HomeMy WebLinkAboutItem 3 - Attachment 2 - Initial Studies - Mitigated Negative Declaration and Response to Written Comments1
MITIGATED NEGATIVE DECLARATION
1. Project Name: 676 Moss Street Project
2. Project Location: 676 Moss Street, Chula Vista, California
3. Assessor’s Parcel No.: 618-010-2601, 618-010-2602, 618-010-3100,
and 618-010-3200
4. Project Applicant: Shopoff Land Fund-Moss Street, LLC
2 Park Plaza, Suite 700, Irvine, California 92614
Contact: James O’Malley
949.417.1396
5. Date of Draft Document: April 27, 2020
6. Case No: IS18-0004
7. Date of Final Document: TBD
A. PROJECT SETTING
The 676 Moss Street Project (proposed project) is located on approximately 6.9 acres located
on the northeast corner of Industrial Boulevard and Moss Street, east of Interstate 5 (I-5)
(Exhibit 1). The project site includes four parcels designated as San Diego County Assessor ’s
Parcel Numbers (APNs): 618-010-2601, 618-010-2602, 618-010-3100, and 618-010-3200
(Exhibit 2). The project site currently has three buildings on‐site used for a variety of light
industrial uses, all of which would be demolished.
The property has a City of Chula Vista Vision 2020 General Plan Land Use Designation of
Limited Industrial and is zoned Limited Industrial Zone (I-L). Refer to Exhibit 3 and Exhibit
4, respectively.
The project site is bounded by light industrial uses to the north; light industrial uses and
residential dwellings to the east; Moss Street and residential dwellings to the south; and light
industrial uses, an at-grade rail crossing, and Industrial Boulevard to the west.
B. PROJECT DESCRIPTION
The proposed project consists of the approvals necessary to remove three existing buildings on
the 6.9-acre project site to develop a residential neighborhood with a variety of housing types.
Approximately, one third of the site (2.5 acres) would be developed as open space as part of
the proposed project. The components of the project are described in more detail below.
Residential
The proposed project would consist of a gated-residential development comprised of 141
dwelling units, including 97 3-story court townhomes and 44 3-story row townhomes. The
proposed dwelling units would be 3-story, 45-foot-tall buildings and would vary from 1,175
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square feet to 1,947 square feet. Each unit would have 2- to 4-bedrooms, and all units would
have 2.5 bathrooms (Exhibit 5). The average household size in the City of Chula Vista is 3.37
persons per dwelling unit. The proposed project is estimated to increase the population by
approximately 475 people.1 The estimated start of construction is approximately October 2020.
Frontage
The proposed project would require a variance for a front-yard setback requirement on Moss
Street due to the two 10-foot by 12-foot concrete box culverts that currently bisect the site. The
proposed front-yard setback is 10 feet instead of 15 feet due to all buildings being shifted away
from the culvert on both sides, thus imposing a burden that is not created by the owner. The
existing right-of-way is 5 feet wider than the City of Chula Vista standard. Therefore, the
resulting setback between the improved street and the proposed buildings would be consistent
with the intended setback.
Parking
The proposed rezoning to R-3 requires two parking spaces per dwelling unit, for a total of 282
parking spaces. The proposed project would provide 282 garage spaces with an additional 66
non-garage spaces. Therefore, the proposed project would provide 2.47 parking spaces per
home equaling 348 parking spaces; 66 more parking spaces than required by the R-3 zoning
(Exhibit 5).
Site Access
Vehicular access to the proposed project would be provided via one full-access, un-signalized
driveway on Moss Street, which is the existing site access point (Exhibit 5).
Open Space
The R-3 District requires a total of 71,120 square feet of open space (approximately 504 square
feet per dwelling unit or 1.6 acres). The proposed project would exceed this requirement by
creating private open space areas of 75,111 square feet (approximately 533 square feet per
dwelling unit or 1.72 acres) (Exhibit 6). The proposed open space includes approximately 19,636
square feet of rooftop decks for recreation,2 and approximately 36,864 square feet of common
open space that would include a community recreational area with barbeque counter, tot lot, and
overhead structures with Americans with Disabilities Act (ADA) compliant seating for social
gatherings and special events (Exhibit 7). A Homeowner ’s Association (HOA) would maintain
the common area landscape and open space.
Utilities
The proposed project would be served by all required public services and utilities, including
electricity, natural gas, telecommunications, sewage, water, and solid waste removal, etc. There
1 Project population (475) calculated by multiplying number of proposed dwelling units (141) by average household size (3.37 persons
per dwelling unit).
2 Chula Vista Municipal Code, Section 19.28.090, Open Space Requirements, allows for roof areas designed and equipped to
accommodate recreational and leisure activities to be included as part of the open space requirement.
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are existing underground utilities on the project site. The proposed project would construct an
on-site private sewer main in the internal private streets and that would connect the sewer main
to the existing public sewer main. Water would be served by the existing water main and a new
public water main would be constructed. Stormwater runoff would flow into a proposed storm
drain system and discharge into an existing double-box culvert. Table 1 lists the Utility
Providers for the proposed project site.
Table 1: Utility Providers
Utility Provider
Electricity San Diego Gas & Electric
Natural Gas San Diego Gas & Electric
Sewage City of Chula Vista
Potable Water Sweetwater Authority
Storm Drain Sweetwater Authority
Solid Waste Removal Republic Services
Telephone AT&T
Cable TV Time Warner Cable
Source: Michael Baker International. Tentative Map 2018.
C. COMPLIANCE WITH ZONING AND PLANS
The proposed project would require a General Plan Amendment from Limited Industrial (I-L)
to High Residential (RH: 18-27 dwelling units per acre), and a Zone Change from Limited
Industrial (I-L) to Apartment Residential Zone (R-3). The High Residential designation is
intended for multi-family units, such as apartment and condominium-type dwellings in
multiple-story buildings, with densities ranging from 18.1 to 27 dwelling units per gross acre.
According to the United States Census Bureau’s 2013-2017 American Community Survey 5-
year Estimates, Tables DP05 and S2504, the population of the City of Chula Vista is 264,101
and the number of occupied housing units is 78,476, for an average household size of 3.37
persons per dwelling unit.3 Therefore, population density would range from 60.6 to 90.5
persons per acre.
The purpose of the R-3 zone is to provide appropriate locations where apartment house
neighborhoods of varying degrees of density may be established, maintained, and protected.
The regulations of this district are designed to promote and encourage an intensively developed
residential environment, with appropriate environmental amenities such as open areas,
landscaping, and off-street parking. To this end, the regulations permit, in accordance with the
respective density districts, multiple dwellings ranging from garden apartments to multi-story
apartment houses, and necessary public services and activities subject to proper controls. Also
permitted, subject to special control, are certain retail and service activities intended for the
3 United States Census Bureau. 2013-2017 American Community Survey 5-year Estimates. Accessed December 23, 2018.
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convenience and service of the residents of the district (Chula Vista Municipal Code, Chapter
19.28.010)
D. PUBLIC COMMENTS
On April 27, 2020, a Notice of Intent was circulated to property owners within a 500-foot
radius of the proposed project site, as well as to other interested parties. The public review
period shall end on May 27, 2020.
E. IDENTIFICATION OF ENVIRONMENTAL EFFECTS
An Initial Study conducted by the City of Chula Vista determined that the proposed project
may have potential significant environmental impacts; however, mitigation measures have
been incorporated into the project to reduce these impacts to a less than significant level. This
MND has been prepared in accordance with Section 15070 of the CEQA Guidelines.
F. MITIGATION NECESSARY TO AVOID SIGNIFICANT IMPACTS
MM AIR-1 Prior to the issuance of any demolition or grading permit, the Project
Applicant shall demonstrate to the satisfaction of the City Development
Services Department that all off-road construction equipment that will be used
on the project site in excess of 50 horsepower will be equipped with engines
meeting the United States Environmental Protection Agency (EPA) Tier IV
Final off-road engine emission standards. This mitigation measure shall be
included on the grading plan.
MM BIO-1 Construction activities that occur during the nesting season (generally March
1 to August 31) could disturb nesting sites for birds protected by the
Migratory Bird Treaty Act (MBTA) and Fish and Game Code. No action is
necessary if no active nests are found or if construction occurs during the non-
breeding season (generally September 1 through February 14).
Implementation of the following avoidance and minimization measures would
reduce impacts to nesting birds to a less than significant level.
• To prevent impacts to MBTA-protected birds, nesting raptors, and their
nests, removal of trees will be limited to only those necessary to construct
the proposed project.
• If any tree removal is necessary, then it will occur outside the nesting
season, between September 1 and February 14. If trees cannot be removed
outside the nesting season, pre-construction surveys will be conducted 3
days prior to tree removal to verify the absence of active nests.
• If an active nest is located during pre-construction surveys, the United
States Fish and Wildlife Service (USFWS) and/or the California
Department of Fish and Wildlife (CDFW) (as appropriate) shall be notified
regarding the status of the nest. Construction activities shall be restricted as
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necessary to avoid disturbance of the nest until it is abandoned or the
agencies deem disturbance potential to be minimal. Restrictions may
include the establishment of exclusion zones (no ingress of personnel or
equipment at a minimum radius of 100 feet around an active raptor nest and
a 50-foot radius around an active migratory bird nest) or alteration of the
construction schedule.
• A Qualified Biologist will delineate the buffer using Environmentally
Sensitive Area (ESA) fencing, pin flags, and or yellow caution tape. The
buffer zone will be maintained around the active nest site(s) until the young
have fledged and are foraging independently.
MM CUL-1 Prior to the issuance of any demolition or grading permit, the Project
Applicant shall demonstrate to the satisfaction of the City Development
Services Department that a program related to potential archaeological
resources uncovered during construction activities on-site has been
established, the program shall include that:
1. The Project Applicant shall retain a qualified professional Archaeologist
approved by the City to be present and monitor all ground-disturbing
activities;
2. The Archaeologist shall halt work in the immediate area in the event that
archaeological resources are identified until the Archaeologist has
evaluated the find and determined if the find is a “unique cultural resource”
as defined in Section 21083.2 (g) of the CEQA statutes;
3. The Project Applicant shall inform the City Development Services
Department of the find;
4. If this determination is positive, the scientifically consequential
information shall be fully recovered by the Archaeologist;
5. The Project Applicant shall stop work in the immediate location of the find
until information recovery has been completed and a report has been filed
with the City; the SCIC at San Diego State University; and, appropriate
Native American representatives;
6. The Project Applicant may continue outside the area of the find; and,
7. The City Development Services Department shall ensure compliance.
MM CUL-2 Prior to the issuance of any demolition or grading permit, the Project
Applicant shall demonstrate to the satisfaction of the City Development
Services Department that a program related to any human remains that might
be encountered during ground-disturbing activities on-site has been
established, the program shall include:
1. The Project Applicant shall halt work in the immediate area of the find;
2. The Project Applicant shall contact the San Diego County Coroner, City
Development Services Department, and Sherriff ’s Department;
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3. The Project Applicant shall be responsible for ensuring that the Native
American Heritage Commission (NAHC) and the appropriate Native
American representatives are contacted and that the NAHC contacts the
most appropriate most likely descendant (MLD) as maybe directed by
either the San Diego County Coroner, City Development Services
Department, or Sherriff ’s Department;
4. The City Development Services Department shall direct the treatment of
the remains pursuant to Coroner and MLD recommendations.
