dirt around the project site would rely on diesel fuel. Construction workers would
travel to and from the project site throughout the duration of construction. It is assumed that construction
workers would travel to and from the project site in gasoline-powered vehicles.
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June 2020 4.5-11
Heavy-duty construction equipment of various types would be used during construction. CalEEMod was used to
estimate construction equipment usage; results are included in Appendix B of this EIR. Based on that analysis, diesel-
fueled construction equipment would operate for an estimated 81,372 hours, as summarized in Table 4.5-1.
Table 4.5-1. Hours of Operation for Construction Equipment
Phase Hours of Equipment Use
Demolition 2,112
Site Preparation 6,720
Grading 19,840
Building Construction 49,640
Paving 2,640
Architectural Coating 420
Total 81,372
Source: Appendix B.
Fuel consumption from construction equipment was estimated by converting the total CO2 emissions from each
construction phase to gallons using conversion factors for CO2 to gallons of gasoline or diesel. The conversion
factor for gasoline is 8.78 kilograms per metric ton CO2 per gallon, and the conversion factor for diesel is 10.21
kilograms per metric ton CO2 per gallon (The Climate Registry 2019). The estimated diesel fuel use from
construction equipment is shown in Table 4.5-2.
Table 4.5-2. Construction Equipment Diesel Demand
Phase Pieces of Equipmenta Equipment CO2 (MT)a kg CO2/Gallonb Gallons
Demolition 6 74.80 10.21 7,326.31
Site Preparation 7 200.61 10.21 19,648.79
Grading 8 844.77 10.21 82,739.49
Building Construction 9 846.06 10.21 82,865.87
Paving 6 55.08 10.21 5,394.29
Architectural Coating 1 8.94 10.21 875.26
Total 198,850.01
Sources:
a Appendix B.
b The Climate Registry 2019.
Notes: CO2 = carbon dioxide; MT = metric ton; kg = kilogram.
Fuel consumption from worker and vendor trips was estimated by converting the total CO2 emissions from the
construction phase to gallons using the conversion factors for CO2 to gallons of gasoline or diesel. Worker
vehicles are assumed to be gasoline fueled, and vendor/hauling vehicles are assumed to be diesel fueled.
Calculations for total worker, vendor, and hauler fuel consumption are provided in Table 4.5-3, Table 4.5-4, and
Table 4.5-5.
Table 4.5-3. Construction Worker Vehicle Gasoline Demand
Phase Trips Vehicle CO2 (MT)a kg CO2/Gallonb Gallons
Demolition 1,760 6.16 8.78 702.12
Site Preparation 4,800 16.81 8.78 1,914.86
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Table 4.5-3. Construction Worker Vehicle Gasoline Demand
Phase Trips Vehicle CO2 (MT)a kg CO2/Gallonb Gallons
Grading 12,400 43.18 8.78 4,917.49
Building Construction 865,780 2,802.44 8.78 319,184.84
Paving 2,750 9.28 8.78 1,056.85
Architectural Coating 3,500 10.91 8.78 1,242.77
Total 329,018.93
Sources:
a Appendix B.
b The Climate Registry 2019.
Notes: CO2 = carbon dioxide; MT = metric ton; kg = kilogram.
Table 4.5-4. Construction Vendor Truck Diesel Demand
Phase Trips Vehicle CO2 (MT)a kg/CO2/Gallonb Gallons
Demolition 0 0.00 10.21 0.00
Site Preparation 0 0.00 10.21 0.00
Grading 0 0.00 10.21 0.00
Building Construction 331,420 4,204.87 10.21 411,838.80
Paving 0 0.00 10.21 0.00
Architectural Coating 0 0.00 10.21 0.00
Total 411,838.80
Sources:
a Appendix B.
b The Climate Registry 2019.
Notes: CO2 = carbon dioxide; MT = metric ton; kg = kilogram.
Table 4.5-5. Construction Haul Truck Diesel Demand
Phase Trips Vehicle CO2 (MT)a kg CO2/Gallonb Gallons
Demolition 574 21.86 10.21 2,140.89
Site Preparation 0 0.00 10.21 0.00
Grading 63,614 363.41 10.21 35,593.57
Building Construction 0 0.00 10.21 0.00
Paving 0 0.00 10.21 0.00
Architectural Coating 0 0.00 10.21 0.00
Total 37,734.46
Sources:
a Appendix B.
b The Climate Registry 2019.
Notes: CO2 = carbon dioxide; MT = metric ton; kg = kilogram.
As shown in Tables 4.5-2 through 4.5-5, the proposed project is estimated to consume 977,442 gallons of
petroleum during the construction phase. By comparison, approximately 55 billion gallons of petroleum would be
consumed in California over the course of the project’s construction phase, based on the California daily
petroleum consumption estimate of approximately 52.9 million gallons per day (CEC 2019c). In 2018, the total
petroleum consumption within the County of San Diego was 1.6 billion gallons (CARB 2019). The proposed project
would also be required to comply with CARB’s Airborne Toxics Control Measures, which restrict heavy-duty diesel
vehicle idling time to five minutes. Therefore, because petroleum use during construction would be temporary and
relatively minimal, and would not be wasteful or inefficient, impacts would be less than significant.
4.5 – Energy
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June 2020 4.5-13
Operational Use
The majority of fuel consumption resulting from the project’s operational phase would be attributable to
employees, visitors, and residents traveling to and from the project site.
Petroleum fuel consumption associated with motor vehicles and delivery trucks traveling to and from the project
site during operation is a function of VMT. Linscott, Law & Greenspan prepared the Traffic Impact Analysis for The
Farm in Poway in January 2020, which is provided in Appendix J of this EIR. Based on the traffic impact analysis
and air quality technical report (Appendix J and Appendix B, respectively), the annual VMT attributable to the
proposed project is expected to be 7,332,485 VMT per year after project buildout. Similar to construction worker
and vendor trips, fuel consumption for operation was estimated by converting the total CO2 emissions from each
land use type to gallons using the conversion factors for CO2 to gallons of gasoline or diesel. The employee and
customer vehicles were assumed to be gasoline powered and the vendor trucks were assumed to be diesel.
Calculations for annual fuel consumption are provided in Table 4.5-6. Mobile sources from the proposed project would
result in approximately 273,052 gallons of gasoline per year and 19,090 gallons of diesel per year, for a total of
292,142 gallons of petroleum consumed per year beginning in 2025 after project buildout. By comparison, California
as a whole consumes approximately 19.3 billion gallons of petroleum per year (CEC 2019b). It is forecasted that in
2025, approximately 1.4 billion gallons of petroleum in San Diego County will be consumed (CARB 2019).
Table 4.5-6. Petroleum Consumption – Operation
Fuel Vehicle CO2 (MT)a kg CO2/Gallonb Gallons
Gasoline 2,397.40 8.78 273,052.25
Diesel 194.91 10.21 19,089.86
Total 292,142.11
Sources:
a Appendix J and B.
b The Climate Registry 2019.
Notes: MT = metric ton; CO2 = carbon dioxide; kg = kilogram.
Over the lifetime of the project, the fuel efficiency of the vehicles being used by the employees is expected to
increase. As such, the amount of petroleum consumed as a result of vehicular trips to and from the project site
during operation would decrease over time. There are numerous regulations in place that require and encourage
increased fuel efficiency. For example, as mentioned previously, CARB has adopted an approach to passenger
vehicles by combining the control of smog-causing pollutants and GHG emissions into a single, coordinated
package of standards. The approach also includes efforts to support and accelerate the number of plug-in hybrids
and zero-emissions vehicles in California (CARB 2013). Additionally, in response to SB 375, CARB adopted the
goal of reducing per-capita GHG emissions from 2005 levels by 8 percent by 2020, and 18 percent by 2035 for
light-duty passenger vehicles in the planning area for the San Diego Association of Governments. As such,
operation of the proposed project is expected to use decreasing amounts of petroleum over time due to advances
in fuel economy.
In summary, although the proposed project would increase petroleum use during operation as a result of
employees and customers commuting to the site and vendor trucks, the use would be a small fraction of the
statewide and countywide use and, due to efficiency increases, would diminish over time. Given these
considerations, petroleum consumption associated with the proposed project would not be inefficient or wasteful
and would result in a less-than-significant impact.
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June 2020 4.5-14
Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Title 24 of the California Code of Regulations contains energy efficiency standards for residential and non -
residential buildings based on a state mandate to reduce California’s energy demand. Specifically, Title 24
addresses a number of energy efficiency measures that impact energy used for lighting, water heating,
heating, and air conditioning, including the energy impact of the building envelope such as windows, doors,
skylights, wall/floor/ceiling assemblies, attics, and roofs.
Part 6 of Title 24 specifically establishes energy efficiency standards for residential and non-residential buildings
constructed in the State of California in order to reduce energy demand and consumption. The proposed project
would comply with Title 24, Part 6, per state regulations. In accordance with Title 24 Part 6, the proposed project
would have: (a) sensor-based lighting controls—for fixtures located near windows, the lighting would be adjusted
by taking advantage of available natural light; and, (b) efficient process equipment—improved technology offers
significant savings through more efficient processing equipment.
Title 24, Part 11, contains voluntary and mandatory energy measures that are applicable to the proposed project
under the CALGreen Code. As discussed under the previous threshold, the proposed project would result in an
increased demand for electricity, natural gas, and petroleum. In accordance with Title 24, Part 11, mandatory
compliance, the applicant would have: (a) 50 percent of its construction and demolition waste diverted from
landfills; (b) mandatory inspections of energy systems to ensure optimal working efficiency; (c) low pollutant-
emitting exterior and interior finish materials, such as paints, carpets, vinyl flooring, and particle boards; and, (d) a
20 percent reduction in indoor water use. Compliance with all of these mandatory measures would decrease the
consumption of electricity, natural gas, and petroleum.
Because the proposed project would comply with Title 24, Part 6 and Part 11, no conflict with existing energy
standards and regulations would occur. Therefore, impacts would be less than significant.
4.5.5 Cumulative Impacts
As shown in Section 4.5.4, impacts associated with the proposed project would be less than significant.
Therefore, there would be no cumulatively considerable impact.
4.5.6 Mitigation Measures
The proposed project would not result in any significant impacts to energy use; therefore, no mitigation
would be required.
4.5.7 Level of Significance After Mitigation
The proposed project would not result in a potentially significant environmental impact due to wasteful,
inefficient, or unnecessary consumption of energy resources, either during project construction or operation. In
addition, the proposed project would not conflict with or obstruct a state or local plan for renewable energy or
energy efficiency. Therefore, no mitigation would be required.
4.6 – Geology and Soils
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June 2020 4.6-1
4.6 Geology and Soils
This section describes the existing geological conditions of The Farm in Poway project (proposed project) site and
vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation
measures related to implementation of the proposed project. The analysis is based on the review of existing
conditions; applicable laws, regulations, and guidelines; and on the conclusions provided in the Geologic
Reconnaissance for the proposed project, prepared by Geocon Inc. in April 2019. The Geologic Reconnaissance is
included as Appendix E to this Environmental Impact Report (EIR).
A Notice of Preparation (NOP) was circulated from May 10, 2019, to June 10, 2019. During the NOP comment
period, no comment letters related to geology and soils were received.
The Initial Study, NOP, and Public Scoping comments are provided in Appendix A of this EIR.
4.6.1 Existing Conditions
City Overview
Landslides, rock falls, seismic-induced rupture or shaking, earth settlement, and expansive soil conditions are the
main geologic hazards in the City (City of Poway 1991). Most of the problems associated with the geologic
hazards in the City are due to the vulnerability of several geologic formations found in the City resulting from
previous poor land development practices (City of Poway 1991). The geology of Poway can be divided into
geologic zones based upon the age and general composition of exposed rocks (City of Poway 1991).
Underlying Geologic Formation
According to the Public Safety Element of the Poway Comprehensive Plan: General Plan (General Plan) (City of
Poway 1991), the project site is underlain by three geologic formations: Green Valley Tonalite, San Marcos
Gabbro, and Woodson Mountain Granodiorite. Green Valley Tonalite is highly susceptible to weathering and forms
low areas with gentle topography. San Marcos Gabbro is rather resistant to weathering; exposures tend to form
broad-based, conical-shaped, bold hills with few surface boulders. Woodson Mountain Granodiorite is very
resistant to erosion, forming most of the high areas in the City; outcrops tend to be characterized by large
rounded boulders and large exfoliated domes (City of Poway 1991).
Soils and Geologic Conditions
The geology underlying the project site consists of surficial soil (artificial fill, alluvium, and colluvium) over
Cretaceous-age granitic rock. The surficial soils and geologic formation are discussed below in order of increasing
age. The estimated extent of these units is outlined in Appendix E of this EIR. The composition, extent, and
approximate thickness of the surficial deposits will need to be determined during a future geotechnical
investigation for the proposed project.
Artificial Fill (Qaf)
Artificial fill deposits were observed in the form of embankments created during contour grading for the golf course.
It appears that artificial fill was also placed in the area of the clubhouse, pro shop, tennis courts, and the
groundskeeper facilities to create level ground for these structures. The artificial fill deposits would require remedial
grading where they are present within the project site. In addition, mulch was observed at the surface (unmapped)
and the thickness is unknown. This material would require removal and exportation from the project site.
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June 2020 4.6-2
Alluvium (Qal)
Alluvium is present within the existing drainages on the project site. These areas generally mimic the drainage
locations indicated on the original topography maps. It is assumed that remedial grading was not performed for
the alluvium during previous grading operations for the golf course. The alluvium would require remedial grading
during future development. Alluvium generally exhibits a high to very high expansion potential (Expansion Index
higher than 90).
Colluvium (Unmapped)
The bedrock in the vicinity of the project site is mantled with colluvial deposits where relatively gently sloping
conditions are present. Remedial grading would be necessary where these soils are present within the project
site. The colluvium encountered in the samples were qualified as medium dense to dense, silty/clayey. Colluvium
with clayey qualities is generally exhibits a high to very high expansion potential (Expansion Index higher than 90).
Cretaceous-Age Granitic Rock
Cretaceous-age Granitic Rock underlies the project site. This formation exhibits a highly variable weathering
profile (Appendix E). It appears that the upper approximately five to 15 feet of granitic rock below the ground
surface is rippable in the areas studied, with the exception of where rock outcroppings are present. This unit
generally exhibits adequate bearing and slope stability characteristics.
Geologic Hazards
Faulting and Seismicity
According to the Public Safety Element of the City’s General Plan, the faults in the City are classified as inactive by
the California Department of Conservation, Division of Mines and Geology. However, the potential exists for a
major seismic event to occur along one of the major faults and result in local damage (City of Poway 1991). As
such, the project site is not located on any known “active,” “potentially active,” or “inactive” fault traces, as
defined by the California Geological Survey (CGS). CGS has included portions of the Rose Canyon Fault zone
within an Alquist–Priolo Earthquake Fault Zone. The nearest known active faults are the Newport–Inglewood and
Rose Canyon Fault Zones, both located approximately 16 miles west of the site, and are the dominant sources of
potential ground motion (Appendix E). Historically, earthquakes between 5 and 6 magnitude intensity have
occurred near the Rose Canyon Fault. Studies indicate the maximum credible earthquake would be between 5.8
and 6.2 magnitude, with two repeat intervals of one per 100 years. The maximum credible earthquake would be
approximately 7.1 magnitude, with no stated recurrence interval (City of Poway 1991). A maximum probable
earthquake on the closest section of the Rose Canyon Fault could cause moderate damage in well-built structures
and heavy damage or collapse in poorly built structures.
The severity of the seismic ground shaking depends on the magnitude of the earthquake, the distance of the site
from the earthquake epicenter, and soil conditions at the site and in between the Project site and the epicenter.
Ground shaking is expected to have the greatest amount of seismic impact on the City; however, the effect of
ground shaking depends on its severity and the integrity of the structure (City of Poway 1991).
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Liquefaction
Liquefaction typically occurs when a site is located in a zone with seismic activity, on-site soils are cohesionless,
groundwater is encountered within 50 feet of the surface, and soil densities are less than about 70 percent of the
relative density. If all four criteria are met, a seismic event could result in a rapid increase in pore water pressure
from the earthquake-generated ground accelerations. The potential for liquefaction at the project site is
considered to be negligible due to the dense formational material encountered on site, remedial grading
recommended, and lack of a shallow groundwater condition.
According to the Public Safety Element of the City’s General Plan, the potential for widespread liquefaction in the
City does not exist due to the structure and particle size mix of the soil types found in the low-lying areas of the
City (i.e., sandy loams with clay substrata), which gives the soils a massive structure (City of Poway 1991)
Landslides
According to the Public Safety Element of the City’s General Plan, the City has many areas that are highly
susceptible to landslides. Landslides occur as a result of a seismic event, gravity, groundwater, and poor geologic
conditions. No evidence of ancient landslide deposits was observed during the site reconnaissance or geologic
literature review completed for the proposed project (Appendix E).
Expansive Soils
Expansive soils are clay soils that expand in volume with an increase in moisture content. Damage is caused
when structures are built on this soil without adequate foundation design (City of Poway 1991). According to the
2016 California Building Code (CBC), Section 1803.5.3 (adopted by the City of Poway), soils meeting all four of
the following provisions shall be considered expansive, except that tests to show compliance with Items 1, 2, and
3 shall not be required if the test prescribed in Item 4 is conducted:
1. Plasticity index of 15 or greater, determined in accordance with ASTM D4318 (Standard Test Methods for
Liquid Limit, Plastic Limit, and Plasticity Index of Soils).
2. More than 10 percent of the soil particles pass a No. 200 sieve (75 micrometers), determined in
accordance with ASTM D422 (Standard Test Method for Particle-Size Analysis of Soils).
3. More than 10 percent of the soil particles are less than 5 micrometers in size, determined in accordance
with ASTM D422.
4. Expansion index greater than 20, determined in accordance with ASTM D4829 (Standard Test Method for
Expansion Index of Soils).
Groundwater
No groundwater or seepage was observed on the property during the field reconnaissance performed for the
project site (Appendix E). However, groundwater levels in the constructed ponds and drainage areas can be
expected to fluctuate seasonally and could potentially affect grading if the alluvial areas extend into the
development footprint. Project grading could potentially encounter wet soils, causing excavation and compaction
difficulty, particularly if proposed project construction is planned during winter months.
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4.6.2 Relevant Plans, Policies, and Ordinances
Federal
Occupational Safety and Health Administration Regulations
Excavation and trenching are among the most hazardous construction operations. The Occupational Safety
and Health Administration (OSHA) Excavation and Trenching Standard (29 CFR 1926.650) covers
requirements for excavation and trenching operations. OSHA requires that all excavations in which
employees could potentially be exposed to cave-ins be protected by sloping or benching the sides of the
excavation, supporting the sides of the excavation, or placing a shield between the side of the excavation
and the work area. In California, the California OSHA has responsibility for implementing federal rules
relevant to worker safety, including slope protection during construction excavations. California OSHA’s
requirements are more restrictive and protective than federal OSHA standards.
U.S. Geological Survey Landslide Hazard Program
In fulfillment of the requirements of Public Law 106-113, the U.S. Geological Survey created the Landslide Hazard
Program in the mid-1970s. According to the U.S. Geological Survey, the primary objective of the National
Landslide Hazards Program is to reduce long-term losses from landslide hazards by improving understanding of
the causes of ground failure and suggesting mitigation strategies. The federal government takes the lead role in
funding and conducting this research, whereas the reduction of losses due to geologic hazards is primarily a state
and local responsibility.
Paleontological Resources Preservation Act
The Paleontological Resources Preservation Act of 2002 was enacted to codify the generally accepted practice of
limiting the collection of vertebrate fossils and other rare and scientifically significant fossils to qualified
researchers; these researchers must obtain a permit from the appropriate state or federal agency and agree to
donate any materials recovered to recognized public institutions, where they will remain accessible to the public
and to other researchers.
State
Alquist–Priolo Earthquake Fault Zoning Act
The Alquist–Priolo Earthquake Fault Zoning Act was passed in 1972 to mitigate the hazard of surface faulting to
structures for human occupancy. In accordance with this act, the State Geologist established regulatory zones,
called “earthquake fault zones,” around the surface traces of active faults, and published maps showing these
zones. Earthquake fault zones are designated by the CGS and are delineated along traces of faults where
mapping demonstrates surface fault rupture has occurred within the past 11,000 years. Construction within
these zones cannot be permitted until a geologic exploration has been conducted to prove that a building planned
for human occupancy would not be constructed across an active fault. These types of site evaluations address the
precise location and recency of rupture along traces of the faults, and are typically based on observations made
in trenches excavated across fault traces.
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Seismic Hazards Mapping Act
The Seismic Hazards Mapping Act of 1990 (California Public Resources Code, Chapter 7.8, Section 2690 et seq.)
directs the CGS to protect the public from earthquake-induced liquefaction and landslide hazards (these hazards are
distinct from fault surface rupture hazard regulated by the Alquist–Priolo Act). This act requires the State Geologist to
delineate various seismic hazard zones and requires cities, counties, and other local permitting agencies to regulate
certain development projects within these zones (i.e., zones of required investigation). Before a development permit
may be granted for a site within a seismic hazard zone, a geotechnical exploration of the site must be conducted and
appropriate mitigation measures incorporated into the design of proposed projects. Evaluation and mitigation of
potential risks from seismic hazards within zones of required investigation must be conducted in accordance with the
Guidelines for Evaluating and Mitigating Seismic Hazards in California, adopted by the State Mining and Geology Board
on March 13, 1997, and updated in 2008 (CGS 2008).
As of 2012, Seismic Hazard Zone Maps have been prepared for portions of populated areas of Southern California
and the San Francisco Bay Area; however, no seismic hazard zones have yet been delineated for the project site. As
a result, the provisions of the Seismic Hazards Mapping Act would not apply to the proposed project.
California Building Code
The California Building Code (CBC) (24 CCR Part 2) is administered by the California Building Standards
Commission, which is responsible for coordinating all building standards. Under state law, all building standards
must be centralized in Title 24 or they are not enforceable. The purpose of the CBC is to establish minimum
standards to safeguard the public health, safety, and general welfare through structural strength, means of
egress facilities, and general stability by regulating and controlling the design, construction, quality of materials,
use and occupancy, location, and maintenance of all building and structures within its jurisdiction. The CBC is
based on the International Building Code, published by the International Code Conference. The CBC contains
California amendments based on the American Society of Civil Engineers Minimum Design Standards 7-05, which
provides requirements for general structural design and includes means for determining earthquake loads and
other loads (such as wind loads) for inclusion into building codes. The provisions of the CBC apply to the
construction, alteration, movement, replacement, and demolition of every building or structure or any
appurtenances connected or attached to such buildings or structures throughout California.
Paleontological Resources
Paleontological resources are afforded consideration under the California Environmental Quality Act (CEQA).
Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.) includes the following as part of its Environmental
Checklist: “Would the project directly or indirectly destroy a unique paleontological resource or site or unique
geologic feature?” Section 5097.5 of the California Public Resources Code specifies that any unauthorized
removal of paleontological remains is a misdemeanor. Further, California Penal Code Section 622.5 sets the
penalties for damage to or removal of paleontological resources.
Local
San Diego County Special Studies Zones
The Alquist–Priolo Act provides that a city or county may establish more restrictive policies than those within the
Alquist–Priolo Act, if desired. The County of San Diego (County) established Special Study Zones that include late-
Quaternary faults mapped by CGS. Late-Quaternary faults (movement during the past 700,000 years) were mapped
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for the County based on geomorphic evidence similar to that of Holocene faults except that tectonic features are
less distinct. As indicated by CGS, these faults may be younger, but the lack of younger overlying deposits precludes
more accurate age classification. Traces of faults within “Special Study Zones” are treated by the County as active
unless a fault investigation can prove otherwise. Before any construction is allowed, a geologic study must be
conducted to determine if any active fault lines are located on or within the vicinity of a project site. For areas where
active faulting is identified, the County’s Fault Displacement Area regulations regulate new development in areas
subject to potential loss of life and property from earthquake fault displacement in order to mitigate such losses
(County of San Diego 2007). The proposed project would not be located in a County Special Study Fault Zone or a
fault rupture hazard zone as identified by the Alquist–Priolo Act.
On-Site Wastewater Treatment System Ordinance
Chapter 3, Division 8, of Title 6 of the San Diego County Code, On-Site Wastewater Treatment System Ordinance
(County of San Diego 2011), establishes the requirements for on-site wastewater treatment systems in the
County. The purpose of this ordinance is to implement state laws and regulations associated with waste discharge
requirements (State Water Resources Control Board and the California Regional Water Quality Control Board for
the San Diego Region), and to implement additional standards for septic systems and graywater systems that are
necessary to protect the health and safety of the community. It also makes it unlawful for any person to cause,
suffer, or permit the disposal of sewage, human excrement, or other liquid wastes in any place or manner except
through and by means of an approved plumbing and drainage system and an approved sewage disposal system.
If no public sanitary sewer system is available, the ordinance allows for installation of on-site wastewater
treatment systems, provided that the requirements and standards of the ordinance are complied with and a
permit issued by the Department of Environmental Health is obtained. Standards and requirements include soil
percolation tests to determine soil suitability, the selection of a treatment system appropriate for site conditions,
and specific setback requirements from lakes, streams, ponds, slopes, and other utilities and structures. Chapter
6, Division 8, of Title 6 of the County Code pertains to Septic Tank and Cesspool Cleaners, which establishes
processes, fees, and requirements for the examination, cleaning, and collection of sewage from septic tanks and
cesspools. The proposed project would not include any septic or on-site wastewater systems. As such, this
ordinance does not apply to the proposed project.
City of Poway Municipal Code
Chapter 16, Division 3 – Excavation and Grading
Chapter 16, Division 3 of the City of Poway Municipal Code (City of Poway 2019), Excavation and Grading,
establishes the requirement to obtain a grading permit prior to grading operations. The Grading Ordinance
requires the submittal of grading plans or improvement plans for review by the City Engineer prior to issuance of a
grading permit. The Grading Ordinance contains design standards and performance requirements that must be
met to avoid—or reduce to an acceptable level—the potential for slope instabilities, expansive soils, excessive
erosion, and sedimentation to adversely affect a proposed development. The ordinance prohibits grading permits
upon a significant portion of natural or existing grade that exceeds a slope of 45 percent unless such grading is
required to mitigate a geologic hazard to adjacent grade, or is required for the construction of necessary water or
sewer mains, storm drains, or fire roads, all as approved and determined necessary by the City Engineer.
The Grading Ordinance also establishes the requirements for expansive soil requirements for cuts and fills;
minimum setback requirements for buildings from cut or fill slopes; and reporting requirements, including a soil
engineer’s report and a final engineering geology report by an engineering geologist that includes specific
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approval of the grading as affected by geological factors. Upon review of grading plans, the City Official has the
authority to approve, attach conditions of approval, or deny the permit application.
Chapter 15.04 – Building Code
Chapter 15.04 of the City’s Municipal Code (City of Poway 2019) outlines the City Building Code, which prescribes
regulations for the erection, construction, enlargement, alteration, repair, moving, removal, conversion,
demolition, occupancy, equipment, use, height, area, and maintenance of buildings and structures in the City. The
City Building Code adopts the 2016 CBC.
4.6.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to geology and soils are based on Appendix G of the
CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to geology and
soils would occur if the project would:
1. Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or
death involving:
a. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake
Fault Zoning Map issued by the State Geologist for the area based on other substantial evidence of
as known fault. Refer to Division of Mines and Geology Special Publication 42.
b. Strong seismic ground shaking.
c. Seismic-related ground failure, including liquefaction.
d. Landslides.
2. Result in substantial soil erosion or the loss of topsoil.
3. Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project,
and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse.
4. Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating
substantial direct or indirect risks to life or property.
5. Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal
systems where sewers are not available for the disposal of waste water.
6. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.
4.6.4 Impacts Analysis
Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss,
injury, or death involving:
a. Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault
Zoning Map issued by the State Geologist for the area based on other substantial evidence of as known
fault. Refer to Division of Mines and Geology Special Publication 42.
As stated under Section 4.6.1, Existing Conditions, the project site is not located on any known “active,”
“potentially active,” or “inactive” fault traces as defined by CGS. CGS considers a fault seismically active
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when evidence suggests seismic activity within roughly the last 11,000 years. According to the results of
the Geologic Reconnaissance (Appendix E), seven known active faults are located within a search radius
of 50 miles from the project site. The Newport–Inglewood and Rose Canyon Fault Zones, located
approximately 16 miles west of the site, are the closest known active faults. Table 4.6-1 lists the
estimated maximum earthquake magnitudes and peak ground accelerations for the most dominant faults
for the site location calculated for Site Class C, as defined by Table 1613.3.2 of the 2016 CBC.
Table 4.6-1. Deterministic Seismic Site Parameters
Fault Name
Distance
from Project
Site (miles)
Maximum
Earthquake
Magnitude (Mw)
Peak Ground Acceleration
Source 1 Source 2 Source 3
Newport–Inglewood 16 7.5 0.19 0.15 0.18
Rose Canyon 16 6.9 0.15 0.13 0.13
Elsinore 21 7.85 0.18 0.13 0.17
Earthquake Valley 29 6.8 0.09 0.07 0.06
Coronado Banks 30 7.4 0.12 0.08 0.09
Palos Verdes 30 7.7 0.13 0.09 0.11
San Jacinto 42 7.88 0.11 0.08 0.09
Source: Appendix E.
Notes: Source 1 = Boore-Atkinson (2008); Source 2 = Campbell-Bozorgnia (2008); Source 3 = Chiou-Youngs (2008).
A site-specific probabilistic seismic hazard analysis was completed in preparation of the Geologic
Reconnaissance (Appendix E) prepared for the proposed project. The site-specific probabilistic seismic
hazard analysis calculated the expected accelerations from considered earthquake sources using a
program that calculates the total average annual expected number of occurrences of site acceleration
greater than a specified value. Given the distance of the nearest fault and magnitude of past seismic
activity, the proposed project would not expose people or structures to potential substantial adverse
effects associated with the rupture of a known earthquake fault. Furthermore, all proposed residences
and structures on site would be designed and constructed in accordance with the CBC guidelines
currently adopted by the City. Therefore, impacts related to fault rupture would be less than significant.
b. Strong seismic ground shaking?
As stated above, the Newport–Inglewood and Rose Canyon Fault Zones, located approximately 16 miles
west of the project site, are the closest known active faults. A site-specific probabilistic seismic hazard
analysis was performed in preparation of the Geologic Reconnaissance for the proposed project
(Appendix E). The results are summarized in Table 4.6-2.
Table 4.6-2. Seismic Hazard Probability
Probability of Exceedance
Peak Ground Acceleration
Source 1 Source 2 Source 3
2% in a 50-year period 0.37 0.36 0.41
5% in a 50-year period 0.28 0.27 0.29
10% in a 50-year period 0.22 0.21 0.21
Source: Appendix E.
Notes: Source 1 = Boore-Atkinson (2008); Source 2 = Campbell-Bozorgnia (2008); Source 3 = Chiou-Youngs (2008).
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While listing peak accelerations is useful for comparison of potential effects of fault activity in a region,
other considerations are important in seismic design, including the frequency and duration of motion and
the soil conditions underlying the site. The project site is likely to be subjected to strong ground motion
from seismic activity similar to that of the rest of the County and Southern California, due to the seismic
activity of the region as a whole. However, compliance with the CBC and seismic design criteria
recommendations would reduce exposure of people or structures to potential substantial adverse effects
from seismic ground shaking. Therefore, impacts would be less than significant.
c. Seismic-related ground failure, including liquefaction?
Liquefaction typically occurs when a site is located in a zone with seismic activity, the on-site soils
are cohesionless, groundwater is encountered within 50 feet of the surface, and soil relative
densities are less than about 70 percent. If all four of the previous criteria are met, a seismic event
could result in a rapid pore-water pressure increase from the earthquake-generated ground
accelerations. Seismically induced settlement may occur whether the potential for liquefaction exists
or not. The surficial soils and geologic formations underlying the project site include artificial fill,
alluvium, colluvium, and cretaceous granite rock. No groundwater or seepage was observed on the
project site during the field reconnaissance (Appendix E). As concluded in the Geologic
Reconnaissance, the potential for liquefaction at the site is considered to be negligible due to the
dense formational material encountered and lack of a shallow groundwater condition (Appendix E).
However groundwater depth is currently unknown and would need to be further studied in an
additional geologic investigation. Additionally, it was recommended in the Geologic Reconnaissance
(Appendix E) that remedial grading take place to fully mitigate for any potentially liquefiable soils, if
they exist on site. As such, impacts associated with seismic-related ground failure, including
liquefaction, would conservatively be potentially significant (Impact GEO-1) until an additional
geologic investigation is conducted and remedial grading is competed.
d. Landslides?
The risk associated with ground rupture hazards, such as landslides, is very low due to the absence of
active faults within the project site. As discussed in Section 4.6.1, no evidence of ancient landslide
deposits were observed during the site reconnaissance or geologic literature review completed for the
proposed project (Appendix E). Additionally, the proposed project would be designed in accordance with
the 2016 CBC, which would minimize potential risks associated with landslides. Therefore, impacts would
be less than significant.
Would the project result in substantial soil erosion or the loss of topsoil?
The demolition and construction phases of the proposed project would require grading, excavation, and the
import and export of soil from the project site, and therefore would increase the potential for erosion. Soil erosion
and loss of topsoil could occur through runoff, wind transport, and vehicle movement. Grading for the site is
balanced at 508,900 cubic yards of cut and fill to avoid export or import of dirt. Cut and fill slopes are designed at
2:1 minimum. The site is underlain by surficial units that include artificial fill, alluvium, colluvium, and cretaceous-
age granite rock. The geologic formations underlying the City vary from highly susceptible to very resistant to
erosion. However, the geologic formations are well beneath the ground surface of the project site (City of Poway
1991). The artificial fill, alluvium, and colluvium deposits are presently unsuitable to support fill and/or structural
loads and would require remedial grading where improvements are planned. All project site slopes would be
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landscaped with drought-tolerant vegetation having variable root depths and requiring minimal landscape
irrigation, and all slopes would be drained and properly maintained to reduce erosion. Additionally, the proposed
project would not be approved or built without adequately demonstrating to the City compliance with the CBC and
applicable geologic hazards regulations. However, without remedial grading where improvements are planned,
the proposed project could result in a potentially significant impact (Impact GEO-2) associated with soil erosion
and mitigation would be required.
Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the
project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
As determined in the Public Safety Element of the City’s General Plan (City of Poway 1991), the project site is not
located in an area subject to landslide, lateral spreading, subsidence, liquefaction, or collapse. As previously
stated, the project site is underlain by surficial units that include artificial fill, alluvial, and colluvial deposits. The
site was previously developed and disturbed, and there are no known cases of landslide, lateral spreading,
subsidence, liquefaction, or collapse occurring on site.
As previously discussed, the proposed project includes the implementation of the recommendations included in
the Geologic Reconnaissance, which would further minimize any potential for on- or off-site landslide, lateral
spreading, subsidence, liquefaction or collapse. Additionally, the proposed project would not be approved or built
without adequately demonstrating compliance with the CBC and applicable geologic hazards regulations.
Therefore, impacts associated with placement on a geologic unit or soil that is unstable, or that would become
unstable as a result of the proposed project, would be less than significant.
Would the project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994),
creating substantial direct or indirect risks to life or property?
Expansive soils contain minerals, such as clay, that are capable of absorbing water and expanding, and
losing water and shrinking. The repetitive stress of a swell/shrink cycle on a foundation can cause severe
damage to buildings and structures. As discussed in Section 4.6.1, the underlying alluvium and colluvium
encountered on the project site during reconnaissance are considered to be “expansive” (expansion index of
greater than 20) as defined by 2016 CBC Section 1803.5.3. Thus, the proposed project could create
substantial direct or indirect risks to life or property due to the expansive soils on site. The proposed project
would be constructed in conformance with the 2016 CBC, which would minimize impacts associated with
expansive soils. However, impacts associated with expansive soils would still be potentially significant
(Impact GEO-3) and mitigation would be required.
Would the project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater
disposal systems where sewers are not available for the disposal of wastewater?
The proposed project would not involve the use of septic tanks or alternative wastewater disposal; therefore, no
impact related to soils incapable of supporting these uses would occur.
Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Most paleontological resources are not exposed at the surface, and fossils are usually found during earthmoving
activities when geologic features are exposed. The project site is almost entirely developed, so the likelihood of
encountering subsurface paleontological resources is greatest on sites that have been minimally excavated in the
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past. However, due to the depth of excavation during grading activities, there is potential to encounter previously
undiscovered paleontological resources. Since the exact depths of such resources are unknown, in the event that
unexpected intact paleontological resources are unearthed during ground-disturbing activities, impacts would be
potentially significant (Impact GEO-4).
The proposed project’s impacts to geological resources are listed as follows:
Impact GEO-1 The proposed project could result in potentially significant impacts associated with
seismic-related ground failure, including liquefaction, due to the unknown depth of
groundwater on site and the potential for liquefiable soils.
Impact GEO-2 The proposed project could result in a potentially significant impact associated with soil
erosion because on-site artificial fill, alluvium, and colluvium deposits are presently
unsuitable to support fill and/or structural loads where improvements are planned.
Impact GEO-3 The proposed project could result in a potentially significant impact relative to the
location of expansive soils on site that may result in substantial direct or indirect risks to
life or property.
Impact GEO-4 If unexpected intact paleontological resources are unearthed during ground-disturbing
activities, then the proposed project could result in significant impacts to unique
paleontological resources or sites, or unique geologic features.
4.6.5 Cumulative Impacts
All of Southern California lies within a seismically active region with an extremely diverse range of geologic and
soil conditions that can vary substantially within short distances. However, impacts from geologic and soil
conditions are also site-specific and would only have potential to combine with impacts of the proposed project if
they occurred in the same general location, or on similar soils and topographies. Thus, the geographic extent of
the cumulative study area for potential impacts to people and structures related to geologic and seismic hazards
is restricted to the project site and the area immediately surrounding the site (see Figure 3-11, Cumulative
Projects, and Table 3-2, Cumulative Projects).
Fault Rupture
It is unlikely that past, existing, and/or future projects could contribute to the cumulative effects of geology and
soils creating the acceleration of erosion, slope failures, fault or ground rupture, and/or earthquake-induced
ground failure. These types of conditions would be limited to the areas within and adjacent to the boundaries of
individual projects or structural components of the project. In order for impacts to be cumulatively considerable,
these conditions would have to occur at the same time and in the same location as the proposed project.
Therefore, potential seismic impacts (ground shaking, earthquake-induced ground failure, and fault rupture) as a
result of local and regional faults, as well as soils that underlie individual projects, comprise an impact to the
geologic environment that would not be cumulatively considerable. Additionally, each individual project would be
designed in accordance with seismic design criteria as required by the CBC and with other specific design criteria
from state and local building and grading regulations, and would be subject to CEQA, including analysis of and
mitigation for geologic and soil impacts on an individual basis. Therefore, the proposed project would not
contribute, even incrementally, to potentially cumulative impacts related to fault rupture.
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Ground Shaking, Liquefaction, Landslides, Expansive Soils, and Adequate Soils for Septic Systems or Other On-
Site Wastewater Systems
Potential geologic and soils impacts associated with the proposed project are restricted to potential facility
damage from earthquake-related ground shaking, liquefaction, landslides, expansive soils, and general soil
suitability. The County Department of Planning and Development Services reviews applications for building
permits for compliance with the CBC, local amendments to the CBC, and County Zoning Ordinance Section
87.209. Grading plans would also be reviewed for compliance with state and local standards.
The proposed project would be designed in accordance with the seismic design requirements of the CBC, which
contains universal standards for seismically sound site preparation and grading practices, foundations design,
and guidelines for the appropriate selection and use of construction materials. In accordance with the CBC, a
more comprehensive Geology and Soils Report would be conducted that further evaluates the soils underlying the
project site to gauge the potential for liquefaction and soil strength during the maximum considered earthquake
geometric mean peak ground acceleration. Once the evaluation is complete, if needed, the design requirements
or the construction materials of the proposed project would be revised as recommended. Therefore, since no
other projects identified on the list of cumulative projects would occur on the project site, impacts associated with
liquefaction would not be cumulatively considerable.
The proposed project does not include any septic or on-site wastewater systems. As such, the proposed project
would not contribute to a cumulative impact related to adequate soils for septic tanks or on-site wastewater
systems. In all cases, the impacts were determined to be less than significant because the existing regulatory
framework controlling the design and construction of structures in California, and actions required to obtain a
grading and/or development permits at the local level, are sufficient to avoid or substantially reduce the potential
impacts. All other projects listed in Table 3-2, Cumulative Projects, would be required to comply with the same or
similar set of laws, regulations, and ordinances.
Therefore, because all cumulative projects would be designed in accordance with seismic design criteria as
required by the CBC and with other specific design criteria from state and local building and grading regulations,
impacts would be less than cumulatively considerable as related to ground shaking, liquefaction, landslides,
expansive soils, and adequate soils for septic systems.
Paleontological Resources
Cumulative projects located in the region would have the potential to result in a cumulative impact associated
with paleontological resources from extensive grading, excavation, or other ground-disturbing activities.
Cumulative projects that require significant excavation, such as regional energy and utility projects or the
construction of new roadways, would result in adverse impacts to paleontological resources. Additionally, if a
cumulative project that requires excavation or grading is located in an area of high or moderate sensitivity, this
would result in an increased potential for an adverse impact to a paleontological resources to occur. Cumulative
projects would be regulated by state and local regulations, including CEQA. However, the loss of paleontological
resources on a regional level may not be adequately mitigated through methods specified in these regulations.
Therefore, the cumulative destruction of significant paleontological resources from planned construction and
development within the region would be cumulatively significant. Additionally, past projects involving development
and construction have already impacted paleontological resources within the region.
As discussed in Section 4.6.4, ground-disturbing activities associated with the proposed project could have a
significant impact on previously undiscovered paleontological resources. Without appropriate mitigation, the
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proposed project in combination with cumulative projects occurring in areas containing geologic formations with
high and moderate sensitivity for previously undiscovered paleontological resources, would have the potential to
result in cumulative impacts to paleontological resources; however, implementation of standard mitigation
measures and adherence to applicable state and local regulations would prevent a cumulative loss of
paleontological resources. Therefore, impacts would be less than cumulatively considerable.
4.6.6 Mitigation Measures
MM-GEO-1 The Geologic Reconnaissance (Appendix E) includes the following recommendations, which shall
be incorporated as mitigation measures to minimize soil erosion or the loss of topsoil, and
potential risks associated with liquefaction:
1) Prior to issuance of a grading permit, an additional geotechnical study shall be completed
that includes a subsurface investigation to evaluate the underlying geologic conditions on the
property and to provide specific geotechnical recommendations. This study shall include
evaluation of surficial deposits, and a rippability analysis of the granitic rock in areas of
planned development.
2) The site is underlain by surficial units that include artificial fill, alluvial, and colluvial deposits.
These deposits shall require remedial grading in the form of removal and compaction where
improvements are planned.
3) Cut slopes shall be observed by an engineering geologist during grading to verify that the soil
and geologic conditions do not differ significantly from those anticipated. Additional
recommendations will be provided in the event that adverse conditions are encountered,
such as but not limited to, scaling of loose rock fragments from proposed cut slopes.
MM-GEO-2 The Geological Reconnaissance (Appendix E) includes the following recommendations, which
shall be incorporated as mitigation measures to minimize potential risks from expansive soil:
1) Samples of soil materials to be used for fill shall be tested in the laboratory to determine the
maximum density, optimum moisture content, and, where appropriate, shear strength,
expansion, and gradation characteristics of the soil.
2) Where practical, soils having an Expansion Index greater than 50 should be placed at least 3
feet below finish pad grade and should be compacted at a moisture content generally 2 to 4
percent greater than the optimum moisture content for the material.
MM-GEO-3 Prior to commencement of project construction, a qualified paleontologist shall be retained to
attend the project pre-construction meeting and discuss proposed grading plans with the project
contractor(s). If the qualified paleontologist determines that proposed grading/excavation
activities would likely affect previously undisturbed areas of Pleistocene-age alluvial deposits as a
result of cuts into native soils, then monitoring shall be conducted as outlined below.
1) A qualified paleontologist or a paleontological monitor under the direction and
supervision of a qualified paleontologist, shall be on site during original cutting of
Pleistocene-age alluvial deposits. A paleontological monitor is defined as an individual
who has at least one year of experience in field identification and collection of fossil
materials, and who is working under the direction of a qualified paleontologist.
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Monitoring of the noted geologic unit shall be conducted at least half-time at the
beginning of excavation, and may be either increased or decreased thereafter depending
upon initial results (per direction of a qualified paleontologist).
a) Qualified Paleontologist: The project paleontologist is a person who has a Ph.D. or M.S. or
equivalent in paleontology or closely related field (e.g., sedimentary or stratigraphic
geology, evolutionary biology); has a demonstrated knowledge of Southern California
paleontology and geology; and has documented experience performing professional
paleontological procedures and techniques.
b) Qualified Paleontological Monitor: A paleontological monitor is defined as an individual with at
least one year of experience in field identification and collecting of fossil materials.
2) Monitoring of the noted geologic unit shall be conducted at least half-time at the beginning of
the excavation, and may be either increased or decreased thereafter by the qualified
paleontologist depending upon initial results of monitoring.
3) In the event that well-preserved fossils are discovered, a qualified paleontologist shall have
the authority to temporarily halt or redirect construction activities in the discovery area to
allow recovery in a timely manner (typically on the order of one hour to two days). All collected
fossil remains shall be cleaned, sorted, cataloged and deposited in an appropriate scientific
institution (such as the San Diego Natural History Museum) at the applicant’s expense.
4) A report (with a map showing fossil site locations) summarizing the results, analyses, and
conclusions of the above-described monitoring/recovery program shall be submitted to the City of
Poway within three months of terminating monitoring activities.