MM GEO-1 All recommendations included in the Preliminary Geotechnical Report,
included as Appendix D of this Draft IS/MND, shall be implemented during
construction activities.
MM GEO-2 The City of Chula Vista assesses and mitigates the potential impacts of private
development and public facilities and infrastructure to paleontological
resources pursuant to the provisions of CEQA. Pursuant to Section 15065 of
the CEQA Guidelines, a lead agency must find that a project may have a
significant effect on the environment where the project has the potential to
eliminate important examples of the major periods of California prehistory,
which includes the destruction of significant paleontological resources.
With the implementation of Mitigation Measure (MM) GEO-2, impacts to any
previously undiscovered paleontological resources would be less than
significant.
Because excavations may extend into undisturbed high sensitivity geological
units, and may be greater than 10 feet below the ground surface in certain
areas of the project, a Paleontological Monitor will be required.
Prior to the issuance of any demolition or grading permit, the Project
Applicant shall demonstrate to the satisfaction of the City Development
Services Department that a program related to paleontological resources
potentially uncovered during ground-disturbing activities on-site has been
established, the program shall include:
1. The Project Applicant shall halt work in the immediate area of the find;
2. The Project Applicant shall notify the City Development Services
Department;
3. The Project Applicant shall retain a qualified professional Paleontologist
approved by the City:
• The Paleontologist shall assess the discovered material(s).
• The Paleontologist shall prepare a survey, study or report evaluating the
find.
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• The Paleontologist’s survey, study, or report shall contain a
recommendation(s), if necessary, for the preservation, conservation, or
relocation of the find.
• The Report shall be reviewed and approved by the City Development
Services Department.
• The Project Applicant shall comply with the recommendations of the
report as approved by the City.
• Project development activities in the immediate area of the find will
resume when copies of the report are submitted in a manner acceptable
to the City Development Services Department.
• A find(s) recovered should be deposited in a manner approved by the
City Development Services Department.
Prior to the issuance of any building permit, the Project Applicant shall submit
a letter to the City Development Services Department indicating what, if any,
paleontological reports have been prepared for the project site, or a statement
indicating that no material was discovered.
MM GHG-1 Prior to the occupancy of the proposed project, the Project Applicant shall
provide for the purchase of voluntary carbon credits in a manner approved by
the City Development Services Department pursuant to the following
performance standards and requirements: the carbon offsets shall achieve real,
permanent, quantifiable, verifiable, and enforceable reductions as set forth in
Cal. Health & Saf. Code Section 38562(d)(1); and ii. one carbon offset credit
shall mean the past reduction or sequestration of one metric ton of carbon
dioxide equivalent that is “not otherwise required” (CEQA Guidelines Section
15126.4(c)(3)). The purchase shall be from a verified greenhouse gas (GHG)
emissions credit broker in an amount sufficient to offset operational GHG
emissions of approximately 0 metric ton (MT) carbon dioxide equivalent
(CO2e) per year until 2030 and 450 MT CO2e per year beginning in 2030 (or a
total amount estimated over the lifetime of the proposed project, which is
estimated to be 9,450 MT CO2e). The purchase shall be verified as occurring
prior to approval of occupancy permits. Copies of emission estimates and
offset purchase contract(s) shall be provided to the City Development Services
Department for review and approval.
MM HAZ-1 Prior to the issuance of any demolition or grading permit, the Project
Applicant shall demonstrate to the satisfaction of the City Development
Services Department that the five groundwater monitoring wells on the project
site will remain in place should additional groundwater testing be necessary.
The Project Applicant will abandon the wells when they are longer needed in
a manner approved by the City Development Services Department and San
Diego County Department of Environmental Health Monitoring Well
Program.
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MM HAZ-2a Prior to the issuance of any grading permit and subsequent to the demolition
of on-site structures, the Project Applicant shall conduct soil testing on the
soils the structures were on. If volatile organic compounds (VOCs) are
present, soil containing elevated concentrations of VOCs shall be excavated
and removed from the project site. The excavation and removal of soil to be
outlined in the Soil Management Plan (SMP) approved by the San Diego
County Department of Environmental Health.
MM HAZ-2b Prior to issuance of any demolition permit, the Project Applicant shall obtain a
permit from the San Diego County Hazardous Materials Division. The permits
shall provide that hydrocarbons or “other products,” including asbestos and
lead based paints, that might be encountered during building demolition,
grading, or construction activities, are disposed of in a manner approved by
the City Development Services Department.
MM HAZ 3 Prior to the issuance of any site development permits (demolition, grading,
building, construction), the Project Applicant shall enter into the County of
San Diego Department of Environmental Health Voluntary Assistance
Program (VAP). Written Confirmation of VAP participation and compliance
shall be received from San Diego County Department of Environmental
Health prior to any site development activities.
MM NOI-1 To meet the interior noise level standard of 45 A-weighted decibel (dBA)
Community Noise Equivalent Level (CNEL), each of the proposed multi-
family residential units shall be supplied with an alternative form of
ventilation, such as air conditioning or noise-attenuated passive ventilation
systems, that would allow an occupant the option of controlling noise by
keeping the windows shut (as the interior noise standard would not be met
with open windows).
MM NOI-2 To reduce potential construction noise impacts, the Project Applicant shall
demonstrate to the satisfaction of the City Development Services Department
that:
• The Construction Contractor shall ensure that all equipment driven by
internal combustion engines shall be equipped with mufflers that are in
good condition and appropriate for the equipment.
• The Construction Contractor shall ensure that unnecessary idling of internal
combustion engines (i.e., idling in excess of 5 minutes) is prohibited.
• The Construction Contractor shall utilize “quiet” models of air compressors
and other stationary noise sources where such market available technology
exists.
• The Construction Contractor shall ensure that stationary noise-generating
equipment shall be located as far as practicable from sensitive receptors and
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placed so that emitted noise is directed away from the nearest residential
land uses at all times during project grading and construction.
• The Construction Contractor shall designate a Noise Disturbance Coordinator
who would be responsible for responding to any local complaints about
construction noise. The Noise Disturbance Coordinator would determine the
cause of the noise complaints (starting too early, bad muffler, etc.) and
establishment reasonable actions necessary to correct the problem. The
Construction Contractor shall visibly post a telephone number for the Noise
Disturbance Coordinator at the construction site.
• The Construction Contractor shall limit noise producing construction
activities to the hours between 7:00 a.m. and 10:00 p.m., Monday through
Friday, and between 8:00 a.m. and 10:00 p.m. on Saturday and Sunday.
Prior to the issuance of each certificate of occupancy, the Construction
Contractor shall demonstrate, to the satisfaction of the City Development
Services Department, compliance with Mitigation Measure (MM) NOI-2.
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Exhibit 1Regio nal Lo catio n Map
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Text Project Site
So urce: Census 2000 Data, The CaSIL
CITY OF CHULA VISTA • 676 MOSS STREETINITIAL STUDY/MITIGATED NEGATIVE DECLARATION34260024 • 03/2019 | 1_ regio nal.mxd
Project Site
San Diego County
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34260024 • 04/2019 | 2_APN_map.mxd
Exhibit 2Assessor Parcel Numbers Map
Source: ESRI Aerial Imagery. San Diego County GIS Data.
CITY OF CHULA VISTA • 676 MOSS STREETINITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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34260024 • 03/2019 | 3_GPLU.mxd
Exhibit 3City o f Chula VistaGeneral Plan Land Use Map
So urce: ESRI Aerial Imagery. City o f Chula Vista and San Diego Co unty GIS Data.
CITY OF CHULA VISTA • 676 MOSS STREETINITIAL STUDY /MITIGATED NEGATIVE DECLARATION
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CR - Commercial Retail
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IL - Limited Industrial
MUR - Mixed Use Residential
OS - Open Space
PQ - Public & Quasi Public
RH - Residential High
RMH - Residential Medium/High
RM - Residential Medium
RLM - Residential Low/Medium
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34260024 • 03/2019 | 4_zo ning.mxd
Exhibit 4City o f Chula Vista Z o ning Map
So urce: ESRI Aerial Imagery. City o f Chula Vista and San Diego Co unty GIS Data.
CITY OF CHULA VISTA • 676 MOSS STREETINITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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34260024 • 02/2020 | 5_conceptual_site_plan.cdr
Exhibit 5
Conceptual Site Plan
CITY OF CHULA VISTA • 676 MOSS STREET
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
Source: WHA Architects, Planners, Designers, February 18, 2020.
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CITY OF CHULA VISTA • 676 MOSS STREET
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
Source: WHA Architects, Planners, Designers, March 26, 2020.
Exhibit 6
Conceptual Open Space Plan
34260024 • 04/2020 | 6_conceptual_open_space_plan.cdr
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34260024 • 02/2020 | 7_conceptual_landscape_plan.cdr
Exhibit 7
Conceptual Landscape Plan
CITY OF CHULA VISTA • 676 MOSS STREET
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
Source: WHA Architects, Planners, Designers, February 18, 2020.
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676 MOSS STREET PROJECT INITIAL STUDY
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1
ENVIRONMENTAL CHECKLIST FORM
1. Proponent Name, Address, and Contact: Shopoff Land Fund-Moss Street, LLC
2 Park Plaza, Suite 700
Irvine, California 92614
Contact: James O’Malley, Vice
President
949.417.1396
2. Lead Agency Name, Address, and Contact: City of Chula Vista
Development Services Department
276 Fourth Avenue
Chula Vista, California 91910
Stan Donn, AICP
619.409.5953
3. Name of Proposal: 676 Moss Street Project
4. Date of Checklist: April 27, 2020
5. Case No. IS18-0004
6. General Plan Designation: Limited Industrial (I-L) to be rezoned
to High Residential (RH).
7. Zoning Designation: Limited Industrial (I-L) to be rezoned
to High Residential (RH).
PROJECT LOCATION AND SETTING
The proposed 676 Moss Street Project (proposed project) is located in the City of Chula Vista,
in San Diego County, California. The City of Chula Vista is surrounded by National City, the
City of San Diego, and unincorporated San Diego County to the north, unincorporated San
Diego County to the east, the City of San Diego to the south, and the San Diego Bay to the
west (Exhibit 1).
The project site is located at 676 Moss Street on the northeast corner of Industrial Boulevard and
Moss Street. The project site is comprised of four parcels, including Assessor’s Parcel Numbers
(APNs): 618-010-2601, 618-010-2602, 618-010-3100, and 618-010-3200 (Exhibit 2).
Surrounding Land Uses
The site area is bounded by light industrial uses to the north; light industrial uses and residential
dwellings to the east; Moss Street and residential dwellings to the south; and light industrial
uses, an at-grade rail crossing, and Industrial Boulevard to the west.
2
Land Use and Zoning
The proposed project would require a General Plan Amendment from Limited Industrial (I-L)
to High Residential (RH: 18-27 dwelling units per acre), and a Zone Change from I-L to
Apartment Residential Zone (R-3). The RH designation is intended for multi-family units, such
as apartment and condominium-type dwellings in multiple-story buildings, with densities
ranging from 18.1 to 27 dwelling units per gross acre. According to the United States Census
Bureau’s 2013-2017 American Community Survey 5-year Estimates, Tables DP05 and S2504,
the population of the City of Chula Vista is 264,101 and the number of occupied housing units
is 78,476, for an average household size of 3.37 persons per dwelling unit.1 Therefore,
population density would range from 60.6 to 90.5 persons per acre.
The purpose of the R-3 zone is to provide appropriate locations
where apartment house neighborhoods of varying degrees of
density may be established, maintained, and protected. The
regulations of this district are designed to promote and
encourage an intensively developed residential environment,
with appropriate environmental amenities such as open areas,
landscaping and off-street parking. To this end, the regulations
permit, in accordance with the respective density districts,
multiple dwellings ranging from garden apartments to multi-
story apartment houses, and necessary public services and
activities subject to proper controls. Also permitted, subject to
special control, are certain retail and service activities intended
for the convenience and service of the residents of the district.
(Ordinance 3153 § 2 [Exh. A] 2010; Ord. 1212 § 1, 1969; prior
code § 33.505(A)).2
ENVIRONMENTAL ANALYSIS QUESTIONS
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
I. Aesthetics
Except as provided in Public Resources Code Section 21099, would the project:
a) Have a substantial adverse effect on a scenic vista?
b) Substantially damage scenic resources, including,
but not limited to, trees, rock outcroppings, and
historic building within a State Scenic Highway?
c) In non-urbanized areas, substantially degrade the
existing visual character or quality of public
1 United States Census Bureau. 2013-2017 American Community Survey 5-year Estimates. Accessed December 23, 2018.
2 City of Chula Vista. Chula Vista Municipal Code. 2019. Chapter 19.28: R-3 Apartment Residential Zone. Section 19.28.010:
Purpose. Website: https://chulavista.municipal.codes/CVMC/19.28. Accessed February 25, 2020.
3
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
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?
d) Create a new source of substantial light or glare
which would adversely affect day or nighttime
views in the area?
Comments:
(a) No impact. According to the City of Chula Vista Vision 2020 General Plan:
Chula Vista has valued scenic vistas and open space that
include the Otay River and Sweetwater River Valleys; Upper
and Lower Otay Lakes; Sweetwater Reservoir; San
Miguel/Mother Miguel Mountains; and the San Diego Bay.
These open space areas make up the majority of the Chula
Vista Greenbelt, the backbone of the City’s open space and
park system, which consists of a 28-mile open space system
encircling the City.3
The project site is located approximately 1.21 miles from the nearest section of the
Chula Vista Greenbelt. Due to the relatively flat nature of the project site and
intervening buildings and topography, the Chula Vista Greenbelt is not visible from the
project site. As such, the proposed project would not have an impact on scenic views
of the open space areas outlined in the City of Chula Vista Vision 2020 General Plan.
Additionally, the City of Chula Vista has designated roadway segments within the City
as scenic. According to the City of Chula Vista Vision 2020 General Plan:4
Chula Vista has several designated Scenic Roadways, where
views of unique natural features and roadway characteristics,
including enhanced landscaping, adjoining natural slopes, or
special design features make traveling a pleasant visual
experience. The designated Scenic Roadways are listed below
and are shown on Figure 5-4, Designated Scenic Roadways.
3 City of Chula Vista. City of Chula Vista Vision 2020 General Plan. Website: https://www.chulavistaca.gov/departments/development-
services/planning/general-plan. Accessed December 18, 2018.
4 Ibid
4
Marina Parkway from the intersection of E Street and Interstate 5 on the
north to its intersection with Bay Boulevard South of J Street
Bonita Road from Interstate 805 to Sweetwater Road
Sweetwater Road from the National City boundary east to State Route 54
East H Street from Interstate 805 to Mount Miguel Road
Proctor Valley Road from Mount Miguel Road east to Jamul
Telegraph Canyon Road/Otay Lakes Road from Interstate 805 to Lower
Otay Lake
Olympic Parkway
Otay Lakes Road from Bonita Road to Telegraph Canyon Road
The nearest City designated Scenic Roadway to the proposed project is Marina
Parkway at J Street, located approximately 0.75 mile northwest. The distance,
geographic, and physical barriers make the project site not visible from this roadway.
Therefore, the proposed project would have no impact to scenic vistas.
(b) No impact. The nearest State Scenic Highway to the project site is State Route 75
(SR-75), which is approximately 2.18 miles west of the project site, across the San
Diego Bay. The distance, geographic, and physical barriers make the project site not
visible from SR-75.
The site is currently developed and contains several species of ornamental trees;
however, none of the ornamental trees are protected resources and there are no rock
outcroppings.
Therefore, the proposed project would not substantially damage scenic resources,
including, but not limited to, trees, rock outcroppings, and historic buildings within a
State Scenic Highway. As such, there would be no impact.
(c) Less than significant impact. The approximately 6.9‐acre site is flat and located in
an urban area. The proposed project would be required to comply with applicable zoning
and the City of Chula Vista Design Guidelines. As previously discussed, implementation
of the proposed project would require a zone change from I-L Zone to R-3. Furthermore,
a General Plan Amendment to amend the land use designation from I-L to High
Residential would be required. Thus, rectifying any potential conflicts with applicable
zoning regulations regarding scenic quality. The proposed project would be designed to
match similar multi-family housing developments in the surrounding area. Furthermore,
the proposed project would be located approximately 1,000 feet east of the Chula Vista
Bayfront Master Plan area. Although the project is not located within the Chula Vista
Bayfront Master Plan area, the project would not conflict or impede in the City’s ability
to implement the Chula Vista Bayfront Master Plan. Because the proposed project would
conform to the City of Chula Vista Design Guidelines, and would not conflict with any
applicable General Plan policies or zoning regulations regarding scenic quality, impacts
would be less than significant.
5
(d) Less than significant impact. The proposed project would introduce new lighting
fixtures from the construction of 141 dwelling units, which would increase new sources
of light. However, all new light fixtures for the proposed project would require City
Staff approval, as outlined in the City of Chula Vista Municipal Code, Chapter 17:
Zoning, 17.28.040 Lighting Plans—Approval Required When:
All lighting plans in multiple-family, commercial and industrial
zones shall be submitted to the Director of Planning for
approval prior to installation thereof. Should the City
disapprove of the plans, appeal may be taken to the Planning
Commission. The determination of the Commission shall be
final. (Ordinance 1324 § 1, 1971; prior code § 20.35.4(C)).5
The proposed project would require City Staff to review and approve the proposed plan
and associated lighting to ensure light and associated glare impacts are minimized.
According to the proposed lighting plan, the project would include street light posts
with lamp shields to minimize light spillage into adjacent properties. Furthermore, the
lighting plan proposes the usage of high efficiency LED lights in order to maximize
light and minimize electrical usage on the property. The proposed lighting plan is
included as Exhibit 8. As such, impacts would be less than significant.
Mitigation Measures: None.
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
II. Agriculture and Forestry Resources
In determining whether impacts to agricultural resources are significant environmental effects, lead
agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997)
prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on
agriculture and farmland. In determining whether impacts to forest resources, including timberland, are
significant environmental effects, lead agencies may refer to information compiled by the California
Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the
Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon
measurement methodology provided in Forest Protocols adopted by the California Air Resources Board.
Would the project:
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland),
as shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of
the California Resources Agency, to non-
agricultural use?
b) Conflict with existing zoning for agricultural
use, or a Williamson Act contract?
5 City of Chula Vista. Chula Vista Municipal Code. 2019. Chapter 17.28: Unnecessary Lights. Section 17.28.040: Lighting Plans.
Website: https://chulavista.municipal.codes/CVMC/17.28. Accessed November 5, 2019.
6
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
c) Conflict with existing zoning for, or cause rezoning
of, forest land (as defined in Public Resources Code
Section 12220(g)), timberland (as defined by Public
Resources Code Section 4526), or timberland
zoned Timberland Production (as defined by
Government Code Section 51104(g))?
d) Result in the loss of forest land or conversion of
forest land to non-forest use?
e) Involve other changes in the existing
environment which, due to their location or
nature, could result in conversion of Farmland,
to non-agricultural use or conversion of forest
land to non-forest use?
Comments:
In determining whether impacts to agricultural resources are significant environmental effects,
lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment
Model (1997) prepared by the California Department of Conservation as an optional model to
use in assessing impacts on agriculture and farmland. In determining whether impacts to forest
resources, including timberland, are significant environmental effects, lead agencies may refer
to information compiled by the California Department of Forestry and Fire Protection (CAL
FIRE) regarding the State’s inventory of forest land, including the Forest and Range Assessment
Project and the Forest Legacy Assessment project; and forest carbon measurement methodology
provided in Forest Protocols adopted by the California Air Resources Board (ARB).
(a) No impact. According to the California Department of Conservation, California
Important Farmland Finder, San Diego, 2016 map, the project site and the surrounding
area is classified as Urban and Built-Up Land. 6 According to the California Department
of Conservation, Urban and Built-Up Land constitutes being occupied “by structures
with a building density of at least 1 unit to 1.5 acres, or approximately 6 structures to a
10-acre parcel. Common examples include residential, industrial, commercial,
institutional facilities, cemeteries, airports, golf courses, sanitary landfills, sewage
treatment, and water control structures” and not farmland.
As such, the proposed project would not convert Prime Farmland, Unique Farmland,
or Farmland of Statewide Importance (Farmland) to non-agricultural use, and there
would be no impact.
6 California Department of Conservation. 2019. Farmland Mapping and Monitoring Program: San Diego County. Website:
ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/pdf/2016/sdg16_w.pdf. Accessed November 5, 2019
7
(b) No impact. According to the City of Chula Vista CVMapper ChulaVista GIS online
tool, the four parcels where a zoning designation I-L is proposed are not zoned for
agricultural use.7 Therefore, the proposed project would not conflict with existing
zoning for agricultural use, as the project site is not zoned as such.
According to the California Department of Conservation’s San Diego County
Williamson Act 2013/2014 Sheet 1 of 2 map, the project site and the surrounding area
is classified as Urban and Built-Up Land and not as Williamson Act Agricultural Land.8
Therefore, the proposed project would not conflict with a Williamson Act contract.
As such, the proposed project would not conflict with existing zoning for agricultural
use, or a Williamson Act contract, and there would be no impact.
(c) No impact. As outlined above in Impact 2.2(b), the four parcels where a zoning
designation I-L is proposed are not zoned for forestland, timberland, nor timberland
production.
As such, the proposed project would not conflict with existing zoning for, or cause
rezoning of, forestland, timberland, or timberland production, and there would be no
impact.
(d) No impact. As outlined above in Impact 2.2(c), the four parcels where a zoning
designation I-L is proposed are not zoned for forest land, timberland, nor timberland
production. Additionally, the project site is currently urbanized and built-up with light
industrial uses and is zoned for industrial uses.
As such, the proposed project would not result in the loss of forest land or conversation
of forest land to non-forest use and there would be no impact.
(e) No impact. As outlined above in Impacts 2.2(a)–2.2(d), neither the project site nor
its surroundings are zoned for or currently agricultural or forest land. As such, the
proposed project would not involve other changes in the existing environment which,
due to their location or nature, could result in conversion of Farmland to non-agricultural
use, or conversion of forest land to non-forest use, thus there would be no impact.
Mitigation Measures: None.
7 City of Chula Vista. CV Web Mapper: ChulaVista GIS. Website: https://gisweb.chulavistaca.gov/cvmapper/. Accessed February 27,
2020.
8 California Department of Conservation. 2014. San Diego County Williamson Act 2013/2014 Sheet 1 of 2 map. Website:
ftp://ftp.consrv.ca.gov/pub/dlrp/wa/San_Diego_w_13_14_WA.pdf. Accessed December 7, 2018.