4.6.7 Level of Significance After Mitigation
Implementation of the recommendations included in the Geological Reconnaissance (Appendix E) and
incorporated herein as mitigation measure MM-GEO-1 would reduce Impact GEO-1 and Impact GEO-2 to less-
than-significant levels. MM-GEO-2 would reduce Impact GEO-3 to less-than-significant levels. Compliance with
MM-GEO-1 would ensure that no significant impacts would result from soil erosion or liquefiable soils. Compliance
with MM-GEO-2 would ensure that no significant impacts would result from expansive soils on site.
Implementation of MM-GEO-3 would reduce Impact GEO-4 to a less-than-significant level by requiring a qualified
paleontologist be retained prior to construction commencing. If the qualified paleontologist determines that
proposed grading/excavation activities would likely affect previously undisturbed areas of Pleistocene-age alluvial
deposits, then monitoring shall be conducted as outlined in MM-GEO-3.
The proposed project would not expose people or structures to potential substantial adverse effects, including the
risk of loss, injury, or death involving rupture of a known earthquake fault, strong seismic ground shaking, or
landslides. The proposed project would not be located on a geologic unit or soil that is unstable or that would
become unstable as a result of the project, and would not involve the use of septic tanks or alternative
wastewater disposal. Site design measures would be used to minimize geology and soil impacts. Through site
design measures discussed in this analysis and outlined in Appendix E, as well as compliance with CBC
regulations, impacts associated with geology and soils would be less than significant.
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4.7 Greenhouse Gas Emissions
This section describes the existing greenhouse gas conditions of The Farm in Poway project (proposed project)
site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies
mitigation measures related to implementation of the proposed project. The analysis is based on the review of
existing conditions; technical data; applicable laws, regulations, and guidelines; and the air quality and
greenhouse gas technical report prepared by Dudek in January 2020. The Air Quality and Greenhouse Gas
Emissions Analysis Technical Report for The Farm in Poway is included in this Environmental Impact Report
(EIR) as Appendix B.
A Notice of Preparation (NOP) was circulated from May 10, 2019, to June 10, 2019. During the NOP comment
period, comment letters related to greenhouse gas (GHG) emissions focused on the following topics:
Vehicle-related emissions
These comments were considered during the preparation of this EIR. The Initial Study, NOP, and Public Scoping
comments are provided in Appendix A of this EIR.
4.7.1 Existing Conditions
Climate Change Overview
Climate change refers to any significant change in measures of climate—such as temperature, precipitation, or
wind patterns—lasting for an extended period of time (decades or longer). The Earth’s temperature depends on
the balance between energy entering and leaving the planet’s system. Many factors, both natural and human, can
cause changes in Earth’s energy balance, including variations in the Sun’s energy reaching Earth, changes in the
reflectivity of Earth’s atmosphere and surface, and changes in the greenhouse effect, which affects the amount of
heat retained by Earth’s atmosphere (EPA 2017).
The greenhouse effect is the trapping and build-up of heat in the atmosphere (troposphere) near the Earth’s
surface. The greenhouse effect traps heat in the troposphere through a threefold process as follows: short-wave
radiation emitted by the Sun is absorbed by the Earth; the Earth emits a portion of this energy in the form of long-
wave radiation; and GHGs in the upper atmosphere absorb this long-wave radiation and emit it into space and
toward the Earth. The greenhouse effect is a natural process that contributes to regulating the Earth’s
temperature and creates a pleasant, livable environment on Earth. Human activities that emit additional GHGs to
the atmosphere increase the amount of infrared radiation that gets absorbed before escaping into space, thus
enhancing the greenhouse effect and causing the Earth’s surface temperature to rise.
The scientific record of the Earth’s climate shows that the climate system varies naturally over a wide range of time
scales and that, in general, climate changes prior to the Industrial Revolution in the 1700s can be explained by
natural causes, such as changes in solar energy, volcanic eruptions, and natural changes in GHG concentrations.
Recent climate changes, in particular the warming observed over the past century, however, cannot be explained by
natural causes alone. Rather, it is extremely likely that human activities have been the dominant cause of that
warming since the mid-20th century and is the most significant driver of observed climate change (EPA 2017; IPCC
2013). Human influence on the climate system is evident from the increasing GHG concentrations in the
atmosphere, positive radiative forcing, observed warming, and improved understanding of the climate system (IPCC
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2013). The atmospheric concentrations of GHGs have increased to levels unprecedented in the last 800,000 years,
primarily from fossil fuel emissions and secondarily from emissions associated with land use changes (IPCC 2013).
Continued emissions of GHGs will cause further warming and changes in all components of the climate system (as
discussed further in Section 3.3.2, Potential Effects of Climate Change, in Appendix B).
Greenhouse Gases
A GHG is any gas that absorbs infrared radiation in the atmosphere; in other words, GHGs trap heat in the
atmosphere. GHGs include, but are not limited to, CO2, CH4, nitrous oxide (N2O), O3, water vapor,
hydrofluorocarbons (HFCs), hydrochlorofluorocarbons (HCFCs), perfluorocarbons (PFCs), and sulfur hexafluoride
(SF6).1 Some GHGs—such as CO2, CH4, and N2O—occur naturally and are emitted to the atmosphere through
natural processes and human activities. Of these gases, CO2 and CH4 are emitted in the greatest quantities from
human activities. Manufactured GHGs, which have a much greater heat-absorption potential than CO2, include
fluorinated gases (e.g., HFCs, HCFCs, PFCs, and SF6), which are associated with certain industrial products and
processes. A summary of the most common GHGs and their sources is included in the following text.2 Also
included is a discussion of other climate-forcing substances.
Carbon Dioxide. CO2 is a naturally occurring gas and a by-product of human activities and is the principal
anthropogenic GHG that affects the Earth’s radiative balance. Natural sources of CO2 include respiration of
bacteria, plants, animals, and fungus; evaporation from oceans; volcanic out-gassing; and decomposition of dead
organic matter. Human activities that generate CO2 are from the combustion of fuels (e.g., coal, oil, natural gas,
and wood) and changes in land use.
Methane. CH4 is produced through both natural and human activities. CH4 is a flammable gas and is the main
component of natural gas. CH4 is produced through anaerobic (without oxygen) decomposition of waste in
landfills, flooded rice fields, animal digestion, decomposition of animal wastes, production and distribution of
natural gas and petroleum, coal production, and incomplete fossil fuel combustion.
Nitrous Oxide. N2O is produced through natural and human activities, mainly through agricultural activities and
natural biological processes, although fuel burning and other processes also create N2O. Sources of N2O include soil
cultivation practices (microbial processes in soil and water), especially the use of commercial and organic fertilizers;
manure management; industrial processes, such as in nitric acid production, nylon production, and fossil-fuel-fired
power plants; vehicle emissions; and using N2O as a propellant (such as in rockets, race cars, and aerosol sprays).
Fluorinated Gases. Fluorinated gases (also referred to as F-gases) are synthetic powerful GHGs emitted from many
industrial processes. Fluorinated gases are commonly used as substitutes for stratospheric O3-depleting substances
(e.g., chlorofluorocarbons, HCFCs, and halons). The most prevalent fluorinated gases include the following:
Hydrofluorocarbons: HFCs are compounds containing only hydrogen, fluorine, and carbon atoms. HFCs are
synthetic chemicals used as alternatives to O3-depleting substances in serving many industrial, commercial,
and personal needs. HFCs are emitted as byproducts of industrial processes and are used in manufacturing.
Perfluorocarbons: PFCs are a group of human-made chemicals composed of carbon and fluorine only.
These chemicals were introduced as alternatives, along with HFCs, to O3-depleting substances. The two
1 California Health and Safety Code 38505 identifies seven GHGs that CARB is responsible for monitoring and regulating to
reduce emissions: CO2, CH4, N2O, SF6, HFCs, PFCs, and nitrogen trifluoride.
2 The descriptions of GHGs are summarized from the Intergovernmental Panel on Climate Change Second Assessment Report
(IPCC 1995), IPCC Fourth Assessment Report (2007), CARB’s Glossary of Terms Used in GHG Inventories (CARB 2018), and the
EPA’s Glossary of Climate Change Terms (EPA 2016).
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main sources of PFCs are primary aluminum production and semiconductor manufacturing. Since PFCs
have stable molecular structures and do not break down through the chemical processes in the lower
atmosphere, these chemicals have long lifetimes, ranging between 10,000 and 50,000 years.
Sulfur Hexafluoride: SF6 is a colorless gas that is soluble in alcohol and ether and slightly soluble in water.
SF6 is used for insulation in electric power transmission and distribution equipment, semiconductor
manufacturing, the magnesium industry, and as a tracer gas for leak detection.
Nitrogen Trifluoride: Nitrogen trifluoride is used in the manufacture of a variety of electronics, including
semiconductors and flat panel displays.
Chlorofluorocarbons. Chlorofluorocarbons are synthetic chemicals that have been used as cleaning solvents,
refrigerants, and aerosol propellants. Chlorofluorocarbons are chemically unreactive in the lower atmosphere
(troposphere), and the production of chlorofluorocarbons was prohibited in 1987 due to the chemical destruction
of stratospheric O3.
Hydrochlorofluorocarbons. HCFCs are a large group of compounds with a structure very close to that of
chlorofluorocarbons—containing hydrogen, fluorine, chlorine, and carbon atoms—but including one or more hydrogen
atoms. Like HFCs, HCFCs are used in refrigerants and propellants. HCFCs were also used in place of
chlorofluorocarbons for some applications; however, their use in general is being phased out.
Black Carbon. Black carbon is a component of fine particulate matter (PM2.5), which has been identified as a
leading environmental risk factor for premature death. It is produced from the incomplete combustion of fossil
fuels and biomass burning, particularly from older diesel engines and forest fires. Black carbon warms the
atmosphere by absorbing solar radiation, influences cloud formation, and darkens the surface of snow and ice,
which accelerates heat absorption and melting. Black carbon is short lived and varies spatially, which makes it
difficult to quantify its global warming potential (GWP). DPM emissions are a major source of black carbon and
are TACs that have been regulated and controlled in California for several decades to protect public health. In
relation to declining DPM from CARB’s regulations pertaining to diesel engines, diesel fuels, and burning
activities, CARB estimates that annual black carbon emissions in California have reduced by 70 percent between
1990 and 2010, with 95 percent control expected by 2020 (CARB 2014a).
Water Vapor. The primary source of water vapor is evaporation from the ocean, with additional vapor generated by
sublimation (change from solid to gas) from ice and snow, evaporation from other water bodies, and transpiration
from plant leaves. Water vapor is the most important, abundant, and variable GHG in the atmosphere and
maintains a climate necessary for life.
Ozone. Tropospheric O3, which is created by photochemical reactions involving gases from both natural sources and
human activities, acts as a GHG. Stratospheric O3, which is created by the interaction between solar ultraviolet
radiation and molecular oxygen, plays a decisive role in the stratospheric radiative balance. Depletion of stratospheric
O3, due to chemical reactions that may be enhanced by climate change, results in an increased ground-level flux of
ultraviolet-B radiation.
Aerosols. Aerosols are suspensions of particulate matter in a gas emitted into the air through burning biomass
(plant material) and fossil fuels. Aerosols can warm the atmosphere by absorbing and emitting heat and can cool
the atmosphere by reflecting light.
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Global Warming Potential
Gases in the atmosphere can contribute to climate change both directly and indirectly. Direct effects occur when
the gas itself absorbs radiation. Indirect radiative forcing occurs when chemical transformations of the substance
produce other GHGs, when a gas influences the atmospheric lifetimes of other gases, and/or when a gas affects
atmospheric processes that alter the radiative balance of the Earth (e.g., affect cloud formation or albedo) (EPA
2016). The Intergovernmental Panel on Climate Change (IPCC) developed the GWP concept to compare the ability
of each GHG to trap heat in the atmosphere relative to another gas. The GWP of a GHG is defined as the ratio of
the time-integrated radiative forcing from the instantaneous release of one kilogram of a trace substance relative
to that of one kilogram of a reference gas (IPCC 2014). The reference gas used is CO2; therefore, GWP-weighted
emissions are measured in metric tons (MT) of carbon dioxide equivalent (CO2e).
The current version of CalEEMod (Version 2016.3.2) assumes that the GWP for CH4 is 25 (so emissions of
one MT of CH4 are equivalent to emissions of 25 MT of CO2), and the GWP for N2O is 298, based on the IPCC
Fourth Assessment Report (IPCC 2007). The GWP values identified in CalEEMod were applied to the
proposed project.
4.7.2 Relevant Plans, Policies, and Ordinances
Federal
Massachusetts v. U.S. Environmental Protection Agency
In Massachusetts v. EPA (April 2007), the U.S. Supreme Court directed the U.S. Environmental Protection Agency
(EPA) administrator to determine whether GHG emissions from new motor vehicles cause or contribute to air
pollution that may reasonably be anticipated to endanger public health or welfare, or whether the science is too
uncertain to make a reasoned decision. In December 2009, the administrator signed a final rule with the
following two distinct findings regarding GHGs under Section 202(a) of the CAA:
The administrator found that elevated concentrations of GHGs—CO2, CH4, N2O, HFCs, PFCs, and SF6—in
the atmosphere threaten the public health and welfare of current and future generations. This is the
“endangerment finding.”
The administrator further found the combined emissions of GHGs—CO2, CH4, N2O, and HFCs—from new
motor vehicles and new motor vehicle engines contribute to the GHG air pollution that endangers
public health and welfare. This is the “cause or contribute finding.”
These two findings were necessary to establish the foundation for regulation of GHGs from new motor vehicles as
air pollutants under the CAA.
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Energy Independence and Security Act
The Energy Independence and Security Act of 2007 (December 2007), among other key measures, would do the
following, which would aid in the reduction of national GHG emissions (EPA 2007):
Increase the supply of alternative fuel sources by setting a mandatory Renewable Fuel Standard requiring
fuel producers to use at least 36 billion gallons of biofuel in 2022.
Set a target of 35 miles per gallon for the combined fleet of cars and light trucks by model year 2020 and
direct National Highway Traffic Safety Administration (NHTSA) to establish a fuel economy program for
medium- and heavy-duty trucks and create a separate fuel economy standard for work trucks.
Prescribe or revise standards affecting regional efficiency for heating and cooling products and
procedures for new or amended standards, energy conservation, energy efficiency labeling for consumer
electronic products, residential boiler efficiency, electric motor efficiency, and home appliances.
Federal Vehicle Standards
In response to the Massachusetts v. EPA ruling, the Bush Administration issued Executive Order (EO) 13432 in
2007 directing the EPA, the Department of Transportation, and the Department of Energy to establish regulations
that reduce GHG emissions from motor vehicles, non-road vehicles, and non-road engines by 2008. In 2009, the
NHTSA issued a final rule regulating fuel efficiency and GHG emissions from cars and light-duty trucks for model
year 2011. In 2010, the EPA and NHTSA issued a final rule regulating cars and light-duty trucks for model years
2012 through 2016 (75 FR 25324–25728).
In 2010, President Obama issued a memorandum directing the Department of Transportation, Department of
Energy, EPA, and NHTSA to establish additional standards regarding fuel efficiency and GHG reduction, clean
fuels, and advanced vehicle infrastructure. In response to this directive, the EPA and NHTSA proposed stringent,
coordinated federal GHG and fuel economy standards for model years 2017 through 2025 light-duty vehicles. The
proposed standards projected to achieve 163 grams/mile of CO2 in model year 2025, on an average industry
fleet-wide basis, which is equivalent to 54.5 miles per gallon if this level were achieved solely through fuel
efficiency. The final rule was adopted in 2012 for model years 2017 through 2021 (77 FR 62624–63200), and
NHTSA intends to set standards for model years 2022 through 2025 in a future rulemaking.
In addition to the regulations applicable to cars and light-duty trucks described above, in 2011, the EPA and
NHTSA announced fuel economy and GHG standards for medium- and heavy-duty trucks for model years 2014
through 2018. The standards for CO2 emissions and fuel consumption are tailored to three main vehicle
categories: combination tractors, heavy-duty pickup trucks and vans, and vocational vehicles. According to the
EPA, this regulatory program will reduce GHG emissions and fuel consumption for the affected vehicles by six
percent to 23 percent over the 2010 baselines (76 FR 57106–57513).
In August 2016, the EPA and NHTSA announced the adoption of the phase two program related to the fuel
economy and GHG standards for medium- and heavy-duty trucks. The phase two program will apply to vehicles
with model year 2018 through 2027 for certain trailers and model years 2021 through 2027 for semi-trucks,
large pickup trucks, vans, and all types of sizes of buses and work trucks. The final standards are expected to
lower CO2 emissions by approximately 1.1 billion MT and reduce oil consumption by up to two billion barrels over
the lifetime of the vehicles sold under the program (EPA and NHTSA 2016).
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The Current Administration
President Trump and the EPA have stated their intent to halt various federal regulatory activities to reduce GHG
emission. California and other states have stated their intent to challenge federal actions that would delay or
eliminate GHG reduction measures and have committed to cooperating with other countries to implement global
climate change initiatives. The timing and consequences of these types of federal decisions and potential
responses from California and other states are speculative at this time.
State
The statewide GHG emissions regulatory framework is summarized below by category: state climate change
targets, building energy, renewable energy and energy procurement, mobile sources, solid waste, water, and other
state regulations and goals. The following text describes executive orders, legislation, regulations, and other plans
and policies that would directly or indirectly reduce GHG emissions and/or address climate change issues.
State Climate Change Targets
Executive Order S-3-05
EO S-3-05 (June 2005) established the following statewide goals: GHG emissions should be reduced to 2000
levels by 2010, GHG emissions should be reduced to 1990 levels by 2020, and GHG emissions should be
reduced to 80 percent below 1990 levels by 2050.
Assembly Bill 32 and CARB’s Climate Change Scoping Plan
In furtherance of the goals established in EO S-3-05, the Legislature enacted AB 32, the California Global
Warming Solutions Act of 2006. AB 32 requires California to reduce its GHG emissions to 1990 levels by 2020.
Under AB 32, CARB is responsible for and is recognized as having the expertise to carry out and develop the
programs and requirements necessary to achieve the GHG emissions reduction mandate of AB 32. Under AB
32, CARB must adopt regulations requiring the reporting and verification of statewide GHG emissions from
specified sources. This program is used to monitor and enforce compliance with established standards. CARB
also is required to adopt rules and regulations to achieve the maximum technologically feasible and cost-
effective GHG emission reductions. AB 32 relatedly authorized CARB to adopt market-based compliance
mechanisms to meet the specified requirements. Finally, CARB is ultimately responsible for monitoring
compliance and enforcing any rule, regulation, order, emission limitation, emission reduction measure, or
market-based compliance mechanism adopted.
In 2007, CARB approved a limit on the statewide GHG emissions level for year 2020 consistent with the
determined 1990 baseline (427 million metric tons [MMT] CO2e). CARB’s adoption of this limit is in accordance
with Health and Safety Code, Section 38550.
Further, in 2008, CARB adopted the Climate Change Scoping Plan: A Framework for Change (Scoping Plan) in
accordance with Health and Safety Code, Section 38561. The Scoping Plan establishes an overall framework for
the measures that would be adopted to reduce California’s GHG emissions for various emission sources/sectors
to 1990 levels by 2020 (CARB 2008). The Scoping Plan evaluates opportunities for sector-specific reductions,
integrates all CARB and Climate Action Team early actions and additional GHG reduction features by both entities,
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identifies additional measures to be pursued as regulations, and outlines the role of a cap-and-trade program.
The key elements of the Scoping Plan include the following (CARB 2008):
Expanding and strengthening existing energy efficiency programs as well as building and appliance standards.
Achieving a statewide renewable energy mix of 33 percent.
Developing a California cap-and-trade program that links with other Western Climate Initiative partner
programs to create a regional market system and caps sources contributing 85 percent of California’s
GHG emissions.
Establishing targets for transportation-related GHG emissions for regions throughout California and
pursuing policies and incentives to achieve those targets.
Adopting and implementing measures pursuant to existing state laws and policies, including California’s
clean car standards, goods movement measures, and the Low Carbon Fuel Standard.
Creating targeted fees, including a public goods charge on water use, fees on high GWP gases, and a fee to
fund the administrative costs of the State of California’s long-term commitment to AB 32 implementation.
In the Scoping Plan, CARB determined that achieving the 1990 emissions level in 2020 would require a reduction
in GHG emissions of approximately 29 percent from the otherwise projected 2020 emissions level (i.e., those
emissions that would occur in 2020, absent GHG-reducing laws and regulations [referred to as “business-as-
usual”]). For purposes of calculating this percent reduction, CARB assumed that all new electricity generation
would be supplied by natural gas plants, no further regulatory action would impact vehicle fuel efficiency, and
building energy efficiency codes would be held at 2005 standards.
In the 2011 Final Supplement to the Scoping Plan’s Functional Equivalent Document (Final Supplement), CARB
revised its estimates of the projected 2020 emissions level in light of the economic recession and the availability
of updated information about GHG-reduction regulations. Based on the new economic data, CARB determined
that achieving the 1990 emissions level by 2020 would require a reduction in GHG emissions of 22 percent
(down from 29 percent) from the business-as-usual conditions. When the 2020 emissions level projection was
updated to account for newly implemented regulatory measures, including Pavley I (model years 2009 through
2016) and the Renewables Portfolio Standard (RPS) (12 percent to 20 percent), CARB determined that achieving
the 1990 emissions level in 2020 would require a reduction in GHG emissions of 16 percent (down from 29
percent) from the business-as-usual conditions.
In 2014, CARB adopted the First Update to the Climate Change Scoping Plan: Building on the Framework (First
Update). The stated purpose of the First Update is to “highlight California’s success to date in reducing its GHG
emissions and lay the foundation for establishing a broad framework for continued emission reductions beyond 2020,
on the path to 80 percent below 1990 levels by 2050” (CARB 2014b). The First Update found that California is on
track to meet the 2020 emissions reduction mandate established by AB 32, and noted that California could reduce
emissions further by 2030 to levels squarely in line with those needed to stay on track to reduce emissions to 80
percent below 1990 levels by 2050 if the state realizes the expected benefits of existing policy goals.
In conjunction with the First Update, CARB identified “six key focus areas comprising major components of the
state’s economy to evaluate and describe the larger transformative actions that will be needed to meet the
state’s more expansive emission reduction needs by 2050.” Those six areas are energy, transportation (e.g.,
vehicles/equipment, sustainable communities, housing, fuels, infrastructure), agriculture, water, waste
management, and natural and working lands. The First Update identifies key recommended actions for each
sector that will facilitate achievement of EO S-3-05’s 2050 reduction goal (CARB 2014b).
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Based on CARB’s research efforts presented in the First Update, it has a “strong sense of the mix of technologies
needed to reduce emissions through 2050.” Those technologies include energy demand reduction through
efficiency and activity changes; large-scale electrification of on-road vehicles, buildings, and industrial machinery;
decarbonizing electricity and fuel supplies; and the rapid market penetration of efficient and clean energy
technologies (CARB 2014b).
As part of the First Update, CARB recalculated the state’s 1990 emissions level using more recent GWPs
identified by the IPCC. Using the recalculated 1990 emissions level (431 MMT CO2e) and the revised 2020
emissions level projection identified in the 2011 Final Supplement, CARB determined that achieving the 1990
emissions level by 2020 would require a reduction in GHG emissions of approximately 15 percent (instead of 29
percent or 16 percent) from the business-as-usual conditions (CARB 2014b).
On January 20, 2017, CARB released The 2017 Climate Change Scoping Plan Update (Second Update) for
public review and comment (CARB 2017). This update proposes CARB’s strategy for achieving the state’s 2030
GHG target as established in SB 32 (discussed below), including continuing the Cap-and-Trade Program
through 2030. The Second Update incorporates approaches to cutting short-lived climate pollutants (SLCPs)
under the Short-Lived Climate Pollutant Reduction Strategy (a planning document adopted by CARB in March
2017), and acknowledges the need for reducing emissions in agriculture and highlights the work underway to
ensure that California’s natural and working lands increasingly sequester carbon. During development of the
Second Update, CARB held a number of public workshops in the Natural and Working Lands, Agriculture,
Energy, and Transportation sectors to inform development of the 2030 Scoping Plan Update (CARB 2017).
When discussing project-level GHG emissions-reduction actions and thresholds, the Second Update states,
“Achieving net zero increases in GHG emissions, resulting in no contribution to GHG impacts, may not be
feasible or appropriate for every project, however, and the inability of a project to mitigate its GHG emissions to
net zero does not imply the project results in a substantial contribution to the cumulatively significant
environmental impact of climate change under CEQA” (CARB 2017). The Second Update was approved by
CARB’s Governing Board on December 14, 2017.
EO B-30-15
EO B-30-15 (April 2015) identified an interim GHG reduction target in support of targets previously identified
under EO S-3-05 and AB 32. EO B-30-15 set an interim target goal of reducing statewide GHG emissions to 40
percent below 1990 levels by 2030 to keep California on its trajectory toward meeting or exceeding the long-term
goal of reducing statewide GHG emissions to 80 percent below 1990 levels by 2050, as set forth in EO S-3-05. To
facilitate achievement of this goal, EO B-30-15 calls for an update to CARB’s Scoping Plan to express the 2030
target in terms of MMT CO2e. The EO also calls for state agencies to continue to develop and implement GHG
emission reduction programs in support of the reduction targets. EO B-30-15 does not require local agencies to
take any action to meet the new interim GHG reduction target.
SB 32 and AB 197
SB 32 and AB 197 (enacted in 2016) are companion bills that set a new statewide GHG reduction targets; make
changes to CARB’s membership and increase legislative oversight of CARB’s climate change-based activities; and
expand dissemination of GHG and other air-quality-related emissions data to enhance transparency and
accountability. More specifically, SB 32 codified the 2030 emissions reduction goal of EO B-30-15 by requiring
CARB to ensure that statewide GHG emissions are reduced to 40 percent below 1990 levels by 2030. AB 197
established the Joint Legislative Committee on Climate Change Policies, consisting of at least three members of
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the Senate and three members of the Assembly, in order to provide ongoing oversight over implementation of the
state’s climate policies. AB 197 also adds two members of the Legislature to CARB as nonvoting members;
requires CARB to make available and update (at least annually through its website) emissions data for GHGs,
criteria air pollutants, and TACs from reporting facilities; and requires CARB to identify specific information for
GHG emissions-reduction measures when updating the Scoping Plan.
SB 605 and SB 1383
SB 605 (2014) requires CARB to complete a comprehensive strategy to reduce emissions of SLCPs in the state;
SB 1383 (2016) requires CARB to approve and implement the Short-Lived Climate Pollutant Reduction Strategy
(SLCP Reduction Strategy). SB 1383 also establishes specific targets for the reduction of SLCPs (40 percent
below 2013 levels by 2030 for CH4 and HFCs, and 50 percent below 2013 levels by 2030 for anthropogenic
black carbon), and provides direction for reductions from dairy and livestock operations and landfills. Accordingly,
and as mentioned above, CARB adopted its SLCP Reduction Strategy in March 2017, which establishes a
framework for the statewide reduction of emissions of black carbon, CH4, and fluorinated gases.
EO B-55-18
EO B-55-18 (September 2018) establishes a new statewide goal “to achieve carbon neutrality as soon as
possible, and no later than 2045, and achieve and maintain net negative emissions thereafter.” This executive
order directs CARB to “work with relevant state agencies to ensure future Scoping Plans identify and recommend
measures to achieve the carbon neutrality goal.”
Building Energy
Title 24, Part 6 of the California Code of Regulations
Title 24 of the California Code of Regulations was established in 1978 and serves to enhance and regulate
California’s building standards. While not initially promulgated to reduce GHG emissions, Part 6 of Title 24
specifically establishes Building Energy Efficiency Standards that are designed to ensure new and existing
buildings in California achieve energy efficiency and preserve outdoor and indoor environmental quality. These
energy efficiency standards are reviewed every few years by the Building Standards Commission and the
California Energy Commission (CEC) (and revised if necessary) (California Public Resources Code, Section
25402[b][1]). The regulations receive input from members of industry, as well as the public, with the goal of
“reducing of wasteful, uneconomic, inefficient, or unnecessary consumption of energy” (California Public
Resources Code, Section 25402). These regulations are carefully scrutinized and analyzed for technological and
economic feasibility (California Public Resources Code, Section 25402[d]), and cost effectiveness (California
Public Resources Code, Sections 25402[b][2] and [b][3]). These standards are updated to consider and
incorporate new energy efficient technologies and construction methods. As a result, these standards save
energy, increase electricity supply reliability, increase indoor comfort, avoid the need to construct new power
plants, and help preserve the environment. The 2016 Title 24 standards are the current applicable building
energy efficiency standards, and became effective on January 1, 2017. The 2019 standards will continue to
improve upon the 2016 standards for new construction of, and additions and alterations to, residential and
nonresidential buildings. The 2019 standards will go into effect on January 1, 2020.
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Title 24, Part 11 of the California Code of Regulations
In addition to the CEC’s efforts, in 2008, the California Building Standards Commission adopted the nation’s first
green building standards. The California Green Building Standards Code (24 CCR 11) is commonly referred to as
CALGreen, and establishes minimum mandatory standards as well as voluntary standards pertaining to the
planning and design of sustainable site development, energy efficiency (in excess of the California Energy Code
requirements), water conservation, material conservation, and interior air quality. The CALGreen standards took
effect in January 2011 and instituted mandatory minimum environmental performance standards for all ground-
up, new construction of commercial, low-rise residential, and state-owned buildings, schools, and hospitals. The
CALGreen 2016 standards became effective on January 1, 2017. The CALGreen 2019 standards will go into
effect on January 1, 2020, and will continue to improve upon the 2016 CALGreen standards for new construction
of, and additions and alterations to, residential and nonresidential buildings.
Title 20 of the California Code of Regulations
Title 20 of the California Code of Regulations requires manufacturers of appliances to meet state and federal
standards for energy and water efficiency. Performance of appliances must be certified through the CEC to
demonstrate compliance with standards. New appliances regulated under Title 20 include refrigerators,
refrigerator-freezers, and freezers; room air conditioners and room air-conditioning heat pumps; central air
conditioners; spot air conditioners; vented gas space heaters; gas pool heaters; plumbing fittings and plumbing
fixtures; fluorescent lamp ballasts; lamps; emergency lighting; traffic signal modules; dishwashers; clothes
washers and dryers; cooking products; electric motors; low voltage dry-type distribution transformers; power
supplies; televisions and consumer audio and video equipment; and battery charger systems. Title 20 presents
protocols for testing for each type of appliance covered under the regulations, and appliances must meet the
standards for energy performance, energy design, water performance and water design. Title 20 contains three
types of standards for appliances: federal and state standards for federally regulated appliances, state standards
for federally regulated appliances, and state standards for non-federally regulated appliances.
AB 1109
Enacted in 2007, AB 1109 required the CEC to adopt minimum energy efficiency standards for general purpose
lighting to reduce electricity consumption 50 percent for indoor residential lighting and 25 percent for indoor
commercial lighting.
Renewable Energy and Energy Procurement
SB 1078
SB 1078 (2002) established the RPS program, which requires an annual increase in renewable generation by the
utilities equivalent to at least one percent of sales, with an aggregate goal of 20 percent by 2017. This goal was
subsequently accelerated, requiring utilities to obtain 20 percent of their power from renewable sources by 2010.
SB 1368
SB 1368 (2006) requires the CEC to develop and adopt regulations for GHG emission performance standards for
the long-term procurement of electricity by local publicly owned utilities. These standards must be consistent with
the standards adopted by the California Public Utilities Commission. This effort will help protect energy customers
from financial risks associated with investments in carbon-intensive generation by allowing new capital
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investments in power plants whose GHG emissions are as low as or lower than new combined-cycle natural gas
plants by requiring imported electricity to meet GHG performance standards in California and by requiring that the
standards be developed and adopted in a public process.
SB X1 2
SB X1 2 (2011) expanded the RPS by establishing that 20 percent of the total electricity sold to retail customers
in California per year by December 31, 2013, and 33 percent by December 31, 2020, and in subsequent years
be secured from qualifying renewable energy sources. Under the bill, a renewable electrical generation facility is
one that uses biomass, solar thermal, photovoltaic, wind, geothermal, fuel cells using renewable fuels, small
hydroelectric generation of 30 megawatts or less, digester gas, municipal solid waste conversion, landfill gas,
ocean wave, ocean thermal, or tidal current, and that meets other specified requirements with respect to its
location. In addition to the retail sellers previously covered by the RPS, SB X1 2 added local, publicly owned
electric utilities to the RPS.
SB 350
SB 350 (2015) further expanded the RPS by establishing that 50 percent of the total electricity sold to retail
customers in California per year by December 31, 2030, be secured from qualifying renewable energy sources. In
addition, SB 350 includes the goal to double the energy efficiency savings in electricity and natural gas final end
uses (such as heating, cooling, lighting, or class of energy uses on which an energy efficiency program is focused)
of retail customers through energy conservation and efficiency. The bill also requires the California Public Utilities
Commission, in consultation with the CEC, to establish efficiency targets for electrical and gas corporations
consistent with this goal.
SB 100
SB 100 (2018) increased the standards set forth in SB 350 establishing that 44 percent of the total electricity
sold to retail customers in California per year by December 31, 2024, 52 percent by December 31, 2027, and 60
percent by December 31, 2030 be secured from qualifying renewable energy sources. SB 100 states that it is the
policy of the State that eligible renewable energy resources and zero-carbon resources supply 100 percent of the
retail sales of electricity to California. This bill requires that the achievement of 100 percent zero-carbon electricity
resources do not increase the carbon emissions elsewhere in the western grid and that the achievement not be
achieved through resource shuffling.
Mobile Sources
AB 1493
In a response to the transportation sector accounting for more than half of California’s CO2 emissions, AB 1493
was enacted in July 2002. AB 1493 required CARB to set GHG emission standards for passenger vehicles, light-
duty trucks, and other vehicles determined by the state board to be vehicles that are primarily used for
noncommercial personal transportation in the state. The bill required that CARB set GHG emission standards for
motor vehicles manufactured in 2009 and all subsequent model years. CARB adopted the standards in
September 2004. When fully phased in, the near-term (2009 through 2012) standards will result in a reduction of
about 22 percent in GHG emissions compared to the emissions from the 2002 fleet, and the mid-term (2013
through 2016) standards will result in a reduction of about 30 percent.
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EO S-1-07
Issued on January 18, 2007, EO S-1-07 sets a declining Low Carbon Fuel Standard for GHG emissions measured
in CO2e grams per unit of fuel energy sold in California. The target of the Low Carbon Fuel Standard is to reduce
the carbon intensity of California passenger vehicle fuels by at least 10 percent by 2020. The carbon intensity
measures the amount of GHG emissions in the lifecycle of a fuel, including extraction/feedstock production,
processing, transportation, and final consumption, per unit of energy delivered. CARB adopted the implementing
regulation in April 2009. The regulation is expected to increase the production of biofuels, including those from
alternative sources, such as algae, wood, and agricultural waste.
SB 375
SB 375 (2008) addresses GHG emissions associated with the transportation sector through regional transportation
and sustainability plans. SB 375 required CARB to adopt regional GHG reduction targets for the automobile and light-
truck sector for 2020 and 2035. Regional metropolitan planning organizations are then responsible for preparing an
SCS within their Regional Transportation Plan (RTP). The goal of the SCS is to establish a forecasted development
pattern for the region that, after considering transportation measures and policies, will achieve, if feasible, the GHG
reduction targets. If a SCS is unable to achieve the GHG reduction target, a metropolitan planning organization must
prepare an Alternative Planning Strategy demonstrating how the GHG reduction target would be achieved through
alternative development patterns, infrastructure, or additional transportation measures or policies.
Pursuant to Government Code, Section 65080(b)(2)(K), a SCS does not (i) regulate the use of land; (ii) supersede
the land use authority of cities and counties; or (iii) require that a city’s or county’s land use policies and
regulations, including those in a general plan, be consistent with it. Nonetheless, SB 375 makes regional and
local planning agencies responsible for developing those strategies as part of the federally required metropolitan
transportation planning process and the state-mandated housing element process.
In 2010, CARB adopted the SB 375 targets for the regional metropolitan planning organizations. The targets for
SANDAG are a seven percent reduction in emissions per capita by 2020 and a 13 percent reduction by 2035.
SANDAG completed and adopted its 2050 Regional Transportation Plan (2050 RTP/SCS) in October 2011
(SANDAG 2011). In November 2011, CARB, by resolution, accepted SANDAG’s GHG emissions quantification
analysis and determination that, if implemented, the 2050 RTP/SCS would achieve CARB’s 2020 and 2035 GHG
emissions-reduction targets for the region.
After SANDAG’s 2050 RTP/SCS was adopted, a lawsuit was filed by the Cleveland National Forest Foundation and
others. In July 2017, the California Supreme Court held that SANDAG’s EIR did not have to use EO S-3-05’s 2050 goal
of an 80-percent reduction in GHG emissions from 1990 levels as a threshold because the EIR sufficiently informed
the public of the potential impacts.
Although the EIR for SANDAG’s 2050 RTP/SCS was pending before the California Supreme Court, in 2015,
SANDAG adopted the next iteration of its RTP/SCS in accordance with statutorily mandated timelines, and no
subsequent litigation challenge was filed. More specifically, in October 2015, SANDAG adopted San Diego
Forward: The Regional Plan (Regional Plan). Like the 2050 RTP/SCS, the Regional Plan meets CARB’s 2020 and
2035 reduction targets for the region (SANDAG 2015). In December 2015, CARB, by resolution, accepted
SANDAG’s GHG emissions quantification analysis and determination that, if implemented, the Regional Plan
would achieve CARB’s 2020 and 2035 GHG emissions reduction targets for the region.
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Advanced Clean Cars Program
In January 2012, CARB approved the Advanced Clean Cars program, a new emissions-control program for model years
2015 through 2025. The program combines the control of smog- and soot-causing pollutants and GHG emissions into a
single coordinated package. The package includes elements to reduce smog-forming pollution, reduce GHG emissions,
promote clean cars, and provide the fuels for clean cars (CARB 2011). To improve air quality, CARB has implemented new
emission standards to reduce smog-forming emissions beginning with 2015 model year vehicles. It is estimated that in
2025 cars will emit 75 percent less smog-forming pollution than the average new car sold before 2012. To reduce GHG
emissions, CARB, in conjunction with the EPA and the NHTSA, has adopted new GHG standards for model year 2017 to
2025 vehicles; the new standards are estimated to reduce GHG emissions by 34 percent in 2025. The zero emissions
vehicle (ZEV) program will act as the focused technology of the Advanced Clean Cars program by requiring manufacturers
to produce increasing numbers of ZEVs and plug-in hybrid EVs in the 2018 to 2025 model years.
EO B-16-12
EO B-16-12 (2012) directs state entities under the Governor’s direction and control to support and facilitate
development and distribution ZEVs. This EO also sets a long-term target of reaching 1.5 million ZEVs on
California’s roadways by 2025. On a statewide basis, EO B-16-12 also establishes a GHG emissions-reduction
target from the transportation sector equaling 80 percent less than 1990 levels by 2050. In furtherance of this
EO, the Governor convened an Interagency Working Group on ZEVs that has published multiple reports regarding
the progress made on the penetration of ZEVs in the statewide vehicle fleet.
AB 1236
AB 1236 (2015) as enacted in California’s Planning and Zoning Law, requires local land use jurisdictions to
approve applications for the installation of electric vehicle (EV) charging stations, as defined, through the
issuance of specified permits unless there is substantial evidence in the record that the proposed installation
would have a specific, adverse impact upon the public health or safety, and there is no feasible method to
satisfactorily mitigate or avoid the specific, adverse impact. The bill provides for appeal of that decision to the
planning commission, as specified. AB 1236 requires local land use jurisdictions with a population of 200,000 or
more residents to adopt an ordinance, by September 30, 2016, which creates an expedited and streamlined
permitting process for EV charging stations, as specified. Prior to this statutory deadline, in August 2016, the
County Board of Supervisors adopted Ordinance No. 10437 (N.S.) adding a section to its County Code related to
the expedited processing of EV charging stations permits consistent with AB 1236.
SB 350
In 2015, SB 350—the Clean Energy and Pollution Reduction Act—was enacted into law. As one of its elements, SB
350 establishes a statewide policy for widespread electrification of the transportation sector, recognizing that
such electrification is required for achievement of the state’s 2030 and 2050 reduction targets (see Public
Utilities Code, Section 740.12).
EO B-48-18
EO B-48-18 (2018) launches an eight-year initiative to accelerate the sale of EVs through a mix of rebate programs
and infrastructure improvements. The order also sets a new EV target of five million EVs in California by 2030. EO B-
48-18 includes funding for multiple state agencies including the CEC to increase EV charging infrastructure and
CARB to provide rebates for the purchase of new EVs and purchase incentives for low-income customers.
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Solid Waste
AB 939 and AB 341
In 1989, AB 939, known as the Integrated Waste Management Act (Public Resources Code, Sections 40000 et
seq.), was passed because of the increase in waste stream and the decrease in landfill capacity. The statute
established the California Integrated Waste Management Board, which oversees a disposal reporting system. AB
939 mandated a reduction of waste being disposed where jurisdictions were required to meet diversion goals of
all solid waste through source reduction, recycling, and composting activities of 25 percent by 1995 and 50
percent by the year 2000.
AB 341 (2011) amended the California Integrated Waste Management Act of 1989 to include a provision
declaring that it is the policy goal of the state that not less than 75 percent of solid waste generated be source-
reduced, recycled, or composted by the year 2020, and annually thereafter. In addition, AB 341 required the
California Department of Resources Recycling and Recovery to develop strategies to achieve the state’s policy
goal. The California Department of Resources Recycling and Recovery has conducted multiple workshops and
published documents that identify priority strategies that it believes would assist the state in reaching the 75
percent goal by 2020 (CalRecycle 2015).
Water
EO B-29-15
In response to the ongoing drought in California, EO B-29-15 (April 2015) set a goal of achieving a statewide
reduction in potable urban water usage of 25 percent relative to water use in 2013. The term of the EO extended
through February 28, 2016, although many of the directives have since become permanent water-efficiency
standards and requirements. The EO includes specific directives that set strict limits on water usage in the state.
In response to EO B-29-15, the California Department of Water Resources has modified and adopted a revised
version of the Model Water Efficient Landscape Ordinance that, among other changes, significantly increases the
requirements for landscape water use efficiency and broadens its applicability to include new development
projects with smaller landscape areas.
Other State Regulations and Goals
SB 97
SB 97 (August 2007) directed the Governor’s Office of Planning and Research to develop guidelines under
CEQA for the mitigation of GHG emissions. In 2008, the Governor’s Office of Planning and Research issued a
technical advisory as interim guidance regarding the analysis of GHG emissions in CEQA documents. The
advisory indicated that the lead agency should identify and estimate a project’s GHG emissions, including those
associated with vehicular traffic, energy consumption, water usage, and construction activities (OPR 2008). The
advisory further recommended that the lead agency determine significance of the impacts and impose all
mitigation measures necessary to reduce GHG emissions to a level that is less than significant. The California
Natural Resources Agency (CNRA) adopted the CEQA Guidelines amendments in December 2009, which
became effective in March 2010.
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Under the amended CEQA Guidelines, a lead agency has the discretion to determine whether to use a
quantitative or qualitative analysis or apply performance standards to determine the significance of GHG
emissions resulting from a particular project (14 CCR 15064.4[a]). The CEQA Guidelines require a lead agency to
consider the extent to which a project complies with regulations or requirements adopted to implement a
statewide, regional, or local plan for the reduction or mitigation of GHG emissions (14 CCR 15064.4[b]). The CEQA
Guidelines also allow a lead agency to consider feasible means of mitigating the significant effects of GHG
emissions, including reductions in emissions through the implementation of project features or off-site measures.
The adopted amendments do not establish a GHG emission threshold, instead allowing a lead agency to develop,
adopt, and apply its own thresholds of significance or those developed by other agencies or experts. The CNRA
also acknowledges that a lead agency may consider compliance with regulations or requirements implementing
AB 32 in determining the significance of a project’s GHG emissions (CNRA 2009a).
With respect to GHG emissions, the CEQA Guidelines, Section 15064.4(a), state that lead agencies should “make
a good faith effort, to the extent possible on scientific and factual data, to describe, calculate or estimate” GHG
emissions. The CEQA Guidelines note that an agency may identify emissions by either selecting a “model or
methodology” to quantify the emissions or by relying on “qualitative analysis or other performance based
standards” (14 CCR 15064.4[a]). Section 15064.4(b) states that the lead agency should consider the following
when assessing the significance of impacts from GHG emissions on the environment: (1) the extent a project may
increase or reduce GHG emissions as compared to the existing environmental setting; (2) whether project
emissions exceed a threshold of significance that the lead agency determines applies to the project; and (3) the
extent to which a project complies with regulations or requirements adopted to implement a statewide, regional,
or local plan for the reduction or mitigation of GHG emissions (14 CCR 15064.4[b]).
EO S-13-08
EO S-13-08 (November 2008) is intended to hasten California’s response to the impacts of global climate change,
particularly sea-level rise. Therefore, the EO directs state agencies to take specified actions to assess and plan for
such impacts. The final 2009 California Climate Adaptation Strategy report was issued in December 2009 (CNRA
2009a), and an update, Safeguarding California: Reducing Climate Risk, followed in July 2014 (CNRA 2014). To
assess the state’s vulnerability, the report summarizes key climate change impacts to the state for the following
areas: agriculture, biodiversity and habitat, emergency management, energy, forestry, ocean and coastal
ecosystems and resources, public health, transportation, and water. Issuance of the Safeguarding California:
Implementation Action Plans followed in March 2016 (CNRA 2016). In January 2018, the CNRA released the
Safeguarding California Plan: 2018 Update, which communicates current and needed actions that state
government should take to build climate change resiliency (CNRA 2018).
Biological Diversity v. California Department of Fish and Wildlife
In its decision in Center for Biological Diversity v. California Department of Fish and Wildlife (Newhall) 62 Cal.4th
204 (2015), the California Supreme Court set forth several options that lead agencies may consider for
evaluating the cumulative significance of a proposed project’s GHG emissions:
1. A calculation of emissions reductions compared to a “business as usual” scenario based upon the
emissions reductions in CARB’s Scoping Plan, including examination of the data to determine what level
of reduction from business as usual a new land use development at the proposed location must
contribute in order to comply with statewide goals.
2. A lead agency might assess consistency with AB 32’s goals by looking to compliance with regulatory
programs designed to reduce GHG emissions from particular activities.
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3. Use of geographically specific GHG emission reduction plans to provide a basis for tiering and
streamlining of project-level CEQA analysis.
4. A lead agency may rely on existing numerical thresholds of significance for GHG emissions, though use of
such thresholds is not required.
The Newhall decision specifically found that use of a numerical threshold is not required.
Local
San Diego Air Pollution Control District
The SDAPCD does not have established GHG rules, regulations, or policies.
Poway Comprehensive Plan: General Plan
The Poway Comprehensive Plan: General Plan (General Plan) (City of Poway 1991) includes air quality policies
that also have direct impacts to GHG emissions. For a complete list refer to the Poway Comprehensive Plan:
General Plan discussion in Section 4.2.2 Relevant Plans, Policies, and Ordinances.
4.7.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to greenhouse gases/climate change are based on
Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related
to greenhouse gas emissions would occur if the project would:
1. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on
the environment.
2. Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of
greenhouse gases.
The Appendix G thresholds for GHGs do not prescribe specific methodologies for performing an assessment, do
not establish specific thresholds of significance, and do not mandate specific mitigation measures. Rather, the
CEQA Guidelines emphasize the lead agency’s discretion to determine the appropriate methodologies and
thresholds of significance consistent with the manner in which other impact areas are handled in CEQA (CNRA
2009a). Additional guidance regarding assessment of GHG’s is discussed below.
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CEQA Guidelines
With respect to GHG emissions, the CEQA Guidelines Section 15064.4(a) states that lead agencies “shall make a
good-faith effort, based to the extent possible on scientific and factual data, to describe, calculate or estimate”
GHG emissions resulting from a project. The CEQA Guidelines note that an agency has the discretion to either
quantify a project’s greenhouse gas emissions or rely on a “qualitative analysis or other performance based
standards” (14 CCR 15064.4[b]). A lead agency may use a “model or methodology” to estimate greenhouse gas
emissions and has the discretion to select the model or methodology it considers “most appropriate to enable
decision makers to intelligently take into account the project’s incremental contribution to climate change” (14
CCR 15064.4[c]). The CEQA Guidelines provide that the lead agency should consider the following when
determining the significance of impacts from GHG emissions on the environment (14 CCR 15064.4[b]):
1. The extent a project may increase or reduce GHG emissions as compared to the existing
environmental setting.
2. Whether the project emissions exceed a threshold of significance that the lead agency determines
applies to the project.
3. The extent to which the project complies with regulations or requirements adopted to implement a
statewide, regional, or local plan for the reduction or mitigation of GHG emissions.
In addition, the CEQA Guidelines specify that “[w]hen adopting or using thresholds of significance, a lead agency
may consider thresholds of significance previously adopted or recommended by other public agencies, or
recommended by experts, provided the decision of the lead agency to adopt such thresholds is supported by
substantial evidence” (14 CCR 15064.7[c]).
Governor’s Office of Planning and Research Guidance
The Governor’s Office of Planning and Research technical advisory titled, CEQA and Climate Change: Addressing
Climate Change through California Environmental Quality Act (CEQA) Review, states that “public agencies are
encouraged but not required to adopt thresholds of significance for environmental impacts. Even in the absence
of clearly defined thresholds for GHG emissions, the law requires that such emissions from CEQA projects must
be disclosed and mitigated to the extent feasible whenever the lead agency determines that the project
contributes to a significant, cumulative climate change impact” (OPR 2008). Furthermore, the advisory document
indicates that “in the absence of regulatory standards for GHG emissions or other scientific data to clearly define
what constitutes a ‘significant impact,’ individual lead agencies may undertake a project-by-project analysis,
consistent with available guidance and current CEQA practice” (OPR 2008).
Cumulative Nature of Climate Change
Global climate change is a cumulative impact; a project participates in this potential impact through its
incremental contribution combined with the cumulative increase of all other sources of GHGs. There are currently
no established thresholds for assessing whether the GHG emissions of a project in the San Diego Air Basin, such
as the proposed project, would be considered a cumulatively considerable contribution to global climate change;
however, all reasonable efforts should be made to minimize a project’s contribution to global climate change.
While the proposed project would result in emissions of GHGs during construction and operation, no guidance exists to
indicate what level of GHG emissions would be considered substantial enough to result in a significant adverse impact
on global climate. However, it is generally believed that an individual project is of insufficient magnitude by itself to
influence climate change or result in a substantial contribution to the global GHG inventory as scientific uncertainty
regarding the significance a project’s individual and cumulative effects on global climate change remains.
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Thus, GHG impacts are recognized as exclusively cumulative impacts; there are no non-cumulative GHG emission
impacts from a climate change perspective (CAPCOA 2008). This approach is consistent with that recommended
by the CNRA, which noted in its Public Notice for the proposed CEQA amendments (pursuant to SB97) that the
evidence before it indicates that in most cases, the impact of GHG emissions should be considered in the context
of a cumulative impact, rather than a project-level impact (CNRA 2009a). Similarly, the Final Statement of
Reasons for Regulatory Action on the CEQA Amendments confirm that an EIR or other environmental document
must analyze the incremental contribution of a project to GHG levels and determine whether those emissions are
cumulatively considerable (CNRA 2009b).
The analysis for compliance with regulatory programs only applies to the individual area addressed by the
regulatory program. If the proposed project is determined to have GHG emissions less than 900 MT CO2e per
year, then the project’s cumulative contribution of GHG emissions would be considered less than significant.
Conversely, if the proposed project is determined to exceed the 900 MT CO2e per year threshold, then the
project’s cumulative contribution of GHG emissions would be considered significant, and feasible mitigation
measures would be required.
A numerical bright-line value for City projects does not yet exist. Moreover, no bright-line threshold has been
formally adopted by an air district or other lead agencies for use in the San Diego region. The California Air
Pollution Control Officers Association (CAPCOA) recommended an interim 900 MT CO2e screening level as a
theoretical approach to identify projects that require further analysis and potential mitigation (CAPCOA 2008). The
900 MT CO2e per year screening threshold was developed by CAPCOA based on data collection on various
development applications submitted among four diverse cities, including the Cities of Los Angeles, Pleasanton,
Dublin, and Livermore. Following the review of numerous pending applications within these four cities, an
analysis was conducted to determine the threshold that would capture 90 percent or more of applications that
would be required to conduct a full GHG analysis and implement GHG emission-reduction measures as part of
final project design. Following CAPCOA’s analysis of development applications in various cities, it was
determined that the threshold of 900 MT CO2e per year would achieve the objective of 90 percent capture and
ensure that new development projects would keep the State of California on track to meet the goals of AB 32.
This 900 MT CO2e screening level threshold is considered appropriate for small maritime projects or other land
use types, but was not devised to include emissions associated with the larger goods movement (e.g.,
oceangoing vessels, freight rail) projects or larger industrial processes that are typically associated with marine
terminals. Consequently, the interim screening level recommended by CAPCOA would be appropriate for the
proposed project. The 900 MT CO2e threshold is applied to evaluate whether the project would generate GHG
emissions, either directly or indirectly, that may have a significant impact on the environment.
Lead agencies can set thresholds on a project-by-project basis, or they can informally or formally adopt thresholds to be
consistently applied to all projects (OPR 2008). For the lead agency, having clearly established thresholds promotes
predictability and consistency (over time and across reviewers) in the environmental review process, can bolster the
defensibility of significance determinations in the lead agency’s documents, and can focus the analysis on impacts
expected to be significant rather than impacts that are simply controversial (AEP 2016). However, CEQA does not
require that a lead agency use the same significance threshold for different CEQA documents (AEP 2016).
Lead agencies are encouraged in the CEQA Guidelines (14 CCR 15064.7[a]) to develop and formally adopt
thresholds of significance, though most do not do so (AEP 2016). Thresholds established for general use by a
lead agency must be adopted by ordinance, resolution, rule, or regulation; be subjected to public review; and be
supported by substantial evidence (CEQA Guidelines Section 15064.7[b]). Thresholds used only for a specific
project are not required to be adopted by ordinance or other formal means (AEP 2016).
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Thresholds of significance must be backed by substantial evidence, which is defined in the CEQA statute to mean
“facts, reasonable assumptions predicated on facts, and expert opinion supported by facts” (14 CCR 15384[b]).3
Substantial evidence can be in the form of technical studies, agency staff reports or opinions, expert opinions
supported by facts, and prior CEQA assessments and planning documents. The 900 MT CO2E per year threshold
is supported by expert opinion (i.e., CAPCOA 2008), agency guidance (e.g., County of San Diego 2015), and prior
environmental impact reports (e.g., San Diego Unified Port District 2016, at a minimum).
The significance of a project’s GHG emissions is evaluated consistent with CEQA Guidelines Section 15064.4(b)
by considering whether the project complies with applicable plans, policies, regulations, and requirements
adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions. As a
land use development project, the most directly applicable adopted regulatory plan to reduce the proposed
project’s GHG emissions is SANDAG’s Regional Plan, which is designed to achieve regional GHG reductions from
the land use and transportation sectors as required by SB 375 and the state’s long-term climate goals. This
analysis also considers consistency with regulations or requirements adopted by the 2008 Climate Change
Scoping Plan and subsequent updates.
4.7.4 Impacts Analysis
Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant
impact on the environment?
Construction Emissions
Construction of the proposed project would result in GHG emissions, which are primarily associated with use of
off-road construction equipment, on-road hauling and vendor (material delivery) trucks, and worker vehicles. GHG
emissions associated with temporary construction activity were quantified using CalEEMod. A detailed depiction
of the construction schedule—including information regarding phasing, equipment utilized during each phase,
haul trucks, vendor trucks, and worker vehicles—is included in Appendix B.
Table 4.7-1 shows the estimated annual GHG construction emissions associated with the proposed project, as well
as the amortized construction emissions over a 30-year project life.
Table 4.7-1. Estimated Annual Construction GHG Emissions
Year
CO2 CH4 N2O CO2e
Metric Tons per Year
2021 1,391.42 0.37 0.00 1,400.24
2022 2,583.76 0.24 0.00 2,589.82
2023 2,792.01 0.20 0.00 2,796.98
3 14 CCR 15384 provides the following discussion: "Substantial evidence" as used in the Guidelines is the same as the standard of
review used by courts in reviewing agency decisions. Some cases suggest that a higher standard, the so called "fair argument
standard" applies when a court is reviewing an agency's decision whether or not to prepare an EIR. Public Resources Code section
21082.2 was amended in 1993 (Chapter 1131) to provide that substantial evidence shall include "facts, reasonable assumptions
predicated upon facts, and expert opinion supported by facts." The statute further provides that "argument, speculation,
unsubstantiated opinion or narrative, evidence which is clearly inaccurate or erroneous, or evidence of social or economic impacts
which do not contribute to, or are not caused by, physical impacts on the environment, is not substantial evidence."
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Table 4.7-1. Estimated Annual Construction GHG Emissions
Year CO2 CH4 N2O CO2e
2024 2,763.04 0.20 0.00 2,767.94
Total 9,554.98
Amortized Emissions 318.50
Notes: GHG = greenhouse gas; CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent.
See Appendix B for complete results.
Total construction emissions for the proposed project were estimated to be approximately 9,555 MT CO2e.
Estimated amortized project-generated construction emissions over 30 years would be approximately 319 MT CO2e
per year. As with project-generated construction air quality pollutant emissions, GHG emissions generated during
construction of the proposed project would be short-term in nature, lasting only for the duration of the
construction period for each phase, and would not represent a long-term source of GHG emissions.
Operational Emissions
Operation of the proposed project would generate GHG emissions through motor vehicle trips to and from the
project site; landscape maintenance equipment operation; energy use (natural gas and generation of electricity
consumed by the proposed project); solid waste disposal; and generation of electricity associated with water
supply, treatment, and distribution, as well as wastewater treatment. CalEEMod was used to calculate the annual
GHG emissions based on the operational assumptions described in Section 3.4.2.2 of Appendix B.
Table 4.7-2 shows the estimated operational (year 2025) project-generated GHG emissions from area
sources, energy usage, motor vehicles, solid waste generation, and water usage and wastewater generation.
Table 4.7-2. Estimated Annual Operational GHG Emissions
Emission Source
CO2 CH4 N2O CO2e
Metric Tons per Year
Area 127.97 0.00 0.00 128.77
Energy 603.13 0.02 0.00 606.62
Mobile 2,592.31 0.13 0.00 2,595.48
Solid waste 65.61 3.88 0.00 162.54
Water supply and wastewater 410.14 0.12 0.07 433.07
Total 3,926.48
Amortized Construction Emissions 318.50
Operation + Amortized Construction Total 4,244.98
Notes: GHG = greenhouse gas; CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent.
See Appendix B for detailed results.
These emissions reflect California Emissions Estimator Model “mitigated” output and operational year 2025.
As shown in Table 4.7-2, estimated annual project-generated GHG emissions in 2025 would be approximately
3,926 MT CO2e per year as a result of proposed project operations. Estimated annual project-generated
emissions in 2025 from area, energy, mobile, solid waste, and water/wastewater sources and amortized project-
generated construction emissions would be approximately 4,245 MT CO2e per year.
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As discussed in Section 4.7.3, the significance threshold for the proposed project would be 900 MT CO2e per
year. Therefore, impacts would be potentially significant (Impact GHG-1) and mitigation would be required.
Would the project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the
emissions of greenhouse gases?
Consistency with SANDAG’s San Diego Forward: The Regional Plan
Regarding consistency with SANDAG’s Regional Plan, the proposed project would include site design elements and
project design features developed to support the policy objectives of the RTP and SB 375. For example, the proposed
project includes 60 acres of open space, including an integrated walking and bicycling trail system that would connect
the various components of the proposed project as well as off-site amenities (e.g., food, coffee shops, drug stores). In
addition, traffic calming measures on-site will enhance pedestrian experiences and widen the network of walkable
routes throughout the community. The convenient availability of walking and bicycling trails and parks that are
accessible for use by both nearby existing residents and new residents will serve to reduce VMT. Finally, because this
proposed project is an infill project, it would have inherently less VMT than a project located at the outskirts of a city.
SANDAG’s Regional Plan is a regional growth-management strategy that targets per-capita GHG reduction from
passenger vehicles and light-duty trucks in the San Diego region. The Regional Plan will integrate land use and
transportation strategies to meet GHG emissions reduction targets that are forecasted to achieve the state’s
2035 and 2050 GHG reduction goals. The Regional Plan incorporates local land use projections and circulation
networks in city and county general plans. Typically, a project would be consistent with the Regional Plan if it does
not exceed the underlying growth assumptions within the Regional Plan.
Implementation of the proposed project would result in an increase in 160 residential units, as well as
recreational, agricultural, and commercial uses. SANDAG’s 2050 Regional Growth Forecast, adopted in October
2013, is the current growth forecast, and estimates that the City would have 16,855 units in 2020 and 17,685
units in 2035 (SANDAG 2013). This would equate to an additional 55 units per year from 2020 to 2035. The
proposed project is expected to bring 160 units to market in 2025. However, the units would be released to the
public in phases as they are constructed, resulting in an average of 40 units per year, which is within SANDAG’s
growth projection for housing. Therefore, the proposed project would not conflict with SANDAG’s regional
growth forecast for the City.
The Regional Plan includes the following daily VMT totals for the San Diego region as a whole: a daily 26 total
VMT per capita for the 2005 base year; a daily 21.83 total VMT per capita for the 2020 plan year; 20.48 total
VMT per capita for the 2035 plan year; and 19.9 total VMT per capita for the 2050 plan year. Linscott, Law &
Greenspan prepared the Transportation Impact Analysis for The Farm in Poway in January 2020, which evaluated
VMT for the proposed project and is provided in Appendix J. To analyze the consistency of the proposed project
with the Regional Plan for informational purposes, the proposed project’s total daily VMT was divided by the
proposed project’s service population to arrive at the per capita total daily VMT estimates. The total proposed
project net daily VMT in 2025 is estimated to be 20,089 (Appendix J). The service population (employees,
residents, and visitors) for the proposed project would be 1,057 (Appendix J). Therefore, the proposed project’s
total VMT per capita in 2025 would be 19.01, which would be less than the overall SANDAG region’s daily
20.48 total VMT per capita for the 2035 plan year and 19.9 daily total VMT per capita for the 2050 plan year.
Therefore, the proposed project would be consistent with the total VMT per capita, growth projections, and GHG
reductions assumed within the Regional Plan.
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Table 4.7-3 illustrates the proposed project’s consistency with all applicable goals and policies of SANDAG’s
Regional Plan (SANDAG 2015).
Table 4.7-3. San Diego Forward: The Regional Plan Consistency Analysis
Category Policy Objective or Strategy Consistency Analysis
The Regional Plan – Policy Objectives
Mobility Choices Provide safe, secure, healthy,
affordable, and convenient travel
choices between the places where
people live, work, and play.
Consistent. The proposed project incorporates
smart growth and sustainable design principles in
its development plan. More specifically, the
proposed project’s design and compact setting
facilitates a comprehensive, multi-modal
transportation network and puts more people in
areas that are more accessible to a range of
transportation options, including public transit. The
design and locational attributes of the proposed
project positively emphasize particular commuting
choices and convenient access to the rest of the
City and the region, which will reduce the number of
vehicle trips and overall VMT.
Mobility Choices Take advantage of new
technologies to make the
transportation system more
efficient and environmentally
friendly.
Consistent. The proposed project includes EV
charging stations to support EV adoption.
Additionally, the proposed project would not impair
SANDAG’s ability to employ new technologies to
make travel more reliable and convenient.
Habitat and Open Space
Preservation
Focus growth in areas that are
already urbanized, allowing the
region to set aside and restore
more open space in our less
developed areas.
Consistent. The proposed project would be located
close to major urban and employment centers. As
such, the proposed project proposes to develop future
housing opportunities in an infill location that
capitalizes on existing infrastructure rather than other
non-developed areas—including open space areas,
sensitive habitats, or areas otherwise constrained due
to topography, flooding, or other factors.
Habitat and Open Space
Preservation
Protect and restore our region’s
urban canyons, coastlines,
beaches, and water resources.
Not Applicable. The proposed project would not impair
the ability of SANDAG to protect and restore urban
canyons, coastlines, beaches, and water resources.
Regional Economic
Prosperity
Invest in transportation projects
that provide access for all
communities to a variety of jobs
with competitive wages.
Not Applicable. The proposed project would not
impair the ability of SANDAG to invest in
transportation projects available to all members of
the Community.
Regional Economic
Prosperity
Build infrastructure that makes
the movement of freight in our
community more efficient and
environmentally friendly.
Not Applicable. The proposed project does not
propose regional freight movement, nor would it
impair SANDAG’s ability to preserve and expand
options for regional freight movement.
Partnerships/Collaboration Collaborate with Native American
tribes, Mexico, military bases,
neighboring counties,
infrastructure providers, the
private sector, and local
communities to design a
transportation system that
Not Applicable. The proposed project would not
impair the ability of SANDAG to provide
transportation choices to better connect the San
Diego region with Mexico, neighboring counties,
and tribal nations.
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Table 4.7-3. San Diego Forward: The Regional Plan Consistency Analysis
Category Policy Objective or Strategy Consistency Analysis
connects to the mega‐region and
national network, works for
everyone, and fosters a high
quality of life for all.
Partnerships/Collaboration As we plan for our region,
recognize the vital economic,
environmental, cultural, and
community linkages between the
San Diego region and Baja
California.
Not Applicable. The proposed project would not
impair the ability of SANDAG to provide
transportation choices to better connect the San
Diego region with Mexico.
Healthy and Complete
Communities
Create great places for everyone
to live, work, and play.
Consistent. The proposed project proposes new
residential development in an infill location that would
facilitate the creation of a more livable neighborhood
that integrates residents into the existing community.
The proposed project’s design and compact mixed
land use setting would improve land use access, as
well as the neighborhood’s multi-modal transportation
network. The proposed project’s internal circulation
features would provide residents with the opportunity
to access employment, recreational, and commercial
uses via multiple modes of transportation.
Additionally, the proposed project was designed to
promote health and sustainability by focusing on a
compact pattern of development and by offering
many amenities to its residents within walking
distance.
Healthy and Complete
Communities
Connect communities through a
variety of transportation choices
that promote healthy lifestyles,
including walking and biking.
Consistent. The proposed project’s internal
circulation features would provide residents with
the opportunity to access employment,
recreational, and commercial uses via multiple
modes of transportation. The proposed project
would also encourage non-vehicular modes of
transportation through its proximate location to
nearby amenities.
Environmental
Stewardship
Make transportation investments
that result in cleaner air,
environmental protection,
conservation, efficiency, and
sustainable living.
Consistent. The proposed project was designed to
promote health and sustainability by focusing on a
compact pattern of development. The proposed
project includes electric-vehicle charging stations.
Environmental
Stewardship
Support energy programs that
promote sustainability.
Consistent. The proposed project would include on-
site renewable energy production through solar
photovoltaic rooftop systems.
Sustainable Communities Strategy – Strategies
Strategy #1 Focus housing and job growth in
urbanized areas where there is
existing and planned
transportation infrastructure,
including transit.
Consistent. The proposed project would be located
close to major urban and employment centers. The
proposed project would provide a significant infill
opportunity for the community. As such, the
proposed project proposes to develop future housing
opportunities in an infill location that capitalizes on
4.7 – Greenhouse Gas Emissions
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Table 4.7-3. San Diego Forward: The Regional Plan Consistency Analysis
Category Policy Objective or Strategy Consistency Analysis
existing infrastructure rather than other non-
developed areas—including open space areas,
sensitive habitats, or areas otherwise constrained
due to topography, flooding, or other factors.
Strategy #2 Protect the environment and help
ensure the success of smart
growth land use policies by
preserving sensitive habitat, open
space, cultural resources, and
farmland.
Consistent. The proposed project would be located
close to major urban and employment centers. As
such, the proposed project proposes to develop
future housing opportunities in an infill location that
capitalizes on existing infrastructure rather than
other non-developed areas—including open space
areas, sensitive habitats, or areas otherwise
constrained due to topography, flooding, or other
factors.
Strategy #3 Invest in a transportation network
that gives people transportation
choices and reduces greenhouse
gas emissions.
Consistent. The proposed project would help
reduce greenhouse gas emissions from vehicles in
the region compared to a non-infill project.
Strategy #4 Address the housing needs of all
economic segments of the
population.
Consistent. With a variety of housing types and
choices, the proposed project seeks to increase the
housing supply and the mix of housing sizes,
tenure, and affordability in the City. These housing
types would support a range of buyers from various
categories.
Strategy #5 Implement the Regional Plan
through incentives and
collaboration.
Not Applicable. The proposed project would not
impair the ability of SANDAG to implement the
Regional Transportation Plan through incentives
and collaborations.
Source: SANDAG 2015.
Notes: City = City of Poway; proposed project = The Farm in Poway; VMT = vehicle miles traveled; SANDAG = San Diego Association of
Governments; EV = electric vehicle.
As shown in Table 4.7-3, the proposed project would be consistent with all applicable Regional Plan policy
objectives or strategies. SANDAG worked with the local jurisdictions to identify Regional Housing Needs
Assessment allocation options that meet the four goals of housing element law (Government Code Section
65484[d][1]–[4]) within the Regional Plan. The second of the four objectives of the SANDAG Regional Housing
Needs Assessment is to promote infill development and socioeconomic equity, the protection of environmental
and agricultural resources, and the encouragement of efficient development patterns. Also, one of the key
achievements projected for the Regional Plan is for nearly three-quarters of multi-family housing to be built on
redevelopment or infill sites. The proposed project would be consistent with that goal as it would be develo ped
on an infill site.
In summary, the proposed project promotes a pedestrian experience for its residents and visitors that would
facilitate non-vehicular travel, consistent with SB 375 and SANDAG’s Regional Plan. As shown in Table 4.7-3,
the proposed project would be consistent with policy objectives of SANDAG’s Regional Plan. Impacts would
be less than significant.
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Consistency with CARB’s Scoping Plan
The Scoping Plan, approved by CARB on December 12, 2008, provides a framework for actions to reduce
California’s GHG emissions and requires CARB and other state agencies to adopt regulations and other
initiatives to reduce GHGs. As such, the Scoping Plan is not directly applicable to specific projects. Relatedly, in
the Final Statement of Reasons for the Amendments to the CEQA Guidelines, the CNRA observed that “[t]he
[Scoping Plan] may not be appropriate for use in determining the significance of individual projects because it
is conceptual at this stage and relies on the future development of regulations to implement the strategies
identified in the Scoping Plan” (CNRA 2009a). Under the Scoping Plan, however, there are several state
regulatory measures aimed at the identification and reduction of GHG emissions. CARB and other state
agencies have adopted many of the measures identified in the Scoping Plan. Most of these measures focus on
area source emissions (e.g., energy usage, high-GWP GHGs in consumer products) and changes to the vehicle
fleet (i.e., hybrid, electric, and more fuel-efficient vehicles) and associated fuels (e.g., low-carbon fuel
standard), among others. The proposed project would comply with all applicable regulations adopted in
furtherance of the Scoping Plan to the extent required by law.
The Scoping Plan recommends strategies for implementation at the statewide level to meet the goals of AB 32
and establishes an overall framework for the measures that will be adopted to reduce California’s GHG emissions.
Table 4.7-4 highlights measures that have been developed under the Scoping Plan and the proposed project’s
consistency with those measures. The table also includes measures proposed in the 2017 Scoping Plan Update.
To the extent that these regulations are applicable to the proposed project, its inhabitants, or uses, the proposed
project would comply with all applicable regulations adopted in furtherance of the Scoping Plan.
Table 4.7-4. Project Consistency with Scoping Plan GHG Emission-Reduction Strategies
Scoping Plan Measure
Measure
Number Project Consistency
Transportation Sector
Advanced Clean Cars T-1 The proposed project’s residents would purchase vehicles
in compliance with CARB vehicle standards that are in
effect at the time of vehicle purchase.
1.5 million zero-emission and plug-in hybrid
light-duty electric vehicles by 2025 (4.2
million Zero-Emissions Vehicles by 2030)
Proposed The proposed project includes EV charging stations.
Low Carbon Fuel Standard T-2 Motor vehicles driven by the proposed project’s residents
would use compliant fuels.
Low Carbon Fuel Standard (18 percent
reduction in carbon intensity by 2030)
Proposed Motor vehicles driven by the proposed project’s residents
would use compliant fuels.
Regional Transportation-Related
GHG Targets
T-3 The proposed project would encourage use of alternative
forms of transportation.
Advanced Clean Transit Proposed This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Last Mile Delivery Proposed This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
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Table 4.7-4. Project Consistency with Scoping Plan GHG Emission-Reduction Strategies
Scoping Plan Measure
Measure
Number Project Consistency
Reduction in Vehicle Miles Traveled Proposed The proposed project is located on an infill site, which
promotes compact walkable communities with an
emphasis on proximity and accessibility.
Vehicle Efficiency Measures
1. Tire Pressure
2. Fuel Efficiency Tire Program
3. Low-Friction Oil
4. Solar-Reflective Automotive Paint and
Window Glazing
T-4 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Ship Electrification at Ports (Shore Power) T-5 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Goods Movement Efficiency Measures
1. Port Drayage Trucks
2. Transport Refrigeration Units Cold
Storage Prohibition
3. Cargo Handling Equipment, Anti-Idling,
Hybrid, Electrification
4. Goods Movement Systemwide
Efficiency Improvements
5. Commercial Harbor Craft Maintenance
and Design Efficiency
6. Clean Ships
7. Vessel Speed Reduction
T-6 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
California Sustainable Freight Action Plan Proposed This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Heavy-Duty Vehicle GHG Emission
Reduction
1. Tractor-Trailer GHG Regulation
2. Heavy-Duty Greenhouse Gas Standards
for New Vehicle and Engines (Phase I)
T-7 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Medium- and Heavy-Duty Vehicle
Hybridization Voucher Incentive Project
T-8 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Medium and Heavy-Duty GHG Phase 2 Proposed This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
High-Speed Rail T-9 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Electricity and Natural Gas Sector
Energy Efficiency Measures (Electricity) E-1 The proposed project will comply with current Title 24, Part
6, of the California Code of Regulations energy efficiency
standards for electrical appliances and other devices at the
time of building construction.
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Table 4.7-4. Project Consistency with Scoping Plan GHG Emission-Reduction Strategies
Scoping Plan Measure
Measure
Number Project Consistency
Energy Efficiency (Natural Gas) CR-1 The proposed project will comply with current Title 24, Part
6, of the California Code of Regulations energy efficiency
standards for electrical appliances and other devices at the
time of building construction.
Solar Water Heating (California Solar
Initiative Thermal Program)
CR-2 The proposed project would not employ solar water heating
as part of the design.
Combined Heat and Power E-2 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Renewable Portfolios Standard (33 percent
by 2020)
E-3 The proposed project would use energy supplied by San
Diego Gas and Electric, which is in compliance with the
Renewable Portfolio Standard.
Renewable Portfolios Standard (50 percent
by 2050)
Proposed The proposed project would use energy supplied by San
Diego Gas and Electric, which is in compliance with the
Renewable Portfolio Standard.
Senate Bill 1 Million Solar Roofs
(California Solar Initiative, New Solar Home
Partnership, Public Utility Programs) and
Earlier Solar Programs
E-4 The proposed project would include solar roofs
installations.
Water Sector
Water Use Efficiency W-1 The proposed project is going to utilize water saving
features including low-flow fixtures and non-potable water
for landscape irrigation.
Water Recycling W-2 Recycled water will not be used on site.
Water System Energy Efficiency W-3 This is applicable for the transmission and treatment of
water, but it is not applicable for the proposed project.
Reuse Urban Runoff W-4 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Renewable Energy Production W-5 Applicable for wastewater treatment systems. Not
applicable for the proposed project.
Green Buildings
State Green Building Initiative: Leading the
Way with State Buildings (Greening New and
Existing State Buildings)
GB-1 The proposed project would be required to be constructed
in compliance with state or local green building standards
in effect at the time of building construction.
Green Building Standards Code (Greening
New Public Schools, Residential and
Commercial Buildings)
GB-2 The proposed project’s buildings would meet green
building standards that are in effect at the time of
construction.
Beyond Code: Voluntary Programs at the
Local Level (Greening New Public Schools,
Residential and Commercial Buildings)
GB-3 The proposed project would be required to be constructed
in compliance with local green building standards in effect
at the time of building construction.
Greening Existing Buildings (Greening
Existing Homes and Commercial Buildings)
GB-4 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
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June 2020 4.7-28
Table 4.7-4. Project Consistency with Scoping Plan GHG Emission-Reduction Strategies
Scoping Plan Measure
Measure
Number Project Consistency
Industry Sector
Energy Efficiency and Co-Benefits
Audits for Large Industrial Sources
I-1 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Oil and Gas Extraction GHG Emission
Reduction
I-2 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Reduce GHG Emissions by 20 percent in Oil
Refinery Sector
Proposed This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
GHG Emissions Reduction from Natural Gas
Transmission and Distribution
I-3 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Refinery Flare Recovery Process
Improvements
I-4 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Work with the local air districts to evaluate
amendments to their existing leak detection
and repair rules for industrial facilities to
include methane leaks
I-5 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Recycling and Waste Management Sector
Landfill Methane Control Measure RW-1 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Increasing the Efficiency of Landfill Methane
Capture
RW-2 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Mandatory Commercial Recycling RW-3 During both construction and operation of the
proposed project, the proposed project would comply
with all state regulations related to solid waste
generation, storage, and disposal, including the
California Integrated Waste Management Act, as
amended. During construction, all wastes would be
recycled to the maximum extent possible.
Increase Production and Markets for
Compost and Other Organics
RW-4 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Anaerobic/Aerobic Digestion RW-5 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Extended Producer Responsibility RW-6 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Environmentally Preferable Purchasing RW-7 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
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Table 4.7-4. Project Consistency with Scoping Plan GHG Emission-Reduction Strategies
Scoping Plan Measure
Measure
Number Project Consistency
Forests Sector
Sustainable Forest Target F-1 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
High Global Warming Potential Gases Sector
Motor Vehicle Air Conditioning Systems:
Reduction of Refrigerant Emissions from
Non-Professional Servicing
H-1 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
SF6 Limits in Non-Utility and Non-
Semiconductor Applications
H-2 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Reduction of Perfluorocarbons in
Semiconductor Manufacturing
H-3 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Limit High Global Warming Potential Use in
Consumer Products
H-4 The proposed project’s residents would use consumer
products that would comply with the regulations that are in
effect at the time of manufacture.
Air Conditioning Refrigerant Leak Test
During Vehicle Smog Check
H-5 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Stationary Equipment Refrigerant
Management Program – Refrigerant
Tracking/Reporting/Repair Program
H-6 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Stationary Equipment Refrigerant
Management Program – Specifications for
Commercial and Industrial Refrigeration
H-6 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
SF6 Leak Reduction Gas Insulated
Switchgear
H-6 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
40 percent reduction in methane and
hydrofluorocarbon emissions
Proposed This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
50 percent reduction in black carbon
emissions
Proposed This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Agriculture Sector
Methane Capture at Large Dairies A-1 This measure does not apply to the proposed project. The
proposed project would not inhibit CARB from
implementing this Scoping Plan Measure.
Source: CARB 2008, 2017.
Notes: GHG = greenhouse gas; proposed project = The Farm in Poway; CARB = California Air Resources Board; EV = electric vehicle;
SF6 = sulfur hexafluoride.
Based on the analysis in Table 4.7-4, the proposed project would be consistent with the applicable strategies and
measures in the Scoping Plan.
4.7 – Greenhouse Gas Emissions
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June 2020 4.7-30
In addition to the measures outlined in the Table 4.7-4, the Scoping Plan also highlights, in several areas, the
goals and importance of infill projects. Specifically, the Scoping Plan calls out an ongoing and proposed measure
to streamline CEQA compliance and other barriers to infill development. The plan encourages infill projects and
sees them as crucial to achieving the State’s long-term climate goals. The plan encourages accelerating equitable
and affordable infill development through enhanced financing and policy incentives and mechanisms.
The state completed an Integrated Natural and Working Lands Climate Change Action Plan (Action Plan), which
considers aggregation of eco-regional plans and efforts to achieve net sequestration goals. The Action Plan
includes goals and plans to promote and provide incentives for infill development through community
revitalization and urban greening and promote the adoption of regional transportation and development plans,
such as SB 375 SCS and Climate Action Plans, which prioritize infill and compact development and also consider
the climate change impacts of land use and management.
The following strategies were outlined to expand infill development within the Scoping Plan:
Encouraging regional transfer of development rights programs to allow owners of natural and working
lands to sell their development rights to developers who can use those rights to add additional density to
development projects in preferred infill areas.
Promoting regional transit-oriented development funds that leverage public resources with private-sector
investment capital to provide flexible capital for transit-oriented development projects.
Rebates for low-VMT/location-efficient housing, similar to programs that use rebates to encourage
adoption of energy-efficient appliances, ZEVs, water-efficient yards, or renewable energy installation. For
example, the rebate could reimburse residents for a portion of the down payment for purchasing or
renting a qualified home in exchange for a minimum term of residence.
Promotion of cross-subsidizing multi-station financing districts along transit corridors to leverage
revenues from development in strong-market station areas in order to seed needed infrastructure and
development in weaker-market station areas.
Abatement of residential property tax increases in exchange for property-based improvements in
distressed infill areas.
Ways to promote reduced parking in areas where viable transportation alternatives are present.
Additional creative financing mechanisms to enhance the viability of priority infill projects.
Ways to promote and strengthen urban growth boundaries to promote infill development and
conservation of natural and working lands by defining and limiting developable land within a metropolitan
area according to projected growth needs.
In summary, the proposed project would be consistent with the measures and policy goals as shown in Table 4.7-4,
Project Consistency with Scoping Plan GHG Emission-Reduction Strategies. The proposed project would also be
consistent with the various efforts the Scoping Plan established to encourage infill development projects. Therefore, the
proposed project would be consistent with CARB’s Scoping Plan.
Finally, the SDAPCD has not adopted GHG reduction measures that would apply to the GHG emissions associated with
the proposed project. Therefore, this impact would be less than significant.
The proposed project’s impacts related to GHGs are listed as follows:
Impact GHG-1 The proposed project would result in 4,245 MT CO2e per year, which would be greater than the
significance threshold of 900 MT CO2e per year.
4.7 – Greenhouse Gas Emissions
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June 2020 4.7-31
4.7.5 Cumulative Impacts
As discussed in Section 4.7.4, Impacts Analysis, global climate change is a cumulative impact; however, as
shown, the proposed project would have a less-than-significant impact with mitigation.
4.7.6 Mitigation Measures
The following mitigation measure is provided to reduce the proposed project’s GHG emissions to less than significant.
MM-GHG-1 The applicant or its designee shall include the following features to reduce greenhouse gas
emissions during operation:
1) Develop a comprehensive pedestrian network designed to provide safe bicycle and
pedestrian access between the various internal proposed project land uses, which will
include design elements to enhance walkability and connectivity and shall minimize barriers
to pedestrian access and interconnectivity. Physical barriers—such as walls or landscaping—
that impede pedestrian circulation shall be eliminated.
2) Include special safety mobility features such as enhanced crosswalks for high visibility,
pedestrian signals with countdown timers, leading pedestrian interval timing, Americans with
Disabilities Act (ADA)-compliant curb ramps, and smart adaptive signals that can adjust signal
phasing and extend pedestrian walk time based upon time of day. The smart adaptive signals
help to optimize traffic flows to reduce idling time.
3) Promote ridesharing programs through a multi-faceted approach, such as designating a
certain percentage of parking spaces for ridesharing vehicles, designating adequate
passenger loading and unloading and waiting areas for ridesharing vehicles, or providing a
website or message board for coordinating rides.
4) Install Energy Star rated heating, cooling, lighting, and appliances.
5) Outdoor lighting shall be light emitting diodes (LED) or other high-efficiency lightbulbs.
6) Implement water-sensitive urban design practices in new construction.
7) Strategically plant trees to provide shade.
8) Equip structures with outdoor electric outlets in the front and rear of the structure to facilitate
use of electrical lawn and garden equipment.
9) Outdoor pavement, such as walkways and patios, shall include paving materials with three-year
Solar Reflective Index (SRI) of 0.28 or initial SRI of 0.33, or other equivalent cool pavement.
MM-GHG-2 The applicant or its designee shall purchase and retire greenhouse gas (GHG) offsets to reduce
the proposed project’s GHG emissions level to 900 metric tons of carbon dioxide equivalent (MT
CO2e) per year, consistent with the performance standards and requirements set forth below.
1) The GHG offsets shall be secured from an accredited registry that is recognized by the
California Air Resources Board (CARB) or a California air district, or from an emissions
reduction credits program that is administered by CARB or a California air district.
2) The GHG offsets shall represent the past reduction or sequestration of one MT CO2e that is
“not otherwise required,” in accordance with California Environmental Quality Act Guidelines
Section 15126.4(c)(3).
3) The GHG offsets shall be real, permanent, quantifiable, verifiable, and enforceable.
4.7 – Greenhouse Gas Emissions
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June 2020 4.7-32
4) The quantity of GHG offsets required to achieve the service population value set forth above
shall be calculated in and supported by technical documentation that is submitted to the City
as part of the Mitigation Monitoring and Reporting Program, using an approved methodology
demonstrating the quantity of reductions is valid and sufficient.
5) The applicant shall offset the proposed project’s GHG emissions prior to receiving the 80th
certificate of occupancy from the City. This represents 50 percent of the proposed project’s
residential build-out and thus the proposed project’s emissions would be offset prior to
completion of the proposed project.
4.7.7 Level of Significance After Mitigation
The GHG reduction measures included within MM-GHG-1 were conservatively not accounted for. With
implementation of MM-GHG-1 and MM-GHG-2, the proposed project would offset 3,345 MT CO2e per year over
the proposed project’s lifetime, for a total of 100,350 MT CO2e. The proposed project’s GHG emissions would be
reduced to a level below the significance threshold efficiency metric of 900 MT CO2e per year. Therefore, the
proposed project would result in a less-than-significant impact.
4.8 – Hazards and Hazardous Materials
The Farm in Poway EIR 11872
June 2020 4.8-1
4.8 Hazards and Hazardous Materials
This section describes the existing hazardous materials conditions of The Farm in Poway project (proposed
project) site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies
mitigation measures for implementation of the proposed project.
A Notice of Preparation (NOP) was circulated from May 10, 2019, to June 10, 2019. During the NOP comment
period, comment letters related to hazards and hazardous materials focused on the following topics:
Wildfire danger
These comments were considered during the preparation of this Environmental Impact Report (EIR). The Initial
Study, NOP, and Public Scoping comments are provided in Appendix A of this EIR.
4.8.1 Existing Conditions
Project Site
In its current state, the former StoneRidge Country Club golf course has resulted in code compliance issues for
the City of Poway (City), including but not limited to unkempt landscape, as well as trespassing and graffiti on the
private property. Conditions of the abandoned former clubhouse facility have created potential ongoing public
health and safety hazards for existing surrounding residents.
Land uses in the proposed project area that may have involved hazardous materials and/or wastes include
former agriculture and golf course maintenance. The former agricultural areas could have a potential risk of
contamination from historical use of herbicides, pesticides, and fertilizer. Golf course maintenance could have
potential risk of contamination from uses of petroleum products (e.g., for vehicle and equipment), pesticides,
herbicides, and fertilizers. Other hazardous materials may have also been used for maintenance activities, such
as solvents and cleaning products.
Site History
Based on a review of publicly available aerial photographs (NETROnline 2019), the former StoneRidge Country
Club golf course was constructed between 1953 and 1964. Prior to construction of the golf course, it appears
that the project site was either undeveloped or used as agricultural land. Residential development surrounding
the project site occurred between 1968 and 1980.
Hazardous Materials
Government Code Section 65962.5 requires the California Department of Toxic Substances Control (DTSC), the
State Department of Health Services, the State Water Resources Control Board (SWRCB), and the California
Department of Resources Recycling and Recovery (CalRecycle) to compile and annually update lists of hazardous
waste sites and lands designated as hazardous waste sites throughout the state. The provisions in Government
Code Section 65962.5 are commonly referred to as the “Cortese List.” The Cortese List, which includes the
resources listed below, was reviewed for hazardous waste sites along the project alignment.
List of hazardous waste and substances sites from the DTSC EnviroStor database
List of leaking underground storage tank (LUST) sites from the SWRCB GeoTracker database
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List of solid waste disposal sites identified by SWRCB with waste constituents above hazardous waste
levels outside the waste management unit
List of “active” cease-and-desist orders and cleanup and abatement orders from SWRCB
List of hazardous waste facilities subject to corrective action identified by DTSC
Dudek reviewed the above-listed databases and lists for information regarding hazardous materials or hazardous
wastes on the project site. There were no Cortese list sites identified on, or within one mile of, the project site.
There were also no sites identified on the EnviroStor database on, or within one mile of, the project site
(EnviroStor 2019). One closed LUST site was identified on the project site on the GeoTracker database, as
discussed below.
GeoTracker Database
One former LUST cleanup site is located in the southwest corner of the project site. Information indicates the
LUST case was associated with the former StoneRidge Country Club, 17166 Stoneridge Country Club Lane.
According to the site background (DES 2013), two 1,000-gallon gasoline underground storage tanks were found
to be leaking and were removed in 1993. Gasoline hydrocarbons (TPHg), benzene, and methyl tertiary butyl ether
(MTBE) were determined to be contaminants of concern in soil and groundwater. Impacted soils were excavated
down to 20 feet below ground surface in the area of the former LUSTs, and groundwater was monitored
intermittently between 1995 and 2012. The approximate location of the former LUSTs is shown on Figure 4.8-1,
Project Site Hazards.
In order to receive regulatory closure, a Corrective Action Plan (CAP) was prepared (DES 2013). The CAP stated
that groundwater at the project site is used for a drinking water supply. However, the proposed project would not
use groundwater for construction or operational activities. Groundwater samples collected in 2012 showed no
detectable concentrations of benzene or TPHg, but MTBE was detected in three wells between 2 and 4 parts per
billion. It was determined that the MTBE plume was stable and decreasing (based on analytical results from 2004
through 2012). The CAP recommended remediation of groundwater to remove residual MTBE. Although the CAP
was approved by the regulatory agency, no additional remedial actions were performed. Groundwater monitoring
wells were removed in 2013 without regulatory agency approval.
In 2015, the San Diego Regional Water Quality Control Board (RWQCB) determined that the remaining MTBE
in groundwater was at an acceptable level for closure. The case received regulatory closure as of February
26, 2015 (Case No. 9UT2469) (GeoTracker 2019). The closure letter included the following advisories (San
Diego RWQCB 2015):
1. Any land use changes for the site may require reevaluation to determine of the changes pose an
unacceptable risk to public health;
2. Any contaminated soil encountered or excavated as part of future subsurface construction/utility work
must be managed in accordance with all applicable legal and regulatory requirements; and
3. All future construction on the project must include post construction best management practices to
control stormwater runoff in compliance with the US EPA Guidance Document: “Technical Guidance on
Implementing the Stormwater Runoff Requirements for Federal Projects under Section 438 of the Energy
Independence and Security Act.”
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In 2017, a Soil Vapor Assessment Workplan (Workplan) (Geocon 2017) was completed in order to assess
potential vapor intrusion risks for future residential development. Mr. Sean McClain of the San Diego RWQCB
responded to the Workplan in an email on November 27, 2017 (McClain, pers. comm. 2017). In the email, Mr.
McClain required additional items for the Workplan, as wells as preparation of a Soil Management Plan and
submittal to the San Diego RWQCB for approval before any grading or excavation of soil near the former
underground storage tank pit area. Based on available information, no additional work has been completed on
the project site with respect to the former LUSTs.