8
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
III. Air Quality
Where available, the significance criteria established by the applicable air quality management district or
air pollution control district may be relied upon to make the following determinations.
Would the project:
a) Conflict with or obstruct implementation of the
applicable air quality plan?
b) Result in a cumulatively considerable net
increase of any criteria pollutant for which the
project region is non-attainment under an
applicable federal or State ambient air quality
standard?
c) Expose sensitive receptors to substantial
pollutant concentrations?
d) Result in other emissions (such as those leading
to odors) adversely affecting a substantial
number of people?
Comments:
Where available, the significance criteria established by the applicable air quality management
or air pollution control district may be relied upon to make the following determinations.
Information included in this section is based, in part, on project-specific air quality modeling;
complete modeling output is provided in Appendix A.
(a) Less than significant impact. The project site is located in the City of Chula Vista,
in San Diego County, which is part of the San Diego Air Basin. San Diego County is
designated nonattainment for State standards for PM10, 8-hour ozone, 1-hour ozone,
and PM2.5. The area is also designated nonattainment of the federal standard for 8-hour
ozone.9
The San Diego County Air Pollution Control District (San Diego County APCD)
prepares air quality plans that include projected emissions inventories and account for
emission reductions strategies in order to demonstrate how the region will achieve the
ambient air quality standards by the given deadlines. The applicable air quality plans
for San Diego County are the Regional Air Quality Strategy (RAQS) and the 8‐hour
Ozone Attainment Plan (Attainment Plan).10
If a project proposes development that is greater than that anticipated in the local plan’s
growth projection, the project might be in conflict with the applicable air quality plans
9 San Diego County Air Pollution Control District (San Diego County APCD). 2020. Attainment Status. Website:
https://www.sdapcd.org/content/sdc/apcd/en/air-quality-planning/attainment-status.html. Accessed February 11, 2020.
10 Ibid.
9
and may contribute to a potentially significant cumulative impact on air quality. The
project site is currently zoned I-L, while the project proposes development of
residential uses. Therefore, the proposed project would not be consistent with the
General Plan Land Use designation for the site and would require a General Plan
Amendment to change the land use designation from I-L to R-3. Chapter 5, Land Use
and Transportation Element, of the City of Chula Vista Vision 2020 General Plan, states
that the floor area ratio (FAR) for the I-L Zone ranges from 0.25 to 0.5.11 The existing
site size is 6.9 acres, thus the maximum building square footage under the current
General Plan Land Use designation would be approximately 150,282 square feet. The
San Diego Association of Governments (SANDAG) Series 13 Regional Growth
Forecast estimates approximately 17.1 civilian jobs per developed employment acre.12
Therefore, the estimated number of employees for existing land use type would be 59
people.13 The proposed project would construct 141 residential units, and thus, is
estimated to house approximately 475 people.
Based on the allowable square footage under the existing zoning designation, the daily
trips generated under the current land use designation buildout is estimated to be
between 300 and 1,491 weekday trips. The proposed project, using a conservative
analysis, would generate 1,128 trips per day.,14,15 Furthermore, the annual regional
vehicle miles traveled (VMT) of the buildout under the current General Plan Land Use
designation is estimated to be between 877,488 and 1,293,042 miles,16 while the annual
VMT of the proposed project is estimated to be 3,059,605 miles. Because the planned
land use and the proposed land use differ and the land use intensity and associated
vehicle trips differ, further analysis is required to determine if the proposed project
would conflict with or obstruct implementation of the applicable air quality plan.
Further analysis is provided below.
Regional Air Quality Strategy
The RAQS outlines how the San Diego County APCD will make progress toward
attainment of the ozone California Ambient Air Quality Standards (CAAQS) in the San
Diego Air Basin by addressing emissions of the two ozone precursors: volatile organic
compounds (VOCs) and oxides of nitrogen (NOX). Control measures identified in the
RAQS regulate stationary emission sources and some area-wide emission sources (e.g.,
11 City of Chula Vista. City of Chula Vista Vision 2020 General Plan. Table 5-4 General Plan Land Use Designations and Zoning.
Website: https://www.chulavistaca.gov/home/showdocument?id=9327. Accessed February 25, 2020.
12 San Diego Association of Governments (SANDAG). 2013. Series 13: 2050 Regional Growth Forecast. October. Website:
https://www.sandag.org/index.asp?classid=12&subclassid=84&projectid=503&fuseaction=projects.detail. Accessed October 25, 2019.
13 The number of employees for the existing land use type was calculated by multiplying employment density (17.1 jobs per developed
employment area) by the maximum building area (3.45 acres); the maximum building area was calculated by multiplying the existing
site size (6.9 acres) by the upper end of the floor area ratio range (0.5).
14 The Draft Transportation Impact Analysis (December 2018) presents a daily trip volume of 1,128 prior to a 5 percent transit
reduction and prior to netting out trips from existing uses.
15 The revised Draft Transportation Impact Analysis, which was revised October 25, 2019, presents a daily trip volume of 846 (prior to
a 5 percent transit reduction and prior to netting out trips from existing uses). However, as a more conservative approach, the Air
Quality Analysis used the higher daily trip volume of 1,128 from the Draft Transportation Impact Analysis (December 2018).
16 Source of existing land use VMT: CalEEMod output based on the industrial park and general light industrial land uses, maximum
building area of 150,282 square feet, and trip generation rates from the ITE Trip Generation Manual, 10th Edition and the project-
specific Transportation Impact Analysis. Source of proposed project VMT: CalEEMod output in Appendix A.
10
water heaters and architectural coatings). The RAQS emission inventories and
projections include all sources of ROGs and NOX. Projections in the RAQS incorporate
all current control measures and projected population growth.17 The proposed project
would not conflict with control measures identified in the RAQS because no new
stationary sources would be constructed and the proposed project would comply with
all area-wide emission source standards.
8-hour Ozone Attainment Plan
The Attainment Plan serves as the State Implementation Plan (SIP) for San Diego
County APCD to achieve the 8‐hour ozone National Ambient Air Quality Standards
(NAAQS) in the San Diego Air Basin by July 20, 2018.18 San Diego County APCD has
limited authority to regulate mobile sources of ozone pollutants; those sources are
regulated by the ARB and United States Environmental Protection Agency (EPA).
Since San Diego County was recently reclassified as a Moderate nonattainment area
for the 2008 8-hour ozone NAAQS, additional planning and emission control
demonstrations are necessary to comply with the Clean Air Act (CAA). These
additional Moderate nonattainment area requirements include, as summarized in the
Attainment Plan, a comprehensive set of stationary and mobile source control measures
to achieve attainment of the 2008 8-hour ozone NAAQS as expeditiously as
practicable.19
San Diego County APCD has also implemented Regulation IV Rule 55 that includes
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; carryout and track-out
removal and cleanup methods; inactive disturbed land; disturbed open areas; unpaved
parking lots/staging areas; unpaved roads; and windblown dust.
The following measures are recommended to meet San Diego County APCD Rule 55
requirements throughout all phases of construction (but are not required to reduce
emissions below significance thresholds):
All haul trucks transporting soil, sand, or other loose material off-site shall be
covered;
Track-out grates or gravel beds shall be placed at each exit point;
Wheel washing stations shall be placed at each exit point during muddy
conditions;
17 San Diego County Air Pollution Control District (San Diego County APCD). 2016. 2016 Revision of the Regional Air Quality
Strategy for San Diego County. December. Website:
https://www.sdapcd.org/content/dam/sdc/apcd/PDF/Air%20Quality%20Planning/2016%20RAQS.pdf. Accessed February 11, 2020.
17 San Diego County Air Pollution Control District (San Diego County APCD). 2016. 2008 8-hour Ozone Attainment Plan for San
Diego County. December. Website: http://www.sdapcd.org/content/dam/sdc/apcd/PDF/Air%20Quality%20Planning/8-Hr-
O3%20Attain%20Plan-08%20Std.pdf. Accessed February 11, 2020.
18 Ibid.
19 Ibid.
11
All visible mud or dirt track-out onto adjacent public roads shall be removed
using PM10 efficient wet power vacuum street sweepers certified to meet current
South Coast Air Quality Management District Rule 1186 requirements—the use
of blowers for track-out is prohibited; and
All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas,
and unpaved access roads) shall be watered two times per day, covered with soil
binders, chemical soil stabilizers, geotextiles, mulch, or seeded.
The following are ARB-recommended control measures that are not specifically
identified in the San Diego County APCD Rule 55:
Idling times shall be minimized either by shutting equipment off when not in use
or reducing the maximum idling time to 5 minutes (as required by the California
airborne toxics control measure Title 13, Section 2485 of California Code of
Regulations ). Clear signage shall be provided for construction workers at all
access points;
All construction equipment shall be maintained and properly tuned in accordance
with manufacturer’s specifications. All equipment shall be checked by a certified
visible emissions evaluator; and
Post a publicly visible sign with the telephone number and person to contact at the
lead agency regarding dust complaints. This person shall respond and take
corrective action within 48 hours. The San Diego County APCD’s phone number
shall also be visible to ensure compliance with applicable regulations.
The proposed project would comply with all required control measures and rules and
regulations required by the San Diego County APCD during construction and
operation. Furthermore, the proposed project would not include any special features
that would disrupt or hinder implementation of the control measures.
Conclusion
The proposed project would comply with all applicable regulations and would not
conflict or obstruct implementation of the San Diego RAQS or the SIP. Thus, the
proposed project would not conflict or obstruct implementation of the applicable air
quality plan. Furthermore, the proposed project incorporates applicable control
measures identified in the San Diego County APCD and County of San Diego
California Environmental Quality Act (CEQA) Guidelines and would not hinder the
implementation of any control measures. The impact would be less than significant.
(b) Less than significant impact. In analyzing cumulative impacts from the proposed
project, the analysis must specifically evaluate a project’s contribution to the
cumulative increase in pollutants for which the San Diego Air Basin is designated as
nonattainment for CAAQS and NAAQS. If an area is in non-attainment for a criteria
pollutant, then the background concentration of that pollutant has historically exceeded
12
the ambient air quality standard. It follows that if a project exceeds the project-level
thresholds for that non-attainment pollutant, it would result in a cumulatively
considerable net increase of that pollutant and result in a significant cumulative impact.
Project-level Significance Thresholds
The City of Chula Vista evaluates project emissions based on the quantitative emission
thresholds established by the South Coast Air Quality Management District
(SCAQMD). The SCAQMD has established regional significance thresholds for
VOCs, NOX, sulfur oxides (SOX), carbon monoxide (CO), and particulate matter
(including dust 10 micrometers or less in diameter [PM10], and dust 2.5 micrometers or
less in diameter [PM2.5]). Project-related air quality impacts would be significant if any
of the applicable significance thresholds, as shown in Table 1, are exceeded.
Table 1: SCAQMD Regional Thresholds
Pollutant
Criteria Pollutant Mass Daily Thresholds (lbs/day)
Construction Operation
VOC 75 lbs/day 55 lbs/day
NOX 100 lbs/day 55 lbs/day
PM10 150 lbs/day 150 lbs/day
PM2.5 55 lbs/day 55 lbs/day
SOX 150 lbs/day 150 lbs/day
CO 550 lbs/day 550 lbs/day
Notes:
NOX = oxides of nitrogen
SOX = sulfur oxide
VOCs = volatile organic compounds
CO = carbon monoxide
PM10 = particulate matter with an aerodynamic resistance diameter of 10 micrometers or less;
PM2.5 = particulate matter with an aerodynamic resistance diameter of 2.5 micrometers
Source: South Coast Air Quality Management District (SCAQMD). 2019. SCAQMD Air Quality Significance Thresholds. April. Website:
http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-quality-significance-thresholds.pdf. Accessed November 5, 2019.