Additional Environmental Databases
The National Pipeline Mapping System provides an online mapping application with information related to gas
transmission and hazardous liquid (petroleum) pipelines, liquefied natural gas plants, and breakout tanks, as well as
accidents and incidents related to these features that fall under the jurisdiction of the Department of Transportation
Pipeline and Hazardous Materials Safety Administration. No pipelines, accidents, incidents, or other features were
identified on, or within one mile of, the project site on the National Pipeline Mapping System database.
Schools
Painted Rock Elementary School, located at 16711 Martincoit Road, is the only school within one-quarter mile of
the proposed project. The school is located approximately 0.16 miles south of the project site (CSCD 2019). There
are no proposed schools located on, or within one-quarter mile of, the project site (CDE 2019).
Fire Hazards
The project site is surrounded on all sides by residential neighborhoods, within the City of Poway Fire Department’s
(PFD’s) jurisdiction; therefore the project site is currently served by PFD. Additionally, PFD Fire Station 2 is located
less than one-half mile east of the project site at 16912 Westling Court, just off of Espola Road. Fire Station 2 has a
travel time goal of six minutes or less, 90 percent of the time. The response time to the furthest planned home
within the project site would be well within this six-minute goal. According to the PFD Deputy Fire Chief, Jon M.
Canavan, there are no department goals regarding ratio of firefighters per capita. There are no additional staffing
requirements anticipated for development of the proposed project (Kruer, pers. comm. 2007).
A small area in the northeast portion of the project site is located within the Very High Fire Severity Zone. (CAL
FIRE 2009). Proposed homes within the Very High Fire Severity Zone include all homes within the Residential –
Homestead (R-H) land use district. The existing homes within the R-H land use district reflect development
standards that include additional setback and building standards. In addition, all new development would be
required to comply with the Fuels Management Plan (FMP) prepared for the Farm in Poway in January 2020. The
FMP is included as Appendix L of this EIR.
Emergency Response
The City does not have a current emergency response plan or evacuation routes; however it does administer the
Community Emergency Response Team (CERT) Program, which educates City residents and adjacent cities about
disaster preparedness. Once a year, the City offers a CERT academy that provides training in basic disaster response
skills such as fire safety, simple search and rescue, basic first aid, terrorism, emergency preparedness, and disaster
psychology. Graduates of the program or an equivalent CERT course are eligible to apply for membership in the
City’s CERT and are required to attend two trainings of community events each year (City of Poway 2019a).
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Law enforcement services are provided by contract with the San Diego County Sheriff’s Department. The Poway
Sheriff’s Station, located at 13100 Bowron Road, provides patrol, traffic, and investigative services to the City.
The Poway Station currently consists of 45 sworn personnel, six civilians, 13 reserve deputies, and 55 senior
volunteer patrol personnel (San Diego County Sheriff 2019).
4.8.2 Relevant Plans, Policies, and Ordinances
Federal
Comprehensive Environmental Response, Compensation, and Liability Act and Superfund Amendments and
Reauthorization Act
Congress enacted the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA),
commonly known as Superfund, on December 11, 1980. CERCLA established prohibitions and requirements
concerning closed and abandoned hazardous waste sites; provided for liability of persons responsible for releases
of hazardous waste at these sites; and established a trust fund to provide for cleanup when no responsible party
could be identified. The Superfund Amendments and Reauthorization Act (SARA) amended CERCLA on October
17, 1986. SARA stressed the importance of permanent remedies and innovative treatment technologies in
cleaning up hazardous waste sites; required Superfund actions to consider the standards and requirements
found in other state and federal environmental laws and regulations; provided new enforcement authorities and
settlement tools; increased state involvement in every phase of the Superfund program; increased the focus on
human health problems posed by hazardous waste sites; encouraged greater citizen participation in making
decisions on how sites should be cleaned up; and increased the size of the trust fund to $8.5 billion.
Emergency Planning Community Right-to-Know Act
The Emergency Planning Community Right-to-Know Act, also known as SARA Title III, was enacted in October
1986. This law requires any infrastructure at the state and local levels to plan for chemical emergencies.
Reported information is then made publicly available so that interested parties may become informed about
potentially dangerous chemicals in their community. The Emergency Planning Community Right-to-Know Act
Sections 301 through 312 are administered by the U.S. Environmental Protection Agency’s (EPA’s) Office of
Emergency Management. In California, SARA Title III is implemented through the California Accidental Release
Prevention (CalARP) Program.
Federal Response Plan
The Federal Response Plan of 1999 is a signed agreement among 27 federal departments and agencies,
including the American Red Cross, that: (1) provides the mechanism for coordinating delivery of federal
assistance and resources to augment efforts of state and local governments overwhelmed by a major disaster or
emergency; (2) supports implementation of the Robert T. Stafford Disaster Relief and Emergency Act, as well as
individual agency statutory authorities; and (3) supplements other federal emergency operations plans developed
to address specific hazards. The Federal Response Plan is implemented in anticipation of a significant event likely
to result in a need for federal assistance or in response to an actual event requiring federal assistance under a
presidential declaration of a major disaster or emergency.
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Hazardous Materials Transportation Act
The U.S. Department of Transportation regulates hazardous materials transportation under Title 49 of the
Code of Federal Regulations. The California Highway Patrol and the California Department of Transportation
are the state agencies with primary responsibility for enforcing federal and state regulations and responding
to hazardous materials transportation emergencies. These agencies also govern permitting for hazardous
materials transportation. Title 49 of the Code of Federal Regulations reflects laws passed by Congress as of
January 2, 2006.
International Fire Code
The International Fire Code (IFC), created by the International Code Council, is the primary means for
authorizing and enforcing procedures and mechanisms to ensure the safe handling and storage of any
substance that may pose a threat to public health and safety. The IFC regulates the use, handling, and storage
requirements for hazardous materials at fixed facilities. The IFC and the International Building Code use a
hazard classification system to determine what measures are required to protect fire and life safety. These
measures may include construction standards, separation from project site lines, and specialized equipment.
To ensure that these safety measures are met, the IFC employs a permit system based on hazard classification.
The IFC is updated every three years.
National Emissions Standards for Hazardous Air Pollutants Program
Under federal law, 188 substances are listed as hazardous air pollutants. Major sources of specific hazardous air
pollutants are subject to the requirements of the National Emissions Standards for Hazardous Air Pollutants
program. The EPA is establishing regulatory schemes for specific source categories, and requires implementation
of Maximum Achievable Control Technologies for major sources of hazardous air pollutants in each source
category. State law has established the framework for California’s Toxic Air Contaminant Identification and Control
Program, which is generally more stringent than the federal program, and is aimed at hazardous air pollutants
that are a problem in California. The state has formally identified more than 200 substances as toxic air
contaminants, and is adopting appropriate control measures for each. Once adopted at the state level, each local
air district will be required to adopt a measure that is equally or more stringent.
Occupational and Safety Health Act
Congress passed the Occupational and Safety Health Act to ensure worker and workplace safety. Its goal was to
make sure employers provide their workers a place of employment free from recognized hazards to safety and
health, such as exposure to toxic chemicals, excessive noise levels, mechanical dangers, heat or cold stress, or
unsanitary conditions. In order to establish standards for workplace health and safety, the Occupational and
Safety Health Act also created the National Institute for Occupational Safety and Health as the research
institution for the Occupational Safety and Health Administration. The Occupational Safety and Health
Administration is a division of the U.S. Department of Labor that oversees the administration of the Occupational
and Safety Health Act and enforces standards in all 50 states. Because California has an approved State Plan,
only California Occupational Safety and Health Administration (Cal/OSHA) standards apply to the project site.
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Renovating, Repair, and Painting Rule
In 2008, the EPA issued the Renovation, Repair, and Painting Rule. This rule requires that firms performing
renovation, repair, and painting projects that disturb lead-based paint in pre-1978 homes, child care
facilities, and schools be certified by the EPA, and that they use certified renovators who are trained by EPA -
approved training providers to follow lead-safe work practices. Individuals can become certified renovators
by taking an eight-hour training course from an EPA-approved training provider. Contractors must use lead-
safe work practices and follow these three simple procedures: (1) contain the work area; (2) minimize dust;
and (3) clean up thoroughly.
Resource Conservation and Recovery Act
Federal hazardous waste laws are generally promulgated under the Resource Conservation and Recovery Act
(RCRA), as amended by the Hazardous and Solid Waste Amendments of 1984. These laws provide for the “cradle
to grave” regulation of hazardous wastes. Any business, institution, or other entity that generates hazardous
waste is required to identify and track its hazardous waste from the point of generation until it is recycled, reused,
or disposed of. The DTSC is responsible for implementing the RCRA program as well as California’s own
hazardous waste laws, which are collectively known as the Hazardous Waste Control Law. Under the Certified
Unified Program Agency program, the California Environmental Protection Agency (CalEPA) has in turn delegated
enforcement authority to the County of San Diego Department of Environmental Health (DEH) for regulating
hazardous waste producers or generators.
Robert T. Stafford Disaster Relief and Emergency Assistance Act
Code of Federal Regulations Sections 206.31–206.48 provide the statutory framework for a presidential
declaration of an emergency or a declaration of a major disaster. Such declarations open the way for a wide range
of federal resources to be made available to assist in dealing with an emergency or major disaster. The Stafford
Act structure for the declaration process reflects the fact that federal resources under this act supplement state
and local resources for disaster relief and recovery. Except in the case of an emergency involving a subject area
that is exclusively or preeminently in the federal purview, the governor of an affected state, or acting governor if
the governor is not available, must request such a declaration by the president.
Risk Assessment and Regional Screening Levels
The EPA and DTSC use risk assessments to characterize the nature and magnitude of health risks to humans and
ecological receptors from chemical contaminants and other stressors that may be present in the environment. In
general terms, risk depends on the following three factors: how much of a chemical is present in an environmental
medium (air, soil, water), how much contact (exposure) a person or ecological receptor has with the contaminated
environmental medium, and the inherent toxicity of the chemical. The EPA developed Regional Screening Levels
(RSLs), which provide a unified set of screening level/preliminary remediation goals for all regions of the EPA for
screening chemical contaminants at superfund sites. The RSLs replaced the Preliminary Remediation Goals (PRGs) in
2008. The RSLs are calculated using the latest toxicity values, default exposure assumptions and physical and
chemical properties. The RSLs are considered by the EPA to be protective for humans (including sensitive groups) over
a lifetime. Under most circumstances, the presence of a chemical in soil, soil gas, or indoor air at concentrations
below the corresponding RSLs can be assumed to not pose a significant health risk to people who may live
(residential RSLs) or work (commercial/industrial RSLs) at the site. The EPA RSL tables were most recently
updated in November 2018.
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The DTSC Human and Ecological Risk Office (HERO) incorporated the EPA RSLs into the HERO human health risk
assessment. The HERO review of the EPA RSLs determined that the revised RSLs included some levels that were
substantially higher, and therefore less protective, than the previous PRGs. HERO therefore created Human
Health Risk Assessment Note 3, which incorporates HERO recommendations and DTSC-modified screening levels
based on review of the EPA RSLs. The DTSC-modified screening levels should be used in conjunction with the EPA
RSLs to evaluate chemical concentrations in environmental media at California sites and facilities. HERO Note 3
was most recently updated in April 2019.
State
California Environmental Quality Act
CEQA (California Public Resources Code, Section 21000 et seq.) and the CEQA Guidelines (14 CCR 15000 et
seq.) are primary sources for environmental legislation in California; they require projects with potential adverse
environmental effects (or impacts) undergo environmental review. Adverse environmental impacts are typically
mitigated as a result of the environmental review process in accordance with existing laws and regulations.
California Emergency Services Act
The California Emergency Services Act was adopted to establish the state’s role and responsibilities during
human-made or natural emergencies that result in conditions of disaster and/or extreme peril to life, property, or
the resources of the state. The California Emergency Services Act is intended to protect health and safety by
preserving the lives and property of the people of the state. The Office of Emergency Services coordinates the
responses of other agencies, including the EPA, California Highway Patrol, RWQCBs, air quality management
districts, and county disaster response offices.
California Fire Code
The California Fire Code (CFC) is provided in California Code of Regulations Title 24, Chapter 9. It was created by
the California Building Standards Commission and is based on the IFC. The CFC is the primary means for
authorizing and enforcing procedures and mechanisms to ensure the safe handling and storage of any substance
that may pose a threat to public health and safety. The CFC regulates the use, handling, and storage
requirements for hazardous materials at fixed facilities. The CFC and the California Building Code use a hazard
classification system to determine what protective measures are required to protect fire and life safety. These
measures may include construction standards, separation from project site lines, and specialized equipment. To
ensure that these safety measures are met, the CFC employs a permit system based on hazard classification. The
CFC is updated every three years.
California Natural Disaster Assistance Act
The California Natural Disaster Assistance Act provides financial aid to local agencies to assist in the permanent
restoration of public real property, other than facilities used solely for recreational purposes, when such real
property has been damaged or destroyed by a natural disaster. The California Natural Disaster Assistance Act is
activated after a local declaration of emergency, after the California Emergency Management Agency gives
concurrence with the local declaration, or after the Governor issues a proclamation of a state emergency. Once
the California Natural Disaster Assistance Act is activated, local government is eligible for certain types of
assistance, depending upon the specific declaration or proclamation issued.
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California State Fire Plan
The 2010 California State Fire Plan is the first statewide fire plan developed in concert between the California
Board of Forestry and Fire Protection and the California Department of Forestry and Fire Protection (CAL FIRE).
The central goals of the California State Fire Plan include (1) improved availability and use of information on
hazard and risk assessment; (2) land use planning, including general plans, new development, and existing
developments; (3) shared vision among communities and the multiple fire protection jurisdictions, including
county-based plans and community-based plans such as community wildfire protection plans; (4) establishing fire
resistance in assets at risk, such as homes and neighborhoods; (5) shared vision among multiple fire protection
jurisdictions and agencies; (6) levels of fire suppression and related services; and (7) post-fire recovery.
Emergency Response to Hazardous Materials Incidents
California has developed an Emergency Response Plan to coordinate emergency services provided by federal,
state, and local government, and private agencies. The Emergency Response Plan is administered by the
California Emergency Management Agency and includes response to hazardous materials incidents. The
California Emergency Management Agency coordinates the response of other agencies, including CalEPA,
California Highway Patrol, California Department of Fish and Wildlife, the RWQCBs, San Diego Air Pollution Control
District, City of San Diego Fire Department, and the DEH Hazardous Incident Response Team.
Cortese List
The Hazardous Waste and Substance Sites Cortese List is a planning document used by the state, local agencies, and
developers to comply with CEQA requirements in providing information about the location of hazardous materials
release sites. Government Code Section 65962.5(a) requires CalEPA to develop at least annually an updated Cortese
List. DTSC is responsible for a portion of the information contained in the Cortese List. Other state and local
government agencies are required to provide additional hazardous materials release information for the Cortese List.
Hazardous Materials Release Response Plans and Inventory
Two programs found in California Health & Safety Code Chapter 6.95 are directly applicable to the CEQA issue of
risk due to hazardous substances release: the Hazardous Materials Business Plan program and the CalARP
program. In the San Diego region, DEH is responsible for implementing the Hazardous Materials Business Plan
and CalARP programs, which provide threshold quantities for regulated hazardous substances. When the
indicated quantities are exceeded, a Hazardous Materials Business Plan or Risk Management Plan is required
pursuant to the regulation. Congress requires the EPA Region 9 to make Risk Management Plan information
available to the public through the EPA’s Envirofacts Data Warehouse. The Envirofacts Data Warehouse is
considered the single point of access to select EPA environmental data.
Senate Bill 1889 – Accidental Release Prevention Law/CalARP Program
Senate Bill 1889 required California to implement a new federally mandated program governing the accidental
airborne release of chemicals promulgated under Section 112 of the Clean Air Act. Effective January 1, 1997, the
Accidental Release Prevention Law/CalARP replaced the previous California Risk Management and Prevention
Program and incorporated the mandatory federal requirements. CalARP addresses facilities that contain specified
hazardous materials (known as regulated substances) that if involved in an accidental release, could result in
adverse off-site consequences. CalARP defines regulated substances as chemicals that pose a threat to public
health and safety or the environment because they are highly toxic, flammable, or explosive.
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State Fire Regulations
State fire regulations are set forth in Sections 13000 et seq. of the California Health and Safety Code, and include
regulations concerning building standards (as also set forth in the CBC), fire protection and notification systems,
fire protection devices such as extinguishers and smoke alarms, high-rise building and childcare facility
standards, and fire suppression training. The State Fire Marshal enforces these regulations and building
standards in all state-owned buildings, state-occupied buildings, and state institutions throughout California.
Title 14 Division 1.5 of the California Code of Regulations
Title 14 Division 1.5 of the California Code of Regulations establishes the regulations for CAL FIRE and is
applicable in all State Responsibility Area areas where CAL FIRE is responsible for wildfire protection.
Development within State Responsibility Area areas must comply with these regulations. Among other things, Title
14 establishes minimum standards for emergency access, fuel modification, project site line setbacks, signage,
and water supply.
Title 22 of the California Code of Regulations and Hazardous Waste Control Law, Chapter 6.5
The DTSC regulates the generation, transportation, treatment, storage and disposal of hazardous waste under
RCRA and the California Hazardous Waste Control Law. Both laws impose “cradle to grave” regulatory systems for
handling hazardous waste in a manner that protects human health and the environment. CalEPA has delegated
some of its authority under the Hazardous Waste Control Law to county health departments and other Certified
Unified Program Agencies, including the DEH.
Underground Storage Tank Act
The Underground Storage Tank Act monitoring and response program is required under Chapter 6.7 of the
California Health & Safety Code and Title 23 of the California Code of Regulations. The program was developed to
ensure that facilities meet regulatory requirements for design, monitoring, maintenance, and emergency
response in operating or owning underground storage tanks. DEH is the administering agency for this program in
the project area.
California Occupational Safety and Health Administration
Cal/OSHA is the primary agency responsible for worker safety in the handling and use of chemicals in the
workplace. Cal/OSHA standards are required to be “as effective as” federal regulations. The employer is required
to monitor worker exposure to listed hazardous substances and notify workers of exposure (8 CCR 330 et seq.).
The regulations specify requirements for employee training, availability of safety equipment, accident prevention
programs, and hazardous substance exposure warnings. The employer is also required, among other things, to
have an Illness and Injury Prevention Program.
Cal/OSHA Asbestos and Carcinogen Unit
Cal/OSHA Asbestos and Carcinogen Unit enforces asbestos standards in construction, shipyards, and general
industry. This includes identification and removal requirements of asbestos in buildings, as well as health and
safety requirements of employees performing work under the Asbestos-In-Construction regulations (8 CCR 1529).
Only a Cal/OSHA-Certified Asbestos Consultant can provide asbestos consulting (as defined by the Business and
Professions Code, 7180–7189.7, and triggered by the same size and concentration triggers as for registered
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contractors). These services include building inspection, abatement project design, contract administration,
supervision of site surveillance technicians, sample collection, preparation of asbestos management plans, and
clearance air monitoring.
California Department of Public Health
The California Department of Public Health enforces lead laws and regulations related to the prevention of lead
poisoning in children, prevention of lead poisoning in occupational workers, accreditation and training for
construction-related activities, lead exposure screening and reporting, disclosures, and limitations on the amount
of lead found in products. Accredited lead specialists are required to find and abate lead hazards in a
construction project and to perform lead-related construction work in an effective and safe manner.
Local
San Diego County of Department of Environmental Health
The DEH protects public health and safeguards environmental quality, educates the public to increase
environmental awareness, and implements and enforces local, state, and federal environmental laws. The DEH
regulates the following: retail food safety; public housing; public swimming pools; small drinking water systems;
mobile-home parks; on-site wastewater systems; recreational water; oversight and cleanup of aboveground
storage tanks and underground storage tanks; and medical and hazardous materials and waste.
County of San Diego Office of Emergency Services
The Unified San Diego County Emergency Services Organization has primary responsibility for preparedness and
response activities, and addresses disasters and emergency situations within the unincorporated area of the
County of San Diego (County). The County of San Diego Office of Emergency Services serves as staff to the Unified
Disaster Council, the governing body of the Unified San Diego County Emergency Services Organization.
Emergency response and preparedness plans include the Operational Area Emergency Response Plan and the
County Multi-Jurisdictional Hazard Mitigation Plan.
San Diego Air Pollution Control District
Under Regulation XI, Subpart M – National Emission Standards for Asbestos, Rule 361.145 – Standard for
Demolition and Renovation, the San Diego Air Pollution Control District requires that the proponent of a proposed
demolition or renovation project submit an Asbestos Demolition or Renovation Operational Plan (“Notice of
Intention”) at least 10 days prior to the onset of any asbestos stripping or removal work. It should be noted that
the Notice of Intention is required for all demolition projects, regardless of the presence of asbestos.
Multi-Jurisdictional Hazard Mitigation Plan
The Multi-Jurisdictional Hazard Mitigation Plan includes an overview of the risk assessment process, vulnerability
assessments, and identifies hazards present in each jurisdiction of the County. Hazards profiled in the plan
include wildfire, structure fire, flood, coastal storms, erosion, tsunami, earthquakes, liquefaction, rain-induced
landslide, dam failure, hazardous materials incidents, nuclear materials release, and terrorism. The plan sets
forth a variety of objectives and actions based on a set of broad goals including the following: (1) promoting
disaster-resistant future development; (2) increased public understanding and support for effective hazard
mitigation; (3) building support of local capacity and commitment to become less vulnerable to hazards; (4)
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enhancement of hazard mitigation coordination and communication with federal, state, local and tribal
governments; and (5) reducing the possibility of damage and losses to existing assets, particularly people, critical
facilities or infrastructure, and County-owned facilities, due to dam failure, earthquake, coastal storm, erosion,
tsunami, landslides, floods, structural fire/wildfire, and human-made hazards.
San Diego County Site Assessment and Mitigation Program
The DEH maintains the Site Assessment and Mitigation list of contaminated sites that have previously or are
currently undergoing environmental investigations and/or remedial actions. The San Diego County Site
Assessment and Mitigation Program has a primary purpose to protect human health, water resources, and the
environment within the County by providing oversight of assessments and cleanups in accordance with the
California Health and Safety Code and the California Code of Regulations. The Site Assessment and Mitigation
Program’s Voluntary Assistance Program also provides staff consultation, project oversight, and technical or
environmental report evaluation and concurrence (when appropriate) on projects pertaining to properties
contaminated with hazardous substances.
Poway Comprehensive Plan: General Plan
The Poway Comprehensive Plan: General Plan (General Plan) includes the following policies regarding hazards
and hazardous materials (City of Poway 1991).
Goal VII: It is the goal of the City of Poway to provide a safe and healthy environment for the residents of Poway.
Policy B – Fire Protection: The City shall maintain a high standard of fire protection services.
Strategy 1: Encourage the development, implementation and public awareness of fire prevention programs.
Strategy 2: Implement programs to reduce the quantity of combustible vegetative materials in the City to
reduce wildland fire hazards including a brush management program subject to approval by the City.
Strategy 3: Continue the use of the Weed Abatement Program and a fire buffer program along heavily
traveled roads through thinning disking or controlled burning subject to air quality standards. Brush, not
trees, should be cleared from both sides of major arterials.
Strategy 4: The existing rows of eucalyptus trees should be trimmed periodically and combustible
vegetative materials at the tree base should be periodically removed.
Strategy 5: All proposed development shall satisfy the minimum structural fire protection standards
contained in the adopted editions of the Uniform Fire and Building Codes; however, where deemed
appropriate, the City shall enhance the minimum standards to provide optimum protection.
Strategy 6: Fire protection requirements shall be expanded where structural and/or capital improvements
cannot adequately protect the community from property damage or potential loss of life.
Strategy 7: Study the feasibility of regulations requiring the installation of a sprinkler system at the time of
construction of new residential structures, and in conjunction with expansion or substantial interior
remodeling of existing structures.
Strategy 8: Require fire retardant roofing materials based upon the type of construction in and outside of
high fire hazard areas.
Strategy 9: Enforce the fire control requirements of the City’s landscape standards.
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Strategy 10: In order to minimize fire hazards, the Poway Fire Department shall routinely be involved in
the review of development applications. Consideration shall be given to adequate emergency access,
driveway widths, turning radii, fire hydrant locations and needed fire flow requirements.
Strategy 11: Advocate and support State legislation which would provide tax incentives encouraging the
repair or demolition of structures which are classified as high fire hazards.
Strategy 12: The construction of public facilities and transportation corridors shall be consistent with the
adopted standards of the Uniform Building Code and Uniform Fire Code.
Strategy 13: Fire stations shall be located on or near arterial roadways to provide for rapid response times.
Strategy 14: The timing of station construction shall relate to the rise of service demand in the
surrounding areas.
Strategy 15: The location of stations should consider existing and projected land uses and appropriate
buffering should be provided where necessary.
Strategy 16: Proposed Fire Station 3 shall be located in the South Poway Business Park.
Strategy 17: Emphasis on future construction and capital improvements should be toward the alleviation
of deficiencies in critical risk areas.
Strategy 18: Opportunities for joint-power agreement facilities and/or operations should be evaluated and
pursued where practical.
Strategy 19: Support mutual aid agreement and communication links with the County and the other
municipalities participating in the Unified San Diego County Emergency Service Organization.
Policy G – Hazardous Waste Management: The City supports the San Diego County Hazardous Waste Management
Plan and seeks its implementation by encouraging waste minimization, proper disposal of household hazardous
wastes and by establishing criteria for land use decisions regarding hazardous waste treatment facility siting.
Strategy 1: Encourage businesses to conduct waste minimization opportunity assessments to determine
their potential for source reduction and recycling and to achieve the County-wide goal of 30 percent
reduction in hazardous waste by 1994.
Strategy 2: Investigate the adoption of an ordinance to require businesses to prepare submit and
implement hazardous waste minimization plans.
Strategy 3: Consider establishing a reward program to recognize businesses that implement waste
minimization successfully and conducting a media campaign designed to recognize these businesses.
Strategy 4: Encourage safe and proper disposal of household hazardous waste; comply with Integrated
Waste Management Act requirements of no Household Hazardous Waste to landfills by 1995.
Strategy 5: Continue to encourage district collection events and seek an appropriate location to establish
a permanent community collection center Contaminated Sites.
Strategy 6: Seek to ensure timely and complete cleanup of contaminated sites.
Strategy 7: The siting criteria of the San Diego County Hazardous Waste Management Plan are
incorporated into the Poway General Plan by reference and shall be used to determine acceptable
locations and conditions for off-site hazardous waste treatment facilities.
Strategy 8: Ensure that off-site hazardous waste treatment facilities are subject to complete and thorough
local review.
Strategy 9: Encourage the coordination of facility siting responsibilities among Southern California’s local
governments through adoption and implementation of the Southern California Hazardous Waste
Management Authority Regional Plan Fair Share Policies and Regional Action Plan
4.8 – Hazards and Hazardous Materials
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City of Poway Municipal Code
Chapter 15.24 of the City’s Municipal Code (City of Poway 2019b) outlines the Fire Code, which provides for
the preparation and carrying out of plans for the protection of persons and property within the City in the
event of an emergency. It also discusses the building standards for residential and commercial structures
within high fire severity zones.
Chapter 8.88 of the City’s Municipal Code discusses the acceptable use and abatement of hazardous
materials, vegetation, defensible space, and waste. The purpose and findings of this section declare that
(City of Poway 2019b):
The City of Poway is at serious risk of wildfire due to its terrain, with steep mountainous slopes and
valleys; a warm, dry climate; and highly flammable chaparral vegetation. For this reason, a
comprehensive strategy for reducing the risk of wildfire is necessary. This strategy includes the
creation of defensible space by clearing highly flammable chaparral vegetation around structures,
and the Vegetation Management Program, involving the removal of weeds and dry grasses from
private property.
The public health and safety are also threatened by the accumulation of waste material that is left out in
the open, such as rubbish, crates, cartons, metal and glass containers, and vehicle bodies and parts. This
chapter also provides for the abatement of accumulated waste material that has been determined to be a
public nuisance.
Hazardous substances and hazardous wastes present in the community may pose acute and chronic
health hazards to individuals who live and work in the City, and who are exposed to such substances as a
result of fires, spills, industrial accidents, or other types of releases or emission.
The people who live and work in the City have a right and need to know of the use and potential hazards
of hazardous materials.
Basic information on the location, type, quantity and the health risks of hazardous materials used, stored,
or disposed of in the City is not now available to firefighters, health officials, health care providers,
planners, elected officials, and residents.
It is the intent of the City Council that this section through PMC [Poway Municipal
Code] 8.88.130 recognize the community’s right and need for basic information on the use and disposal
of hazardous materials in the City and that it establish an orderly system for the provision of such
information including appropriate education and training for use of information.
It is further the intent of the City Council that the system of disclosure set forth through
PMC 8.88.130 shall provide the information essential to firefighters, health officials, health care
providers, planners, elected officials and residents in meeting their responsibilities for the health and
welfare of the community in such a way that the statutory privilege of trade secrecy is not abridged.
(Ord. 94 § 1, 1983; Ord. 29 § 1, 1981; CC § 68.641)
It is the intent of the City Council that the Health Officer establish a program to monitor establishments
where hazardous wastes are produced, stored, handled, disposed of, treated or recycled. It is further the
intent of the City Council that the Health Officer provide health care information and other appropriate
technical assistance on a 24-hour basis to emergency responders in the event of a hazardous waste
incident involving community exposure. (Ord. 95 § 2, 1983; Ord. 29 § 1, 1981; CC § 68.901)
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City of Poway Landscape and Irrigation Design Manual
The City’s Landscape and Irrigation Design Manual provides for the requirements for the establishment of
irrigation systems for the purpose of providing consistency with the City’s General Plan and Municipal Code.
Section 4 of the manual, Vegetative Fuel Management in Very High Fire Hazard Areas, establishes the following
requirements for the City (City of Poway 2018):
1. Vegetative Fuel Management Plans
Plans shall be approved prior to fuel modification work. Plans shall be based on site plans and grading
plans showing elevation contours (slopes). Plans shall indicate the widths of the fuel modification zones on
the site, including slopes. Plans shall include, at a minimum: (1) plan showing existing vegetation; and, (2)
grading plans showing location of proposed structures and setback from top of slope to all structures.
2. Fuel Modification Installations
All fuel modification work shall be completed prior to the final inspection for issuance of a certificate
of occupancy.
3. Plant Selection and Removal
Plant lists at the end of this Section (Tables 4-1 and 4-2) suggest species that should be avoided or
removed, and are acceptable fire-resistant species. Prior to removal of vegetation, consult a qualified
professional landscape architect or biologist to identify desirable native plants to remain. Removal of
native trees, as outlined in Chapter 12.32 PMC, URBAN FORESTRY, requires a separate Tree Removal
Permit from the City. Native tree species are defined in the City of Poway Urban Forestry Ordinance.
4. Tree Pruning
4.1 Native trees to be retained within fuel modification zones shall be pruned to maintain a vertical
separation of not less than six (6) feet above underlying groundcover. If shrubs are located
underneath the drip line of a tree, the lowest branch should be at least three times as high as the
understory shrubs or 10 feet, whichever is greater. Pruning of the shrubs and groundcover will
minimize the impact of the tree pruning.
4.2 Trees shall not be topped, as defined in the City of Poway Urban Forestry Ordinance.
4.3 Tree pruning work shall be in accordance with the standards of the International Society of
Arboriculture (ISA), Western Chapter. Refer to Section Four, Landscape Planting
Requirements, herein for pruning standards.
City of Poway Habitat Conservation Plan/Natural Community Conservation Plan
Section 6.2.2.1 of the Poway Subarea Habitat Conservation Plan/Natural Community Conservation Plan (Poway
Subarea HCP/NCCP) (City of Poway 1996) provides for management strategies for the prevention of wildfires. Fire
management can focus on two potentially different objectives: (1) achievement of biological resources goals, and
(2) hazard reduction for humans and their property. Biological resources goals recognize that fire is a natural
process in ecosystems. These goals include maintaining or restoring specific species; rejuvenating vegetation
communities; creating vegetation mosaics that favor increased animal species diversity; providing habitat for
species characteristic of early post-fire landscapes; and controlling exotic plant species invasions. Fire
management can also affect restoration of disturbed habitats and site hydrology, which will directly impact habitat
value for wildlife. Fire management for human hazard reduction involves reducing fuel loads in areas where fire
may threaten human safety or property, and suppressing fires once they have started. Provision for access of fire
suppression equipment and personnel is important to achieving safety goals.
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4.8.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts related to hazards and hazardous materials are
based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant
impact related to hazards and hazardous material would occur if the project would:
1. Create a significant hazard to the public or the environment through the routine transport, use, or
disposal of hazardous materials.
2. Create a significant hazard to the public or the environment through reasonably foreseeable upset and
accident conditions involving the release of hazardous materials into the environment.
3. Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste
within one-quarter mile of an existing or proposed school.
4. Be located on a site which is included on a list of hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as result, would it create a significant hazard to the public
or the environment.
5. Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan.
6. Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death
involving wildland fires.
4.8.4 Impacts Analysis
Would the project create a significant hazard to the public or the environment through the routine transport, use,
or disposal of hazardous materials?
Construction
Construction of the proposed project would involve the transport of commonly used hazardous substances, such
as gasoline, diesel fuel, lubricating oil, grease, and solvents. These materials would be used and stored in
designated construction staging areas within the boundaries of the project site, and once the proposed project
has been constructed, any remaining materials would be transported off site. These materials would be
transported, handled, and disposed of in accordance with all applicable federal, state, and local laws and
regulations pertaining to the management and use of hazardous materials. Consequently, use of these materials
for their intended purpose would not pose a significant risk to the public or environment. Therefore, construction
impacts would be less than significant.
Operational
The operational phase of the proposed project would not create a significant hazard to the public or the
environment through the routine transport, use, or disposal of hazardous materials. The proposed project involves
residential dwellings with associated landscape and facility maintenance. The open space features of the
proposed project would include community gardens, specialty gardens, and agrifields.
Hazardous materials associated with the residential dwellings, associated landscape, and facility maintenance
would be limited to private use of commercially available cleaning products, landscaping chemicals and fertilizers,
and various other commercially available substances. Although the proposed project would introduce dwelling
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units to the site resulting in an increased use of commercially available potentially hazardous materials, the use
of these substances would be subject to all applicable federal, state, and local health and safety laws and
regulations that are intended to minimize health risk to the public associated with hazardous materials. More
specifically, as stated in Chapter 3, Land Use, of The Farm in Poway Specific Plan (Specific Plan), “All agricultural
uses shall comply with the applicable permits and regulations enforced by the California Department of
Agriculture and County of San Diego Department of Agriculture” (The Farm in Poway LLC 2020). The agrifields
would potentially use commercially available fertilizers, pesticides, and other regulated materials commonly used
in agricultural operations. While organic and biodynamic farming practices are preferred, as stated in the Specific
Plan, limited use of pesticides may be permitted when other Integrated Pest Management methods have proven
to be ineffective. To ensure compatibility of agricultural operations with residential uses, as previously stated, any
chemical or pesticide use shall be in compliance with the applicable permits and regulations enforced by the
California Department of Agriculture and County of San Diego Department of Agriculture (The Farm in Poway LLC
2020). Additionally, agricultural operations are addressed in the Stormwater Quality Management Plan prepared
for the proposed project in January 2020 (Appendix G). Structural best management practice (BMP)
recommendations specifically suited to address expected pollutants from agricultural uses and amenities are
provided in the Stormwater Quality Management Plan. These regulations and structural BMPs would guide the
use of these materials so that a significant hazard to the public or the environment would not occur. Therefore,
impacts related to the operational phase of the proposed project would be less than significant.
Would the project create a significant hazard to the public or the environment through reasonably foreseeable
upset and accident conditions involving the release of hazardous materials into the environment?
Construction
As mentioned above, the potential materials used during the proposed project construction phase may be
deemed hazardous; however the proposed project would be required to follow all federal, state, and local
policies regarding the use, transportation, and removal of these products. Additionally, in the event of a
reasonably foreseeable upset and accident regarding the release of hazardous materials, procedures and
policies would be followed to remove the materials in a safe and timely manner. The State of California Office
of Emergency Services provides a Hazardous Material Incident Contingency Plan, which outlines the
procedures and responsibilities of agencies and private organizations concerning hazardous materials
emergencies (CalOES 1991).
The golf course was constructed in 1962. Therefore, many of the structures onsite have the potential to contain
asbestos-containing materials, lead-based paint, and universal wastes; and electrical components, such as
transformers, could contain polychlorinated biphenyls (PCBs). Should demolition or alteration occur without
proper identification and abatement of these hazardous building materials, this could pose a significant hazard to
the public or environment (Impact HAZ-1). Prior to demolition or renovation of these structures, survey for, and
abatement of, any hazardous building materials would be required to incorporate mitigation measures in
accordance with MM-HAZ-1.
By following the appropriate procedures and policies outlined in the Hazardous Material Incident Contingency
Plan (CalOES 1991), and following the procedures outlined in MM-HAZ-1, the impact of a hazardous materials
accident to the environment during proposed project construction would be less than significant with mitigation.
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Operational
During the operational phase of the proposed project, hazardous materials associated with the residential
dwellings, associated landscape, and facility maintenance would be limited to private use of commercially
available cleaning products, landscaping chemicals and fertilizers, and various other commercially available
substances. The reasonably foreseeable likelihood that an accident or upset would occur is very low, and it is
assumed that there would not be a significant hazard to the public or the environment. As stated above, to ensure
compatibility of agricultural operations with residential uses, any chemical or pesticide use shall be in compliance
with the applicable permits and regulations enforced by the California Department of Agriculture and County of
San Diego Department of Agriculture (The Farm in Poway LLC 2020). Additionally, agricultural operations are
addressed in the Stormwater Quality Management Plan (Appendix G). Structural BMP recommendations
specifically suited to address expected pollutants from agricultural uses and amenities are provided in the
Stormwater Quality Management Plan. These regulations and structural BMPs would guide the use of these
materials so that a significant hazard to the public or the environment would not occur. Therefore, this impact
would be less than significant.
Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or
waste within one-quarter mile of an existing or proposed school?
Painted Rock Elementary School is located at 16711 Martincoit Road, approximately 0.16 miles south of
the project site. Thus the project site is within one-quarter mile of the elementary school and analysis is
provided below.
Construction Impacts
Construction of the proposed project would entail transport, use, or disposal of potentially hazardous materials
including, but not limited to, diesel fuel, gasoline, equipment fluids, concrete, cleaning solutions and solvents,
paints, lubricant oils, adhesives, dust, human waste, and chemical toilets. Direct impacts to human health and
biological resources from accidental spills of small amounts of hazardous materials from construction equipment
during proposed construction could occur with the transport, use, or disposal of these materials. However, existing
federal and state standards are in place for the handling, storage, and transport of these materials and would be
implemented during construction of the proposed project (as described in Section 4.8.2, Relevant Plans, Policies,
and Ordinances). Additionally, implementation of MM-HAZ-1 would occur prior to demolition or renovation of existing
structures, thereby properly managing potential emissions of hazardous building materials (asbestos, lead-based
paint, PCBs) from the project site. Impacts to nearby schools as a result of construction would be less than
significant with mitigation.
Operational Impacts
Once operational, hazardous materials associated with the residential dwellings, associated landscape, and
facility maintenance would be limited to private use of commercially available cleaning products, landscaping
chemicals and fertilizers, and various other commercially available substances. Although the proposed project
would introduce dwelling units to the site resulting in an increased use of commercially available potentially
hazardous materials, the use of these substances would be subject to all applicable federal, state, and local
health and safety laws and regulations that are intended to minimize health risk to the public associated with
hazardous materials.
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The agrifields would potentially use commercially available fertilizers, pesticides, and other regulated materials
commonly used in agricultural operations. While organic and biodynamic farming practices are preferred, as
stated in the Specific Plan, limited use of pesticides may be permitted when other Integrated Pest Management
methods have proven to be ineffective. As stated above, to ensure compatibility of agricultural operations with
residential uses, any chemical or pesticide use shall be in compliance with the applicable permits and regulations
enforced by the California Department of Agriculture and County of San Diego Department of Agriculture (The
Farm in Poway LLC 2020). Additionally, agricultural operations are addressed in the Stormwater Quality
Management Plan (Appendix G). Structural BMP recommendations specifically suited to address expected
pollutants from agricultural uses and amenities are provided in the Stormwater Quality Management Plan. These
regulations and structural BMPs would guide the use of these materials so that a significant hazard to the public
or the environment would not occur.
Although the project site is within one-quarter mile of a school, by following federal, state, and local policies
regarding hazardous waste transportation and removal during operation, as well as the localized private nature of
hazardous waste during operation, the proposed project would have a less-than-significant impact on the existing
school, Painted Rock Elementary.
Would the project be located on a site that is included on a list of hazardous materials sites compiled
pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to
the public or the environment?
As discussed in Section 4.8.1, Existing Conditions, a former LUST case is located at the southwest corner of the
project site, as shown on Figure 4.8-1. While this case received regulatory closure from the San Diego RWQCB,
MTBE contamination was allowed to remain in groundwater on the project site (Impact HAZ-2). The closure letter
included the following advisories, should the property be redeveloped (San Diego RWQCB 2015):
1. Any land use changes for the site may require reevaluation to determine of the changes pose an
unacceptable risk to public health;
2. Any contaminated soil encountered or excavated as part of future subsurface construction/utility work
must be managed in accordance with all applicable legal and regulatory requirements; and
3. All future construction on the project must include post construction best management practices to
control stormwater runoff in compliance with the US EPA Guidance Document: “Technical Guidance on
Implementing the Stormwater Runoff Requirements for Federal Projects under Section 438 of the Energy
Independence and Security Act.”
In addition to the Workplan for residential development of the project site (Geocon 2017), the San Diego RWQCB
requested additional measures to be implemented in the Workplan, and requested a Soil Management Plan for
excavation and management of soils near the former underground storage tank area (McClain 2017).
Advisories 2 and 3 of the closure letter require management of excavated soils and stormwater in accordance
with applicable federal, state, and local laws and regulations, which are also outlined in Section 4.8.2. However,
assessment and management of potentially contaminated soils, groundwater, and soil vapor would require
mitigation measures in accordance with MM-HAZ-2. Following implementation of these measures, impacts would
be less than significant with mitigation.
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Would the project impair implementation of or physically interfere with an adopted emergency response plan or
emergency evacuation plan?
The City does not currently have an adopted emergency response plan or emergency evacuation plan; however
they do include information on the City’s website regarding personal preparation during an emergency (City of
Poway 2019c). This information is related to personal planning before an emergency occurs, as well as the
specific details of where to meet with separated family members during an emergency and responding to law
enforcement and fire officers.
The PFD has necessary turnarounds and turnouts for fire apparatus access roads within the project area to
provide access to all structures—all of which conform to the required diameter for turnarounds and turnouts. All
new roads in the City—including any that would be constructed as part of the proposed project—must follow PFD’s
protocol to ensure adequate emergency access (PFD 2013).
Additionally, Section 3.12, Fire Prevention Regulation, of the Specific Plan includes the following policies
regarding fire access roadways (The Farm in Poway LLC 2020):
Fire apparatus access roads shall have an unobstructed, improved width of not less than 20 feet, except
single-family residential driveways serving no more than two improved parcels containing dwelling units shall
have a minimum of 16 feet of unobstructed improved width. Vertical overhead clearance shall be a minimum
of 13.5 feet. Fire apparatus access roads and driveways shall be designed and maintained to support the
imposed loads of fire apparatus not less than 75,000 pounds unless authorized by the Poway Fire Department
and shall be provided with an approved paved surface as to provide all-weather driving capabilities. When
deemed necessary in the opinion of the fire code official, a paved driving surface shall mean asphalt or
concrete surface. The turning radius of a fire apparatus access road shall be a minimum of 28 feet as
measured to the inside edge of the improvement width or as approved by the fire code official.
Fire access roadways, gated entrances with card readers, guard stations, or center medians, which have
separated lanes of one-way traffic shall be not less than 12 feet wide per lane.
For all non-residential facilities or buildings, approved fire apparatus access roadways shall be provided
for every facility, building or portion of a building. The fire apparatus access roadway shall extend to within
150 feet of all portions of the facility and all portions of the exterior walls of the first story of the building
as measured by an approved route around the exterior of the building or facility.
The gradient for a fire apparatus access roadway shall not exceed 20 percent. Grades exceeding 15
percent (incline or decline) shall be constructed of Portland cement concrete (PCC), with a deep broom
finish perpendicular to the direction of travel, or equivalent, to enhance traction. The fire code official may
require additional mitigation measures where he or she deems appropriate.
The angle of departure and the angle of approach of a fire access roadway shall not exceed seven
degrees (12 percent) or as approved by the fire code official.
All dead-end fire access roads in excess of 150 feet in length shall be provided with approved provisions
that allow emergency apparatus to turn around. For these fire access roads in excess of 150 feet in
length, a cul-de-sac shall be provided in residential areas where the access roadway serves more than
two structures. The minimum, unobstructed paved radius width for a cul-de-sac shall be 38 feet in
residential areas.
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All gates or other structures or devices that could obstruct fire access roadways or otherwise hinder
emergency operations are prohibited unless they meet the standards approved by the fire code official
and receive Specific Plan approval. All automatic gates across fire access roadways and driveways shall
be equipped with approved, emergency, key-operated switches overriding all command functions and
opening the gate(s). Gates accessing more than four residences or residential lots, or gates accessing
hazardous institutional, educational or assembly occupancy group structures shall also be equipped with
approved emergency traffic control-activating strobe light sensor(s), or other devices approved by the fire
code official, which will activate the gate on the approach of emergency apparatus with a battery backup
or manual-mechanical disconnect in case of power failure. In the event of a power failure, the gate shall
be automatically transferred to a fail-safe mode allowing the gate to be manually pushed open without
the use of special knowledge or equipment. All automatic gates must meet fire department policies
deemed necessary by the fire code official for rapid, reliable access. Where this section requires an
approved key-operated switch, it shall be dual keyed or dual switches shall be provided to facilitate
access by law enforcement personnel.
The Specific Plan’s circulation and development standards have been designed with consideration of natural and
other disasters that may occur by providing adequate access for emergency services, evaluating adequacy of
emergency services to provide service to the increased population, and reducing the risk of fire and other
potential emergencies through design and maintenance standards. Further, as stated in the Specific Plan, any
gages, structures, or devices that could obstruct fire access roadways or otherwise hinder emergency operations
would be prohibited unless they meet the standards approved by the Fire Code official and receive appropriate
building and planning permits from the City (The Farm in Poway LLC 2020). See also Section 4.17.4 of this EIR for
potential impacts related to wildfire.
Further, the proposed project would result in increased access to Espola Road, thereby enhancing emergency
egress and ingress in the event of an emergency or evacuation. Residents within the vicinity of the proposed
project would have increased pedestrian accessways and bikeways, as well as a new road that connects at
Martincoit Road and Espola Road. Also, PFD Fire Station 2 is less than one-half mile from the project site, fronting
Espola Road. Thus, the proposed project would not impair implementation of or physically interfere with an
adopted emergency response plan or emergency evacuation plan; therefore the proposed project’s impact would
be a less than significant.
Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or
death involving wildland fires?
A relatively small area in the northeast portion of the project site is located within a Very High Fire Hazard Area
(CAL FIRE 2009; The Farm in Poway LLC 2020). That area has a R-H land use designation and all proposed
homes within that area would be subject to the R-H development standards. Development standards for the R-H
land use district reflect the fire hazard designation in this area and include additional setback and building
standards. However, a majority of the project site is not adjacent to wildlands, has been previously developed,
and is located in an area surrounded by residential uses. Compliance with all applicable existing laws, regulations,
and policies would reduce impacts associated with wildland fires. The proposed project would also be subject to
all of the requirements and recommendations of The Farm in Poway FMP (Appendix L). As discussed therein,
compliance with the FMP would significantly reduce the probability of flame impingement from wildfires burning
on the adjacent development and undeveloped properties, and of structure loss due to the onslaught of airborne
embers (Appendix L). See Table 4.0, Table of Required Actions, in Appendix L for additional information.
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The proposed project would also be required to pay a fire protection impact fee per dwelling unit, which would
ensure fire response times are adequately met throughout the City (Section 105.3.9 in City of Poway 2019b).
Additionally, the proposed project would incorporate site design, maintenance practices, fuel modification
zones, and fire resistant landscaping to protect properties and reduce risks, consistent with the General Plan,
Chapter 15 of the City’s Municipal Code, the FMP, and Section 3.12 of the Specific Plan. Further, as previously
described, the proposed project would result in increased access to Espola Road by providing additional
pedestrian accessways and bikeways and a new road that connects at Martincoit Road and Espola Road—
thereby enhancing emergency egress and ingress in the event of an emergency or evacuation. Also, PFD Fire
Station 2 is less than one-half mile from the project site, fronting Espola Road. Therefore, impacts would be
less than significant. For additional information regarding wildfires, see Section 4.17, Wildfire, of this EIR.
The proposed project’s impacts as related to hazards and hazardous materials are listed as follows:
Impact HAZ-1 Many of the structures on the project site have the potential to contain asbestos-containing
materials, lead-based paint, and universal wastes; and electrical components, such as
transformers, which could contain PCBs. Should demolition or alteration occur without proper
identification and abatement of these hazardous building materials, this could pose a significant
hazard to the public or environment.
Impact HAZ-2 A former LUST case is located at the southwest corner of the project site. While this case received
regulatory closure from the San Diego RWQCB, MTBE contamination was allowed to remain in
groundwater on the project site. Contaminated groundwater could pose a significant hazard to
the public or environment should the site be redeveloped.
4.8.5 Cumulative Impacts
The geographic scope of the cumulative impact analysis for hazards and hazardous materials is limited to projects
within the City limits (see Figure 3-11, Cumulative Projects, and Table 3-2, Cumulative Projects). Cumulative impacts
related to hazards and hazardous materials would result from projects within the City that combine and increase
exposure to hazards and hazardous materials. Cumulative projects with the potential to increase exposure include
St. Bartholomew’s Episcopal Church, Liguori Ranch, and the Vista Madera’s Subdivision.
Hazardous Materials
Hazardous soils, underground storage tanks, and other existing sources of hazardous materials are generally site
specific and handled on a project-by-project basis. The cumulative projects identified in Table 3-2 would be
expected to have little effect on the exposure to, or the chances of, release of hazardous materials because
proposed land uses associated with the cumulative projects do not typically involve large quantities of potentially
hazardous materials. Further, cumulative projects would be required to comply with all applicable federal, state,
and local standards regarding the handling, use, transportation, storage, and disposal of hazardous materials,
which are intended to minimize the risk to public health and the environment. As such, the proposed project
would not result in a cumulatively considerable impact related to the transportation, use, or storage of hazardous
materials or related to a hazardous materials site.
Schools
The potential to handle or emit hazardous materials within one-quarter mile of a school is generally site
specific. The proposed project would not result in construction or operational impacts to Painted Rock
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Elementary School due to existing federal, state, and local policies in place for the handling, storage, and
transport of these materials. Additionally, implementation of MM-HAZ-1 would occur prior to construction to
properly managing potential emissions of hazardous building materials (asbestos, lead-based paint, PCBs) from
existing structures on the project site. Finally, none of the cumulative projects identified in Table 3-2 are within
one quarter mile of Painted Rock Elementary School. Therefore, the impact on schools would be less than
significant and not cumulatively considerable.
Emergency Response/Emergency Evacuation Plans
Cumulative projects within the City would be required to comply with applicable emergency response and
evacuation policies outlined in regulations such as the Federal Response Plan, the California Emergency Services
Act, local fire codes, and regional/jurisdictional emergency response and evacuation plans. Due to existing
regulations, cumulative projects would not result in a significant cumulative impact associated with the
implementation of emergency response and evacuation plans. The proposed project’s construction would take
place entirely on the project site, and existing access for emergency service providers would be maintained during
the entire construction phase and enhanced after development of the project is complete. Additionally, the
proposed project would not cause hazards to emergency response to aircrafts as no structures over 100 feet tall
are proposed. Thus, the proposed project would not contribute to a cumulative impact to emergency response
plans or emergency evacuation plans.
Wildland Fires
The potential for wildland fires resulting in the loss of life or property is generally unique to each site. All cumulative
projects are subject to the fire codes and regulations and, with some projects, the preparation of Fire Protection
Plans to determine the potential risk for wildland fires. Similar to the proposed project, other cumulative projects
would be required to include such features as fuel modification zones, fire access roads, and fire hydrants to reduce
the risk of potential wildland fires. Further, the proposed project would result in increased access to Espola Road by
providing additional pedestrian accessways and bikeways and a new road that connects at Martincoit Road and
Espola Road—thereby enhancing emergency egress and ingress in the event of an emergency or evacuation. Also,
PFD Fire Station 2 is less than one-half mile from the project site, fronting Espola Road. Any project in a given area
cannot be approved unless it is determined to meet the fire codes (e.g., fire retardant roof materials, increased
setbacks, fire sprinklers on structures) and regulations for the fire authority having jurisdiction over the cumulative
projects. The project site has been previously developed, and is located in an area surrounded by residential uses.
Through the proposed project’s compliance with the FMP and Specific Plan policies related to fire protection the
potential cumulative impacts from wildland fires would be less than significant.
4.8.6 Mitigation Measures
MM-HAZ-1 Prior to demolition or renovation of project site structures that were built before 1980, a hazardous
building materials survey shall be conducted by a California Department of Public Health (DPH)
Certified Asbestos Consultant and/or Certified Site Surveillance Technician and a California DPH
Certified Lead Inspector/Risk Assessor or Sampling Technician. A report documenting material
types, conditions and general quantities will be provided, along with photos of positive materials
and diagrams. Demolition or renovation plans and contract specifications shall incorporate any
abatement procedures for the removal of material containing asbestos, lead-based paint, universal
wastes and/or polychlorinated biphenyl (PCB)-containing equipment. All abatement work shall be
done in accordance with federal, state, and local regulations, including those of the U.S.
4.8 – Hazards and Hazardous Materials
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June 2020 4.8-23
Environmental Protection Agency (which regulates disposal), Air Pollution Control District,
Occupational Safety and Health Administration, U.S. Department of Housing and Urban
Development, California Occupational Safety and Health Administration (which regulates
employee exposure), and the South Coast Air Quality Management District.
MM-HAZ-2 The San Diego Regional Water Quality Control Board (San Diego RWQCB) is the regulatory
agency in charge of the former leaking underground storage tank (LUST) case on the project
site. Prior to construction or excavation activities in the area of the former LUST, San Diego
RWQCB will be consulted regarding requirements necessary to meet the advisories of the
LUST closure letter and requirements for residential development in order to protect human
health and the environment. Requirements set forth by the San Diego RWQCB will be
implemented prior to excavation and development of the project site. An example of these
requirements may include participation in the County of San Diego Department of
Environmental Health Voluntary Assistance Program and a soils management plan prepared
by a Geotechnical Engineer or Geologist.
4.8.7 Level of Significance After Mitigation
As discussed in this section, impacts associated with potential on-site hazardous materials would be mitigated
with implementation of MM-HAZ-1 and MM-HAZ-2. Additionally, the proposed project would comply with all
federal, state, and local policies and protocols mandating safe practices for use, transport, disposal, and
accidents, and thus would not create a significant hazard to the public from routine transport, use, or disposal of
hazardous materials. Finally, emissions and handling of hazardous or acutely hazardous materials within one-
quarter mile of Painted Rock Elementary School would be monitored and required to follow all legislative policies
and procedures.
Upon compliance with MM-HAZ-1 and MM-HAZ-2, all impacts related to hazards and hazardous materials would
be less than significant.
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FIGURE 4.8-1
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4.9 – Hydrology and Water Quality
The Farm in Poway EIR 11872
June 2020 4.9-1
4.9 Hydrology and Water Quality
This section describes the existing hydrology and water quality conditions of The Farm in Poway project (proposed
project) site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies
mitigation measures related to implementation of the proposed project. This analysis is based on the review of
existing resources; technical data; applicable laws, regulations, and guidelines; as well as the following technical
reports prepared for the proposed project:
Drainage Study for The Farm at Poway, prepared by Hunsaker & Associates in January 2020 (Appendix F
to this Environmental Impact Report [EIR])
Priority Development Project – Stormwater Quality Management Plan, prepared by Hunsaker & Associates
in January 2020 (Appendix G to this EIR)
A Notice of Preparation (NOP) was circulated from May 10, 2019, to June 10, 2019. During the NOP comment
period, comment letters related to hydrology and water quality focused on the following topics:
Drainage patterns
Wastewater quality
Drinking water quality
These comments were considered during the preparation of this EIR. The Initial Study, NOP, and Public Scoping
comments are provided in Appendix A of this EIR.
4.9.1 Existing Conditions
Hydrology
The site drains in a general southern direction with the exception of the northern portion of the site. Currently, the
project site has three total concrete brow ditches that convey on-site and off-site flows to two separate outflow
locations—one to the north and one to the south. An existing brow ditch conveys off-site flows from St. Andrews
Drive and flows from the southern portion of the StoneRidge Country Club south through the site discharging into
a triple arch culvert beneath Espola Road. Flows from Tam O’Shanter Drive and Cloudcroft Court are also
conveyed southerly through the project site, and are discharged into the same triple arch culvert beneath Espola
Road as described above. In the northern portion of the project site, flows from Boca Raton Lane flow into a brow
ditch and are routed to a pipe that conveys the flow underneath Valle De Lobo Drive and Villamoura Drive,
eventually discharging into the open space near Glen Arven Lane. The project site north of Tam O’Shanter Drive
drains in a northerly direction, eventually discharging into Sycamore Creek. The southerly part of the project site
flows towards Espola Boulevard, meeting flows from Tam O’Shanter and St. Andrews Drive before entering the
existing storm drain system. Southerly flows are eventually discharged into the Los Peñasquitos 906 Watershed.
The City of Poway Department of Public Works Storm Water and Flood Control Division manages and maintains the
stormwater drain lines within the City to collect stormwater runoff and help prevent flooding of developed areas. The
City is located within two watershed areas, Los Peñasquitos Watershed, which covers 61.7 percent of the City, and San
Dieguito Watershed, which covers the remaining area. The proposed project would fall within the San Dieguito
Watershed; however, southerly flows from the project site travel to the Los Peñasquitos 906 Watershed.
4.9 – Hydrology and Water Quality
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June 2020 4.9-2
Water Quality
The City’s strategy and policy direction is to reduce discharges of pollutants into the stormwater conveyance
system through implementation of best management practices (BMPs). In 2015, the City adopted the City of
Poway Jurisdictional Runoff Management Program, which includes implementation of BMP requirements, water
quality monitoring, educational outreach, municipal maintenance procedures, and inspection and enforcement
programs (City of Poway 2015). The City conducts annual storm drain facility rehabilitation and replacement
projects as needed. Development projects throughout the City are required to implement site-specific storm drain
improvements and contribute fees toward regional improvements.
Stormwater runoff collected from the project site may contain high sediment loads and many types of pollutants,
including oil and grease, chemicals, pesticides, heavy metals, bacteria, viruses, and oxygen-demanding
compounds. The primary method for treating stormwater from the project site involves a series of bioretention
basins, as described above. Stormwater from the project site is collected and conveyed to these basins via a
series of private catch basins and pipes located within private streets. Once collected, the bioretention basins are
designed to slow the velocity and volume of water, a process called hydromodification, and treat stormwater
through various processes collectively referred to as bioretention. Hydromodification is important to protecting
stormwater quality by preventing flooding, sedimentation, and erosion downstream. Flooding of areas that are
normally dry can result in chemicals, fuel, trash, bacteria and other potential pollutants entering the natural
drainage system. Sedimentation and erosion can also damage the environment by altering the physical
characteristics of water bodies that provide habitat for plant and animal species. Biofiltration is important to
protecting stormwater quality by removing potential pollutions within water prior to leaving the site.
Groundwater
The project site is not located within a known groundwater basin. The nearest groundwater basin to the project site
is Poway Valley Groundwater Basin (PVGB), located approximately 2.5 miles south (SanGIS 2007). A Geologic
Reconnaissance for the proposed project was prepared by Geocon Inc. in April 2019, and included as Appendix E to
this EIR. No groundwater or seepage was observed on the project site during the geologic reconnaissance (Appendix
E). However, groundwater levels in the constructed ponds and drainage areas existing on site can be expected to
fluctuate seasonally and could affect grading of the site if the alluvial areas extend into the development footprint.
Flooding
Flood zones are areas that the Federal Emergency Management Agency (FEMA) has defined as a geographic
space that has varying levels of flood risk. These zones are depicted on a community’s Flood Insurance Rate
Map or Flood Hazard Boundary Map. Each respective map annotates different zones that reflect the severity or
type of flooding in the area. Although portions of the City are within a FEMA 100-year flood zone, the project
site is not located in a 100- or 500- year flood hazard zone (floodway or flood plain). According to the FEMA U.S.
Geological Survey map for the proposed project area, the project site is located in Zone X, an area of minimal
flood hazard (FEMA 2019).
Dam inundation areas are downstream areas subject to flooding as a result of an uncontrolled release from an
upstream reservoir, such as from breaks in levees or dams. The project site is located approximately 3.4 miles
south of Lake Hodges in Escondido, approximately 2.5 miles west of Lake Ramona, and approximately 1.7 miles
northwest of Lake Poway. The project site is not located within a dam inundation area. No other lakes or large
reservoirs are located in the vicinity of the project site.
4.9 – Hydrology and Water Quality
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June 2020 4.9-3
The project site is located approximately 14 miles inland from the Pacific Ocean, at a minimum elevation of
approximately 590 feet above mean sea level. Therefore, the project site would not be subject to inundation by
tsunami. The project site is generally gently sloping, with elevations ranging across the site from 590 to 775 feet
above mean sea level, respectively. The topography locally undulates where the existing golf fairways and greens
were graded for relief; however, no steep slopes, which could be subject to failure, are present on site.
4.9.2 Relevant Plans, Policies, and Ordinances
Federal
Federal Emergency Management Agency
FEMA is the primary federal agency for coordination with communities to establish effective floodplain
management standards. FEMA prepares Federal Insurance Rate Maps, which delineate the areas of special
flood hazards and applicable risk premium zones. The project site is located in Zone X, an area of minimal
flood hazard (FEMA 2019).
Under FEMA, the National Flood Insurance Program aims to reduce the impact of flooding on private and public
structures by providing affordable insurance to property owners and by encouraging communities to adopt and
enforce floodplain management regulations. These efforts help mitigate the effects on flooding on new and
improved structures. Overall, the program reduces the socio-economic impact of disasters by promoting the
purchase and retention of general risk insurance, but also of flood insurance specifically.
Clean Water Act
The Clean Water Act is the principal federal law for the regulation of water quality. The Clean Water Act
includes water quality standards, discharge limitations, and required permits. The fundamental purpose of
the Clean Water Act is the protection of designated beneficial uses of water resources. The 1987
amendments to the Clean Water Act includes provisions prohibiting discharges of pollutants contained in
stormwater runoff and requires many cities to obtain a National Pollutant Discharge Elimination System
(NPDES) permit to control urban and stormwater runoff.
Section 303(d) of the Clean Water Act defines water quality standards as consisting of both the uses of
surface waters (beneficial uses) and the water quality criteria applied to protect those uses (water quality
objectives). The State Water Resources Control Board (SWRCB) and the nine Regional Water Quality Control
Boards (RWQCBs) have been charged with ensuring that beneficial uses and water quality objectives are
established for all waters of the state.
State
California Environmental Quality Act
The California Environmental Quality Act (CEQA) (California Public Resources Code, Section 21000 et seq.) and
CEQA Guidelines (14 CCR 15000 et seq.) are primary sources for environmental legislation in California; they
require projects with potential adverse environmental effects (or impacts) undergo environmental review. Adverse
environmental impacts are typically mitigated as a result of the environmental review process in accordance with
existing laws and regulations.
4.9 – Hydrology and Water Quality
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California Porter–Cologne Water Quality Control Act
This legislation establishes the responsibilities and authorities of the state’s nine RWQCBs and the SWRCB. In
California, all surface waters and groundwater are considered to be “waters of the state” under this Act. The nine
RWQCBs are semi-autonomous and are comprised of seven part-time Board members, appointed by the Governor
and confirmed by the Senate. Regional boundaries are based on watersheds, and water quality requirements are
based on the unique differences in climate, topography, geology, and hydrology for each watershed. Each RWQCB
makes critical water quality decisions for its region, including setting standards, issuing permits (i.e., waste
discharge requirements), determining compliance with those requirements, and taking appropriate enforcement
actions. The project site is located with RWQCB Region 9, which includes San Diego, Imperial, and Riverside
counties. The SWRCB protects water quality by setting statewide policy, coordinating and supporting the RWQCB
efforts, and reviewing petitions that contest RWQCB actions.
Sustainable Groundwater Management Act of 2014
On September 16, 2014, Governor Jerry Brown signed into law a three-bill legislative package 2014 (Assembly
Bill 1739, Senate Bill 1168, and Senate Bill 1319) known as the Sustainable Groundwater Management Act of
2014. The legislation provides a framework for sustainable management of groundwater supplies by local
authorities in high- and medium-priority alluvial basins, as designated by the SWRCB. The groundwater
sustainability agency, which can be a county, city, or water district, must be formed by June 30, 2017, and
prepare a groundwater sustainability plan by January 31, 2022 (or January 31, 2020, for critically overdrafted
basins). Each plan requires implementation measures to bring each basin into sustainability within 20 years of
implementation of the plan. In San Diego County, four basins require plans, specifically the San Diego River
Valley Basin, the San Pasqual Valley Basin, the San Luis Rey River Basin, and the Borrego Valley Basin (all
medium-priority basins).
Geologic and soil conditions in the City are not conducive to the replenishment of the limited groundwater supply
that exists. Therefore, the City has existed and grown on imported water after the establishment of the Poway
Municipal Water District. However, some areas of the City are not served by the community water system. The
foothill and mountain areas of the eastern portion of the City must rely on groundwater pumped from wells to use
for potable water and to irrigate agriculture (City of Poway 1991).
Construction General Permit
As stated in Poway City Municipal Code Chapter 13.09.070-3, runoff at significant construction sites in the
City of Poway City are subject to any NPDES permit, and shall comply with such permit, which is: SWRCB,
Division of Water Quality, NPDES General Permit for Storm Water Discharges Associated with Construction
and Land Disturbance Activities, Order No. 2010-0014-DWQ, NPDES No. CAS000002 (City of Poway 2018a).
This General Permit authorizes discharges of stormwater associated with construction activity so long as the
dischargers comply with all requirements, provisions, limitations, and prohibitions in the permit. This General
Permit authorizes discharges of pollutants in stormwater associated with construction activity to waters of
the United States from construction sites that disturb one or more acres of land surface, or are part of a
common plan of development or sale that disturbs more than one acre of land surface. The NPDES permit
must require implementation of Best Available Technology Economically Achievable and Best Conventional
Pollutant Control Technology to reduce or eliminate pollutants in stormwater runoff (SWRCB 2018).
4.9 – Hydrology and Water Quality
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June 2020 4.9-5
Local
The Water Quality Control Plan for the San Diego Basin (Basin Plan)
The SWRCB carries out the regulation, protection, and administration of water quality within the state. The state is
divided into nine regions for the purposes of regional administration of California’s water quality control program,
and each region has its own RWQCB. The Water Quality Control Plan for the San Diego Basin (Basin Plan)
designates beneficial uses for water bodies in the San Diego region, and establishes water quality objectives and
implementation plans to protect those beneficial uses.
Any change to the Basin Plan requires a Basin Plan Amendment. All Basin Plan amendments are subject to a full
public participation and hearing process prior to adoption by the San Diego RWQCB. Basin Plan amendments also
much be approved by the SWRCB, Office of Administrative Law, and in many cases, the U.S. Environmental
Protection Agency. Basin Plan amendments become effective and are added to the Basin Plan document after
final approval by the Office of Administrative Law and/or the U.S. Environmental Protection Agency, as applicable.
State and federal laws require periodic review and update of the Basin Plan.
Municipal Separate Storm Sewer Systems Permit
In an effort to protect and enhance local creeks, the City implements water quality improvement and runoff
management in compliance with the RWQCB’s Order No. R9-2013-0001 as amended (the Municipal Separate
Storm Sewer Systems [MS4] Permit) (San Diego RWQCB 2018). The City enforces Chapter 22 of the Municipal
Code in accordance with the MS4 permit and implementation of a Jurisdictional Runoff Management Program,
and collaborates with other jurisdictions to implement and update Water Quality Improvement Plans on a
watershed basis.
County of San Diego Watershed Protection, Stormwater Management, and Discharge Control Ordinance
The County of San Diego Watershed Protection, Stormwater Management, and Discharge Control Ordinance
(WPO), effective February 26, 2016, contains discharge prohibitions and requirements that vary depending on
type of land use activity proposed and location within the County. The intent of the WPO is to protect water
resources and improve water quality through the uses of management practices aimed at reducing polluted
runoff. The requirements of the WPO are specifically intended to implement a Jurisdictional Runoff Management
Program in accordance with California RWQCB amended Order No. R9-2013-0001, NPDES No. CAS0109266
(County Public Works 2017).
The WPO is generally only implemented in unincorporated areas of the County (County Public Works 2017).
However, because the WPO is intended to prevent surface water quality impacts to County stormwater
conveyance systems, and project runoff would flow downstream through such County conveyance systems, the
WPO would be applicable to the proposed project. The proposed project meets the requirements of a WPO Priority
Development Plan under WPO Section 67.8111, Additional Planning, Design and Post-Construction Requirements
for Development Projects, Part (b) Additional Requirements for Priority Development Projects, due to the amount
of proposed impervious surfaces relative to the amount of existing pervious surfaces.
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June 2020 4.9-6
City of Poway Jurisdictional Runoff Management Program
On May 8, 2013, the San Diego RWQCB, adopted an updated NPDES Municipal Permit, Order No. R9-2013-
000, as amended by Order No, R9-2015-001. The Municipal Permit regulates the discharges into stormwater
conveyance systems within 18 Municipalities in San Diego County. Each co-permittee, including the City, were
required to develop a comprehensive Jurisdictional Urban Runoff Management Program. The City developed
the Jurisdictional Runoff Management Program (JRMP) in response to the permit order. The City’s approach to
following the permit entailed reducing discharges of pollutants to the stormwater conveyance system within the
City, by means of BMPs. Major components of the JRMP include the implementation of BMP requirements,
water quality monitoring, educational outreach efforts, municipal maintenance procedures, and water quality
monitoring procedures.
City of Poway Municipal Code – Chapter 13.09 – Stormwater Management and Discharge Control
The purpose of Chapter 13.09 of the City’s Municipal Code is to establish requirements for discharges into the
stormwater conveyance system, receiving waters, and the environment, to protect the stormwater conveyance
system from damage, and to meet the requirements of State and Federal law and the MS4 Permit. The chapter
also states that BMPs are required for all dischargers. The following requirements regarding BMPs will apply (City
of Poway 2018a):
1. Every responsible person as defined in Chapters 1.08 and 1.10 PMC [Poway Municipal Code]
undertaking any activity or use of premises that may cause or contribute to stormwater
pollution or contamination, illegal discharges, or non-stormwater discharges to the
stormwater conveyance system shall comply with BMP guidelines or pollution control
requirements, as may be established by the authorized enforcement official. BMPs shall be
maintained routinely throughout the life of the activity. Such BMPs include the minimum
BMPs set forth in the BMP Manual.
2. An authorized enforcement official may require any business or operations that are
engaged in activities which may result in pollutant discharges to the stormwater
conveyance system to develop and implement an SWPPP [Stormwater Pollution Prevention
Plan], which must include an employee training program and the applicable minimum
BMPs from the BMP Manual.
3. Each discharger that is subject to any NPDES permit shall comply with all requirements of all
such permits. The discharger must also make reports submitted to the RWQCB or other
permitting agency, including monitoring data, available to the City upon request.
4. Parties undertaking land disturbance activities shall comply with all applicable requirements
of this chapter, the BMP Manual, and Division III of PMC Title 16 (Chapters 16.40
through 16.54 PMC).
5. Parties undertaking land development and redevelopment activities shall comply with all
applicable requirements of this chapter and the BMP Manual.
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Poway Comprehensive Plan: General Plan
The Poway Comprehensive Plan: General Plan (General Plan) includes the following policies and strategies
regarding hydrology and water quality (City of Poway 1991):
Goal I: It is the goal of The City of Poway to preserve Poway’s unique and desirable character as “The City
in the Country” and to maintain high quality design and environmental standards in all new development
and redevelopment.
Policy D, Grading – Necessary grading should be done so as to minimize the disturbance to the site and the
environmental and aesthetic impacts.
Strategy 1: Mass grading of custom residential subdivision lots in hillside areas is prohibited.
Strategy 2: Grading in hillside areas shall leave rounded off natural appearing slopes and shall use a
variable slope ratio instead of manicured cut and fill areas. Grading shall be limited to that required for
building pad placement and for driveways and utility lines.
Strategy 3: To the extent possible cut slopes should be concealed by the structure.
Strategy 4: All exposed graded slopes shall be revegetated with plant materials compatible with
surrounding vegetation.
Strategy 5: Land should be graded and landscaped in workable increments to avoid exposing expanses of
bared earth at any given time.
Strategy 6: Topsoil removed during grading should be retained and replaced on the landscaped areas of
the building site to minimize the grading and removal of top soil from other locations.
Strategy 7: Long term erosion shall be controlled by vegetation replanting or erosion control materials as
well as the installation of proper drainage control devices where necessary.
Strategy 8: Soils having a high or moderate permeability capacity or rate should be left in their natural
state to reduce run off and encourage groundwater recharge.
Goal IV: It is the goal of the City of Poway to preserve its natural, scenic, and cultural resources for the future
benefit and enjoyment of its residents and to protect biological and ecological diversity.
Policy B, Waterways – The natural character of creeks and channels should be maintained or restored to the
greatest extent possible with consideration for maintaining adequate flood protection.
Strategy 1: Development including roads should be set back from riparian corridors a minimum distance
of 50 feet or a sufficient distance as determined by a qualified biologist to avoid any damage to these
areas. These riparian corridors and associated buffer areas should be designated as permanent natural
open space easements and the buffer areas should be vegetated only with appropriate native species as
determined by a qualified biologist or native plant horticulturist.
Strategy 2: No activity or development shall be permitted within the watershed or viewshed of Lake Poway
which would diminish water quality of the lake or its open space and recreational value.
Strategy 3: Natural locations and rates of discharge into creeks and channels should not be increased
without sufficient mitigation to ensure that significant alteration of the natural system will not occur.
Strategy 4: The use of rip rap in stream channels shall be limited to the minimum area required to protect
adjacent improvements and stream banks from excessive erosion.
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Strategy 5: Public access to creeks via trails paths and greenways shall be encouraged to the extent
possible without negatively impacting the riparian habitat value.
Strategy 6: Coordinate with other jurisdictions to monitor and maintain acceptable water quality
standards in local streams.
Strategy 7: Activities within the City’s natural drainage systems which would adversely affect water quality
(such as pesticide use construction of septic leach fields and underground storage of hazardous
substances) shall be strictly regulated.
Strategy 8: Substances such as hazardous wastes or untreated wastewater shall not be discharged into
the City’s natural water systems.
Strategy 9: Urban runoff from impermeable surfaces which may be contaminated with oil grease vehicle
fuels or other toxic substances shall have such contaminants substantially removed before discharge into
the City’s natural drainage systems. The City shall comply with the requirements of the nonpoint source
urban runoff wastewater discharge permit.
Strategy 10: Grading for development shall not increase the natural rate of erosion or cause siltation of
stream channels.
4.9.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to hydrology and water quality are based on
Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related
to hydrology and water quality would occur if the project would:
1. Violate any water quality standards or waste discharge requirements or otherwise substantially degrade
surface or ground water quality.
2. Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such
that the project may impede sustainable groundwater management of the basin.
3. Substantially alter the existing drainage pattern of the site or area, including through the alteration of the
course of a stream or river or through the addition of impervious surfaces, in a manner which would:
a. result in substantial erosion or siltation on or off site;
b. substantially increase the rate or amount of surface runoff in a manner which would result in flooding
on or off site;
c. create or contribute runoff water which would exceed the capacity of existing or planned stormwater
drainage systems or provide substantial additional sources of polluted runoff; or
d. impede or redirect flood flows.
4. In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation.
5. Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater
management plan?
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4.9.4 Impacts Analysis
Would the project violate any water quality standards or waste discharge requirements or otherwise substantially
degrade surface or ground water quality?
The following discussion of water quality impacts is organized into two subsections: (1) short-term construction
activities and (2) long-term post-construction activities.
Construction
Proposed demolition, grading, excavation, and construction activities associated with the proposed project could
create a substantial additional source of polluted runoff, which could have short-term impacts on surface water
quality. Additional sources of polluted runoff could include, heavy metals, organic compounds, trash and debris,
oxygen demanding substances, oil and grease, bacteria and viruses, pesticides, sediments, and nutrients could
occur as a result of project uses.
Figure 3-8, Conceptual Grading & Drainage Plan, illustrates the proposed grading and drainage concept for the
Farm in Poway. Grading of the site respects the existing topography to the extent feasible for implementing the
plan and adheres to the PMC Grading Standards. Grading for the site is balanced at 508,900 cubic yards of cut
and fill to avoid export or import of dirt. Figure 3-9, Conceptual Cut & Fill Map, highlights how dirt will be
redistributed throughout the site. Cut and fill slopes are designed at 2:1 minimum. The cut north of The Club is
greater than 30 feet in height (66 feet total) and requires City Council approval.
As illustrated in Figure 3-8, the project site currently accepts stormwater drainage from a number of adjoining
properties. To maintain these existing drainage patterns and minimize drainage impacts to existing
neighborhoods, a series of public bypass storm drains would be provided to collect this stormwater at The Farm in
Poway Specific Plan (Specific Plan) area boundary and convey it through the site to the City’s existing storm drain
system downstream. The grading plan is designed to drain all stormwater from within the Specific Plan area to
swales that convey water to streets or to drain stormwater directly to private streets. Once in the street,
stormwater is collected by catch basins and a private system of pipes. These pipes then conveyed water to a
series of bioretention basis that release stormwater into the City’s existing system via the bypass storm drains
described above or via existing ditches, channels, or pipes located adjacent to the Specific Plan area. Issuance of
building permits for the proposed project would generally be phased along with the necessary public
improvements to support the land uses. Required improvements would include water and wastewater pipelines,
public and private roadways, drainage improvements, public trails, public park facilities, and a community
recreation center facility. Demolition of the existing clubhouse building and associated structures would occur
initially. It is assumed that site-preparation of the project site (i.e., grading, soil import, trenching for dry and wet
utilities, and surface improvements) for vertical building construction would follow. Pollutants associated with
construction would degrade water quality if those pollutants are washed into surface waters. Sediment is often
the most common pollutant associated with construction sites because of the associated earth-moving
activities and areas of exposed soil. Hydrocarbons such as fuels, asphalt materials, oils, and hazardous
materials such as paints and concrete discharged from construction sites could also result in impacts
downstream. Debris and trash could be washed into existing storm drainage channels to downstream surface
waters. These activities could impact aquatic habitat, upland wildlife, and aesthetic land values.
Under the NPDES permit program, BMPs are mandated for construction sites in which grading would be greater
than one acre, through preparation of Stormwater Pollution Prevention Plans (SWPPPs) in order to reduce the
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occurrence of pollutants in surface water. SWPPPs are submitted to the RWQCB prior to ground-disturbing
activities and set forth the measures that will be employed during construction to avoid runoff into surface
waters. Project temporary construction BMPs would typically include the following: street sweeping, waste
disposal, vehicle and equipment maintenance, concrete washout area, materials storage, minimization of
hazardous materials, and proper handling and storage of hazardous materials. Typical erosion and sediment
control BMPs include silt fences, fiber rolls, gravel bags, temporary desilting basins, velocity check dams,
temporary ditches or swales, stormwater inlet protection, and soil stabilization measures. Implementation of
these state-mandated measures, and implementation of the required SWPPP for the proposed project, would
ensure that short-term impacts from construction-related activities would not violate any water quality
standards or waste discharge requirements and not further contribute to water quality impacts identified in the
Clean Water Act Section 303(d) List of Water Quality Limited Segments. With implementation of a SWPPP and
compliance with applicable water quality requirements, runoff from the project site during construction would
not adversely affect surface waters and water quality.
Operation
The clubhouse and all other existing on-site structures would be replaced with the proposed project, as described
in Chapter 3, Project Description, of this EIR. The project proposes features such as pools, spas, ponds,
decorative fountains, refuse areas, landscaped areas, walkways and parking lots that could potentially result in
increased pollutants from the project site. During operation of the proposed project, all on-site runoff would be
collected through the proposed internal storm drain system described above, and routed to one of the seven
biofiltration basins that would detain and attenuate 100-year peak flows per City design standards. As described
above, the drainage basins would be scattered throughout the site at low elevation points within the project site.
The northern part of the project site proposes four of these biofiltration bases scattered in different quadrants of
the northern loop. The southern portion of the project site proposes two biofiltration basins, while one basin would
be in the center of the project site. Additional flows from the agricultural areas will be routed to proposed
agricultural basins. Analysis for the agricultural basins will be provided during final engineering.
Hydromodification management flow control, or BMPs, would be implemented in order to reduce potential
impacts to water quality. As outlined and recommended in the Stormwater Quality Management Plan (Appendix
G), the proposed project would implement source control BMPs, site design BMPs, and priority development
project BMPs, which are outlined in Table 4.9-1.
Table 4.9-1. Hydromodification Management Flow Control Best Management Practices
No. BMP
Source Control BMPs
SC-BMP-1 Prevention of Illicit Discharge into the MS4 Permit Areas
SC-BMP-2 Storm Drain Stenciling or Signage
SC-BMP-3 Protection of Trash Storage Areas from Rainfall, Run-On, Runoff, and Wind Dispersal
SC-BMP-4 Additional BMPs for the following areas of concern: Onsite Storm Drain Inlets, Landscape/Outdoor
Pesticide Use, Pools, Spas, Ponds, Decorative Fountains and Water Features, Food Service, Refuse
Areas, Miscellaneous Drain or Wash Water, Plazas, Sidewalks, and Parking Lots.
Site Design BMPs
SD-BMP-1 Maintain Natural Drainage Pathways and Hydrologic Features
SD-BMP-2 Conserve Natural Areas, Soils, and Vegetation
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Table 4.9-1. Hydromodification Management Flow Control Best Management Practices
No. BMP
SD-BMP-3 Minimize Impervious Areas
SD-BMP-4 Minimize Soil Compaction
SD-BMP-5 Impervious Area Dispersion
SD-BMP-6 Runoff Collection
SD-BMP-7 Landscaping with Native or Drought Tolerant Species
SD-BMP-8 Harvesting and Using Precipitation
PDP BMPs
PDP-BMP-1 Biofiltration, which will include the installment of six bio filtration basins which serve the purpose of
pollutant and hydromodification control at six separate areas within the project site. This BMP would be
inspected by a third party inspector post-construction. The final owners of the biofiltration BMP would
be the Homeowners Association (HOA). The HOA will maintain this BMP into perpetuity, and fund the
maintenance of the BMP through HOA dues.
Source: Appendix G.
Note: SC = source control; BMP = best management practice; SD = site design; PDP = priority development project.
All priority development projects must implement BMPs for stormwater pollutant control. Priority development
projects subject to hydromodification management requirements, such as this project, must also implement
water pollutant control and flow control for hydromodification management. Both stormwater pollutant control
and flow control for hydromodification management can be achieved within the same structural BMPs as outlined
above. These BMPs would be verified by the City at the completion of construction, generally through certification
by the project owner.
The selection, sizing and preliminary design of stormwater treatment and other control measures in the
engineering plan were drafted in compliance with the City’s Stormwater Design Manual, which meets the
requirements of the San Diego RWQCB Order R9-2013-0001. The proposed basins were designed to capture 1.5
times the required design capture volume. The detention basins would require maintenance by the Homeowners
Association to ensure they continue to operate properly into perpetuity. Maintenance includes repairing erosion,
removing sediment and trash, mowing and managing vegetation, and ensuring filters are not blocked and are
functioning properly. This maintenance would be intermittently confirmed by the City. Post treatment, stormwater
is then released from the basins into bypass pipes which convey existing ditches, channels or pipes that are part
of the City’s existing storm drain system.
The City’s Stormwater Design Manual, which is the jurisdiction-specific BMP manual for the City, addresses updated on-
site post-construction stormwater requirements for standard projects and priority development projects, and provides
updated procedures for planning, preliminary design, selection, and design of permanent stormwater BMPs based on
the performance standards presented in the MS4 Permit and the City’s JRMP. All of the proposed biofiltration BMPs
would be designed per City specifications and the drainage study recommendations (Appendix F). Hydromodification
BMPs must be sized and designed such that post-project runoff conditions, including flow rates and durations, would
not exceed pre-development runoff conditions by more than 10 percent for the range of flows that result in increased
potential for erosion or degraded instream habitat downstream of the proposed project. As indicated in the project-
specific drainage study (Appendix F), this requirement would be met. The proposed biofiltration detention basins and
channels would minimize off-site discharge of surface water pollutants while simultaneously preventing downstream
flooding-related impacts. The conceptual drainage plan for the project has been designed to provide adequate storm
drainage of the property, including detention basins designed to regulate the quantity and quality of stormwater
entering the City’s storm drain system to prevent flooding downstream.
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Agricultural uses are required to limit the use of pesticides and other chemical applications, which could
potentially runoff into stormwater systems. The stormwater system is designed to detain and treat any runoff
onsite prior to releasing it into the stormwater system.
Based on the proposed project design and applicable requirements, and in particular with the inclusion of the
proposed biofiltration detention basins, grading, and design strategies, long-term water quality and stormwater
impacts associated with the proposed project would be minimal. Implementation of proposed BMPs,
implementation of recommendations in the project-specific drainage study (Appendix F) and Stormwater Quality
Management Plan (Appendix G), and preparation and implementation of the required SWPPP would ensure that the
proposed project would comply with regulatory ordinances and with the standards set forth in the City’s Stormwater
Design Manual. Further, potential impacts associated with the use of commercially available fertilizers, pesticides,
and other regulated materials commonly used in agricultural operations would be restricted in accordance with
applicable state and federal regulations. Finally, tree wells would be designed in accordance with the Stormwater
Quality Management Plan to provide water quality treatment for agricultural drainage management areas, which
would treat all pollutants of concern generated by these agricultural areas (Appendix G).
For the reasons stated above, both short-term construction impacts, and long-term operational impacts to water
quality as a result of project implementation would be less than significant.
Would the project substantially decrease groundwater supplies or interfere substantially with groundwater
recharge such that the project may impede sustainable groundwater management of the basin?
The project site is not located within a known groundwater basin (City of Poway 2018b). The nearest groundwater
basin is the PVGB, located approximately 2.5 miles south of the project site (SanGIS 2007). PVGB has not been
identified as a critically over drafted basin. As of 2018, PVGB is estimated by the State to have over 2,300 acre-
feet of groundwater storage (City of Poway 2018b). Groundwater use within the PVGB is very limited. Groundwater
is not pumped for municipal water supply in the PVGB and imported water provides for most of the water used in
the PVGB. Private domestic wells located in the PVGB serve individual users mainly for irrigation of residential
parcels. No active municipal water supply wells or groundwater replenishment projects occur in the Plan area (City
of Poway 2018b). Instead, the City receives 99 percent of its water supply from the San Diego County Water
Authority in the form of raw water, and then treats the water at Lester J. Berglund Water Treatment Plant, which is
located in the City, before distributing treated potable water to City residences and businesses. All uses within the
project site, including agricultural uses would use water from the City’s water distribution system to allow
monitoring of groundwater supplies. Existing wells on site would be maintained; however, the use of existing wells
is not proposed, and no new wells would be constructed.
According to the Stormwater Quality Management Plan prepared for the proposed project (Appendix G), the
proposed project is not located within 10 feet from the bottom of any of the proposed basins. Therefore, the
likelihood of polluted stormwater infiltration into any groundwater supplies is considered negligible. In addition to
treatment methods within the stormwater system, pollution prevention strategies including proposed best
management practices (as outlined in Table 4.9-1, Hydromodification Management Flow Control Best
Management Practices), agricultural use strategies, and the required SWPPP would be specifically designed to
protect stormwater from potential contamination. Compliance with local and site-specific stormwater regulations
and plans would further reduce the potential for contamination of groundwater.
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Considering the proposed project would not use groundwater for construction or operational activities, and
considering the depth to groundwater underlying the project site, no substantial decrease to groundwater
supplies, or substantial interference with groundwater recharge is anticipated as a result of the proposed project.
Therefore, impacts to groundwater would be less than significant.
Would the project substantially alter the existing drainage pattern of the site or area, including through the
alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner
which would:
a. result in substantial erosion or siltation on or off site;
As discussed above, the project site currently accepts stormwater drainage from a number of adjoining
properties. The proposed project would include construction of new impervious surfaces such as
residential structures, recreational facilities, access roads, sidewalks, driveways and walkways. The
proposed drainage improvements and cut and fill changes would respect the existing topography to the
extent feasible, and would adhere to the City’s Municipal Code Grading Standards. Implementation of the
Grading Plan would allow drainage of stormwater from the project site to discharge to swales on site that
would convey water to streets or to drain stormwater directly to private streets. Once in the street,
stormwater is collected by catch basins and a private system of pipes. These pipes then convey water to a
series of bioretention basis that release stormwater into the City’s existing system via the bypass storm
drains described above or via existing ditches, channels, or pipes located adjacent to the project site.
The entire property is underlain with soils classified as Hydrologic Soil Group B and C, which are classified
as soils having a layer that impedes the downward movement of water or soils of moderately fine texture
or fine texture. These soils have a slow rate of water transmission (Appendix G). To reduce the effects of
soil erosion and siltation on site, the project proposes to grade the site to a 2:1 ratio (horizontal:vertical),
consistent with the surrounding natural topography of the area. The Geologic Reconnaissance (Appendix
E) identifies recommended BMPs for grading specifications to ensure that sliding and erosion does not
occur on or off site during construction. Additionally, implementation of BMPs outlined in Table 4.9-1,
and implementation of the required SWPPP for the proposed project, would ensure that impacts from
construction-related activities would not result in substantial erosion or siltation on or off site. Post-
construction, proposed landscaping throughout the site, in addition to the proposed drainage
improvements would reduce the potential for substantial erosion or siltation. For these reasons,
impacts are determined to be less than significant.
b. substantially increase the rate or amount of surface runoff in a manner which would result in flooding on
or off site;
As previously described, the majority of the existing property consists of vegetative cover with the
exception of associated parking lots, structures, and tennis courts, and the project site currently accepts
stormwater drainage from a number of adjoining properties. The project proposes 51 acres of impervious
area, and 22.36 acres of pervious area, for a total of 73.36 acres of disturbed area on site. Impervious
features include residential structures, access roads, sidewalks, driveways and walkways. Pervious
features include biofiltration basins, community gardens, trails, open space, and landscaped area/slopes.
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As outlined in Figure 3-8, the proposed drainage improvements would respect the existing topography to
the extent feasible, as to minimize drainage impacts to existing neighborhoods surrounding the project
site. The proposed drainage improvements would allow drainage of stormwater from the project site to
discharge to swales on site that would convey water to streets or to drain stormwater directly to private
streets. Once in the street, stormwater is collected by catch basins and a private system of pipes. These
pipes would then convey water to one of six bioretention basis that will detain and attenuate 100-year
peak flows per City design standards. Post-attenuated flow would then release stormwater into the City’s
existing system via the bypass storm drains or via existing ditches, channels, or pipes located adjacent to
the project site. Additional flows from the agricultural areas on site would be routed to proposed
agricultural basins.
The proposed grading changes to the entire site would be in respect of existing topography, pursuant to
the City’s Municipal Code Grading Standards. The site will be balanced at 508,900 cubic yards of cut and
fill to avoid export or import of dirt on site, and all excavated areas would provide positive drainage to
prevent ponding of water.