The San Diego Air Basin has been designated as a federal nonattainment area for ozone
and a State nonattainment area for ozone, PM10, and PM2.5. Ozone is not emitted
directly into the air, but is a regional pollutant formed by photochemical reactions in
the atmosphere. Ozone precursors, VOCs and NOX, react in the atmosphere in the
presence of sunlight to form ozone. Therefore, the SCAQMD does not have a
recommended ozone threshold, but it does have thresholds of significance for VOCs
and NOX.
Project-specific Construction Emissions
Construction of the proposed project would result in the temporary generation of
VOCs, NOX, CO, SOX, PM10, and PM2.5 emissions from construction activities
13
including demolition, grading, building construction, architectural coating, and asphalt
paving. Fugitive particulate matter (PM) dust emissions are primarily associated with
earth disturbance and grading activities, and vary as a function of soil silt content, soil
moisture, wind speed, acreage of disturbance area, and miles traveled by construction
vehicles on- and off-site. Construction-related NOX emissions are primarily generated
by exhaust emissions from heavy-duty construction equipment, material and haul
trucks, and construction worker vehicles. VOC emissions are mainly generated by
exhaust emissions from construction vehicles, off-gas emissions associated with
architectural coatings and asphalt paving.
Construction activities would consist of the demolition of existing buildings, mass
grading, building construction, asphalt paving of new parking lots, and architectural
coating of the inside and outside of the buildings. The proposed project would construct
141 residential units with 2-car garages and 66 additional surface parking spaces.
Construction emissions were estimated using California Emissions Estimator Model
(CalEEMod), Version 2016.3.2. Information provided by the Project Applicant at the
time the Air Quality Analysis was conducted indicated that the anticipated construction
start date would be in September 2019 and would last for 15 months, although the exact
timing of each construction phase would be subject to change. The construction
schedule used in the analysis represents a reasonable “worst-case” analysis scenario
since emission factors for construction equipment decrease as the analysis year
increases, due to improvements in technology and more stringent regulatory
requirements. Therefore, construction emissions would likely decrease if the
construction schedule moves to later years. The proposed project would demolish three
existing buildings, totaling approximately 41,560 square feet. During the grading
phase, the proposed project would import 10,000 cubic yards of material and would
export 15,000 cubic yards of material.
The proposed project would be subject to San Diego County APCD Rule 55, Fugitive
Dust Control. Compliance with Rule 55 would limit any fugitive dust (PM10 and PM2.5)
that would be generated during grading and construction activities. Rule 55 requires
construction or demolition activity subject to this rule in a manner that discharges
visible dust emissions into the atmosphere beyond the property line for a period or
periods aggregating more than 3 minutes in any 60-minute period. The proposed project
would be subject to San Diego County APCD Rule 67.0.1, Architectural Coatings,
which limits the VOC content of architectural coatings.
Table 2 presents the proposed project’s unmitigated maximum daily construction
emissions for each construction activity.
14
Table 2: Project Construction Emissions—Unmitigated
Activity
Mass Daily Emissions (pounds per day)
VOC NOX CO SOX PM10 PM2.5
Demolition 3.64 37.74 22.94 0.04 2.66 1.83
Grading 3.58 60.00 23.97 0.11 6.38 3.45
Building Construction-2019 3.29 26.55 23.41 0.05 2.96 1.69
Building Construction-2020 2.96 24.15 22.53 0.05 2.78 1.52
Paving 1.62 14.11 15.05 0.02 0.88 0.73
Architectural Coating 52.47 1.78 2.71 0.01 0.38 0.18
Maximum Daily Emissions
(lbs/day) 52.47 60.00 23.97 0.11 6.38 3.45
SCAQMD Threshold 75 100 550 150 150 55
Exceed Threshold? No No No No No No
Notes:
NOX = oxides of nitrogen SOX = sulfur oxide VOC = volatile organic compounds CO = carbon monoxide
PM10 = particulate matter with an aerodynamic resistance diameter of 10 micrometers or less; PM2.5 = particulate matter with an
aerodynamic resistance diameter of 2.5 micrometers or less
Emissions include adjustments in accordance with San Diego County APCD Rules 55 and 67.0.1.
Source of emissions: FirstCarbon Solutions (FCS) 2019, Appendix A.
As shown above, the proposed project’s maximum daily construction emissions would
not exceed the SCAQMD threshold of significance. Therefore, the short-term
construction emissions would not 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. The cumulative impact from construction
of the proposed project would be less than significant.
Project-Specific Operational Emissions
Operational emissions for land use development projects are typically generated from
mobile, area, and energy sources. Mobile-source emissions are those associated with
automobiles that would travel to and from the project residences. Area-source emissions
are those associated with landscape maintenance activities and periodic architectural
coatings. Energy-source emissions are those associated with natural gas combustion for
space and water heating and electricity consumption. The three existing buildings would
be removed as part of the proposed project; therefore, the existing emissions were
included in the analysis baseline to estimate the net increase in emissions. Assumptions
used to estimate existing and proposed emissions were consistent with the trip generation
estimates presented in Table 3 below. Table 4 presents the proposed project’s maximum
daily operational emissions. A conservative analysis has been provided for trip generation
15
of the proposed project, so the project’s mobile-source emissions would likely be lower
than those reported below.20
Table 3: Project Trip Generation
Table 4: Project Operational Emissions
Category
Mass Daily Emissions (pounds per day)
VOC NOX CO SOX PM10 PM2.5
Area 5.97 1.42 12.22 0.01 0.17 0.17
Energy 0.03 0.26 0.11 0.00 0.02 0.02
Mobile 1.90 7.98 22.44 0.08 6.55 1.79
Estimated Maximum Daily
Project Emissions 7.90 9.67 34.77 0.09 6.74 1.98
Estimated Maximum Daily
Existing Emissions (1.32) (0.76) (1.90) (0.01) (0.53) (0.15)
Estimated Maximum Daily Net
Emissions 6.58 8.90 32.87 0.08 6.21 1.83
SCAQMD Significance
Thresholds (lbs/day) 55 55 550 150 150 55
Exceeding Thresholds? No No No No No No
Notes:
20 The Draft Transportation Impact Analysis (December 2018) presents a daily trip volume of 1,128 prior to a 5 percent transit
reduction and prior to netting out trips from existing uses. The Transportation Impact Analysis was revised in October 2019, while
the Air Quality Analysis was completed in April 2019. The revised Draft Transportation Impact Analysis (October 2019) presents a
daily trip volume of 846 (prior to reductions), which is lower than the estimate provided in the Transportation Impact Analysis
prepared in December 2018. A higher daily trip volume would lead to higher project emissions generated by the proposed project.
Therefore, reliance on the Draft Transportation Impact Analysis (December 2018) provides a conservative analysis.
Land Use Size
Daily Trip Ends
(ADT) a AM Peak-hour PM Peak-hour
Rate Volume % of ADT In:Out Split
Volume % of ADT In:Out Split
Volume
In Out Total In Out Total
Apartment 141 DU 6/DU 846 8% 2:8 14 54 68 9% 7:3 53 23 76
Trip Reductions
Existing Site Uses Reduction b (84) – – (3) (2) (5) – – (4) (4) (8)
Transit Reduction (5%) c (42) – – (1) (3) (4) – – (3) (1) (4)
Subtotal Reductions (126) – – (4) (5) (9) – – (7) (5) (12)
Net Total Project Site Trips 720 – – 10 49 59 – – 46 18 64
Notes:
a Rate is based on SANDAG’s (Not So) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region, April 2002 (“Brief
Guide”). “Apartment” is the appropriate trip generation rate from the Brief Guide based on the Project’s density.
b Trips for the existing use calculated for a total 42 GFA rooftop area of existing buildings based on a “Storage Land Use” rates from
SANDAG’s (Not So) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region, April 2002.
c Transit reduction of 5 percent recommended by City of Chula Vista consistent with SANDAG Guidelines.
General Note:
(x) = Numbers shown in parenthesis are negative values.
16
Category
Mass Daily Emissions (pounds per day)
VOC NOX CO SOX PM10 PM2.5
NOX = oxides of nitrogen
VOC = volatile organic compounds
SOX = sulfur oxide
CO = carbon monoxide
PM10 = particulate matter with an aerodynamic resistance diameter of 10 micrometers or less
PM2.5 = particulate matter with an aerodynamic resistance diameter of 2.5 micrometers or less
Source of emissions: FCS 2019, Appendix A.
As shown above, the proposed project’s daily operational emissions would not exceed
any SCAQMD threshold of significance. Therefore, the long-term daily operational
emissions would not 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. The cumulative impact from long-term operation of
the proposed project would be less than significant.
(c) Less than significant impact with mitigation incorporated. This impact
evaluates the potential for the project’s construction and operational emissions to
expose sensitive receptors to substantial pollutant concentration. Sensitive receptors
are defined as those individuals who are sensitive to air pollution including children,
the elderly, and persons with preexisting respiratory or cardiovascular illness.
For the proposed project, the closet sensitive receptors are multi-family residences
located directly adjacent to the project site to the east. This analysis evaluates the
potential construction-related toxic air contaminant (TAC) emissions, and ozone
precursor.
Toxic Air Pollutants—Construction
Health risk significance thresholds are represented as a cancer risk to the public and a
non-hazard from exposures to TACs. Cancer risks represent the probability (in terms
of risk per million individuals) that an individual would contract cancer resulting from
exposure to TACs continuously over a lifetime period of several years. Construction-
related activities would result in short-term, project-generated emissions of diesel
particulate matter (DPM) exhaust emissions from off-road, heavy-duty diesel
equipment for grading, building construction, and other miscellaneous activities.
The analysis uses the following project-specific health risk significance thresholds. The
acute hazard index was not evaluated because the San Diego County APCD or the
SCAQMD does not provide an applicable acute Reference Exposure Level (REL)
threshold.21,22 As noted above under section Project-level Significance Thresholds,
21 County of San Diego. 2007. Guidelines for Determining Significance and Report Format and Content Requirements—Air Quality.
March 19.
22 South Coast Air Quality Management District (SCAQMD). 2015. SCAQMD Air Quality Significance Thresholds. March. Website:
http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysis-handbook. Accessed December 3, 2018.
17
project emissions were evaluated based on the quantitative emission thresholds
established by the SCAQMD.
Maximum Incremental Cancer Risk > = 10 in 1 million
Hazard Index (project increment) > = 1.0
A significant impact would occur if a project’s impacts exceeded any of these
thresholds.
Estimation of Cancer Risks
The California Office of Environmental Health Hazard Assessment (OEHHA) has
developed Risk Assessment Guidelines for estimating cancer risks that provide
adjustment factors that emphasize the increased sensitivities and susceptibility of
human to exposures to TACs.23 The recommend method for the estimation of cancer
risk is shown in the equations below for the duration of the construction time period:
Cancer Risk = CDPM x Inhalation Exposure Factor (EQ-1)
Where:
Cancer Risk = Total individual excess cancer risk defined as the cancer
risk a hypothetical individual faces if exposed to carcinogenic emissions
from a particular source for specified exposure durations; this risk is
defined as an excess risk because it is above and beyond the background
cancer risk to the population; cancer risk is expressed in terms of risk
per million exposed individuals.