The drainage report prepared for the proposed project (Appendix F), analyzed the 100-year flood flow
rates for the proposed drainage basins located within the project site. The Rational Method, which is the
most widely used hydrologic model for estimating peak runoff rates, was used to analyze the proposed
project’s site topography and drainage basin locations at common drainage points (nodes). Table 4.9-2
outlines post-attenuated flows at three common drainage nodes. The attenuation provided by each of the
six proposed basins would reduce flow at each of the outfalls when compared to the existing condition.
Table 4.9-2 Summary of Rational Method Hydrologic Analysis
Existing Condition Proposed Condition
Node Area (ac) 100-Year Peak Flow (cfs) Area (ac) 100-Year Peak Flow (cfs)
100 159.9 258.11 159.7 243.1* (306.47)**
300 91.2 177.11 90.8 175.35* (200.69)**
400 5.4 9.05 5.7 7.13* (25.53)**
Totals 256.5 — 256.2 —
Source: Appendix F
Notes: ac = acres; cfs = cubic feet per second.
* Post-mitigated (attenuated) flow ** Post-condition (unattenuated) flow
The drainage report concluded that the proposed project would not increase runoff in the 100-year storm event
because of the on-site flood attenuation provided by the proposed drainage basins (Appendix F). Additionally,
since there would be no increase in runoff, there would be no negative impacts to downstream drainage facilities.
Furthermore, in compliance with federal and state regulations, as well as municipal guidelines such as the City’s
JRMP and MS4 permit, the proposed project would incorporate site design, structural, and source control BMPs to
help minimize surface runoff and prevent flooding. With implementation of the proposed drainage improvements,
and compliance with applicable regulations, the proposed project would not substantially increase the rate of
surface runoff such that flooding would occur. Therefore, impacts would be less than significant.
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c. create or contribute runoff water which would exceed the capacity of existing or planned stormwater
drainage systems or provide substantial additional sources of polluted runoff; or
As discussed above, the proposed project plans to create an improved stormwater drainage system in
compliance with the City’s Stormwater Design Manual, which meets the requirements of the San Diego
RWQCB (Appendix G). The proposed method for treating stormwater runoff from the project site involves a
series of bioretention basins. Stormwater would be collected and conveyed to these basins via a series of
private catch basins and pipes located within private streets. Once collected, the proposed bioretention
basins would slow the velocity and volume of water, a process called hydromodification, and treat
stormwater through various processes collectively referred to as bioretention. Hydromodification is
important to protecting stormwater quality by preventing flooding, sedimentation, and erosion
downstream. Biofiltration is import to protecting stormwater quality by removing potential pollutions
within water prior to leaving the site. Biofiltration removes pollutants in a variety of ways:
Evapotranspiration, the process in which water is transferred from the soil by evaporation and
from plants by transpiration into the air, leaving pollutants behind.
Nutrient Cycling, the process in which plants extract nutrients, i.e. organic and inorganic matter
that can affect water quality, back into the production of organic matter.
Filtration through grasses, grates, and screens that remove pollutants.
Once water passes through the bioretention basis, it would be released into the City’s existing storm drain system
via the bypass storm drains or via existing ditches, channels, or pipes located adjacent to the project site.
As described under the first threshold analysis, under the NPDES permit program, BMPs are mandated for
construction sites greater than one acre, through preparation of an SWPPP in order to reduce the occurrence of
pollutants in surface water. Implementation of state-mandated measures, proposed BMPs, and implementation
of the required SWPPP for the proposed project, would ensure project construction and operational activities
would not result in substantial sources of polluted runoff.
As shown in Table 4.9.-1, the attenuated flow rates of the proposed project would have a lower volume than the
conditions that currently exist on site. Additionally, since there would be no increase in runoff, project
implementation would not result in negative impacts to downstream drainage facilities. Therefore,
implementation of the proposed project would not result in runoff that would exceed the capacity of existing
storm drain systems, nor cause substantial additional sources of pollution. Therefore, impacts would be less
than significant.
d. Impede or redirect flood flows?
As described above, the project proposes 51 acres of impervious area, and 22.36 acres of pervious area,
for a total of 73.36 acres of disturbed area on site. Impervious features include residential, educational,
and recreational structures; access roads; sidewalks; driveways; and walkways. Pervious features include
biofiltration basis, community gardens, trails, open space, and landscaped area/slopes. The proposed
drainage improvements would respect the existing topography to the extent feasible, as to minimize
drainage impacts to existing neighborhoods surrounding the project site. The proposed drainage
improvements would allow drainage of stormwater from the project site to discharge to swales on site
that would convey water to streets or to drain stormwater directly to private streets. Once in the street,
stormwater is collected by catch basins and a private system of pipes. These pipes would then convey
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water to one of six bioretention basis that will detain and attenuate 100-year peak flows per City design
standards. Post-attenuated flow would then release stormwater into the City’s existing system via the
bypass storm drains or via existing ditches, channels, or pipes located adjacent to the project site.
Additional flows from the agricultural areas on site would be routed to proposed agricultural basins.
The proposed grading and drainage changes would be in compliance with the City’s Municipal Code
Grading Standards. The planned expansion and continuation of existing drainage patterns would be
consistent with surrounding topography and drainage patterns and would not impede or redirect flood
flows, therefore the impact is less than significant.
In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation?
The project site is located approximately 14 miles inland from the Pacific Ocean and would not be subject to
inundation by tsunami. Given that the project site is not located near a large standing body of water (the nearest
is Lake Poway, approximately 1.75 miles southeast of the site), inundation by seiche (or standing wave) is
considered negligible. As the project site is not located within a flood hazard, tsunami, or seiche zone, the release
of pollutants due to project inundation is not anticipated, and no impact would occur.
Would the project conflict with or obstruct implementation of a water quality control plan or sustainable
groundwater management plan?
As previously discussed, the proposed project would comply with all applicable federal, state, and local policies
regarding water quality and groundwater management. The proposed internal drainage system would be pursuant
to any existing standards, such as the Poway JRMP, the City’s Municipal Code, and City BMPs for water quality
management. The proposed biofiltration BMPs would be certified by a third party inspector, and funded and
maintained into perpetuity by the proposed project’s Homeowners Association (Appendix G).
The project site is not located within or near the PVGB, and therefore would not conflict or obstruct
implementation of the City’s management plan for the basin (City of Poway 2018b). As the proposed project
would not conflict with an applicable water quality control plan or groundwater management plan, impacts would
be less than significant.
4.9.5 Cumulative Impacts
The cumulative study area for hydrology and water quality would be the boundaries of the Poway Creek
Watershed. The proposed project would replace portions of an existing golf course with residences. As a
result, the proposed project would increase the amount of impermeable surfaces, which in turn would reduce
the ability of the ground surface to absorb potential high intensity surface runoff and surface water pollutants.
This increase in impermeable surfaces would be incrementally greater than under existing conditions and
could contribute to downstream impacts to Poway Creek. However, the proposed project would retain 22.36
acres of permeable surfaces, which would consist of biofiltration basins, community gardens, trails, open
space, and landscaped areas/slopes. The proposed drainage system, in combination with proposed BMPs
outlined in Table 4.9-1 would reduce downstream runoff volumes and flow rates to levels less than or equal
to existing conditions.
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Similar to the proposed project, all cumulative projects would be subject to regulations, policies, and plans
established by the City, County of San Diego, and the San Diego RWQCB. Regulations and plans that cumulative
projects would be subject to comply with include, NPDES permitting and associated SWPPPs and BMPs; Water
Quality Objectives for Inland Surface Waters, established in the Basin Plan; the County of San Diego WPO; Chapter
13 of the City’s Municipal Code, regarding grading and stormwater discharges; and applicable General Plan goals
and policies (see Section 4.9.2, Relevant Plans, Policies, and Ordinances). Therefore, the proposed project, in
combination with identified cumulative projects, would result in less-than-significant impacts to cumulative
hydrology, water quality, and stormwater/flooding.
4.9.6 Mitigation Measures
No mitigation measures are required, as all impacts are determined to be less than significant.
4.9.7 Level of Significance After Mitigation
Based on the above analysis, impacts related to hydrology, water quality, stormwater, and flooding are
determined to be less than significant, and no mitigation is required.
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4.10 – Land Use and Planning
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4.10 Land Use and Planning
The section describes the existing land use and planning conditions of The Farm in Poway project (proposed
project) site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies
mitigation measures related to implementation of the proposed project. The analysis is based on the review of
existing conditions; applicable laws, regulations, and guidelines; existing community character, surrounding land
uses, and compatibility of the proposed project with neighboring areas; and consistency of the proposed project
with relevant adopted local land use policies. The Project Consistency with City of Poway General Plan is included
in this Environmental Impact Report (EIR) as Appendix H.
A Notice of Preparation (NOP) was circulated from May 10, 2019, to June 10, 2019. During the NOP comment
period, comment letters related to land use and planning focused on the following topics:
Zoning changes
Inclusion of more open space
Preservation of open space
Proposals of lower density development
These comments were considered during the preparation of this EIR. The Initial Study, NOP, and Public Scoping
comments are provided in Appendix A of this EIR.
4.10.1 Existing Conditions
The project site is designated as “Open Space” in the Poway Comprehensive Plan: General Plan (General Plan),
and is currently zoned as “Open Space”– Recreation (OS-R)” (City of Poway 1991).
Surrounding Land Uses
The land uses surrounding the project site consist of single-family and multi-family residential development that
includes detached residences on a variety of lot sizes, attached residences of several different densities, and
several planned community developments; see Chapter 3, Project Description, Figure 3-10, Surrounding Land
Use. The surrounding development consists of mostly single-family homes zoned Residential Single-Family 4 (RS-
4), which is intended for 10,000-square-foot lots and maximum densities of four units per acre. A small cluster of
residential condominium-zoned (RC) multi-family homes exist along the western edge of the project boundary
along Port Marnock Drive, which allows for 12 units per acre. Along the northern portion of the project site, along
Villamoura Drive and Villa De Lobo Drive, similar RC zoned multi-family housing is present.
Along Boca Raton Lane, on the northwestern border of the project site, a Residential Single-Family 2 (RS-2) Zone
is present and serves as an area for low-density residential uses with minimum lot size of 20,000 square feet and
maximum density of two units per net acre. The southern border on Espola Road consists of residential rural
zoned homes (RR-C), which allow for very low-density residential uses and minimum lot sizes of one acre and
maximum densities of one unit per acre. These density of homes are also found farther west of the project site.
A large area just east of the project site is a large cluster of Planned Community (PC-4) zoning, which is a
minimum area of 300 contiguous acres, under single ownership or otherwise subject to unified planning, by
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persons, corporations, or other entities. Property owned by public utilities, local districts, or local governments will
not be counted toward the 300-acre minimum, but may be used as a connector of single ownership. The zoning
within the PC-4 community follows the RS-4 Zone residential requirements within a planned community, which
allows for a minimum lot size of 10,000 acres and maximum densities of four units per acre.
Vineyard Hills is located to the west of the project site and is zoned Planned Residential Development (PRD-3). This
zone allows for development of areas designated for residential use on the General Plan by permitting greater flexibility
and, more creative and imaginative designs for the development of such residential areas than generally is possible
under conventional zoning or subdivision regulations. The maximum density of these lots is 12 units per acre, and lot
sizes may vary to promote flexibility of development and needs.
The City of Poway is also known as the “City in the Country”, and takes pride in its use of larger lots and variety of
open space uses. These open space uses generally promote resource management and recreation within the City.
Open space uses are present in many places outlying the project site.
4.10.2 Relevant Plans, Policies, and Ordinances
Federal
There are no federal policies related to land use that apply to the proposed project.
State
California Planning and Zoning Law
The legal framework in which California cities and counties exercise local planning and land use functions is
provided in the California Planning and Zoning Law, Government Code Sections 65000 et seq. Under state
planning law, each city and county is required to adopt a general plan “for the physical development of the county
or city, and any land outside its boundaries which bears relation to its planning” (Section 65300). The California
Supreme Court has called the general plan the “constitution for future development.” A general plan expresses
the community’s development goals and embodies public policy relative to the distribution of future land uses,
both public and private. A general plan consists of several elements, including land use, circulation, housing,
conservation, open space, noise, and safety; other elements may be included at the discretion of the jurisdiction
that relate to the physical development of the county or city.
California Environmental Quality Act
The California Environmental Quality Act (CEQA) (California Public Resources Code, Section 21000 et seq.) and
CEQA Guidelines (14 CCR 15000 et seq.) are primary sources for environmental legislation in California; they
require projects with potential adverse environmental effects (or impacts) undergo environmental review. Adverse
environmental impacts are typically mitigated as a result of the environmental review process in accordance with
existing laws and regulations.
Senate Bill 375
Senate Bill 375, the Sustainable Communities and Climate Protection Act, was adopted in September 2008 to
coordinate land use planning, regional transportation plans, and funding priorities to reduce greenhouse gas
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(GHG) emissions from passenger vehicle travel through better-integrated regional transportation, land use, and
housing planning that provides easier access to jobs, services, public transit, and active transportation options.
Senate Bill 375 consists of five aspects: (1) creation of regional targets for GHG emissions reduction tied to land
use; (2) a requirement that regional planning agencies create a Sustainable Communities Strategy (SCS) to meet
those targets, even if that plan is in conflict with local plans; (3) a requirement that regional transportation
funding decisions be consistent with this new plan; (4) a requirement that the Regional Housing Needs Allocation
numbers, established by the State Department of Housing and Community Development and allocated by the San
Diego Association of Governments (SANDAG), must conform to the SCS; and (5) new CEQA exemptions and
streamlining for projects that conform to the SCS.
Senate Bill 375 specifically requires the metropolitan planning organization relevant to a project area (in this
case, SANDAG) to develop an SCS in its Regional Transportation Plan (RTP). The intent of the SCS is to achieve
GHG emissions reduction targets set by the California Air Resources Board (CARB) by reducing vehicle miles
traveled from light-duty vehicles through the development of more compact, complete, and efficient communities.
For the area under SANDAG’s jurisdiction, including the project site, CARB adopted regional targets for the
reduction of mobile source GHG emissions. Those reduction targets are 7 percent for 2020 and 13 percent for
2035, compared with a 2005 baseline. In preparing its 2015 SCS, also known as San Diego Forward: The
Regional Plan (Regional Plan), SANDAG stated it would achieve (and exceed) the region’s GHG targets, with a 15
percent per-capita reduction by 2020 and a 21 percent per-capita reduction by 2035 (SANDAG 2015). In
response, CARB accepted SANDAG’s determination that its SCS would achieve its 2020 and 2035 GHG emissions
reduction targets.
Local
SANDAG San Diego Forward: The Regional Plan
The SANDAG Board of Directors adopted the final Regional Plan on October 9, 2015. The Regional Plan combines
the region’s two most important existing planning documents—the Regional Comprehensive Plan and the
Regional Transportation Plan and its Sustainable Communities Strategy (RTP/SCS). The Regional Comprehensive
Plan, adopted in 2004, laid out key principles for managing the region’s growth while preserving natural
resources and limiting urban sprawl. The plan covered eight policy areas, including urban form, transportation,
housing, healthy environment, economic prosperity, public facilities, our borders, and social equity. These policy
areas were addressed in the 2050 Regional Transportation Plan (2050 RTP/SCS) and are now fully integrated
into the Regional Plan.
In 2011, SANDAG approved the 2050 RTP/SCS. This approval marked the first time SANDAG’s RTP included an
SCS, consistent with Senate Bill 375. The 2050 RTP/SCS provided a blueprint to improve mobility, preserve open
space, and create communities, all with transportation choices to reduce GHG emissions and meet specific
targets set by CARB in 2010, as required by Senate Bill 375. Targets for the San Diego region were 7 percent per-
capita GHG emissions reductions for 2020 and 13 percent for 2035, compared with a 2005 baseline. The 2050
RTP/SCS integrates land use and transportation plans to achieve reductions in GHG emissions and meet the
CARB-required targets.
Poway Comprehensive Plan: General Plan
The City’s General Plan is a statement of what the representatives of the residents want for their community in
the future. Its function is to allow the citizens to consciously consider the shape their City will take for the
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foreseeable future and to preserve and enhance those qualities they presently find appealing. It accomplishes
this by setting forth broad goals, and translating these goals into specific policies and strategies to accomplish the
plan’s objective. The goals of the City’s General Plan are as follows (City of Poway 1991):
1. It is the goal of the City of Poway to preserve Poway’s unique and desirable character as “The City in
the Country” and to maintain high quality design and environmental standards in all new
development and redevelopment.
2. It is the goal of the City of Poway to provide for an orderly balance of both public and private land uses in
convenient and compatible locations throughout the city and to ensure that all such uses serve to protect
and enhance the environment character and image of the city.
3. It is the goal of the City of Poway to enhance the well-being of Poway residents by providing opportunities
for relaxation rest activity and education through a well-balanced system of private and public facilities
distributed to serve the entire community.
4. It is the goal of the City of Poway to preserve its natural scenic and cultural resources for the future
benefit and enjoyment of its residents and to protect biological and ecological diversity.
5. It is the goal of the City of Poway to achieve a climate for economic growth and stability which will attract high
quality commercial and industrial development to serve the employment shopping recreation and service
needs of Poway residents and will provide a healthy and diverse economic base for the community.
6. It is the goal of the City of Poway to provide a safe realistic efficient and integrated transportation system
to serve the present and future mobility needs of all the residents of Poway.
7. It is the goal of the City of Poway to provide a safe and healthy environment for the residents of Poway.
8. It is the goal of the City of Poway to minimize injuries loss of life and property damage resulting from
natural and man-made hazards.
9. It is the goal of the City of Poway to provide an efficient and economical public water and wastewater
treatment system to serve the current and future residents of Poway.
The City of Poway Zoning Ordinance
The City of Poway Zoning Ordinance (Zoning Ordinance), as located in Title 17 of the municipal code, is the primary way
that the City administers the General Plan. The General Plan identifies general land use policies, while the Zoning
Ordinance identifies specific uses and development standards within these policies. The purpose of the Zoning Ordinance
is to serve the public health, safety, comfort, convenience, and general welfare by do the following (City of Poway 2019):
Aiding in the establishment of residential zones which serve the following purposes:
1. To reserve appropriately located areas for family living at a broad range of dwelling unit densities
consistent with the general plan and with sound standards of public health, safety and welfare;
2. To ensure adequate light, air, privacy, and open space for each dwelling;
3. To minimize traffic congestion and to avoid the overloading of public services and utilities by
preventing the construction of buildings of excessive bulk or number in relation to the land area
around them;
4. To protect residential properties from noise, illumination, unsightliness, odors, smoke and other
objectionable influences;
5. To facilitate the provision of utility services and other public facilities commensurate with anticipated
population, dwelling unit densities, and service requirements.
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Supporting the establishment of planned residential development zones which serve the following purpose:
1. Planned residential development regulations are intended to facilitate development of areas
designated for residential use on the general plan by permitting greater flexibility and, consequently,
more creative and imaginative designs for the development of such residential areas than generally is
possible under conventional zoning or subdivision regulations.
2. These regulations are further intended to promote more economical and efficient use of the land
while providing a harmonious variety of housing choices, a higher level of urban amenities, and
preservation of natural and scenic qualities of open spaces. (Ord. 113 § 1 (Exh. A 5.2.1), 1983)
Establishing a planned community zone in the development regulations to achieve the following purposes:
1. To promote and protect the public health, safety, and welfare;
2. To implement the objectives and policies of the general plan;
3. To safeguard and enhance environmental amenities and the quality of development;
4. To attain the physical, social, and economic advantages resulting from comprehensive and orderly
planned use of land resources;
5. To lessen congestion and assure convenience of access; to secure safety from fire, flood, and other
dangers; to provide for adequate light, air, sunlight, and open space; to promote and encourage
conservation of scarce resources; to prevent overcrowding of land and undue concentration of
population; to facilitate the creation of a convenient, attractive, and harmonious community; to attain
a desirable balance of residential and employment opportunities; and to expedite the provision of
adequate and essential public services;
6. To facilitate development within the City in accordance with the general plan by permitting greater
flexibility and encouraging more creative and imaginative designs for major urban development
projects subject to large-scale community planning;
7. To promote more economical and efficient use of the land while providing a harmonious variety of
housing choices and commercial and industrial activities, a high level of urban amenities, and
preservation of natural and scenic qualities of open space;
8. To provide a process for initiation, review, and regulation of large-scale comprehensively planned
urban communities that affords the maximum flexibility to the developer within the context of an
overall development program and specific, phased development plans coordinated with the provision
of necessary public services and facilities. (Ord. 113 § 1 (Exh. A 5.3.1), 1983)
Incorporating the development of open space zones for the purpose of:
1. Provide for compatible recreational uses.
2. Provide public or private active-recreation uses and activities on land within the community.
3. Promote land use compatibility with existing or planned residential, commercial, manufacturing, and
open space land uses which surround the OS-R zone activity or land use.
4. Encourage in-fill active-recreation land uses which provide a range of opportunities within the
community that service the recreational and social interaction needs of City residents of all ages,
economic situations, and physical conditions.
5. Provide for recreational opportunities within planned communities and planned residential developments.
6. Provide for associated building construction and development which is architecturally compatible and
sensitive to existing and planned land uses on the same parcel of land and on surrounding
properties. (Ord. 372 § 4, 1993)
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The City’s Zoning Ordinance establishes development regulations for specific land uses, identified by zones, as well as
overlay areas established in the General Plan, such as open space and floodplain areas. For example, Chapter 17.08,
Residential Zones, establishes the permitted land uses and development standards such as setbacks, dwelling unit
maximum, agricultural allotments, and building height requirements for areas zoned for residential use. Additionally,
some portions of the Zoning Ordinance apply to all areas of the City, regardless of zone, such as Chapter 17.32,
Keeping of Animals. The purpose of Title 17 is to assure that development occurs in a manner that protects the natural
and topographic character and identity of the environment, the visual integrity of hillsides and ridgelines, sensitive
species and unique geologic/geographic features, and the health, safety, and welfare of the general public by
regulating grading on private and public property and providing standards and design criteria implementing best
management practices to control stormwater and erosion during all construction activities for all development.
Proposition FF
Pursuant to Elections Code Section 4013, Proposition FF, also known as Ordinance 283, passed by the voters of
the City of Poway on November 8, 1988, as part of a vote at the general election. In order to preserve open space
in the community, no property zoned OS-R shall be rezoned to any zone other than O-S nor shall any amendment
to this Title 17 of the Poway Municipal Code be adopted that would increase the residential density on property so
zoned or change the uses permitted to allow commercial or manufacturing uses until and unless such rezoning or
amendment is approved by ordinance adopted by the voters of the City at a special or general election, or first
approved by the Poway City Council and then adopted by the voters of the City at a special or general election. As
such, a Proposition FF vote would be required for approval of the proposed project, subject to the approval of the
voters of the City, and without such approval, the proposed project would not proceed.
Poway Subarea Habitat Conservation Plan/Natural Community Conservation Plan
The Poway Subarea Habitat Conservation Plan/Natural Community Conservation Plan (Poway Subarea
HCP/NCCP) serves two general functions (City of Poway 1996):
1. To create a sustainable interconnected network of habitat preserves throughout and ultimately beyond
the City, and thus maintain functioning ecosystems and viable populations of biological resources.
2. To mitigate adverse impacts to biological resources from building the Scripps Poway Parkway Extension,
and implementing the Poway General Plan and Paguay Redevelopment Plan.
The Poway Subarea HCP/NCCP is implemented primarily through the City’s established land use regulatory process
supplemented by new implementation regulations tailored to the plan’s conservation objectives. The Poway Subarea
HCP/NCCP also defines mitigation requirements for development projects inside and outside of a specified Mitigation
Area, and methods for funding land acquisitions and preserve management within the Mitigation Area. The project site
does not fall within the Poway Subarea HCP/NCCP Mitigation Area (City of Poway 1996).
4.10.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to land use and planning are based on Appendix G
of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to land use
and planning would occur if the project would:
1. Physically divide an established community.
2. Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an environmental effect.
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4.10.4 Impacts Analysis
Would the project physically divide an established community?
The proposed project is located on the site of a currently vacant and abandoned golf course and is surrounded by
the existing StoneRidge residential neighborhood to the north, east, and west. As seen on Figure 3-1, Land Use Plan,
the proposed project’s land uses would be organized in a manner that is compatible with the existing single-family
homes surrounding the site, and includes design parameters intended to maintain the scenic character of the
StoneRidge neighborhood. Residential lots of similar size would be clustered together within the site, and
separated by other proposed residence types by large open space areas to define new neighborhoods and
maintain view corridors through area. Any development within the project site would be guided by The Farm in
Poway Specific Plan (Specific Plan), which includes setback requirements, performance standards, and other
development regulations to protect the privacy and quality of life for existing residents around the project site
(The Farm in Poway LLC 2020).
Primary access into the proposed project would be from a four-way signalized intersection at Espola Road and
Martincoit Road. Secondary access into the site would be from the central portion of the site on the eastern
boundary off of Cloudcroft Drive, as well as from the northeastern portion of the project site off of Boca Raton
Lane. Proposed entryways to the site are existing roadways used for surrounding neighborhoods. The project
proposes construction of internal neighborhood streets and private streets within the project site that would
improve access on and around the site, but would not result in any new division of an established community
since the site already existed as a golf course.
The proposed project would change the land use from an abandoned golf course to residential use with open space,
social and recreational amenities. The proposed project would not result in the division of an established community.
Rather, the proposed project would result in the infill of residential uses surrounded by an existing residential
community, which is entirely consistent with the proposed uses and precisely the type of residential development
encouraged by state law and regional planning documents. Therefore, impacts would be less than significant.
Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or
regulation adopted for the purpose of avoiding or mitigating an environmental effect?
As previously described, the existing General Plan Land Use and Zoning Map designates the entire project site as
“Open Space – Recreation (OS-R).” A General Plan amendment and zoning amendment would be processed
concurrently with the Specific Plan for the proposed project, to re-designate the project site as “Planned
Community (PC-9).” Pursuant to the City’s Proposition FF, these amendments are subject to the approval of the
voters of the City, and without such approval, the proposed project would not proceed. The amendment consists
of both a map amendment and a zoning text amendments. Currently, a Planned Community (PC) zone may only
be applied to properties 300 acres or larger. The proposed text amendment would revise this portion of the text to
allow the proposed project, at approximately 117 acres, to be zoned as a Planned Community (PC). In addition, a
new section would be added to the Zoning Ordinance that briefly describes The Farm in Poway Planned
Community and requirements for future voter approval for changes to residential density and open space that are
not addressed in the Specific Plan. This designation and zoning would be consistent with a few other specific plan
areas throughout the City.
Government Code Section 65453(a) authorizes local jurisdictions to adopt specific plans as a tool for the
systematic implementation of the general plan. A specific plan must be consistent with the adopted general plan,
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but can provide a unique set of land uses, design regulations, and development standards not permitted under a
city’s existing zoning or by a city’s current standards. By allowing greater flexibility, development patterns can be
specifically tailored to the characteristics of a site, including creative design concepts, density ranges that differ
from a city’s zoning code, specially designed roadways, and a mix of uses unique to the specific plan area.
Specific plans may be adopted, in whole or in part, by either resolution or by ordinance. All development and
improvements constructed within a specific plan area must be consistent with the City’s general plan, the specific
plan, and the tentative map(s).
The proposed project includes the adoption of a new specific plan, the purpose of which is to establish a link
between implementing policies of the General Plan and the individual development proposals in a defined area.
As required by Government Code Section 65450 et seq., the Specific Plan contains land uses and development
regulations, infrastructure requirements, and implementation measures for the development of a specific
geographic area (referred to as the project site or Specific Plan Area). These provisions require that a specific plan
be consistent with the adopted general plan. The Specific Plan includes a General Plan Consistency Analysis,
which demonstrates it is consistent with applicable General Plan policies (The Farm in Poway LLC 2020). The
General Plan Consistency Analysis is outlined in Appendix H.
As previously described, the proposed project densities would be compatible with the existing, adjacent
residential uses. The surrounding area is zoned as RS-4, which allows for single-family residential development on
minimum lot sizes of 10,000 square feet; additional uses are permitted that are complementary to, and can exist
in harmony with, a residential neighborhood. Proposed residential development within the project site
incorporates a design that reflects the rural and open space elements found throughout neighboring
communities. The proposed project design includes 55.72 acres of open space conservation for largely
agricultural purposes, 14.65 acres of recreational open space, and 33.85 acres of residential land use. The
proposed zoning would be as follows (The Farm in Poway LLC 2020):
Open Space – Conservation (OS-C) is designed to permanently preserve the open space amenities that
provide the rural setting for the existing neighborhood and a new residential master planned community.
These open space areas serve as a physical and visual buffer between existing residential uses and new
residential development, maintaining neighbor’s privacy and providing the visual backdrop for the new
community. Parcels designated as OS-C shall be deed-restricted to ensure that they are preserved as
open space in perpetuity. Parcels designated as OS-C may be planted with agriculture or naturalized open
space areas.
The Open Space – Recreation (OS-R) is intended to replace the recreational amenities once provided by
the golf course to support new and existing residential uses within and around the Specific Plan area.
Recreational amenities include social, recreational, and educational uses that support healthy and active
lifestyles, promote lifelong learning and community education, and encourage ecological stewardship.
Residential Twin (R-T) consist of two single-family attached homes (twin homes) adjoined along a
common property line.
Residential Cottage (R-C) include a group of 2 to 4 single-family homes grouped together around a shared
motor court. Similar to traditional farmsteads, these consist of an enclave of buildings that are designed
to relate to one another. Residential Farmsteads offer a unique opportunity to create a neighborhood
within a neighborhood.
Residential Garden (R-G) include traditional single-single-family homes that take direct access from a
private street.
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Residential Homesteads (R-H) are located within the Very High Fire Hazard Severity Area (VHFHSZ). As such,
they maintain significantly larger building separation that resemble those found on rural homesteads.
Residential Meadows (R-M) are large single-family homes situated on traditional lots with
conventional setbacks.
As described above, the proposed project’s consistency with applicable land use plans, policies, or regulations
adopted for the purpose of avoiding or mitigating an environmental effect is detailed in Appendix H. Based on the
preceding discussion regarding the proposed project’s land use and design compatibility and based on the
consistency analysis presented in Appendix H, the proposed project would not result in a conflict with any
applicable land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental
effect; therefore, impacts would be less than significant.
4.10.5 Cumulative Impacts
Figure 3-11, Cumulative Projects, and Table 3-2, Cumulative Projects, identify the projects generally considered
for the cumulative analysis. While land use impacts tend to be localized in nature, and specific impacts are tied
either directly or indirectly to the specific action, the proposed project may have the potential to work in concert
with other past, present, or future projects to cause unintended land use impacts (e.g., reducing available open
space or accommodating increased growth that may result in more intensive land uses).
Therefore, impacts to land use tend towards larger policy areas as opposed to the more focused project-specific
impacts. The geographic scope for analyzing cumulative impacts related to land use includes consideration of all
the cumulative projects listed in Table 3-2.
The cumulative projects approved and under review within the City of Poway, City of Escondido, and City of San
Diego would also be localized in nature. In respect to land uses, the proposed projects would be required to
comply with any policies and planning requirements that the City of Poway voters had previously approved in
regards to recreational open space zoning. Additionally, any proposed zoning changes would also have to be
approved by the City of Poway and associated bodies of interest. Therefore, the land use and planning impacts
would have been foreseen and less than cumulatively significant.
4.10.6 Mitigation Measures
The proposed project would not result in any significant impacts to land use; therefore, no mitigation would be required.
4.10.7 Level of Significance After Mitigation
As analyzed in Section 4.10.4, Impacts Analysis, implementation of the proposed project would not result in the
division of an established community, as proposed land uses are compatible with surrounding residential
neighborhoods, and proposed design elements are consistent with the community character of the City. Additionally,
the proposed project would incorporate recreational open space land uses open to the public. With adoption of the
proposed Specific Plan, General Plan amendment, and Zoning amendment, the proposed project would not conflict
with any land use plan, policy, or regulation adopted for the purpose of reducing an environmental effect. Impacts
related to land use would be less than significant, and no mitigation would be required.
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4.11 – Noise
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4.11 Noise
This section describes the existing noise conditions of The Farm in Poway project (proposed project) site and vicinity,
identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures
related to implementation of the proposed project. This analysis is based on review of existing resources; technical
data; applicable laws, regulations, and guidelines; and the noise technical report prepared by Dudek in February
2020. The Noise Technical Report for The Farm in Poway Project is included in this Environmental Impact Report
(EIR) as Appendix I.
A Notice of Preparation (NOP) was circulated from May 10, 2019, to June 10, 2019. During the NOP comment
period, comment letters related to Noise focused on the following topics:
Permanent increase in ambient noise
Temporary increase in construction noise
Increased noise during events at The Barn and The Social
These comments were considered during the preparation of this EIR. The Initial Study, NOP, and Public Scoping
comments are provided in Appendix A of this EIR.
4.11.1 Existing Conditions
Environmental Setting
The project site is located in the northern portion of the City of Poway (City), California, and consists of the
decommissioned StoneRidge Country Club and its associated 18-hole golf course. The project site is bordered
by Espola Road to the south, and existing residential communities along St. Andrews Drive to the west and north.
The eastern boundary largely adjoins existing homes along Cloudcroft Drive, Tam O’Shanter Drive, and Boca
Raton Lane. The project site consists of approximately 117.2 acres and currently has an address of 17166
Stoneridge Country Club Lane, Poway, California 92064. Figure 3-9, Project Location, in Chapter 3, Project
Description, shows the proposed project’s location within the County of San Diego (County) and the City.
Regionally, the City is situated near the middle of the County, approximately 20 miles north of downtown San
Diego via Interstate 15. The project site is approximately two miles east of Interstate 15. The City boundary is
approximately one-half mile to the west of the project site. Figure 1-1, Site Plan, in Chapter 1, Executive Summary,
depicts an aerial view of the project site vicinity.
The proposed project includes a total of 160 single-family homes and a mix of open space and recreational uses
open to the public (see Figure 3-9). Residential land uses would compose approximately 33.85 acres and would
range in density from 2.5 to 10.7 dwelling units per acre. Open space uses would compose approximately 70.37
acres and would be comprised of Open Space – Conservation (OS-C) and Open Space – Recreational (OS-R).
Approximately 12.96 acres would be private streets.
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Noise Factors and Terminology
Sound
Sound is mechanical energy transmitted by pressure waves in a compressible medium, such as air. Noise is defined
as sound that is loud, unpleasant, unexpected, or undesired. The sound pressure level has become the most
common descriptor used to characterize the loudness of an ambient sound level. The unit of measurement of sound
pressure is a decibel (dB). Under controlled conditions in an acoustics laboratory, the trained, healthy human ear
is able to discern changes in sound levels of one dB when exposed to steady, single-frequency signals in the mid-
frequency range. Outside such controlled conditions, the trained ear can detect changes of two dB in normal
environmental noise. It is widely accepted that the average healthy ear, however, can barely perceive noise level
changes of three dB. A change of five dB is readily perceptible, and a change of 10 dB is perceived as twice or half
as loud (Caltrans 2013a). A doubling of sound energy results in a three dB increase in sound, which means that a
doubling of sound energy (e.g., doubling the number of daily trips along a given road) would result in a barely
perceptible change in sound level.
Sound may be described in terms of level or amplitude (measured in dB), frequency or pitch (measured in hertz, or
cycles per second), and duration (measured in seconds or minutes). Because the human ear is not equally sensitive
to sound at all frequencies, a special frequency-dependent rating scale is used to relate noise to human sensitivity.
The A-weighted decibel (dBA) scale performs this compensation by discriminating against low and very high
frequencies in a manner approximating the sensitivity of the human ear.
Several descriptors of noise (noise metrics) exist to help predict average community reactions to the adverse effects
of environmental noise, including traffic-generated noise. These descriptors include the equivalent noise level over
a given period (Leq), the statistical sound level (Ln), the day–night average noise level (Ldn), and the community noise
equivalent level (CNEL). Each of these descriptors uses units of dBA.
Leq is a sound level energy-averaged over a specified time period, represented by a single constant value equivalent
to the variable sound energy received at a location. For example, a one-hour Leq measurement would represent the
average amount of energy contained in all the noise that occurred in that hour. Leq is an effective noise descriptor
because it allows convenient comparison of time-varying sound levels at different locations. Lmax is the greatest
sound level measured during a designated time interval or event.
Unlike the Leq metrics, Ldn and CNEL metrics always represent 24-hour periods. Ldn and CNEL also differ from Leq
because they apply a time-weighted factor designed to emphasize noise events that occur during the evening and
nighttime hours (when speech and sleep disturbance is of more concern). “Time weighted” refers to the fact that
Ldn and CNEL penalize noise that occurs during certain sensitive periods. In the case of CNEL, noise occurring during
the daytime (7 a.m. to 7 p.m.) receives no penalty. Noise during the evening hours (7 p.m. to 10 p.m.) is penalized
by adding five dB to the measured or predicted Leq values, and nighttime (10 p.m. to 7 a.m.) noise is penalized by
adding 10 dB. Ldn differs from CNEL in that the daytime period is defined as 7 a.m. to 10 p.m., thus eliminating the
evening period. Ldn and CNEL are the predominant criteria used to measure roadway noise affecting residential
receptors. These two metrics generally differ from one another by no more than one-half to one dB, and are thus
often considered comparable or even equivalent and interchangeable by many jurisdictions.
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Vibration
Vibration is the oscillatory movement of solid mass. Like sound, it is described in terms of frequency and amplitude,
which can be expressed as displacement, velocity, or acceleration. For purposes of this analysis and consistent
with environmental assessment, vibration is presented and discussed herein as units of velocity (inches per second
[ips]) and their decibel equivalents, as appropriate. Vibration impacts to buildings are generally discussed in terms
of peak particle velocity (PPV), while human annoyance or disturbance is often discussed with root-mean-square
vibration velocity levels that are converted to decibels. But for purposes of this analysis, PPV will be used to describe
all vibration for ease of reading and comparison. Vibration can impact people, structures, and sensitive equipment
or processes (Caltrans 2013b). Common sources of vibration within communities include construction activities
and railroad operations. Groundborne vibration generated by construction projects exhibits highest amplitudes
during pile driving, rock blasting, soil compacting, jack hammering, and demolition-related activities that involve
sudden impacts or other transient impulses of energy delivered to soil and rock strata. Vibration can also occur
more regularly or even be continuous in nature, such as the steady operation of mechanical equipment featuring
reciprocating or rotating components that are slightly imbalanced. The maximum vibration level standard used by
the California Department of Transportation (Caltrans) for the prevention of structural damage to typical residential
buildings is 0.3 ips PPV (Caltrans 2013b).
Methodology
On June 11, 2019, noise measurements were conducted on and near the project site to quantify and help characterize
the existing pre-project outdoor sound environment. Table 4.11-1 provides the locations, date, and times these noise
measurements were performed. The noise measurements were taken using a Rion NL-52 sound level meter equipped
with a one-half-inch, pre-polarized condenser microphone with pre-amplifier. The sound level meter meets the current
American National Standards Institute standard for a Type 1 (Precision Grade) sound level meter. The accuracy of the
sound level meter was verified using a field calibrator before and after the measurements, and the measurements were
conducted with the microphone positioned approximately five feet above the ground.
Table 4.11-1. Measured Community Outdoor Noise Levels
Receptor Location/Address
Date
(mo:dd:yy)
Time
(hh:mm)
Leq
(dBA)
Lmax
(dBA)
ST1 North of 16616 Espola Rd.
Poway, California 92064
06/11/19 10:20–10:30 a.m. 64.9 75.1
ST2 South of multi-family homes
on Port Marnock Dr.
Poway, California 92064
06/11/19 11:30–11:40 a.m. 43.1 49.9
ST3 South of 17956 St Andrews Dr.
Poway, California 92064
06/11/19 11:15–11:25 a.m. 42.2 67.5
ST4 East of 17154 Cloudcroft Dr.
Poway, California 92064
06/11/19 11:00–11:10 a.m. 52.5 64.5
Source: Appendix I.
Notes: mo = month; dd = day; yy = year; hh = hour; mm = minute; Leq = equivalent continuous sound level (time-averaged sound level); dBA
= A-weighted decibels; Lmax = maximum sound level during the measurement interval; ST = short-term noise measurement locations.
The four short-term noise measurement locations (ST1–ST4) were selected to represent sample existing noise-sensitive
receivers on and near the project site. These locations are depicted as receivers ST1–ST4 on Figure 4.11-1, Noise
Measurement Locations. The measured energy-averaged (Leq) and maximum (Lmax) noise levels at these field survey
4.11 – Noise
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locations are provided in Table 4.11-1. The primary noise sources at the sites identified in Table 4.11-1 consisted of
traffic along adjacent roadways; and, the sounds of rustling leaves, aircraft overflights, distant conversation, and
birdsong. As shown in Table 4.11-1, the measured sound levels ranged from approximately 42.2 dBA Leq at ST3 to 64.9
dBA Leq at ST1. More details of the collected noise measurement data can be found in Appendix I.
4.11.2 Relevant Plans, Policies, and Ordinances
Federal
Noise Control Act
The Noise Control Act of 1972 was passed to promote healthy environments for Americans free from noise that
jeopardizes their health and welfare. The Noise Control Act serves to (1) establish a means for effective coordination
of federal research and activities in noise control, (2) authorize the establishment of federal noise emission
standards for products distributed in commerce, and (3) provide information to the public respecting the noise
emission and noise reduction characteristics of such products.
In 1982, the U.S. Environmental Protection Agency phased out its Office of Noise Abatement and Control in an effort
to shift the onus of noise control policy from the federal government to state and local governments.
Federal Transit Administration
In its Transit Noise and Vibration Impact Assessment Manual, the Federal Transit Administration recommends a
daytime construction noise level threshold of 80 dBA Leq over an eight-hour period (FTA 2018) when “detailed”
construction noise assessments are performed to evaluate potential impacts to community residences surrounding
a project. Although this guidance is not a regulation, it can serve as a quantified standard in the absence of such
limits at the state and local jurisdictional levels.
State
California Environmental Quality Act
The California Environmental Quality Act (CEQA) (California Public Resources Code, Section 21000 et seq.) and the
CEQA Guidelines (14 CCR 15000 et seq.) are primary sources for environmental legislation in California; they
require projects with potential adverse environmental effects (or impacts) undergo environmental review. Adverse
environmental impacts are typically mitigated as a result of the environmental review process in accordance with
existing laws and regulations.
California Noise Insulation Standards (California Code of Regulations Title 24)
California noise regulations are contained in Title 24 of the California Code of Regulations, Noise Insulation
Standards, which establishes the acceptable interior environmental noise level (45 dBA Ldn) for multi-family
dwellings (the regulations may be extended by local legislative actions to include single-family dwellings). Section
1207 of Title 24 also requires that an interior acoustical study demonstrating that interior noise levels due to
exterior sources will be less than or equal to 45 dBA CNEL be performed for affected multi-family structures that
are exposed to exterior noise levels in excess of 60 dBA CNEL.
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California Department of Health Services Guidelines
The State Department of Health Services has developed guidelines of community noise acceptability for use by
local agencies (OPR 2003). Selected relevant levels are listed as follows:
Below 60 dBA CNEL – normally acceptable for low-density residential use
50 to 70 dBA – conditionally acceptable for low-density residential use
Below 65 dBA CNEL – normally acceptable for high-density residential use and transient lodging
60 to 70 dBA CNEL – conditionally acceptable for high-density residential, transient lodging, churches,
educational, and medical facilities
The normally acceptable exterior noise level for transient lodging use is up to 65 dBA CNEL. Conditional acceptable
exterior noise levels range up to 70 dBA CNEL for transient lodging.
California Department of Transportation
In its Transportation and Construction Vibration Guidance Manual, Caltrans recommends a vibration velocity
threshold of 0.2 ips PPV for assessing “annoying” vibration impacts to occupants of residential structures (Caltrans
2013b). Although this guidance is not a regulation, it can serve as a quantified standard in the absence of such
limits at the local jurisdictional level. Similarly, thresholds to assess the risk of building damage due to construction
vibration vary with the type of structure and its fragility, but tend to range between 0.3–0.4 ips PPV for typical
residential structures (Caltrans 2013b).
Local
Poway Municipal Code, Chapter 8.08 – Noise Abatement and Control
The following sections of the City’s Municipal Code would apply to the proposed project (City of Poway 2019):
Section 8.08.010 Purpose and Intent
The City Council finds and declares that:
A. Inadequately controlled noise presents a growing danger to the health and welfare of the residents of the City;
B. The making and creating of disturbing, excessive, offensive or unusually loud noises within the jurisdiction
limits of the City is a condition which has persisted and the level and frequency of occurrence of such noises
continue to increase;
C. The making, creation or continuance of such excessive noises which are prolonged or unusual in their time,
place, and use effect and are a detriment to the public health, comfort, convenience, safety, welfare, and
prosperity of the residents of the City;
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D. Every person is entitled to an environment in which the noise is not detrimental to his or her life, health,
and enjoyment of property; and
E. The necessity in the public interest for the provisions and prohibitions contained in this chapter and enacted
as declared to be a matter of legislative determination and public policy and it is further declared that the
provisions and prohibitions contained and enacted are in the pursuance of and for the purpose of securing
and promoting the public health, comfort, convenience, safety, welfare, prosperity, peace and quiet of the
City and its inhabitants. (Ordinance 29, Section 1, 1981; CC Section 36.401)
Section 8.08.040 Sound Level Limits
Unless a variance has been applied for and granted pursuant to this chapter, it is unlawful for any person to cause
or allow the creation of any noise to the extent that the one-hour average sound level, at any point on or beyond the
boundaries of the property on which the sound is produced, exceeds the applicable limits set forth below, except
that construction noise level limits shall be governed by PMC 8.08.100:
Zone or Land Use Designation Allowable Time
Applicable Limit One-Hour
Average Sound Level
(In decibels)
OS-RM, OS, OS/1du, RR-A, RR-B, RR-C, RS-2, RS-
3, RS-4, RS-7, and Specific Plan, PRD and PC
regulations with a density of 11 dwelling units or
less per acre
10:00 p.m. to 7:00 a.m. 40
7:00 a.m. to 10:00 p.m. 50
PF, RA, RC, MHP, and Specific Plan, PRD and PC
regulations with a density of 11 or more dwelling
units per acre
7:00 a.m. to 7:00 p.m. 55
7:00 p.m. to 10:00 p.m. 50
10:00 p.m. to 7:00 a.m. 45
SPC, MU, CO, CN, CB, CG, TC, A/GC and HC 7:00 a.m. to 7:00 p.m. 60
7:00 p.m. to 10:00 p.m. 55
10:00 p.m. to 7:00 a.m. 50
MRE, SC, LI, LI/S and IP Anytime 70
The sound level limit at a location on a boundary between two zoning districts is the arithmetic mean of the
respective limits for the two districts.