CDPM = Period average DPM air concentration calculated from the air
dispersion model in µg/m3
Inhalation is the most important exposure pathway to impact human health from DPM
and the inhalation exposure factor is defined as follows:
Inhalation Exposure Factor = CPF x EF x ED x DBR x AAF/AT (EQ-2)
Where:
CPF = Inhalation cancer potency factor for the TAC: 1.1 (mg/kg-day)-1 for DPM
EF = Exposure frequency: 350 (days/year)
ED = Exposure duration (2 years of construction)
AT = Averaging time period over which exposure is averaged (days)
AAF = set of age-specific adjustment factors that include age sensitivity
factors (ASF), daily breathing rates (DBR), and time at home factors (TAH)
23 California Office of Environmental Health Hazard Assessment (OEHHA). Air Toxics Hot Spots Program—Risk Assessment
Guidelines. Guidance Manual for Preparation of Health Risk Assessments. February 2015.
18
The OEHHA recommended values for the various cancer risk parameters shown in
Equation 2 are shown in Table 5.
Table 5: Exposure Assumptions for Cancer Risk
Receptor Type
Exposure Frequency Exposure Duration (years)
Age Sensitivity Factors (ASF)
Time at Home Factor (TAH)(1) (percent)
Daily Breathing Rate(2) (DBR) (L/kg-day) Hours/day Days/year
Sensitive/Residential
3rd Trimester 24 350 0.25 10 100 361
0–2 years 24 350 2 10 100 1,090
3–16 years 24 350 2 3 100 572
17-30 years 24 350 2 1 100 261
Notes:
(1) TAH factors recommended by the SCAQMD
(2) The DBR recommended by the SCAQMD are the 95th percentile rate for sensitive/residential receptors 0 to 2 years (L/kg-day) = liters per kilogram body weight per day
Sources of Current OEHHA Guidance: California Office of Environmental Health Hazard Assessment (OEHHA). 2015. Air Toxics Hot Spots Program-Risk Assessment Guidelines. February. Website: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf. Accessed November 6, 2019.
South Coast Air Quality Management District (SCAQMD). 2015. Fact Sheet for Applying CalEEMod to Localized Significance Thresholds. Website: http://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significance-thresholds/caleemod-guidance.pdf?sfvrsn=2. Accessed November 6, 2019.
Source: Appendix A.
Estimation of Non-Cancer Hazards
An evaluation of the potential non-cancer effects of chronic chemical exposures was
also conducted. Adverse health effects are evaluated by comparing the annual receptor
concentration of each chemical compound with the appropriate REL. To calculate the
hazard index, each chemical concentration or dose is divided by the appropriate toxicity
REL. For compounds affecting the same toxicological endpoint, this ratio is summed.
Where the total equals or exceeds 1, a health hazard is presumed to exist.
To quantify non-carcinogenic impacts, the hazard index approach was used.
HI = Cann/REL (EQ-3)
Where:
HI = chronic hazard index
Cann = annual average concentration of TAC as derived from the air
dispersion model (g/m3)
REL = reference exposure level above which a significant impact is
assumed to occur (g/m3)
For purposes of this assessment, the TAC of concern is DPM for which the OEHHA
has defined a chronic non-cancer REL for DPM of 5 micrograms per cubic meter
19
(g/m3). The principal toxicological endpoint assumed in this assessment was through
inhalation.
Air Dispersion Modeling—Construction
An air dispersion model is a mathematical formulation used to estimate the air quality
impacts at specific locations (receptors) surrounding a source of emissions given the
rate of emissions and prevailing meteorological conditions. The air dispersion model
applied in this assessment was the American Meteorological Society/Environmental
Protection Agency Regulatory Model (AERMOD Version 18081) air dispersion model.
Specifically, the AERMOD model was used to estimate levels of air emissions at
sensitive receptor locations from the project’s construction PM10 exhaust emissions.
The use of the AERMOD model provides a refined methodology for estimating
construction impacts by utilizing long-term measured, representative meteorological
data for the project site, construction area, and a representative construction schedule.
The air dispersion model assessment used meteorological data from the Brown Field
Municipal Airport monitoring station for the years 2009–2013. Sensitive receptors
were placed at locations of existing residences. All the receptors were placed within the
breathing zone at zero meters above ground level.24
The emissions from the on-site source were represented in the AERMOD model as an
area source, and the emissions from the off-site source were represented as line volume
source. Construction was assumed to take place on an 8-hour per day/5 days per week
basis for the years 2019 and 2020.
Health Risk Assessment
The results of the health risk assessment prepared for the project construction, for
cancer risks, and long-term chronic hazards are summarized below. Air dispersion
modeling was utilized to assess the project’s potential health risks. Exhaust emissions
of DPM were estimated using CalEEMod, Version 2016.3.2. Table 6 summarizes the
emission rates of unmitigated DPM (PM10 exhaust) and mitigated DPM emission rates
with Tier IV Final off-road engines.
Table 6: DPM Construction Emissions
Year
On-site DPM
(grams/m2-sec)
Off-site DPM
(grams/sec)
Annual Construction Emissions (Unmitigated)
2019 8.29E-07 6.47E-06
2020 5.83E-07 1.13E-05
24 South Coast Air Quality Management District (SCAQMD). Final Localized Significance Threshold Methodology. Revised July 2008.
Page 15.
20
Year On-site DPM (grams/m2-sec) Off-site DPM (grams/sec)
Annual Construction Emissions (Tier IV Mitigation)
2019 2.79E-08 6.47E-06
2020 2.18E-08 1.13E-05
Source: CalEEMod and FCS; see Appendix A.
The sensitive receptor that has the highest cancer risks during project construction is
located 75 feet from the east edge of project site, at the northwest corner of Villa Marina
Apartment. As noted in Table 7, the proposed project’s construction activities would
result in cancer risk that exceed the significance thresholds prior to the implantation of
mitigation measures. Therefore, mitigation would be required to reduce the health risk
impacts during the construction phase of development. Specifically, Mitigation
Measure (MM) AIR-1 is required to reduce impacts to the maximum extent feasible.
MM AIR-1 requires Tier IV Final engines for all on-site equipment greater than 50
horsepower to be used during construction of the project. The mitigated health risks are
shown in Table 8.
Table 7: Estimated Health Risks and Hazards during Construction—Unmitigated
Source Cancer Risk (risk per million) Chronic Non-Cancer Hazard Index(2)
Risks and Hazards at the Maximum Impacted Sensitive
Receptor (MIR): Infants(1) 93 0.1
Risks and Hazards at the MIR: Child(1) 13 0.1
Risks and Hazards at the MIR: Adult(1) 2 0.1
Significance Threshold 10 1
Exceeds Individual Source Threshold? YES
(Infants and children) No
Notes:
(1) Maximum impacted sensitive receptor is a residence located approximately 75 feet from the east edge of the project site, at the
northwest corner of Villa Marina Apartment Community.
(2) Chronic non-cancer hazard index was estimated by dividing the maximum annual DPM concentration (as PM10 exhaust) by the REL
of 5 g/m3.
Source: AERMOD and FCS; refer to Appendix A.
Table 8: Estimated Health Risks and Hazards during Construction—Tier IV Mitigated
Source
Cancer Risk
(risk per million)
Chronic
Non-Cancer Hazard Index(2)
Risks and Hazards at the MIR: Infants(1) 2.9 <0.01
Risks and Hazards at the MIR: Child (1) 0.4 <0.01
Risks and Hazards at the MIR: Adult (1) 0.1 <0.01
Significance Threshold 10 1
21
Source Cancer Risk (risk per million) Chronic Non-Cancer Hazard Index(2)
Exceeds Individual Source Threshold? No No
Notes:
(1) Maximum impacted sensitive receptor is a residence located approximately 75 feet from the east edge of the project site, at the
northwest corner of Villa Marina Apartment Community.
(2) Chronic non-cancer hazard index was estimated by dividing the maximum annual DPM concentration (as PM10 exhaust) by the REL
of 5 g/m3.
Source: AERMOD and FCS; refer to Appendix A.
As shown above, the proposed project’s construction activities would not exceed the
recommended thresholds of significance with implementation of mitigation. Therefore,
impacts would be less than significant with mitigation.
Toxic Air Pollutants—Operation
Common sources of TACs include distribution centers, large gas dispensing stations,
manufacturing warehouses and high-traffic freeways. The majority of project-related
trips during operations would consist of residents and visitors traveling to and from the
project site, predominately in passenger vehicles. Because most passenger vehicles are
gasoline-combusted (approximately 99 percent of all passenger vehicles), the proposed
project would not generate significant amounts of DPM emissions during operation.
Thus, impacts would be less than significant.
Carbon Monoxide Hotspots
Localized high levels of CO (CO “hotspots”) are associated with traffic congestion and
idling or slow-moving vehicles. A screening analysis can determine if a project has the
potential to contribute to a CO hotspot. The screening criteria identify when site-
specific CO dispersion modeling is not necessary. Although Chula Vista does not have
specific guidelines or criteria, the County of San Diego has developed the screening
standards for CO concentrations, as shown below:25
CO “hotspots,” or pockets where the CO concentration exceeds
the NAAQS and/or CAAQS, have been found to occur only at
signalized intersections that operate at or below level of service
(LOS) E with peak-hour trips for that intersection exceeding
3,000 trips. Therefore, any project that would place receptors
within 500 feet of a signalized intersection operating at or
below LOS E (peak-hour trips exceeding 3,000 trips) must
conduct a “hotspot” analysis for CO. Likewise, projects that
will cause road intersections to operate at or below a LOS E
(with intersection peak-hour trips exceeding 3,000) will also
have to conduct a CO “hotspot” analysis.
25 County of San Diego. March 2007. Guidelines for Determining Significance and Report Format and Content Requirements—Air Quality.
Website: https://www.sandiegocounty.gov/content/dam/sdc/pds/ProjectPlanning/docs/AQ-Guidelines.pdf. Accessed February 25, 2020.
22
None of the intersections (e.g., Industrial Boulevard/Interstate 5 [I-5] northbound
ramps) operate with volumes that would exceed 3,000 peak-hour trips.
The maximum peak-hour traffic volume for the Existing Plus Project and 2025
Condition scenarios occur at Broadway/Moss Street, with 2,698 and 2,772 trips during
PM peak-hour, respectively. None of the intersections has a peak-hour traffic volume
that exceeds the 3,000 trips; thus, the impacts would be less than significant.
The maximum peak-hour traffic volume for 2045 also occurs at Broadway/Moss Street
with a traffic volume of 3,276 trips during PM peak-hour. Although the peak-hour
traffic volume exceeds the 3,000 trips limit, but the Broadway/Moss Street intersection
is calculated would operate at a LOS D. Therefore, the screening criteria are met, and
the proposed project would not result in the potential for a CO hotspot. Impacts would
be less than significant.
(d) Less than significant impact. The impact of an odor is dependent on interacting
factors such as frequency (how often), intensity (strength), duration (in time),
offensiveness (unpleasantness), location, and sensory perception. While offensive
odors rarely cause any physical harm, they still can be very unpleasant, leading to
considerable distress and often generating citizen complaints to local governments and
regulatory agencies.
Odors would be generated from vehicles and construction equipment exhaust emissions
during construction of the proposed project. Odors produced during construction would
be attributable to concentrations of unburned hydrocarbons from tailpipes of
construction equipment and architectural coatings. Such odors are temporary and
generally occur at magnitudes that would not affect substantial numbers of people.
Therefore, the construction of the project would not result in other emissions (such as
those leading to odors) adversely affecting a substantial number of people. Impacts
would be less than significant.
The proposed project would develop residential units that are not typical odor-
generating land uses. Land uses typically considered associated with odors include
wastewater treatment facilities, waste-disposal facilities, or agricultural operations.
Minor sources of odors, such as exhaust from mobile sources, are not typically
associated with numerous odor complaints, but are known to have temporary and less
concentrated odors. Therefore, the proposed project’s operational activities would not
result in other emissions (such as those leading to odors) adversely affecting a
substantial number of people. Impacts would be less than significant.
Mitigation Measures:
MM AIR-1 Prior to the issuance of any demolition or grading permit, the Project
Applicant shall demonstrate to the satisfaction of the City Development
23
Services Department that all off-road construction equipment that will be used
on the project site in excess of 50 horsepower will be equipped with engines
meeting the United States Environmental Protection Agency (EPA) Tier IV
Final off-road engine emission standards. This mitigation measure shall be
included on the grading plan.
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
IV. Biological Resources
Would the project:
a) Have a substantial adverse effect, either directly or
through habitat modifications, on any species
identified as a candidate, sensitive, or special status
species in local or regional plans, policies, or
regulations, or by the California Department of
Fish and Game or U.S. Fish and Wildlife Service?
b) Have a substantial adverse effect on any riparian
habitat or other sensitive natural community
identified in local or regional plans, policies, and
regulations or by the California Department of
Fish and Game or U.S. Fish and Wildlife Service?
c) 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?
d) 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 wildlife
nursery sites?
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community
Conservation Plan, or other approved local,
regional, or state habitat conservation plan?
Comments:
The following analysis is based on the Biological Resources Summary Memorandum for the
676 Moss Street Project, Chula Vista, California, prepared by FCS on January 17, 2020. A site
visit was conducted on January 2, 2020, to confirm the findings and conclusions of the desktop-
level analysis for the proposed project, which is discussed in detail in the Biological Resources
Summary Memorandum. The memorandum is included as Appendix B of this Draft IS/MND.
24
(a) Less than significant with mitigation incorporated.
The project site has been developed with buildings and associated paved lots since the
1960s. The project site is located in an urbanized area of the City of Chula Vista and is
zoned for industrial uses. For these reasons, the habitat type associated with the
proposed project site is identified as Urban/Developed. When the environmental
analysis for the project commenced in November 2018, activities on the project site
included heavy machinery rental and sales yard, storage container rental, boat repair,
steel surface preparation equipment rental, and sales of specialty abrasives and
sandblast media.
The project site is surrounded by man-made improvements and development, including
light industrial uses to the north; light industrial uses and residential dwellings to the east;
Moss Street and residential dwellings to the south; and light industrial uses, an at-grade
rail crossing, and Industrial Boulevard to the west. Landscaping on-site is almost non-
existent, with two small clusters of trees, one within the northwest portion of the project
site adjacent to the railroad right-of-way, and the other along the southeastern boundary
of the project site (Exhibit 9).
Special-status plant and wildlife species with the potential to occur on-site or in the
project vicinity were determined from a search of the California Natural Diversity
Database (CNDDB);26 the United States Fish and Wildlife Service (USFWS)27
Information for Planning and Consultation System (IPaC) list of special-status species
that are known to occur in the project vicinity; and professional expertise. A complete list
of recorded occurrences of special-status species within 1 mile of the project site is
appended to the Biological Resources Summary Memorandum (see Attachment D of
Appendix B). In addition, Table 9 and Table 10 identify the special-status plant and
wildlife species recorded within 1 mile of the project site, their preferred habitat, and the
potential for these species to occur on the project site.
26 California Department of Fish and Wildlife (CDFW). 2019. California Natural Diversity Database (CNDDB). Accessed September 4, 2019.
27 United States Fish and Wildlife Service (USFWS). 2019. Information for Planning and Consultation. Website:
https://ecos.fws.gov/ipac/. Accessed September 4, 2019.
25
Table 9: Special-status Plant Species Recorded within 1 Mile of the Proposed Project
Scientific Name Common Name
Status
Habitat Description4 Potential to Occur and Rationale Included in Impact Analysis USFWS1 CDFW2 CNPS3
Ambrosia monogyra Singlewhorl burrobrush — — 2B.2 Perennial shrub found in chaparral or Sonoran desert scrub Blooming period: August–November 10–500 m.
Unlikely to Occur: no suitable habitat is present within the project site. No
Acmispon prostratus Nuttall’s acmispon — — 1B.1 Annual herb found in coastal dunes and coastal scrub (sandy). Blooming period: March–June 0–10 m.
Unlikely to Occur: no suitable habitat or suitable soils are present within the project site.
No
Isocoma menziesii var.
decumbens Decumbent goldenbush
— — 1B.2 Dicot shrub found in coastal scrub and chaparral on sandy soils; often found in disturbed sites. Blooming period: April–November 10–135m.
Unlikely to Occur: no suitable habitat or suitable soils are present within the project site.
No
Nemacaulis denudata var.
denudata Coast woolly-heads
— — 1B.2 Dicot annual herb found in coastal dunes. Blooming period: April–September 0–100m.
Unlikely to Occur: no suitable habitat is present within the project site. No
Stemodia durantifolia Purple stemodia — — 2B.1 Perennial herb found in Sonoran desert scrub (often mesic, sandy) Blooming period: April–December 180–300 m.
Unlikely to Occur: no suitable habitat or suitable soils are present within the project site.
No
Suaeda esteroa Estuary seablite — — 1B.2 Dicot perennial herb found in marshes and swamps. Prefers coastal salt marshes in clay, silt, and sand substrates. Blooming period: May–October 0–5m.
Unlikely to Occur: no suitable habitat or suitable soils are present within the project site.
No
Code Designations
1 Federal Status: 2020 USFWS Listing 2 State Status: 2020 CDFW Listing 3 CNPS: 2020 CNPS Listing
FE = Listed as endangered under FESA FT = Listed as threatened under FESA FC = Candidate for listing (threatened or endangered)
under FESA FD = Delisted in accordance with FESA — = Not federally listed
SE = Listed as endangered under CESA ST = Listed as threatened under CESA SSC = Species of Special Concern as identified by CDFW CFP = Listed as fully protected under Fish and Game
Code (FGC) CR = Species identified as rare by CDFW
— = Not State listed
1A = Plants species that presumed extinct in California. 1B = Plant species that are rare, threatened, or endangered in California and
elsewhere. List 2 = Plant species that are rare, threatened, or endangered in California, but more
common elsewhere. Blooming period: Months in parentheses are uncommon.
4 Habitat description: Habitat description adapted from CNDDB (CDFW 2015) and CNPS online inventory (CNPS 2015).
26
Table 10: Special-status Wildlife Species Recorded within 1 Mile the Proposed Project
Scientific Name Common Name
Status
Habitat Description3 Potential to Occur and Rationale Included in Impact Analysis USFWS1 CDFW2
Invertebrates
Cicindela gabbii
Western tidal-flat beetle
— — Inhabits estuaries and mudflats along the coast of Southern
California. Generally is found on dark-colored mud in the
lower zone; occasionally found on dry saline flats of estuaries.
Unlikely to Occur: no suitable habitat is present
within the project site.
No
Cicindela latesignata
Western beach tiger beetle
— — Inhabits mudflats and beaches in coastal Southern
California.
Unlikely to Occur: no suitable habitat is present
within the project site.
No
Reptiles
Anniella stebbinsi
Southern California legless
lizard
— SSC Occurs in moist warm loose soil with plant cover. Moisture
is essential. Occurs in sparsely vegetated areas of beach
dunes, chaparral, pine-oak woodlands, desert scrub, sandy
washes, and stream terraces. Often can be found under
leaf litter, rocks, boards, driftwood, and logs.
Unlikely to Occur: no suitable habitat is present
within the project site. No
Masticophis fuliginosus
Baja California coachwhip
— SSC Inhabits scrub, coastal sand dunes, rocky arroyos, thorn
forests, marshlands, and sandy flats.
In California, found mainly in open areas such as
grassland, shrubland, and coastal sand dunes.
Unlikely to Occur: no suitable habitat is present
within the project site. No
Arizona elegans occidentalis
California glossy snake
— SSC Inhabits arid scrub, rocky washes, grasslands, chaparral.
Appears to prefer microhabitats of open areas and areas
with soil loose enough for easy burrowing.
Unlikely to Occur: no suitable habitat is present
within the project site.
No
Chelonia mydas
green turtle
FT — Inhabits the shallow waters of lagoons, bays, estuaries,
mangroves, eelgrass and seaweed beds.
Prefers areas with abundant aquatic vegetation, such as
pastures of sea grasses and algae, in shallow, protected
water.
Unlikely to Occur: no suitable habitat is present
within the project site. Project site is not located
on or adjacent to beaches or the ocean
No
Phrynosoma blainvillii
Coast horned lizard
— SSC Frequents a wide variety of habitats, most common in
lowlands along sandy washes with scattered low bushes.
Requires open areas for sunning, bushes for cover,
patches of loose soil for burial, and abundant supply of ants
and other insects.
Unlikely to Occur: no suitable habitat is present
within the project site.
No
27
Table 10 (cont.): Special-status Wildlife Species Recorded within 1 Mile the Proposed Project
Scientific Name Common Name
Status
Habitat Description3 Potential to Occur and Rationale Included in Impact Analysis USFWS1 CDFW2
Birds
Charadrius alexandrinus
nivosus Western snowy plover
FT MBTA SSC Found in sandy beaches, salt pond levees, and shores of large alkali lakes. Requires sandy, gravelly, or friable soils for nesting.
Unlikely to Occur: no suitable habitat is present within the project site. No
Pandion haliaetus Osprey — MBTA FP FGC Inhabits ocean shore, bays, freshwater lakes, and larger streams. Builds large nests in tree tops within 15 miles of a good fish-producing body of water.
Low Potential to Occur: no suitable nesting habitat is present within the project site. Species was observed flying overhead during the January 2, 2020, site survey.
No
Passerculus sandwichensis
beldingi Belding’s savannah sparrow
— MBTA SE Inhabits coastal salt marshes from Santa Barbara County south through San Diego County. Nests in saltwort (Salicornia spp.) on and around margins of tidal flats.
Unlikely to Occur: no suitable habitat is present within the project site. No
Rallus longirostris levipes Light-footed clapper rail FE SE FP Found in salt marshes traversed by tidal sloughs, where cordgrass (Spartina spp.) and pickleweed (Salicornia spp.) are the dominant vegetation. Requires dense vegetation growth for nesting and escape cover. Feeds on mollusks and crustaceans.
Unlikely to Occur: no suitable nesting or foraging habitat is present within the project site. No
Mammals
Nyctinomops femorosaccus Pocketed free-tailed bat — SSC Found in a variety of arid areas in southern California; pine-juniper woodlands, desert scrub, palm oasis, desert wash, or desert riparian habitat. Prefers rocky areas with high cliffs.
Unlikely to Occur: no suitable habitat is present within the project site. No
Code Designations
1 Federal Status: 2020 USFWS Listing 2 State Status: 2020 CDFW Listing
ESU = Evolutionary Significant Unit is a distinctive population.
FE = Listed as endangered under FESA.
FT = Listed as threatened under FESA.