Fixed location public utility distribution or transmission facilities located on or adjacent to a property line shall be
subject to the noise level limits of this section, measured at or beyond six feet from the boundary of the easement
upon which the equipment is located. (Ordinance 646, Section 3, 2006; Ordinance 172, Section 1 (Exh. A), 1985;
Ordinance 29, Section 1, 1981; CC, Section 36.404)
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Section 8.08.100 – Construction Equipment
Except for emergency work, it is unlawful for any person, including the City, to operate any single or combination or
powered construction equipment at any construction site, except as outlined in subsections A and B of this section:
A. It is unlawful for any person, including the City, to operate any single or combination of powered
construction equipment during specific hours before 7:00 a.m. or after 5:00 p.m. on Mondays through
Saturdays or at any time on a Sunday or holiday except as provided below. For purposes of this section,
“construction” does not include minor home repairs, lawn mowing, gardening and similar types of routine
as identified in PMC 8.078.170(D).
a. The City Engineer may permit, in writing, the use of powered construction equipment during specific hours
before 7:00 a.m. or after 5:00 p.m. Monday through Saturday, or any time on a Sunday or holiday, if he or
she determines that such operations are not detrimental to the health, safety, or welfare of the surrounding
community, that the conduct of the activity is limited by the nature of the work, and that is in the best interest
of the public to perform the work outside of normal hours and days of work.
b. A residential property owner constructing a single-family residence, or constructing an addition to, or
otherwise modifying, a single-family residence for personal occupancy may operate powered
construction equipment on Sundays or holidays between the hours of 10:00 a.m. and 5:00 p.m. in
compliance with the requirements of subsection B of this section; provided, that:
i. The type of equipment used is limited to handheld construction equipment or equipment powered by
small electrical motors, including, but not limited to, small cement mixers, table saws, and similar
small equipment; and
ii. The construction is not carried out for profit or livelihood. Upon request of the City, a property owner
shall provide documentation, to the satisfaction of the Director of Development Services, of personal
occupancy of the residence, or the intent to personally occupy the residence.
B. No such equipment, or combination of equipment regardless of age or date of acquisition, shall be operated
so as to cause noise at a level in excess of 75 decibels for more than eight hours during any 24-hour period
when measured at or within the property lines of any property which is developed and used either in part
or in whole for residential purposes. These found levels shall be corrected for time duration in accordance
with the following table:
Total Duration in 24 Hours Decibel Level Allowance Total Decibel Level
Up to 15 Minutes +15 90
Up to 30 Minutes +12 87
Up to 1 Hour +9 84
Up to 2 Hours +6 81
Up to 4 Hours +3 78
Up to 8 Hours 0 75
In the event that lower noise limit standards are established for construction equipment pursuant to State or
Federal law, said lower limits shall be used as a basis for revising and amending the noise level limits specified in
subsection B of this section. (Ordinance 646, Section 4, 2006; Ordinance 29, Section 1, 1981; CC Section 36.410).
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Poway Comprehensive Plan: General Plan – Emergency Services Element
The Noise Hazards section of the Emergency Services Element of the Poway Comprehensive Plan: General Plan
(General Plan), in compliance with Section 65302(f) of the Government Code requiring a noise element that
quantifies the community noise environment and serves to guide development to achieve noise compatible land
uses, includes the following policy and strategies regarding noise (City of Poway 1991):
Goal VII, Policy H – Noise: The City shall ensure a safe and pleasant acoustical environment for the residents of Poway.
Strategy 1: Utilize site planning, zoning, regulations, architectural design standards and building
construction regulations to reduce noise impacts.
Strategy 2: Review all discretionary project applications which include sensitive land uses for conformance
with the Exterior CNEL Compatibility Matrix table.
Strategy 3: Require mitigation measures for all proposed projects which are found, according to an
Acoustical Analysis Report, to be subject to incompatible CNEL values.
Strategy 4: Proposed land uses which generate noise should be subject to an Acoustical Noise Report, with
mitigation measures to be specified.
Strategy 5: An Acoustical Noise Report shall be prepared for all public works projects which have a potential
for public noise exposure.
Strategy 6: Increases in traffic noise caused solely by roadway improvements shall be mitigated to future
levels which would have occurred without the improvement.
Strategy 7: When noise protection barriers are needed, they shall be located in the most cost-effective location.
The maximum protection for a given barrier height and length shall be determined by acoustical analysis using
the current edition of the FHWA [Federal Highway Administration] noise level model program.
Strategy 8: Noise protection walls may be limited to a height of eight feet, even when a taller wall may
be needed to achieve Noise Element standards, if a taller one is deemed to be aesthetically degrading
to the environment.
Strategy 9: Mitigation wall will be at least four feet high, even if mitigation calculations call for a shorter wall.
Strategy 10: A time-averaging should level meter meeting American National Standards Institute S.4
standards shall be used to enforce the noise control provisions of the Zoning Ordinance.
Strategy 11: Enforce the provisions of the California Noise Insulation Standards (California Code of
Regulations, Title 24) prior to issuing a building permit for multi-family dwelling units. If these units are
located in an area of noise incompatibility (exposed to 60 decibels or more, CNEL), an Acoustical Analysis
Report, as prescribed in Section IID of the Noise Hazard Element, shall be prepared demonstrating that
interior noise levels of habitable rooms will not exceed 45 decibels.
Strategy 12: The interior floor/ceiling and party wall assemblies for multi-family dwelling, whether or not
they are located in areas of noise incompatibility, shall provide a minimum insulation between units of 45
decibels, FSTC [field transmission class].
Strategy 13: Standard care and practice guidelines for building construction shall include, but not be limited
to, the current edition of the American Standards for Testing and Materials, E-497, standard practice for
installing sound-insulating lightweight partitions.
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Strategy 14: When new projects are submitted to the City that require Conditional Use Permits Tentative
Map approval, etc. a report must be submitted that demonstrates that significant environmental impacts,
including noise, are mitigated to less than significant levels.
Strategy 15: Acoustical Analysis Report standards containing the required format, measurements,
calculations and exhibits for land use, zoning and building permit applications shall be prepared and
updated annually.
4.11.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts related to noise are based on Appendix G of the CEQA
Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to noise would occur if the
project would:
1. Result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity
of the project in excess of standards established in the local general plan or noise ordinance, or applicable
standards of other agencies.
2. Result in generation of excessive groundborne vibration or groundborne noise levels.
3. For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan
has not been adopted, within two miles of a public airport or public use airport, expose people residing or
working in the project area to excessive noise levels.
For this noise assessment and The Farm in Poway Specific Plan (Specific Plan), up to 70 dBA CNEL noise exposure
at the property lines of residences within the project site would be allowed and thus serve as the relevant threshold.
At the boundary lines of existing residences outside of (or adjoining) the project site, the threshold would be a more
stringent 60 dBA CNEL.
4.11.4 Impacts Analysis
Would the project result in generation of a substantial temporary or permanent increase in ambient noise levels in
the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or
applicable standards of other agencies?
Construction
Construction noise and vibration are temporary phenomena. Construction of the proposed project would generate
noise that could expose nearby sensitive receptors (i.e., existing residences) to elevated noise levels that may
disrupt communication and routine activities. The magnitude of the impact would depend on the type of
construction activity, equipment, duration of the construction, distance between the noise source and receiver, and
intervening structures. The analysis that follows is in regards to the noise levels calculated to result from
construction of the proposed project at nearby sensitive receptors.
The construction activities for the proposed project would vary by component (i.e., Open Space Land Use Districts
and Residential Land Use Districts) and location. The proposed construction activities located nearest to a
sensitive receptor were used for each phase and component. Representative equipment for residential lot
earthwork and for residential building construction was assembled from similar residential subdivision projects
that Dudek has evaluated for construction noise. Table 4.11.-2 summarizes the construction phases and
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distances to the apparent closest noise-sensitive receptors that are used in the predictive analysis of
construction noise levels at various community locations. Distance values of zero indicate the listed construction
phase is not applicable to the project feature.
Table 4.11-2. Construction Phase Distance to Nearest Pre-Existing Noise-Sensitive Receptors (in feet)
Construction
Phase
Project Feature (and distance in feet to nearest NSR)
Residential
The
Farm
The
Meadow
The
Club
Trail
System
Road
Paving Basin
The
Working
Farm
Community
Garden
Demolition 120 120 0 120 0 0 120 0 0
Site
Preparation
50 50 150 50 25 36 15 50 50
Grading 50 50 150 50 25 36 15 50 50
Building
Construction
100 360 0 300 25 0 0 0 0
Paving 0 120 0 50 25 36 0 0 0
Architectural
Finishes
100 360 0 300 0 0 0 0 0
Note: NSR = noise-sensitive receptor.
An Excel-based noise prediction model emulating and using reference data from the Federal Highway
Administration’s Roadway Construction Noise Model (RCNM) (FHWA 2008) was used to estimate construction noise
levels at the nearest occupied noise-sensitive land use.1 Input variables for the predictive modeling consist of the
equipment type and number of each (e.g., two graders, one loader, one tractor), the duty cycle for each piece of
equipment (e.g., percentage of time within a specific time period, such as an hour, when the equipment is expected
to operate at full power or capacity and thus make noise at a level comparable to what is presented in Table 4.11-
2), and the distance from the noise-sensitive receiver. The predictive model also considers how many hours that
equipment may be on site and operating (or idling) within an established work shift. No topographical or structural
shielding was assumed in the modeling. The RCNM has default duty-cycle values for the various pieces of
equipment, which were derived from an extensive study of typical construction activity patterns. Those default duty-
cycle values were used for this noise analysis.
Equipment that would be in use during proposed construction would include, in part, graders, backhoes, rubber-
tired dozers, loaders, cranes, forklifts, cement mixers, pavers, rollers, and air compressors. The typical maximum
noise levels for various sample pieces of construction equipment at a distance of 50 feet are presented in Table
4.11-3. Note that the equipment noise levels presented in Table 4.11-3 are maximum noise levels, which likely
result in overestimating actual impacts from the construction of the proposed project. Typically, construction
equipment operates in alternating cycles of full power and low power, producing average noise levels less than the
maximum noise level. The average sound level of construction activity also depends on the amount of time that the
equipment operates and the intensity of construction activities during that time.
1 Although the RCNM was funded and promulgated by the Federal Highway Administration, it is often used for non-roadway projects,
because the same types of construction equipment used for roadway projects are often used for other types of construction.
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Table 4.11-3. Typical Construction Equipment Maximum Noise Levels
Equipment Type Typical Maximum Noise Level (Lmax, dBA at 50 Feet)
All Other Equipment > 5 HP 85
Backhoe 78
Compressor (air) 78
Concrete Saw 90
Crane 81
Dozer 82
Excavator 81
Flat Bed Truck 74
Front-End Loader 79
Generator 72
Grader 85
Man Lift 75
Paver 77
Roller 80
Scraper 84
Welder / Torch 73
Source: Appendix I
Notes: Lmax = maximum sound level; dBA = A-weighted decibels; HP = horsepower.
With the exception of the concrete saw, and as suggested by the list of Lmax values in Table 4.11-3, the maximum
noise levels at 50 feet tend not to exceed 85 dBA for common equipment and vehicles anticipated for this kind of
multi-use development project. Hourly Leq values at this distance, however, would vary depending on duty cycle.
Construction noise in a well-defined area typically attenuates at approximately six dB per doubling of distance, as
each piece of equipment can be approximated as an individual point-type source. Alternately, a set of equipment
in proximity to one another could be considered geographically a common point source; or, on average with respect
to time, a set of operating equipment with uncertain positions within a defined area could be considered a common
point source. Proposed project construction would take place both near and far from adjacent, existing noise-
sensitive uses. For example, construction near the northern project site boundary would appear to take place within
approximately 15 feet of existing residential property lines, but during construction of other proposed project
components, construction activities would be much further away from noise-sensitive receptors, as indicated in the
distance values in Table 4.11-2, Construction Phase Distance to Nearest Pre-Existing Noise-Sensitive Receptors.
Appendix I provides details on the calculations of estimated construction noise, which are summarized in the
following sections and categorized in a manner similar to what is presented in Chapter 3.
Construction of Open Space Land Use Districts
The Club
The Club would be located towards the middle of the project site, north of the R-C residential district (see Figure 1-
1). Construction activities could occur within 50 feet of the nearest noise-sensitive receiver. Estimated noise levels
from the major construction phases of The Club were calculated for the nearest noise-sensitive land use, as presented
in Table 4.11-4.
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Table 4.11-4. Construction Noise Modeling Summary Results for The Club
Construction Phase (expected equipment types) Estimated 8-hour Leq (dBA)a
Demolition (dozer, excavator, concrete saw) 74
Site Preparation (backhoe, dozer, front-end loader) 75
Grading (excavator, grader, scraper) 75
Building Construction (crane, man lift, generator, backhoe, front-end loader, welder) 64
Paving (paver, roller, other equipment > 5 HP) 74
Architectural Coating (air compressor) 59
Source: Appendix I
Notes: Leq = equivalent continuous sound level (time-averaged sound level); dBA = A-weighted decibel; HP = horsepower.
a At nearest distance per Table 4.11-2.
As presented in Table 4.11-4, the estimated construction noise levels are predicted to be as high as 75 dBA Leq
over an eight-hour period at the nearest existing residences (as close as 50 feet away) when grading activities take
place near the project site boundary. Distances to the nearest noise-sensitive receiver are greater, as shown in
Table 4.11-2 for activities such as demolition and building construction and therefore yield lower eight-hour
predicted noise levels. Note that these estimated construction noise levels at a source-to-receiver distance of 50
feet include consideration of limited operation duration of specific anticipated equipment as detailed in Appendix
I. By way of example, a grader might make one or more passes on site that are this close to the receiver; but, for
the remaining time during the day, the grader would be sufficiently farther away, performing work at a more distant
location or simply not operating.
The Meadow
The Meadow would be located directly adjacent to the east of The Club. Construction activities could occur within
150 feet of the nearest noise-sensitive receiver. Estimated noise levels from the major construction phases of The
Meadow were calculated for the nearest noise-sensitive land use, as presented in Table 4.11-5.
Table 4.11-5. Construction Noise Modeling Summary Results for The Meadow
Construction Phase (expected equipment types) Estimated 8-hour Leq (dBA)a
Site Preparation (backhoe, dozer, front-end loader) 71
Grading (excavator, grader, scraper) 75
Source: Appendix I
Notes: Leq = equivalent continuous sound level (time-averaged sound level); dBA = A-weighted decibel.
a At nearest distance per Table 4.11-2.
As presented in Table 4.11-5, the estimated construction noise levels are predicted to be as high as 75 dBA Leq
over an eight-hour period at the nearest existing residences (as close as 150 feet away) when grading activities
take place near the project site boundary. Therefore, under these conditions, the predicted 75 dBA eight-hour Leq
value would be compliant with the City’s threshold for construction noise.
The Farm (The Barn and Butterfly Farm)
The Farm, a collective reference for both The Barn and Butterfly Farm features of the proposed project, would be
located at the southernmost portion of the project site, adjacent to Espola Road and at the proposed entrance of the
project site at the intersection of Espola Road and Martincoit Road (see Figure 1-1). Construction activities could occur
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within 50 feet of the nearest noise-sensitive receiver. Estimated noise levels from the major construction phases of
The Farm were calculated for the nearest noise-sensitive land use, as presented in Table 4.11-6.
Table 4.11-6. Construction Noise Modeling Summary Results for The Farm
Construction Phase (expected equipment types) Estimated 8-hour Leq (dBA)a
Demolition (dozer, excavator, concrete saw) 74
Site Preparation (backhoe, dozer, front-end loader) 75
Grading (excavator, grader, scraper) 75
Building Construction (crane, man-lift, generator, backhoe, front-end loader, welder) 63
Paving (paver, roller, other equipment > 5 HP) 72
Architectural Coating (air compressor) 57
Source: Appendix I
Notes: Leq = equivalent continuous sound level (time-averaged sound level); dBA = A-weighted decibel; HP = horsepower.
a At nearest distance per Table 4.11-2.
As presented in Table 4.11-6, the estimated construction noise levels are predicted to be as high as 75 dBA Leq
over an eight-hour period at the nearest existing residences (as close as 50 feet away) when grading activities take
place near the project site boundary. Distances to the nearest noise-sensitive receiver are greater, as shown in
Table 4.11-2, for activities such as demolition and building construction and therefore yield lower eight-hour
predicted noise levels. Note that these estimated construction noise levels at a source-to-receiver distance of 50
feet include consideration of limited operation duration of specific anticipated equipment as detailed in Appendix
I. By way of example, a grader might make one or more passes on site that are this close to the receiver; but, for
the remaining time during the day, the grader would be sufficiently farther away, performing work at a more distant
location or simply not operating. Therefore, under these conditions, the predicted 75 dBA eight-hour Leq value would
be compliant with the City’s threshold for construction noise.
The Working Farm (Agrifields)
The Working Farm would be composed of agrifields located at the northernmost portion of the project site, along
the northwestern and northern project site boundaries (see Figure 1-1). Construction activities could occur within
50 feet of the nearest noise-sensitive receiver. Estimated noise levels from the major construction phases of The
Working Farm were calculated for the nearest noise-sensitive land use, as presented in Table 4.11-7.
Table 4.11-7. Construction Noise Modeling Summary Results for The Working Farm
Construction Phase (expected equipment types) Estimated 8-hour Leq (dBA)a
Site Preparation (backhoe, front-end loader) 75
Grading (excavator, grader, scraper) 75
Source: Appendix I
Notes: Leq = equivalent continuous sound level (time-averaged sound level); dBA = A-weighted decibel.
a At nearest distance per Table 4.11-2.
As presented in Table 4.11-7, the estimated construction noise levels are predicted to be as high as 75 dBA Leq
over an eight-hour period at the nearest existing residences (as close as 50 feet away) when grading activities take
place near the project boundary. Therefore, under these conditions, the predicted 75 dBA eight-hour Leq value would
be compliant with the City’s threshold for construction noise.
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Community Gardens
Community gardens would be located throughout the project site, providing future residents a garden plot within
walking distance of their home Construction activities could occur within 50 feet of the nearest noise-sensitive
receiver. Estimated noise levels from the major construction phases of the community gardens were calculated for the
nearest noise-sensitive land use, as presented in Table 4.11-8.
Table 4.11-8. Construction Noise Modeling Summary Results for the Community Gardens
Construction Phase (expected equipment types) Estimated 8-hour Leq (dBA)a
Site Preparation (backhoe, front-end loader) 75
Grading (excavator, grader, scraper) 75
Source: Appendix I
Notes: Leq = equivalent continuous sound level (time-averaged sound level); dBA = A-weighted decibel.
a At nearest distance per Table 4.11-2.
As presented in Table 4.11-8, the estimated construction noise levels are predicted to be as high as 75 dBA Leq
over an eight-hour period at the nearest existing residences (as close as 50 feet away) when grading activities take
place near the project site boundary. Therefore, under these conditions, the predicted 75 dBA eight-hour Leq value
would be compliant with the City’s threshold for construction noise.
Trail System
A multi-use trail system would circulate throughout the project site to provide mobility and recreational opportunities
for pedestrians and bicyclists. The majority of the trail system would include decomposed granite or compacted
earth trails. Trails along the southwest project boundary would require construction activities that could occur within
50 feet of the nearest noise-sensitive receiver. On average, this anticipated distance between trail construction activity
and a receiver would be 25 feet. Some accessory structures, such as a landscaping maintenance shack, would also be
installed as part of this construction phase and could be in similar proximity to an existing noise-sensitive receiver.
Estimated noise levels from the major construction phases for the trail system were calculated for the nearest noise-
sensitive land use, as presented in Table 4.11-9.
Table 4.11-9. Construction Noise Modeling Summary Results for the Trail System
Construction Phase (expected equipment types) Estimated 8-hour Leq (dBA)a
Site Preparation (backhoe, front-end loader) 74
Grading (grader) 78
Building Construction (generator, welder / torch) 69
Paving (concrete mixer truck, paver) 74
Source: Appendix I
Notes: Leq = equivalent continuous sound level (time-averaged sound level); dBA = A-weighted decibel.
a At nearest distance per Table 4.11-2.
As presented in Table 4.11-9, the estimated construction noise levels are predicted to be as high as 78 dBA Leq
over an eight-hour period at the nearest existing residences (as close as 25 feet away) when grading activities take
place near the project site boundary. Therefore, under these conditions, the predicted eight-hour Leq value would
not be compliant with the City’s threshold for construction noise and would require mitigation.
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The Basins
Bio-retention basins would be scattered throughout the proposed project, and construction of these basins would
involve site preparation and grading activities as close as 15 feet away from noise-sensitive receptors. Estimated
noise levels from the construction phases of the basins were calculated for the nearest noise-sensitive land use, as
presented in Table 4.11-10. The detailed RCNM input and output values are provided in Appendix I.
Table 4.11-10. Construction Noise Modeling Summary Results for the Basins
Construction Phase (expected equipment types) Estimated 8-hour Leq (dBA)a
Site Preparation (backhoe, dozer, front-end loader) 85
Grading (excavator, grader, scraper) 85
Source: Appendix I.
Notes: Leq = equivalent continuous sound level (time-averaged sound level); dBA = A-weighted decibel.
a At nearest distance per Table 4.11-2.
As presented in Table 4.11-10, the estimated construction noise levels are predicted to be as high as 85 dBA Leq
over an eight-hour period at the nearest existing residences (as close as 15 feet away) when grading activities take
place near the project site boundary. Note that these estimated noise levels at a source-to-receiver distance of 15
feet would only occur when the single loudest piece of heavy equipment is operating along the project site boundary
for a cumulative period of up to 0.75 hours a day. By way of example, the grader might make multiple passes on
site that are this close to the receiver; but, for the remaining time during the day, the grader would be sufficiently
farther away, performing work at a more distant location or simply not operating. When the entire assemblage of
equipment is working right at the edge of the construction zone in each phase, within 15 feet of existing residences,
construction noise levels are anticipated to reach up to 85 dBA Leq. Assuming relatively steady work, this would result
in an exceedance of the City’s construction noise limit of 75 dBA eight-hour Leq.
Overall, regarding construction of open space land use districts, noise levels would not exceed established
thresholds, with the exception of trail system and basin construction, which has the potential to exceed the City’s
construction noise limit of 75 dBA eight-hour Leq. Therefore, impacts would be potentially significant (Impact NOI-1)
and mitigation would be required (MM-NOI-1).
Construction of Residential Land Use Districts
New Residential Homes
The proposed project would allow for up to 160 single-family homes to be built around the project site. Construction
activities during this component could occur within 50 feet of the nearest sensitive receiver. Estimated noise levels
from the major construction phases of new residential homes were calculated for the nearest noise-sensitive land use,
as presented in Table 4.11-11.
Table 4.11-11. Construction Noise Modeling Summary Results for New Residential Homes
Construction Phase (expected equipment types)
Estimated 8-hour Leq
(dBA)a
Demolition (dozer, excavator, concrete saw) 74
Site Preparation (backhoe, front-end loader) 75
Grading (excavator, grader, scraper) 75
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Table 4.11-11. Construction Noise Modeling Summary Results for New Residential Homes
Construction Phase (expected equipment types)
Estimated 8-hour Leq
(dBA)a
Building Construction (crane, man lift, generator, backhoe, welder) 64
Paving (concrete mixer truck, backhoe, air compressor, paver, roller) 74
Architectural Coating (air compressor) 59
Source: Appendix I.
Notes: Leq = equivalent continuous sound level (time-averaged sound level); dBA = A-weighted decibel.
a At nearest distance per Table 4.11-2.
As presented in Table 4.11-11, the estimated construction noise levels are predicted to be as high as 75 dBA Leq
over an eight-hour period at the nearest existing residences (as close as 50 feet away) when grading activities take
place near the project site boundary. Distances to the nearest noise-sensitive receiver would be greater, as shown
in Table 4.11-2, for activities such as demolition and building construction, and therefore yield lower eight-hour
predicted noise levels. Note that these estimated construction noise levels at a source-to-receiver distance of 50
feet include consideration of limited operation duration of specific anticipated equipment as detailed in Appendix
I. By way of example, a grader might make one or more passes on site that are this close to the receiver; but, for
the remaining time during the day, the grader would be sufficiently farther away, performing work at a more distant
location or simply not operating. Therefore, under these conditions, the predicted 75 dBA eight-hour Leq value would
be compliant with the City’s threshold for construction noise.
Private Street B
The proposed project’s internal street network would consist of all private streets in which construction would
involve site preparation, grading, and paving. Construction activities involved with Private Street B near the southern
project site boundary could occur as close as approximately 36 feet away from noise-sensitive receptors. Estimated
noise levels from the major construction phases associated with Private Street B were calculated for the nearest noise-
sensitive land use, as presented in Table 4.11-12.
Table 4.11-12. Construction Noise Modeling Summary Results for Private Street B
Construction Phase (expected equipment types) Estimated 8-hour Leq (dBA)a
Site Preparation (backhoe, dozer, front-end loader) 78
Grading (excavator, grader, scraper) 78
Paving (paver, roller, other equipment > 5 HP) 77
Source: Appendix I.
Notes: Leq = equivalent continuous sound level (time-averaged sound level); dBA = A-weighted decibel; HP = horsepower.
a At nearest distance per Table 4.11-2.
As presented in Table 4.11-12, the estimated construction noise levels are predicted to be as high as 78 dBA Leq
over an eight-hour period at the nearest existing residences (as close as 36 feet away) when grading activities take
place near the project site boundary. Note that these estimated noise levels at a source-to-receiver distance of 36
feet would only occur when the single loudest piece of heavy equipment is operating along the project site boundary
for a cumulative period of up to 0.75 hours a day. By way of example, the grader would make multiple passes on
site that are this close to the receiver; but, for the remaining time during the day, the grader would be sufficiently
farther away, performing work at a more distant location or simply not operating. When the entire assemblage of
equipment is working right at the edge of the construction zone in each phase, within 36 feet of existing residences,
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construction noise levels are anticipated to reach up to 78 dBA Leq. Assuming relatively steady work, this would
result in an exceedance of the City’s construction noise limit of 75 dBA Leq over an eight-hour period.
Although nearby off-site residences would be exposed to elevated construction noise levels, the increased noise
levels would typically be relatively short term. It is anticipated that construction activities associated with the
proposed project would take place primarily within the allowable hours of the City (7 a.m. and 5 p.m., Monday
through Saturday). In the event that proposed construction is required to extend beyond these times, extended
hours permits would be required and would be obtained by the project applicant.
If work were to occur outside of the allowable hours, annoyance or sleep disturbance could result from construction
noise; also, due to the relatively limited distance to existing adjacent residences, construction noise annoyance
could result even during daytime hours.
Therefore, although construction of new residential units is not anticipated to exceed established noise thresholds,
construction of Private Street B would exceed the construction noise limit of 75 dBA Leq over an eight-hour period.
Therefore, construction of on-site residential land use districts would result in potentially significant impact (Impact
NOI-2) and mitigation would be required (MM-NOI-1).
Blasting
Blasting operations would be required for site preparation. Rock blasting is the controlled use of explosives to
excavate, break down, or remove rock. The result of rock blasting is often known as a rock cut. The most commonly
used explosives today are ammonium nitrate/fuel oil-based blends, due to their lower cost compared to dynamite.
No more than five blasts per day, of up to 1.2 tons of explosive each, would occur during construction activities.
Blasting would only be required where existing topography or geologic conditions require blasting to be conducted,
and for purposes of this analysis would be no closer to an existing residential receptor than 400 feet. This analysis
also assumes a per-delay charge weight of up to 18.5 pounds that is heavily confined prior to the blast event per
industry guidance (Dyno Nobel 2010). With all the delayed charges detonated in succession, the A-weighted hourly
Leq is estimated to be 82.2 dBA per blast. For all five blasts occurring within the same eight-hour period, the Leq
would be 80 dBA and exceed the City’s construction noise threshold by five dBA; hence blasting noise would result
in a potentially significant impact (Impact NOI-3) and mitigation would be required (MM-NOI-2).
Blasting involves drilling a series of boreholes and placing explosives in each hole. By limiting the amount of
explosives in each hole, the blasting contractor can limit the total energy released at any single time, which in turn
can reduce noise and vibration levels. Rock drilling generates impulsive noise from the striking of the hammer with
the anvil within the drill body, which drives the drill bit into the rock. Rock drilling generates noise levels of
approximately 81 dB Lmax (maximum sound level during the measurement interval) at a distance of 50 feet (FHWA
2006). Given a typical work cycle, this would equate to 74 dBA Leq at 50 feet. At a distance of 400 feet, consistent
with the distance blast-to-receptor distance value, the drill noise would be 56 dBA Leq over an eight-hour period and
thus compliant with the City’s construction noise limit.
Long-Term Operational Noise
Off-Site Traffic Noise Exposure
The proposed project would result in the creation of additional vehicle trips on local arterial roadways (i.e., Espola
Road), which could result in increased traffic noise levels at adjacent noise-sensitive land uses. Appendix I includes
a spreadsheet with traffic volume data (average daily traffic) for Espola Road. In particular, the proposed project
would create additional traffic along Espola Road, which according to the Transportation Impact Analysis prepared
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by Linscott, Law & Greenspan for The Farm in Poway in January 2020 (Appendix J of this EIR) would add 2,938 total
average daily trips to adjacent to the project site.
According to Caltrans, a three-dBA change in sound is the beginning at which humans generally notice a barely
perceptible change in sound, a five-dBA change is generally readily perceptible, and a 10-dBA increase is perceived
by most people as a doubling of the existing noise level (Caltrans 2013a). Due to the existing and proposed urban
setting of the project site, a readily perceptible change in noise (five dBA) would be the appropriate threshold to
determine significant increases in traffic noise.
Potential noise effects from vehicular traffic were assessed using the Federal Highway Administration’s Traffic Noise
Model version 2.5 (FHWA 2004). Information used in the model included the roadway geometry, existing (year
2019), near-term (opening day), near-term plus project, horizon year (2035) without project, and horizon year plus
project traffic volumes and posted traffic speeds. Noise levels were modeled at representative noise-sensitive
receivers ST1 through ST4, as shown in Figure 4.11-1. The receivers were modeled to be five feet above the local
ground elevation. The noise model results are summarized in Table 4.11-13. Based on results of the model,
implementation of the proposed project would not result in readily perceptible increases in traffic noise.
Table 4.11-13. Traffic Noise Modeling Results
Modeled
Receiver No.
Existing
(2019) Noise
Level
(dBA CNEL)
Near-Term
(Opening
Day) without
Project Noise
Level
(dBA CNEL)
Near-Term
(Opening
Day) with
Project Noise
Level
(dBA CNEL)
Horizon Year
(2035)
without
Project Noise
Level
(dBA CNEL)
Horizon Year
(2035) with
Project Noise
Level
(dBA CNEL)
Maximum
Project-
Related
Noise Level
Increase (dB)
ST1 65.7 65.9 66.2 66.9 67.1 0.3
ST2 41.0 41.1 44.1 41.4 44.3 3.0
ST3 52.5 52.6 52.7 52.8 52.8 0.1
ST4 47.8 48.0 50.1 48.3 50.2 2.1
Source: Appendix I.
Notes: dBA = A-weighted decibel; CNEL = community noise equivalent level; dB = decibel.
Table 4.11-13 shows that at all four listed representative receivers, the addition of proposed project traffic to the
roadway network would result in an increase in the CNEL of less than three dB, which is below the discernible level
of change for the average healthy human ear. Thus, a less-than-significant impact is expected for proposed project-
related off-site traffic noise increases affecting existing residences in the vicinity.
On-site Traffic Interior Noise Exposure
The City and the state require that interior noise levels not exceed a CNEL of 45 dB within residences. Typically, with the
windows open, building shells provide approximately 15 dB of noise reduction; with windows closed, residential construction
generally provides a minimum of 25 dB attenuation. Therefore, rooms exposed to an exterior CNEL not greater than 60 dB
would result in an interior CNEL of 45 dB or less even with windows open. But when exterior CNEL values range from 60 to
70 dBA, the windows would need to be closed and thus require that the occupied structure feature mechanical ventilation
for interior comfort. The future exterior noise levels in Table 4.11-14 are calculated at modeled positions M1, M2, and M3
on Figure 4.11-1, and correspond with the facades of three sample proposed new homes on southernmost “Cottage” lots
parallel with Espola Road. Consequently, interior noise levels within these proposed future residences on the project site
would be expected to achieve compliance with the interior noise criterion of 45 dBA CNEL by employing standard residential
construction techniques and materials.
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Table 4.11-14. Future Ambient Noise Levels at Residential Facades
Receptor Location Noise Source Distance from Roadway CNEL
Backyard, Espola Road West Espola Road 150 feet 59
Backyard, Espola Road Center Espola Road 150 feet 59
Backyard, Espola Road East Espola Road/Private Street A 150 feet 59
Source: Appendix I.
Note: CNEL = community noise equivalent level.
Traffic noise results displayed in Table 4.11-14 indicate that future traffic noise exposure levels at the closest building
facades would all be well under the maximum exterior noise level for single-family residences (70 CNEL dBA) within the
project site and would also result in an interior CNEL of 45 dB or less, even with the windows open (i.e., 59 dBA CNEL
minus 15 dBA = 44 dBA CNEL). Therefore, future roadway traffic noise levels at residences would be less than significant.
Stationary Noise Sources
The proposed project’s development would result in 160 new single-family homes and a mix of open space and
recreational uses (see Figure 1-1) that would add a variety of noise-producing mechanical equipment (discussed below).
Most of the noise-producing equipment would be considered stationary, or limited in mobility to a defined area.
Additionally, the open space and recreational uses would attract participants and their guests (or in some situations,
such activities would be open to the public) to enjoy proposed project facilities and thus create potential community noise
relating to added aggregate speech and music (both acoustic and amplified) as appropriate or expected for the venue..
The Farm in Poway Specific Plan
The Specific Plan adopts noise level thresholds that are summarized by the following excerpts (The Farm in
Poway LLC 2020):
Section 3.2.3, Additional Open Space Standards, “(7) The noise level emanating from any use or activity
shall not exceed 60 dBA CNEL, as the acceptable outdoor noise exposure level when measured at the
exterior boundaries of the Specific Plan area unless otherwise specified herein. This may be achieved through
the construction of sound attenuation barriers based upon an approved noise study.”
Section 3.2.3.B, under the description for regular events: “The aggregate sounds level from live (acoustic) or
amplified music does not exceed the maximum total weighted decibel (dBA) at a distance of 10 feet as specified
in Table 3.4: Event Sound Levels.” For convenience, Table 3.4 is reproduced below in Table 4.11-15.
Table 4.11-15. Event Sound Levels
Venue Location and Time of Regular Event
(up to 3 hours duration)
Maximum Total A-weighted Decibel (dBA) at a
Distance of 10 feeta
The Barn + The Social
Daytime (8 a.m. to 7 p.m.)
Evening (7 p.m. to 10 p.m.)
103
98
The Meadow (Amphitheater)
Daytime (8 a.m. to 7 p.m.)
Evening (7 p.m. to 10 p.m.)
97
92
Source: The Farm in Poway LLC 2020.
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Note:
a If speakers are positioned to distribute amplified sound, they must be positioned in such a manner that linear occlusion occurs
between the speaker and the nearest residential receptors outside of the Specific Plan area.
Section 3.2.3.C, Dog Parks, “(3) Noise shall be sound attenuated so that the noise level measured at the
exterior boundaries of the Specific Plan area does not exceed 60 dBA CNEL.”
Section 3.3.3, Residential Performance Standards, “The noise level emanating from any residential use or
operation within the Residential (R) Land Use Districts shall not exceed 70 dBA CNEL as the acceptable
outdoor noise exposure level when measured at the property line. The interior noise levels shall not exceed
45 dBA CNEL for all residential uses.”
For purposes of the noise analyses herein and consistent with the Specific Plan, it is assumed that a 70 dBA CNEL
standard represents the applicable noise limit for non-transportation and non-construction “stationary” sources of
noise associated with anticipated typical project-attributed operation and activities at residential land use property
lines within the project site. At the property lines of off-site residential land uses that adjoin the exterior boundary
of the project site, 60 dBA CNEL would be the standard for impact significance, consistent with state planning
guidelines. These noise sources include operation of heating, ventilation, and air-conditioning (HVAC) equipment
from the newly-created residential and non-residential land uses attributed to the proposed project.
New Residential Homes
For purposes of this analysis, each of the 160 new single-family homes would be expected to feature an air-
conditioning unit having operation noise comparable to 60 dBA at 20 feet (Berger et al. 2015). Assuming these
units are installed at grade and near a facade of the residence, they should be no closer than 50 feet to the nearest
existing residential property and would thus be expected to yield—as a worst-case—a property line noise level of 52
dBA Leq continuously throughout the day and night during hot summer conditions. At this hourly level, the
corresponding CNEL value would be 59 dBA, which is less than 60 dBA CNEL standard at the exterior boundaries
of the project site.
The Club
The Club is anticipated to feature a family swimming pool, yoga pavilion, locker rooms, and outdoor tennis and pickle
ball courts. These facilities suggest regular, continuous operation of pool filtration pumps and air-conditioning units
for the occupied interior spaces that should be no closer than 150 feet to the nearest existing noise-sensitive
residential property to the west. At this distance, the combined noise level of a typical operating pump (assume source
level of 80 dBA Leq at three feet [Bies and Hansen 1996]) and a commercial rooftop condenser unit (source level of
74 dBA at three feet [Johnson Controls 2010]) would be 47 dBA Leq, which translates to 54 dBA CNEL (assuming
continuous operation of equipment through nighttime hours, to keep the pool clean and The Club interior climate-
controlled) and thus less than the 60 dBA CNEL standard at the exterior boundaries of the project area.
Residents and their guests enjoying the outdoor pool and ball courts during daytime hours would likely raise their
voices while doing so. For purposes of this analysis, up to 100 participants (44 at the ball courts, and another 56
in or at the pool area) with individual speech levels of 66 dBA at three feet (Hayne et al. 2006) recreating outdoors
at an average distance of 150 feet from the nearest noise-sensitive receptor to the west would result in an
aggregate hourly sound level of 52 dBA Leq, which translates to 52 dBA CNEL (assuming no operation during
nighttime hours) and thus less than the 60 dBA CNEL standard at the exterior boundaries of the project site.
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Anticipated noise due to pickle ball play from a single court is estimated to be 54 dBA Leq at a distance of 80 feet,
based on prior Dudek project experience and generally consistent with measurement data from publicly available
sources (Spendiarian and Willis 2012). Assuming up to eight pickle ball courts, on average, would experience
concurrent play from residents, guests, and visitors, the predicted noise exposure at the nearest existing residential
receiver to the west (at a distance of 150 feet, representing the average distance if pickle ball play was considered
as a single-point source) would be 55 dBA, which translates to 55 dBA CNEL (assuming no play during nighttime
hours) and thus less than the 60 dBA CNEL standard at the exterior boundaries of the project site.
In aggregate, sound from these three sources (operation of mechanical equipment, speech from The Club attendance,
and pickle ball play) would logarithmically combine into an hourly level of 57 dBA Leq, which translates into 58 dBA
CNEL and thus less than the 60 dBA CNEL standard at the western boundary adjoining off-site residences.
The Butterfly Farm
The Butterfly Farm is expected to include a butterfly vivarium, greenhouse, classroom, and associated
office/maintenance support space. These facilities would require ventilation and air-conditioning units that should
be located no closer than 350 feet to the nearest existing noise-sensitive residential property to the east. At this
distance, the combined noise level of a typical axial-flow box-type ventilation fan (84 dBA Leq at three feet, calculated
from 22,575 cubic feet per minute [Farmtek n.d.]) and a commercial rooftop condenser unit (source level of 74
dBA at three feet [Johnson Controls 2010]) would be 43 dBA Leq, which translates to 50 dBA CNEL (assuming 24-
hour operation as a worst-case scenario) and thus less than the 60 dBA CNEL standard at the exterior boundaries
of the project site.
Residents and their guests enjoying the outdoor garden and picnic area during daytime hours would likely raise
their voices while doing so. For purposes of this analysis, up to 50 participants with individual speech levels of 66
dBA at three feet (Hayne 2006) recreating outdoors at an average distance of 400 feet from the nearest noise-
sensitive receptor to the east would result in an aggregate hourly sound level of 38 dBA Leq, which translates to 40
dBA CNEL (assuming no operation during nighttime hours) and thus less than the 60 dBA CNEL standard at the
exterior boundaries of the project site. Hence, noise impact attributed to operation of equipment used to serve
facilities at the Butterfly Farm, as well as residents and guests enjoying the facilities at the Butterfly Farm, would
be less than significant.
The Event Barn and The Social
The Event Barn and The Social—included in The Barn component of the proposed project—would be located
northeast of the proposed project entrance across from Martincoit Road. These locations would be used as venues
for weekday and weekend weddings, farmer’s markets, concerts, fairs, and other hosted private and public
gatherings. The two detached structures would be expected to feature HVAC systems (to provide ventilation and
air-conditioning for interior spaces) functionally similar to those assumed for the Butterfly Farm. However, the
nearest existing residential receptor to this operating equipment would likely be south of Espola Road,
approximately 200 feet away. At this distance, the estimated aggregate HVAC equipment noise level would be 48
dBA Leq, which translates to 55 dBA CNEL (assuming 24-hour operation as a worst-case scenario) and thus less
than the 60 dBA CNEL standard at the exterior boundaries of the project area. Hence, noise impact from operation
of these equipment serving the facilities at The Event Barn and The Social would be less than significant.
According to the Specific Plan, the hosted events would not normally last beyond 10 p.m., and any that do would
require a Special Use Permit per 3.2.3.B.2 of the Specific Plan Additional Open Space Standards (The Farm in
Poway LLC 2020). The number of participants at hosted events could be as high as 300, and this analysis assumes
that individual average speech levels of up to 66 dBA at three feet (Hayne 2006) could occur. To help illustrate a
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sample outdoor event noise scenario, Appendix I shows the predicted noise propagation out to the community from
the following assumed sound sources and sound-blocking features:
Two pole-mounted outdoor speaker systems, each six feet in height above grade, are positioned at the
southwest and southeast corners of The Barn and each emit an average sound level of up to 100 dBA Leq
at a distance of approximately 10 feet, comparable to an amplified guitar (on stage with the performer
using ear monitors [Darling n.d.]).
An attendance of 300, with individual speech level at 66 dBA Leq at three feet each, is distributed south of the
buildings’ southern facades and over the event lawn north of the proposed curved Event Barn Lawn wall.
The Event Barn Lawn wall, a stone barrier topped with glass panels and having an extent shown in the
Specific Plan, is assumed to be eight feet in height above grade.
Under these assumed conditions, predicted dominant noise from the pair of speakers operating during a “regular
event” (per 3.2.3.B of the Specific Plan Additional Open Space Standards) would cause sound levels at the nearest
noise-sensitive receptor (an existing residential property on the south side of Espola Road, just 180 feet away from
the Event Barn Lawn wall) to reach up to 69 dBA hourly Leq. At this estimated sound level, a regular three-hour event
could transpire during the allowable daytime hours (9 a.m. to 3 p.m. on any weekday, except holidays) and still
result in a CNEL value compliant with the 60 dBA CNEL standard and thus represent a less-than-significant noise
impact to the community. If the three-hour event were to occur during evening hours (i.e., between 7 p.m. and 10
p.m.), the resulting CNEL at the same existing off-site receptor would be 65 dBA CNEL and thus need a five dB
reduction at each of the two speakers in order to comply with the 60 dBA CNEL off-site standard.
At the nearest proposed on-site residential lot to the west of The Barn, approximately 120 feet away, the sound
exposure from the three-hour regular event during daytime hours would be as high as 74 dBA hourly Leq at a second-
story listener position—a receptor location, such as a bedroom window, at the end of a direct sound path that may
not be occluded by The Barn wall. At this magnitude during daytime hours, the resulting CNEL value would be 65
dBA; and, for an evening event, the CNEL would be 60 dBA. Both of these predicted on-site residential façade levels
would be compliant with the 70 dBA CNEL limit per the Specific Plan.
During “special events” (per 3.2.3.B of the Specific Plan Additional Open Space Standards) requiring a temporary
permit that could occur during nighttime hours and/or last for more than three hours duration, the same two
speakers (at 100 dBA at 10 feet each) and speech from 50 to 300 guests would risk exceeding the off-site receptor
standard of 60 dBA CNEL and require mitigation. For example, a three-hour special event hosted between 10 p.m.
and 1 a.m. would result in 70 dBA CNEL at the nearest existing residence south of Espola Road; thus, compliance
during such nighttime hours would require that the two speakers have their amplified sound levels reduced by 10
dBA each. At the resulting 90 dBA at 10 feet per speaker, the scale and type of event would likely need to be
different: 100 dBA at 10 feet would be consistent with an amplified guitar, but 90 dBA at 10 feet would be
compatible with live, unamplified vocalists or a playing classical instruments (e.g., four-piece band). Given such
considerations, a variety of special event possibilities could risk exceeding the 60 dBA CNEL off-site standard and/or
the on-site residential outdoor limit of 70 dBA CNEL and thus result in a potentially significant impact (Impact NOI-
4) requiring mitigation (MM-NOI-3).
The Meadow
According to the Specific Plan, outdoor concerts may be performed at The Meadow area, which is bounded by a
planned on-site slope and open space to the north, Private Street D to the south, Private Street A to the west, and
new residential lots to the east. Similar to the sample event modeled for The Barn and The Social venue, Appendix
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I shows the predicted noise propagation out to the community from the following assumed sound sources and
sound-blocking features:
Two pole-mounted outdoor speaker systems, six feet in height above grade, are positioned slightly
northeast of the geographic center of The Meadow event lawn and each emit an average sound level of up
to 94 dBA Leq at a distance of approximately 10 feet.
An attendance of 300, with individual speech level at 66 dBA Leq at three feet each, is distributed across the
event lawn south of the two speakers.
A stone barrier topped with glass panels, totaling eight feet in height above grade, protects the nearest new
residence (#105 per the proposed project site plan) by extending along its lot boundary from the north edge
of Private Street D to the western edge of the open space.
Under these assumed conditions, predicted dominant noise from the pair of speakers operating during a “regular
event” would cause sound levels at the nearest noise-sensitive receptor (an existing residential property 100 feet
south of The Meadow beyond Private Street D) to attain 64 dBA Leq. At this estimated sound level, a regular event
could transpire for up to three hours during the daytime period and result in a CNEL value of 55 dBA. A similar
regular event during evening hours would yield a CNEL value of 60 dBA at the exterior boundaries of the project
site. Both CNEL values would be compliant with the 60 dBA CNEL standard and thus represent a less-than-
significant noise impact to the neighboring off-site community.
At the nearest proposed on-site residential lot easterly adjacent to The Meadow, the sound exposure from the event
would be as high as 72 dBA Leq at a second-story listener position. At this magnitude, the same regular event during
daytime hours would be 63 dBA CNEL. In the evening, a comparable three-hour event would yield 68 dBA CNEL at
the same second-story receptor. Both values are less than 70 dBA CNEL limit per the Specific Plan for on-site
residential use boundaries.
During “special events” (per 3.2.3.B of the Specific Plan Additional Open Space Standards), the aggregate
sound from live or amplified music from a well-attended event at The Meadow venue could occur during
nighttime hours. Using the same sample event scenario conditions as described for regular events, a three-
hour special event at night would not meet the 60 dBA CNEL off-site threshold at the edge of existing residential
land use 100 feet south of The Meadow. By way of example, the CNEL at the nearest off-site residence would
be 65 dBA and thus require at least five dB of sound reduction at each of the two speakers. Given such
considerations, a variety of special event possibilities could risk exceeding the 60 dBA CNEL off-site standard
and/or the on-site residential outdoor limit of 70 dBA CNEL and thus result in a potentially significant impact
(Impact NOI-5) requiring mitigation (MM-NOI-4).
The Working Farm
The Working Farm would be expected to involve typical agricultural equipment operating as close as 60 feet to
adjacent residential property. At this distance, noise levels could range from 55 dBA Lmax for a pickup truck and up
to 84 dBA Lmax for a tractor (FHWA 2006). However, Section 8.08.170.E from the City’s Noise Ordinance exempts
agricultural operations so long as they occur during daytime hours (7 a.m. to 7 p.m.) or are performed for crop
protection (City of Poway 2019). But to yield noise exposure levels at the adjoining off-site residential properties
that meet the Specific Plan’s exterior project area property line standard of 60 dBA CNEL, hours of operation for
the noisiest expected on-site equipment would need to be limited. By way of example, a tractor could operate for
up to two hours (during the aforementioned allowable daytime period) at an average working distance of no less
than 150 feet from a receptor point along the exterior project site property line and result in a noise level less than
4.11 – Noise
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60 dBA CNEL. Quieter equipment, such as a flatbed truck (Lmax = 74 dBA at 50 feet), could operate for all 12 daytime
hours at this same average working distance and yield a noise level compliant with this adopted standard.
The Dog Park
The Dog Park is a designated area southwest of The Meadow and approximately 150 feet north of the nearest off-
site existing residence abutting Cloudcroft Court. Assuming up to four dogs may be barking (each bark considered
comparable to 100 dBA Lmax at one meter [Helmut 2019]) intermittently (no more than 12 barks each per hour)
during a typical daytime hour when the area would be available for usage, at this distance of 150 feet to the Specific
Plan boundary the estimated CNEL would be less than 45 dBA and thus compliant with the off-site residential
property line standard.
The Tot Lot
The Tot Lot is a designated area north of The Butterfly Farm and approximately 150 feet south-southeast of the
nearest off-site existing residence abutting St. Andrews Drive. Assuming up to eight children may be yelling during
excited play (each yell considered comparable to a human shout [90 dBA Lmax at three feet] [Hayne 2006])
intermittently (no more than 12 shouts each per hour) during a typical daytime hour when the area would be
available for usage, at this distance of 150 feet to the Specific Plan boundary the estimated CNEL would be less
than 40 dBA and thus compliant with the off-site residential property line standard.
For two on-site future residential “Cottage” lots that adjoin The Tot Lot to the southwest, the playing children would
be much closer—potentially 50 feet, on average. At this time-averaged distance, the yelling children would result in
a noise level of 48 dBA CNEL and thus be compliant with the Specific Plan performance standard of 70 dBA CNEL.
Since predicted noise levels associated with The Working Farm, Dog Park, and Tot Lot appear to be compliant with
the appropriate Specific Plan performance standard(s), noise impacts from these proposed project features would
be less than significant.
Would the project result in generation of excessive groundborne vibration or groundborne noise levels?
Construction activities may expose persons to excessive groundborne vibration or groundborne noise, causing a
potentially significant impact. Caltrans has collected groundborne vibration information related to construction
activities that indicates that continuous vibrations with a PPV of approximately 0.2 ips is considered “annoying”
(Caltrans 2013b). For context, heavier pieces of construction equipment—such as a bulldozer that may be used
during proposed construction activities—have PPVs of approximately 0.089 ips or less at a reference distance of
25 feet (DOT 2006).
Groundborne vibration attenuates rapidly, even over short distances. And when groundborne vibration encounters a
building foundation, a coupling loss occurs depending on the mass and design. For typical wood-framed houses, like
those near the project site, this coupling loss is five vibration velocity dB according to Federal Transit Administration
guidance (FTA 2006). The attenuation of groundborne vibration as it propagates from source to receptor through
intervening soils and rock strata can be estimated with expressions found in Federal Transit Administration and
Caltrans guidance. By way of example, for a bulldozer operating on site and as close as the western project site
boundary (i.e., 15 feet from the nearest receiving noise-sensitive land use) the estimated vibration velocity level would
be 0.19 ips and thus no greater than the annoyance threshold recommended by Caltrans.
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Construction vibration, at sufficiently high levels, can also present a building damage risk. However,
anticipated construction vibration from conventional heavy equipment associated with this proposed project
would not yield levels that surpass this risk. Per Caltrans, the recommended PPV threshold is 0.5 ips for newer
residential structures and 0.3 ips for older residential structures—both of which are less stringent that the
aforementioned threshold to annoy occupants of such structures.
For blasting events associated with project construction, Caltrans offers different “transient event” guidance:
0.5 ips PPV for “repeated” blasts where the class of receiving structure would be comparable to “relatively old
residential structures in poor condition” (Caltrans 2013b). Detonation of an 18.5-pound, heavily confined, per-delay
charge would be predicted to result in a groundborne vibration velocity level of 0.5 ips PPV at a residential receptor
no closer than 400 feet away.
Once operational, the proposed project would not be expected to feature major producers of groundborne vibration.
Anticipated mechanical systems like HVAC units are designed and manufactured to feature rotating (fans, motors)
and reciprocating (compressors) components that are well balanced with isolated vibration within or external to the
equipment casings.
Therefore, potential vibration-induced annoyance to occupants of nearby existing homes and potential
vibration damage risk to nearby structures due to conventional construction and blasting activities, and
potential vibration due to proposed project operation would be less than significant.
For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has
not been adopted, within two miles of a public airport or public use airport, would the project expose people residing
or working in the project area to excessive noise levels?
There are no private airstrips within the vicinity of the project site. The closest airport to the proposed project site
is the Ramona Municipal Airport, approximately 6.25 miles northeast of the site, which would therefore not expose
people residing or working in the project area to excessive noise levels. Impacts would be less than significant.
The proposed project’s noise impacts are listed as follows:
Impact NOI-1 During proposed grading activities for the on-site trail system that are expected as close as 25 feet
to off-site noise-sensitive receptors, and retention basin construction involving the assemblage of
equipment working right at the edge of the construction zone in each phase and within 15 feet of
existing residences, construction noise levels are anticipated to exceed the City’s construction noise
limit of 75 dBA Leq over an eight-hour period.
Impact NOI-2 Regarding proposed construction of Private Street B, when the entire assemblage of construction
equipment is working right at the edge of the construction zone in each phase, within 36 feet of
existing residences, construction noise levels are anticipated to reach up to 78 dBA Leq. Assuming
relatively steady work, this would result in an exceedance of the City’s construction noise limit of 75
dBA Leq over an eight-hour period.
Impact NOI-3 Regarding proposed rock blasting event noise, at 400 feet of existing off-site residences, eight-hour
noise levels are anticipated to reach up to 80 dBA Leq. Assuming a heavily confined per-delay charge
weight of 18.5 pounds, this would result in an exceedance of the City’s construction noise limit of
75 dBA Leq over an eight-hour period.
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Impact NOI-4 Regarding The Event Barn and The Social, under the right conditions the occurrence and duration of
regular events could risk exceeding the required off-site residential land use threshold of 60 dBA CNEL
as identified by the Specific Plan. The on-site noise limit of 70 dBA CNEL may also be exceeded under
the right conditions. At the same venue, the occurrence, type, intensity and duration of special events
(especially those during nighttime hours) would also risk exceeding the same standards.
Impact NOI-5 Regarding The Meadow (Amphitheater), under the right conditions the occurrence and duration of
regular events could risk exceeding the required off-site residential land use threshold of 60 dBA CNEL
as identified by the Specific Plan. The on-site noise limit of 70 dBA CNEL may also be exceeded under
the right conditions. At the same venue, the occurrence, type, intensity, and duration of special events
(especially those during nighttime hours) would also risk exceeding the same standards.
4.11.5 Cumulative Impacts
Noise levels tend to diminish quickly with distance from a source; therefore, the geographic scope for the analysis
of cumulative impacts related to noise was limited to locations within proximity to noise-generating operational
components and construction equipment. Implementation of the proposed project would result in significant noise
impacts associated with the combination of construction activities and stationary noise sources. However, noise is
a localized occurrence and attenuates rapidly with distance. Therefore, only future development projects in the
direct vicinity of the project site could add to construction- or stationary-source noise generated by the proposed
project and result in a cumulative noise impact.
Excessive Noise Levels
A cumulative noise impact would occur if development associated with cumulative projects would expose new land
uses to noise levels that exceed proposed noise compatibility guidelines. Cumulative projects within the region
would be subject to regulations that require compliance with noise standards, including Title 24, and the City’s
applicable Noise Ordinance and General Plan policies. Looking at the cumulative projects in the area, the distance
to the nearest approved project is approximately 3.7 miles away, which would make cumulatively considerable
noise impacts unlikely. In this case, the noise from added cars to roadways would not travel far enough to create
excessive noise levels in the project area. Additionally, approved projects would be subject to the same noise
policies and ordinances as would apply to the proposed project. Therefore, the proposed project would not result
in a cumulatively considerable contribution to excessive noise levels.
Excessive Groundborne Vibration
A cumulative groundborne vibration impact would occur if one or more projects in the area would result in combined
groundborne vibration that would increase vibration to a level that would result in sleep disturbance or interfere
with activities at vibration-sensitive land uses (e.g., precision labs, surgical facilities). Groundborne vibration
impacts could result from construction operations, railroad operations, or mining. The proposed project’s
construction activity would not include pile driving, and there are no sensitive operations (e.g., precision research
labs) within 200 feet of the project site boundaries. Consequently, the proposed project would not result in a
cumulatively considerable contribution related to excessive groundborne vibration.
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Permanent Increase in Ambient Noise Levels
A cumulative noise impact would occur if construction and development associated with cumulative regional land
use projects, such as those identified in adjacent city and county general plans and regional transportation plans,
would result a permanent increase in ambient noise that exceeds the applicable noise standards on roadways
throughout the region. At this time, it is assumed that the approved near-term projects said to be completed by
2025 would be outside of the proposed project’s noise influence area. That said, the closest near-term approved
project would be The Junipers Senior Development located approximately 3.75 miles from the proposed project.
The construction and operation of The Junipers project would have no impact on ambient noise levels, and
therefore, would not result in a cumulatively considerable impact.
Temporary Increase in Ambient Noise Levels
A cumulative temporary noise impact would occur if one or more cumulative projects in close proximity to one
another would be constructed at the same time and result in combined construction noise levels that exceed 75
dBA. With respect to construction noise, construction sites that are located within approximately one-quarter mile
of one another would have the potential to cause an increase in noise exposure levels for receptors located near
each of the sites, compared to a single construction project occurring at a single point in time. Based on the list of
cumulative projects (as taken from Appendix J), it is not anticipated that another project would be actively under
construction within one-quarter mile of the project site during the same construction period as the proposed project.
Although the proposed project would result in exceedance of the City’s construction noise limit of 75 dBA Leq, there
is no currently proposed or approved construction projects that would occur within one-quarter mile of the project
site during the same timeframe. The closest approved project is located 3.75 miles away and thus, temporary
increases in ambient noise levels would not be cumulatively considerable.
Excessive Noise Exposure from Airports
Noise related to airports is generally site specific and not cumulative in nature. The placement of a structure within
the noise contours of a public airport or in close proximity to a private airstrip would not affect airport noise related
to the placement of another cumulative project. The proposed project is not within the vicinity of a public or private
airport; therefore, no cumulative impact would occur.
4.11.6 Mitigation Measures
The following mitigation measures would be implemented to reduce potentially significant impacts to less
than significant.
MM-NOI-1 Prior to the issuance of a Construction Permit, the project applicant/owner or construction
contractor shall prepare and submit to the City of Poway Planning Division for its review and
approval a Construction Noise Management Plan (CNMP). Prior to the issuance of a Construction
Permit, construction plans shall also include a note indicating compliance with the CNMP is
required. The CNMP shall be prepared or reviewed by a qualified acoustician (retained at the
project applicant/owner or construction contractor’s expense) and feature the following:
1) A detailed construction schedule, at daily (or weekly, if activities during each day of the week
are typical) resolution and correlating to areas or zones of on-site project construction activities
and the anticipated equipment types and quantities involved. Information shall include
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expected hours of actual operation per day for each type of equipment per phase and indication
of anticipated concurrent construction activities on site.
2) Suggested locations of a set of noise-level monitors, attended by a qualified acoustician or
another party under his/her supervision or direction, at which sample outdoor ambient noise
levels will be measured and collected over a sufficient sample period and subsequently analyzed
(i.e., compared with applicable time-dependent A-weighted decibel [dBA] thresholds) to ascertain
compliance with the eight-hour City of Poway threshold of 75 dBA equivalent noise level over a
consecutive eight-hour period. Sampling shall be performed, at a minimum, on the first (or
otherwise considered typical construction operations) day of each distinct construction phase
(e.g., each of the five listed phases in Table 4.11-2, Construction Phase Distance to Nearest Pre-
Existing Noise-Sensitive Receptors).
3) If sample collected noise level data indicates that the eight-hour noise threshold has or will be
exceeded, construction work shall be suspended (for the activity or phase of concern) and the
project applicant/owner or construction contractor shall implement one or more of the following
measures as detailed or specified in the CNMP:
a) Administrative controls (e.g., reduce operating time of equipment and/or prohibit usage of
equipment type[s] within certain distances).
b) Engineering controls (upgrade noise controls, such as install better engine exhaust mufflers).
c) Install noise abatement on the project site boundary fencing (or within the project site, as
practical and appropriate) in the form of sound blankets or comparable temporary barriers
to occlude construction noise emission between the project site (or specific equipment
operation as the situation may define) and the noise-sensitive receptor(s) of concern.
The implemented measure(s) shall be reviewed or otherwise inspected and approved by the
qualified acoustician (or another party under his/her supervision or direction) prior to resumption
of the construction activity or process that caused the measured noise concern or need for noise
mitigation. Noise levels shall be re-measured, after installation of said measures, to ascertain post-
mitigation compliance with the noise threshold. As needed, this process shall be repeated and
refined until noise level compliance is demonstrated and documented. A report of this implemented
mitigation and its documented success shall be provided to the City of Poway Planning Division.
4) The project applicant/owner or construction contractor shall make available a telephone hotline
so that concerned neighbors in the community may call to report noise complaints. The CNMP shall
include a process to investigate these complaints and, if determined to be valid, detail efforts to
provide a timely resolution and response to the complainant—with copy of resolution provided to
the City of Poway Planning Division.
MM-NOI-2 The project applicant/owner or its construction contractor(s) shall prepare, or cause to be
prepared, a blasting/drilling monitoring plan. The plan shall be site specific, based on general and
exact locations of required blasting and the results of a project-specific geotechnical investigation.
The blasting plan shall include a description of the planned blasting methods, an inventory of
receptors potentially affected by the planned blasting, and calculations to determine the area
affected by the planned blasting that include estimates of the pre-blast drill noise levels, air-blast
overpressure sound levels, and groundborne vibration levels at each residence within 500 feet of
a blasting location. Where potential exceedances of relevant noise and vibration exposure limits
are identified, the blasting/drilling monitoring plan shall identify mitigation measures shown to
effectively reduce noise and vibration levels (e.g., altering orientation of blast progression,
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increased delay between charge detonations, pre-splitting) to be implemented in order to
demonstrate compliance with these thresholds. Additionally, all project phases involving blasting
shall conform to the following requirements:
1. All blasting shall be performed by a blast contractor and blasting personnel licensed to operate
per appropriate regulatory agencies.
2. Prior to blasting, a qualified geotechnical professional shall inspect and document the existing
conditions of facades and other visible structural features or elements of the nearest
residential buildings. Should this inspector determine that some structural features or
elements appear fragile or otherwise potentially sensitive to vibration damage caused by the
anticipated blasting activity, the maximum per-delay charge weights and other related blast
parameters shall be re-evaluated to establish appropriate quantified limits.
3. Each blast shall be monitored and recorded with an air-blast overpressure monitor and
groundborne vibration accelerometer that is located outside the closest residence to the blast.
This data shall be recorded, and a post-blast summary report shall be prepared and be
available for public review or distribution as necessary.
4. Blasting shall not exceed 0.5 inches per second peak particle velocity at the nearest occupied
residence, in accordance with the California Department of Transportation’s Transportation
and Construction Vibration Guidance Manual.
5. To ensure that potentially impacted residents are informed, the applicant shall provide notice
by mail to all property owners within 1,000 feet of the project at least one week prior to a
scheduled blasting event. Notice shall also be provided to Maderas Golf Course and the Green
Valley Civic Association.
6. Pre-blast drilling operations associated with blasting preparations shall be performed in a
manner consistent with adherence to City of Poway regulations and guidance.
MM-NOI-3 Operation of any “regular event” at The Event Barn (and The Social), as defined by 3.2.3.B of The
Farm in Poway Specific Plan Additional Open Space Standards, shall conform to the following
acoustical conditions:
1) Daytime (within 8 a.m. to 7 p.m.)
a) Attendance shall not exceed 300, including residents, guests, visitors, and any on-site
support staff that host the event in progress.
b) Event duration shall not exceed a cumulative total of three hours.
c) The aggregate sound level from live (acoustic) or amplified music shall not exceed a total of
103 A-weighted decibel (dBA) at a distance of 10 feet. If speakers are positioned to distribute
the amplified sound, they must be positioned in such a manner that The Event Barn Wall
provides linear occlusion between the speaker and the nearest existing residential receptors
south of Espola Road.
d) If any proposed event parameters above are not listed or may exceed the indicated
constraints, then a qualified acoustician shall prepare or review a predictive sound
propagation analysis prior to the proposed event in order to identify need for
recommended noise control or sound abatement implantation measures that could
include (but not be limited to):
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i. Via the pre-installed house audio-visual (A/V) system or on A/V hardware supplied by the
hosted event performers, set electronic controls on amplified sound levels to comply with
recommended front-of-stage and/or property line expectations.
ii. Install temporary noise walls, curtains, or other barrier forms so as to improve
containment and absorption of sound within The Event Barn Lawn venue space and
minimize spill-over noise to the property line and community beyond.
iii. Install on-site sound level measurement systems (e.g., akin to NTiAudio or comparable
supplier technology) to monitor event sound levels in real-time and provide alerts to event
hosts and administrators. Collected data and alerts offer opportunity to provide feedback to
event performers as part of implementing administrative control of sound emission levels.
Collected data from 1.d.iii can also provide documentation that an event was fully compliant with
required sound limits at the property line(s), and might be used to support assertions that future
events having identical conditions (e.g., an annual seasonal festival) would also be compliant and
thus waive the need for additional monitoring (at the discretion or approval of the City of Poway).
2) Evening (7 p.m. to 10 p.m.)
a) Attendance shall not exceed 300, including residents, guests, visitors, and any on-site
support staff that host the event in progress.
b) Event duration shall not exceed a cumulative total of three hours.
c) The aggregate sound level from live (acoustic) or amplified music shall not exceed a total of 98
dBA at a distance of 10 feet. If speakers are positioned to distribute the amplified sound, they
must be positioned in such a manner that The Event Barn Wall provides linear occlusion
between the speaker and the nearest existing residential receptors south of Espola Road.
d) If any proposed event parameters above are not listed or may exceed the indicated
constraints, then a qualified acoustician shall prepare or review a predictive sound
propagation analysis prior to the proposed event in order to identify need for
recommended noise control or sound abatement implantation measures that could
include (but not be limited to):
i. Via the pre-installed house A/V system or on A/V hardware supplied by the hosted event
performers, set electronic controls on amplified sound levels to comply with
recommended front-of-stage and/or property line expectations.
ii. Install temporary noise walls, curtains, or other barrier forms so as to improve
containment and absorption of sound within The Event Barn Lawn venue space and
minimize spill-over noise to the property line and community beyond.
iii. Install on-site sound level measurement systems (e.g., akin to NTiAudio or comparable
supplier technology) to monitor event sound levels in real-time and provide alerts to
event hosts and administrators.
Collected data from 2.d.iii can also provide documentation that an event was fully compliant with
required sound limits at the property line(s), and might be used to support assertions that future
events having identical conditions (e.g., an annual seasonal festival) would also be compliant and
thus waive the need for additional monitoring (at the discretion or approval of the City of Poway).
3) Conduct of a “special event” (i.e., that is not considered a “regular event”) at The Event Barn
(and The Social), as defined by 3.2.3.B of The Farm in Poway Specific Plan Additional Open
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Space Standards, shall require a City-approved Temporary Use Permit. At the City’s discretion,
the Temporary Use Permit application may require the approval of a predictive sound
propagation analysis prepared by a qualified acoustician to identify recommended noise
control and sound abatement implementation measures that—as implemented properly by the
permit applicant—would be expected to result in event-attributed noise levels that are
compliant with the Farm in Poway Specific Plan Additional Open Space Standards as follows:
a) No greater than 60 dBA CNEL at the property lines of existing residential receptors adjoining
the project site; and,
b) No greater than 70 dBA CNEL at the property lines of on-site residential receptors within the
project site.
MM-NOI-4 Operation of any “regular event” at The Meadow (Amphitheater), as defined by 3.2.3.B of The
Farm in Poway Specific Plan Additional Open Space Standards, shall conform to the following
acoustical conditions:
1) Daytime (within 8 a.m. to 7 p.m.)
a) Attendance shall not exceed 300, including residents, guests, visitors, and any on-site
support staff that host the event in progress.
b) Event duration shall not exceed a cumulative total of three hours.
c) The aggregate sound level from live (acoustic) or amplified music shall not exceed a total of
97 A-weighted decibel (dBA) at a distance of 10 feet. If speakers are positioned to distribute
the amplified sound, they must be positioned in such a manner that The Event Barn Wall
provides linear occlusion between the speaker and the nearest existing residential receptors
south of Espola Road.
d) If any proposed event parameters above are not listed or may exceed the indicated
constraints, then a qualified acoustician shall prepare or review a predictive sound
propagation analysis prior to the proposed event in order to identify need for
recommended noise control or sound abatement implantation measures that could
include (but not be limited to):
i. Via the pre-installed house audio-visual (A/V) system or on A/V hardware supplied by the
hosted event performers, set electronic controls on amplified sound levels to comply with
recommended front-of-stage and/or property line expectations.
ii. Install temporary noise walls, curtains, or other barrier forms so as to improve
containment and absorption of sound within The Event Barn Lawn venue space and
minimize spill-over noise to the property line and community beyond.
iii. Install on-site sound level measurement systems (e.g., akin to NTiAudio or comparable
supplier technology) to monitor event sound levels in real-time and provide alerts to event
hosts and administrators. Collected data and alerts offer opportunity to provide feedback to
event performers as part of implementing administrative control of sound emission levels.
Collected data from 1.d.iii can also provide documentation that an event was fully
compliant with required sound limits at the property line(s), and might be used to support
assertions that future events having identical conditions (e.g., an annual seasonal festival)
would also be compliant and thus waive the need for additional monitoring (at the
discretion or approval of the City of Poway).
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2) Evening (7 p.m. to 10 p.m.)
a) Attendance shall not exceed 300, including residents, guests, visitors, and any on-site
support staff that host the event in progress.
b) Event duration shall not exceed a cumulative total of three hours.
c) The aggregate sound level from live (acoustic) or amplified music shall not exceed a total of 92
dBA at a distance of 10 feet. If speakers are positioned to distribute the amplified sound, they
must be positioned in such a manner that The Event Barn Wall provides linear occlusion
between the speaker and the nearest existing residential receptors south of Espola Road.
d) If any proposed event parameters above are not listed or may exceed the indicated constraints,
then a qualified acoustician shall prepare or review a predictive sound propagation analysis prior
to the proposed event in order to identify need for recommended noise control or sound
abatement implantation measures that could include (but not be limited to):
i. Via the pre-installed house A/V system or on A/V hardware supplied by the hosted event
performers, set electronic controls on amplified sound levels to comply with
recommended front-of-stage and/or property line expectations.
ii. Install temporary noise walls, curtains, or other barrier forms so as to improve
containment and absorption of sound within The Event Barn Lawn venue space and
minimize spill-over noise to the property line and community beyond.
iii. Install on-site sound level measurement systems (e.g., akin to NTiAudio or comparable
supplier technology) to monitor event sound levels in real-time and provide alerts to
event hosts and administrators.
Collected data from 2.d.iii can also provide documentation that an event was fully compliant
with required sound limits at the property line(s), and might be used to support assertions that
future events having identical conditions (e.g., an annual seasonal festival) would also be
compliant and thus waive the need for additional monitoring (at the discretion or approval of
the City of Poway).
3) Conduct of a “special event” (i.e., that is not considered a “regular event”) at The Meadow, as
defined by 3.2.3.B of The Farm in Poway Specific Plan Additional Open Space Standards, shall
require a City-approved Temporary Use Permit. At the City’s discretion, the Temporary Use
Permit application may require the approval of a predictive sound propagation analysis
prepared by a qualified acoustician to identify recommended noise control and sound
abatement implementation measures that—as implemented properly by the permit applicant—
would be expected to result in event-attributed noise levels that are compliant with The Farm
in Poway Specific Plan Additional Open Space Standards as follows:
a) No greater than 60 dBA CNEL at the property lines of existing residential receptors adjoining
the project site; and,
b) No greater than 70 dBA CNEL at the property lines of on-site residential receptors within the
project site.
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4.11.7 Level of Significance After Mitigation
In order to reduce potentially significant construction noise impacts upon existing residences in the project vicinity,
mitigation measure MM-NOI-1 shall be implemented as indicated site conditions may warrant. Proper application
of temporary noise barriers or comparable sound abatement that may arise as a result of MM-NOI-1 implementation
has the ability to realize a 10-dB reduction in noise levels that would correspondingly reduce the predicted 85 dBA
eight-hour Leq during construction of the basins (Impact NOI-1), and the predicted 78 dBA eight-hour Leq during
construction of Private Street B (Impact NOI-2) to a level of 75 dBA Leq, which would be compliant with the 75 dBA
threshold. With implementation of MM-NOI-1, Impact NOI-1 and Impact NOI-2 would be reduced to a less-
than-significant level.
When implemented properly, mitigation measure MM-NOI-2 would keep noise and vibration from blasting events
associated with project construction (Impact NOI-3) below appropriate thresholds and thus result in less-than-
significant impacts.
Implementation of MM-NOI-3 for hosted “regular” and “special” events at The Event Barn (plus The Social), would
help keep event-attributed noise from exceeding off-site 60 dBA CNEL and on-site 70 dBA CNEL thresholds, thereby
reducing this potential project operations noise impact (Impact NOI-4) to a less-than-significant level.
Implementation of MM-NOI-4 for hosted “regular” and “special” events at The Meadow (Amphitheater), would help
keep event-attributed noise from exceeding off-site 60 dBA CNEL and on-site 70 dBA CNEL thresholds, thereby
reducing this potential project operations noise impact (Impact NOI-5) to a less-than-significant level.
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Noise Measurement Locations
The Farm in Poway
SOURCE: SANGIS 2017, 2019
0 500250Feet
Project Boundary
Noise Measurement Locations
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FIGURE 4.11-1
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4.12 – Population and Housing
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4.12 Population and Housing
This section describes the existing population and housing conditions of The Farm in Poway project (proposed
project) site and vicinity, identifies associated regulatory requirements, evaluates potential impacts, and identifies
mitigation measures, if necessary, related to implementation of the proposed project.
A Notice of Preparation (NOP) was circulated from May 10, 2019, to June 10, 2019. During the NOP comment
period, no comment letters related to population and housing were received.
The Initial Study, NOP, and Public Scoping comments are provided in Appendix A of this Environmental
Impact Report (EIR).
4.12.1 Existing Conditions
Population
The San Diego Association of Governments (SANDAG) is the council of governments and metropolitan planning
organization responsible for developing demographic projections, including population, household, and
employment projection for jurisdictions in the County of San Diego (County), including for the City of Poway (City).
SANDAG is required to update these forecasts every four years.
According to SANDAG’s Series 13 Regional Growth Forecast population estimates, the County supported 3,095,313
people as of 2010. By 2050, the County’s population is expected to reach over 4 million (SANDAG 2013). According
to SANDAG estimates, the City of Poway supported 47,811 residents in 2010, and its population is expected to
reach 50,010 by 2020, and 52,860 by 2050 (SANDAG 2013). According to the U.S. Census Bureau, population for
the City of Poway was 49,704 on July 1, 2018 (U.S. Census Bureau 2018).
Housing
According to SANDAG Series 13 Regional Growth Forecast housing estimates for the County, there were
1,158,076 total housing units as of 2010 (SANDAG 2013). By 2050, the County is forecasted to have
approximately 1,491,804 total housing units (SANDAG 2013). According to the SANDAG Growth Forecast, the
City of Poway had 16,476 total housing units in 2010, with single-family housing units accounting for 12,862
(SANDAG 2013). The SANDAG Growth Forecast estimated an increase of housing units to 17,602 by 2035,
and 17,800 by 2050 (SANDAG 2013). This change would account for an average annual increase of 0.2
percent each year or 8 percent housing increase from 2010 to 2050.
According to the City’s Housing Element Update, total housing saw a modest increase overall from 2000 to 2010
(City of Poway 2013). During that time, single-family units increased by 409 units, and multi-family units increased
by 103 units. Overall, the total increase in housing units between 2000 and 2010 was 762. The City’s vacancy rate
is less than 4 percent, putting housing within the area in high demand. In the last 10 years, the City has experienced
some of the highest home appreciation rates of any community in the nation. Real estate in the City appreciated
55.05 percent over the last 10 years, which is an average annual home appreciation rate of 4.48 percent, putting
the City in the top 10 percent nationally for real estate appreciation (U.S. Census Bureau 2018).
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4.12.2 Relevant Plans, Policies, and Ordinances
Federal
No federal regulations related to population and housing apply to the proposed project.
State
California Environmental Quality Act
The California Environmental Quality Act (CEQA) (California Public Resources Code, Section 21000 et seq.) and
CEQA Guidelines (14 CCR 15000 et seq.) are primary sources for environmental legislation in California; they
require projects with potential adverse environmental effects (or impacts) undergo environmental review. According
to CEQA Guidelines Section 15126.2, an EIR shall identify the significant effects of a project on the environment.
Since the proposed project does not contain any affordable housing or lie within the criteria of a residential infill
exception (14 CCR Sections 15192, 15195), an EIR is required to analyze the proposed project’s potential effects
on population and housing. Adverse environmental impacts are typically mitigated as a result of the environmental
review process in accordance with existing laws and regulations.
California Planning and Zoning Law
The legal framework in which California cities and counties exercise local planning and land use functions is
provided in Sections 65000–66499.58 of the California Government Code, the California Planning and Zoning Law.
Under state planning law, each city and county must adopt a comprehensive, long-term general plan. State law
gives cities and counties wide latitude in how a jurisdiction may create a general plan, but there are fundamental
requirements that must be met. These requirements include seven mandatory elements described in the California
Government Code. Each of the elements must contain text and descriptions setting forth objectives, principles,
standards, policies, and plan proposals; diagrams and maps that incorporate data and analysis; and
implementation measures.
California Building Standards Code
In 2001, California consolidated the Uniform Building, Plumbing, Electrical, and Mechanical codes into the
California Building Standards Code, which is contained in Title 24 of the California Code of Regulations. The
California Building Standards Code contains 11 parts: Electrical Code, Plumbing Code, Administrative Code,
Mechanical Code, Energy Code, Residential Building Code, Historical Building Code, Fire Code, Existing Building
Code, Green Building Standards Code, and the Reference Standards Code. These codes promote public health
and safety and ensure that safe and decent housing is constructed in the state. The codes serve to protect
residents from hazards and risks, and are not considered to be undue constraints to housing production. The
2019 California codes became effective in January 2020.
Senate Bill 375
Senate Bill 375 (codified in the Government Code and Public Resources Code) took effect in 2008 and provides
a new planning process to coordinate land use planning, regional transportation plans, and funding priorities
in order to help California meet the greenhouse gas (GHG) reduction goals established in Assembly Bill 32.
Senate Bill 375 requires metropolitan planning organizations to incorporate a Sustainable Communities
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Strategy (SCS) in their Regional Transportation Plans (RTPs) that will achieve GHG emissions reduction targets
by reducing vehicle miles traveled from light-duty vehicles through the development of more compact,
complete, and efficient communities.
Regional Housing Needs Assessment
State Housing Law mandates metropolitan planning organizations undertake a Regional Housing Needs
Assessment (RHNA) as part of the periodic process of updating the local housing elements of their general plans.
The RHNA quantifies the need for housing within each jurisdiction during specified planning periods. Communities
use the RHNA in land use planning, prioritizing local resource allocation, and in deciding how to address identified
existing and future housing needs resulting from population, employment, and household growth. The RHNA does
not necessarily encourage or promote growth, but rather allows communities to anticipate growth, so that the region
and subregion can grow in ways that enhance quality of life, improve access to jobs, promote transportation
mobility, and address social equity, fair share housing needs.
The Housing Crisis Act of 2019 (Senate Bill 330)
Through the passage of the Housing Crisis Act of 2019 (Senate Bill 330), codified in the Government Code, effective
January 1, 2020, the state legislature has declared a statewide housing emergency. The goal of the Housing Crisis
Act is to suspend certain restrictions on development of new housing and encourage local governments to approve
more housing development projects.
Local
San Diego Association of Governments
SANDAG is a public agency, composed of 18 cities and the County, which builds strategic plans guiding the San Diego
region in land use, growth, economics, and the environment. SANDAG offers planning, coordination, and technical
assistance to its members, administers programs at the regional level, and acts as an intermediary between the local
government and the state and federal government. In terms of population and housing, SANDAG serves a crucial role
in developing a big-picture vision for how the region will grow over the next 35 years. Through the development of a
regional comprehensive plan, the region identifies smart growth.
Regional Transportation Plan and Sustainable Communities Strategy
Over the years, SANDAG has coordinated regional efforts to address a large number of important issues. In 2011,
SANDAG approved the 2050 Regional Transportation Plan (2050 RTP/SCS) (SANDAG 2011), which marked the
first time SANDAG’s RTP included an SCS, consistent with the Sustainable Communities and Climate Protection Act
of 2008 (also known as Senate Bill 375). The 2050 RTP/SCS provided a blueprint to improve mobility, preserve
open space, and create communities, all with transportation choices to reduce GHG emissions and meet specific
targets set by the California Air Resources Board (CARB) as required by the 2008 Sustainable Communities Act.1 In
2010, CARB established targets for each region in California governed by a metropolitan planning organization.
SANDAG is the metropolitan planning organization for the San Diego region.
1 SANDAG’s Environmental Impact Report under CEQA assessing the environmental consequences of its 2050 RTP/SCS is the
subject of review by the California Supreme Court in Cleveland National Forest Foundation v. San Diego Association of
Governments, Case No. S223603.
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The SANDAG target, as set by CARB, is to reduce the region’s per capita emissions of GHG emissions from cars
and light-duty trucks by 7 percent by 2020, compared with a 2005 baseline. By 2035, the target is a 13 percent
per-capita reduction. There is no target set beyond 2035. To achieve the 2020 and 2035 targets, SANDAG and
other metropolitan planning organizations are required to develop an SCS as an element of its RTP. The SANDAG
SCS integrates land use and transportation plans to achieve reductions in GHG emissions and meet the CARB-
required targets.
SANDAG is required by law to update its regional transportation plan every four years. In October 2015, SANDAG
certified a new EIR and adopted the latest update to its RTP/SCS—known as San Diego Forward: The Regional Plan
(Regional Plan) (SANDAG 2015)—which integrates the elements of its prior Regional Comprehensive Plan and
combines those elements with its Regional Plan.
The Regional Plan updates growth forecasts and is based on the most recent planning assumptions considering adopted
general plans, and other factors, from all 18 cities of the region and the County. It shows how the regional development
pattern and the transportation network, policies, and programs can work together to achieve per capita GHG emission
reduction targets for cars and light-duty trucks. As stated, CARB has set a target for the San Diego region to lower GHG
emissions from cars and light-duty trucks by 7 percent for 2020 and 13 percent for 2035, compared with a 2005
baseline. The Regional Plan will result in reduced GHG emissions that will exceed the state’s emission reduction targets,
reaching per capita reductions of 15 percent by 2020 and 21 percent by 2035 (SANDAG 2015).
The Regional Plan is based on the currently adopted land use plans, as reflected in general plans, including the County’s
General Plan. SANDAG’s latest Regional Plan will necessarily change in response to the ongoing land use planning of the
County and comprising cities. These land use inputs may change based on general plan amendments initiated by the
jurisdiction or landowner applicants. The general plan amendments may result in increases in development densities by
amending the Regional Category designations or zoning classifications. Accordingly, the latest forecasts in SANDAG’s
Regional Plan of future development in the San Diego region, including location, must be coordinated closely with each
jurisdiction’s ongoing land use planning because that planning is not static, as recognized by the need for updates to
SANDAG’s RTP/SCS every four years (SANDAG 2015).
Regional Growth Forecast
Since 1972, SANDAG has produced long-range forecasts of population, housing, and employment for the San Diego
region that are used as a basic resource for numerous purposes. For example, SANDAG uses these forecasts to
develop its SCS and supporting transportation network in the Regional Plan; water agencies (e.g., San Diego County
Water Authority and local retail water districts) use the data for water planning purposes; and utility providers use
the data for long-range planning. The County and local jurisdictions also use the forecast data for general plan and
infrastructure planning purposes.
SANDAG’s most recent forecast—the Regional Growth Forecast (also known as the Series 13 Forecast)
(SANDAG 2013)—is the basis for the Regional Plan. These forecasts represent an assessment of the changes
that SANDAG anticipates for the San Diego region based on the best available information and computer
modeling. As stated, the forecasts are based on the most recent planning assumptions, considering local
general plans and other factors, per Senate Bill 375 (Government Code Section 65080[b][2][B]). The SANDAG
forecasts are meant to help decision makers prepare for the future and, according to SANDAG, are “not an
expression for or against growth” (SANDAG 2013).
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Regional Housing Needs Assessment
SANDAG is required by state law (Government Code Section 65584[a]) to complete a RHNA, in consultation with
the California Department of Housing and Community Development, to determine the region’s housing needs in
four income categories: very low, low, moderate, and above moderate. The adopted RHNA for the San Diego region
covers the eight-year period from January 1, 2013, through December 31, 2020.
The RHNA allocates housing needs in the four income categories for each of the cities and the County to use in
their housing element. The cities and County are required to update their housing elements to include RHNA
allocations every eight years.
Poway Comprehensive Plan: General Plan
The Poway Comprehensive Plan: General Plan (General Plan) is a statement of what the representatives of the
residents want for their community in the future. Its function is to allow the citizens to consciously consider the
shape their City will take for the foreseeable future and to preserve and enhance those qualities they presently find
appealing. It accomplishes this by setting forth broad goals, and translating these goals into specific policies and
strategies to accomplish the plan’s objective. The goals of the City’s General Plan as they relate to population and
housing are as follows (City of Poway 1991).
Goal XI: It is the goal of the City of Poway to provide adequate, appropriate housing opportunities to meet the needs
of current and future residents.
Policy A – Existing Housing: Preserve and maintain existing housing and neighborhoods to ensure that housing is
both sound and safe for occupants and to meet as much as possible of the housing needs of the current and future
residents of Poway through existing development.
Strategy 1: The retention and maintenance of all existing mobile home parks shall be encouraged through
use of a mobile home park zone and through acquisition and operation of parks by the
City/Redevelopment Agency.
Strategy 2: The retention of an adequate supply of rental housing shall be encouraged by maintaining
ordinance provisions that restrict condominium conversions in the Residential Apartment category/RA zone
and which require that new developments in this category be for rental only.
Strategy 3: Promote increased awareness among property owners and residents of the importance of
property maintenance to long-term housing quality.
Strategy 4: Adopt ordinance requiring that all renter occupied housing be kept in a well maintained safe
and sanitary condition.
Strategy 5: Participate, through the County of San Diego Housing Authority, in a program of low interest
rehabilitation loans to assist low and moderate income homeowners whose homes are in need of repair.
Strategy 6: Maintain ordinance provisions prohibiting the occupancy of substandard dwelling units and
requiring that such units be made to comply with all applicable zoning, building safety, and housing codes
or when this cannot be achieved that such units be demolished.
Strategy 7: Take actions necessary to ensure that assisted rental units at risk of conversion are not
converted to market rate units
Strategy 8: Investigate opportunities and funding sources to assist households with members who are
handicapped to appropriately retrofit existing housing.
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Strategy 9: Support the shared housing referral and information service.
Strategy 10: Continue to participate in housing programs administered by the County Department of
Housing and Community Development which provide housing assistance.
Strategy 11: Investigate opportunities and funding sources to provide assistance to low and moderate
income households to reduce the incidence of housing overpayment.
Policy B – New Housing: Provide opportunities for high quality new housing construction as necessary to meet the
needs of current and future Poway residents including those with special needs.
•Strategy 1: Ensure that housing constructed for very-low, low, and moderate income households be high
quality in terms of design and construction and be compatible in design with surrounding development.
•Strategy 2: Establish land use and zoning categories in the General Plan and Zoning Ordinance that
allow a diversity of housing types to be built to provide for the actual needs of residents while minimizing
conflicts with existing development and unnecessary erosion of residents’ quality of life and investment in
their homes.
•Strategy 3: In-fill development shall be encouraged in order to make efficient use of existing public
infrastructure.
•Strategy 4: Encourage the use of innovative site development techniques and the use of alternative
building materials that both meet the intent of City policies and ordinances and reduce the cost of site
preparation or construction.
•Strategy 5: Regularly review development fee schedules to ensure that user charges and fees are
consistent with costs incurred by the City. Pursue a reduction of fees to affordable housing projects.
•Strategy 6: Determine the feasibility of using public subsidies to assist in the development of
affordable housing.
•Strategy 7: Require coaches and lots within newly created mobile home parks to be held in common
ownership except in cases where the coaches and or lots are owned by a public agency or nonprofit
housing entity.
•Strategy 8: Encourage the development of affordable housing for the elderly in proximity to public
transportation and community services.
•Strategy 9: Encourage the development of residential units which are accessible to handicapped persons
or are adaptable for conversion to use by handicapped persons.
•Strategy 10: Investigate programs to assist first-time buyers.
•Strategy 11: All new businesses which employ more than five persons in agricultural or landscaping jobs
shall provide suitable housing for them or pay an in lieu fee to allow such housing to be provided.
•Strategy 12: Require that housing constructed expressly for very low, low, and moderate income
households not be concentrated in any single area.
•Strategy 13: Encourage the development of child care facilities coincident with new housing
development and consider the use of incentives such as density bonus reduced development fees and or
financial assistance.
•Strategy 14: Require deed restrictions for new units provided under this policy in order to ensure their
permanent affordability.
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Policy C – Fair Housing Practices: Assure that all housing whether market or assisted is sold or rented in
conformance with open housing policies free of discriminatory practices.
Strategy 1: Make every reasonable effort to ensure that the provisions of all applicable Federal and State
laws and regulations concerning nondiscrimination are enforced.
Strategy 2: Disseminate information on housing discrimination complaints to appropriate agencies.
City of Poway’s Housing Element Update
The City’s Housing Element Update is an eight-year plan for the 2013–2020 housing cycle for jurisdictions in the
San Diego region (City of Poway 2013). The Housing Element Update serves as an integrated part of the General
Plan, but is updated more frequently, as required by state law, to ensure its relevancy and accuracy. The Housing
Element identifies strategies and programs that focus on the following:
Matching housing supply with need
Maximizing housing choices throughout the community
Assisting in the provision of affordable housing
Removing governmental and other constraints to housing investment
Promoting fair and equal housing opportunities.
4.12.3 Thresholds of Significance
The significance criteria used to evaluate the project impacts to population and housing are based on Appendix G
of