FC = Candidate for listing (threatened or endangered) under FESA.
FD = Delisted in accordance with FESA.
FPD = Federally Proposed to be Delisted.
MBTA = protected by the Migratory Bird Treaty Act
— = Not federally listed
SE = Listed as endangered under CESA.
ST = Listed as threatened under CESA.
SSC = Species of Special Concern as identified by the CDFW.
FP = Listed as fully protected under FGC.
CFG = FGC =protected by FGC 3503.5
CR = Rare in California.
— = Not State listed
3 Habitat description: Habitat description adapted from CNDDB (CDFW 2020a).
28
An FCS Biologist visited the project site on January 2, 2020, to evaluate the potential for
sensitive biological resources to occur on-site. Wildlife observed within the surrounding
area consists of species commonly found in an urban setting. Species observed during
the FCS January 2020 site visit included, Anna’s hummingbird (Calypte anna), rock
dove (Columba livia), common raven (Corvus corvax), American crow (Corvus
brachyrhynchos), California gull (Larus californicus), osprey (Pandion haliaetus), and
western fence lizard (Sceloporus occidentalis).
As discussed in Appendix B, Biological Resources Summary Memorandum, due to the
lack of suitable habitat present on-site, the project site is unlikely to contain any species
identified as candidate, sensitive, or special-status species in local or regional plans,
policies, or regulations, or by the California Department of Fish and Wildlife (CDFW)
or the USFWS. Despite the highly urbanized setting of the project site, there is potential
for migratory birds and raptors protected under the Migratory Bird Treaty Act (MBTA)
to utilize the few trees that are present on-site or immediately adjacent to the site for
nesting. If construction is scheduled to occur during the nesting season (generally March
1–August 31), FCS recommends preconstruction surveys be conducted prior to
construction in order to ensure that no nesting birds are adversely affected due to
construction of the proposed project, as described in MM BIO-1. With the
implementation of MM BIO-1, potential impacts to nesting birds from project
implementation would be reduced to a less than significant level.
(b) No impact. According to the USFWS National Wetlands Mapper,28 no known
riparian habitat or other locally or regionally designated sensitive natural communities
exist on or adjacent to the project site. As a result, no natural ecological communities
are found on-site or in the surrounding area and no impact would occur. FCS confirmed
there are no sensitive habitats found on the project site during the January 2, 2020, site
visit. As such, the proposed project would have no impact on any riparian habitat or
other sensitive natural community identified in local or regional plans, policies, and
regulations, or by the CDFW or USFWS.
(c) No impact. According to the USFWS National Wetlands Mapper, no wetlands
occur on the project site; therefore, the proposed project is not anticipated to have direct
or indirect impacts on State or federally protected wetlands as defined by Section 404
of the federal Clean Water Act.29 The project site is previously developed and located
in an urbanized area of the City of Chula Vista, surrounded by industrial and residential
development. FCS confirmed there are no wetlands on the project site during the
January 2020 site visit. As such, the proposed project would have no substantial adverse
effect on federally protected wetlands through direct removal, filling, hydrological
interruption, or other means.
28 United States Fish and Wildlife Service (USFWS). 2019. National Wetlands Inventory. Website:
https://www.fws.gov/wetlands/data/mapper.html. Accessed December 17, 2018.
29 United States Fish and Wildlife Service. 2019. National Wetlands Inventory. Website:
https://www.fws.gov/wetlands/data/mapper.html. Accessed December 12, 2019.
29
(d) No impact. The project site is located in an urbanized area of the City of Chula
Vista and is surrounded by industrial and residential development. There is no native
habitat on the project site, nor does the project site function as part of a wildlife corridor
due to its urbanized and developed condition. As such, the proposed project is not
anticipated to interfere substantially with or impede (1) the movement of any resident
or migratory fish or wildlife species, (2) established resident or migratory wildlife
corridors, or (3) the use of wildlife nursery sites. No impact would occur.
(e) No impact. The project site is located within a developed urban area and contains
ornamental trees (Exhibit 9). The project site does not contain any protected biological
resources or tree species that are considered sensitive. The City of Chula Vista has a
Multiple Species Conservation Program (MSCP) Subarea Plan, stemming from the
County of San Diego’s MSCP; however, the project site is not located within the City
of Chula Vista MSCP Subarea Plan.30
Additionally, the City does not have a tree preservation policy or ordinance; however,
Chapter 15.04: Excavation, Grading, Clearing, Grubbing, and Fills, of the Chula Vista
Municipal Code31 does mention that the City of Chula Vista encourages, insofar as
practical, retaining the maximum number of existing trees. As shown in Exhibit 7, the
proposed project would include more trees than are currently located on the project site,
including trees around the boundary of the project site and within the interior.
Additionally, the proposed project would proceed through the City’s plan check
process, during which time the Project Applicant would work with City Staff to ensure
compliance with Chapter 15.04 of the Chula Vista Municipal Code. As such, the
proposed project would not conflict with any local policies or ordinances protecting or
preserving biological resources and there would be no impact.
(f) No impact. As mentioned above in Impact 2.4(e), the proposed project will not
impact an adopted or approved local, regional, or state habitat conservation plan
because the proposed project is located in an urban area. The construction and operation
of the proposed project will not affect any designated San Diego County Significant
Ecological Area since the proposed project is not located within an MSCP area and is
not located in either the San Diego County or the City of Chula Vista MSCP Subarea.
As such, there would be no such impacts from the proposed project.
Mitigation Measures:
MM BIO-1 Construction activities that occur during the nesting season (generally March
1 to August 31) could disturb nesting sites for birds protected by the
Migratory Bird Treaty Act (MBTA) and Fish and Game Code. No action is
30 City of Chula Vista. 2003. City of Chula Vista MSCP Subarea Plan. Website:
https://www.chulavistaca.gov/home/showdocument?id=7106. Accessed November 6, 2019.
31 City of Chula Vista. 2019. City of Chula Vista Municipal Code. Title 15, Buildings and Construction. Chapter 15.04: Excavation,
Grading, Clearing, Grubbing and Fills. Website: https://chulavista.municipal.codes/CVMC/15.04. Accessed November 6, 2019.
30
necessary if no active nests are found or if construction occurs during the non-
breeding season (generally September 1 through February 14).
Implementation of the following avoidance and minimization measures would
reduce impacts to nesting birds to a less than significant level.
To prevent impacts to MBTA-protected birds, nesting raptors, and their
nests, removal of trees will be limited to only those necessary to construct
the proposed project.
If any tree removal is necessary, then it will occur outside the nesting
season, between September 1 and February 14. If trees cannot be removed
outside the nesting season, pre-construction surveys will be conducted 3
days prior to tree removal to verify the absence of active nests.
If an active nest is located during pre-construction surveys, the United
States Fish and Wildlife Service (USFWS) and/or the California
Department of Fish and Wildlife (CDFW) (as appropriate) shall be notified
regarding the status of the nest. Construction activities shall be restricted as
necessary to avoid disturbance of the nest until it is abandoned or the
agencies deem disturbance potential to be minimal. Restrictions may
include the establishment of exclusion zones (no ingress of personnel or
equipment at a minimum radius of 100 feet around an active raptor nest and
a 50-foot radius around an active migratory bird nest) or alteration of the
construction schedule.
A Qualified Biologist will delineate the buffer using Environmentally
Sensitive Area (ESA) fencing, pin flags, and or yellow caution tape. The
buffer zone will be maintained around the active nest site(s) until the young
have fledged and are foraging independently.
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
V. Cultural and Tribal Cultural Resources
Would the project:
a) Cause a substantial adverse change in the
significance of a historical resource as defined in
Section 15064.5?
b) Cause a substantial adverse change in the
significance of an archaeological resource pursuant
to Section 15064.5?
c) Disturb any human remains, including those
interred outside of formal cemeteries?
31
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
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:
d) Listed or eligible for listing in the California
Register of Historical Resources, or in a local
register of historical resources as defined in
Public Resources Code Section 5020.1(k), or
e) A resource determined by the lead agency, in its
discretion and supported by substantial evidence,
to be significant pursuant to criteria set forth in
subdivision (c) of Public Resources Code
Section 5024.1. In applying the criteria set forth
in subdivision (c) of Public Resource Code
Section 5024.1, the lead agency shall consider
the significance of the resource to a California
Native American tribe.
Comments:
The project site lies in an urbanized area of the City of Chula Vista. Currently and historically,
the site has been used for industrial purposes; therefore, the ground surface and topsoil has
been routinely disturbed by the construction and paving of the existing surfaces, existing
industrial uses, and vehicular traffic.
The proposed project is expected to disturb the majority of the ground surface area, (±) 6.49
acres between 5–12 feet of depth, depending on the portion of the site. Project grading is
expected to include 15,000 cubic yards of raw earthwork to be removed as these soils are not
suitable for construction, and 10,000 cubic yards of imported earthwork fill.
The following analysis is based on the Phase I Cultural Resources Assessment (Phase I CRA)
prepared by FCS on November 7, 2019, and the Historical Resources Evaluation Report
prepared by GPA Consulting in January 2020. The Phase I CRA and Historical Resources
Evaluation Report are included as Appendices C.1 and C.2 of the Draft Initial Study,
respectively.
Environmental Evaluation
Cultural Resources
(a) Less than significant impact. CEQA Guidelines Section 15064.5 defines “historic
resources” as resources listed in the California Register of Historical Resources
(CRHR), or determined to be eligible by the California Historical Resources
Commission for listing in the CRHR. The criteria for eligibility are generally set by the
Historic Sites Act of 1935, which established the National Register of Historic Places
32
(NRHP) and which recognizes properties that are significant at the national, State, and
local levels. To be eligible for listing in the CRHR, a district, site, building, structure,
or object must possess integrity of location, design, setting, materials, workmanship,
feeling and association relative to American history, architecture, archaeology,
engineering, or culture.32 In addition, unless the property possesses exceptional
significance, it must be at least 45 years old to be eligible.
According to the Historic Resources Evaluation Report prepared for the proposed
project and a review of historic aerials, there appears to be two structures within the
project boundary that have reached a sufficient age to be evaluated as potential
historical resources.33 Based on the review of historic aerials, Assessor’s records, and
building permits, it was determined that the buildings located on the project site were
completed on October 3, 1969. According to the Historic Resources Evaluation Report,
these buildings on-site are not currently listed under any national, State, or local
landmark or historic district programs, and were not identified during the most recent
historic resources survey of the City in 2012. In addition, due to a lack of historical
significance, these buildings do not qualify for the NRHP, the CRHR, or the Chula
Vista Register of Historical Resources. The recommended California Historical
Resource Status Code for the buildings is 6Z, “ineligible for designation at the national,
state, and local levels through survey evaluation.”
Because the existing buildings do not meet the definition of a historical resource
according to CEQA Guidelines, the proposed project would have no direct impacts on
historical resources. As such, no mitigation is required or recommended.
(b) Less than significant impact with mitigation incorporated. Section 15064.5 of
the CEQA Guidelines defines significant archaeological resources as resources that
meet the criteria for historical resources, as discussed above, or resources that constitute
unique archaeological resources. A project-related significant adverse effect could
occur if a project were to affect archaeological resources that fall under either of these
categories.
The project site has not been the subject of any previous studies, and, therefore, the
cultural resource sensitivity is unknown. As previously discussed, the project site is
completely developed and paved, should any archaeological resources exist on the
project site, they would be beneath the paved surface. Therefore, initial ground
disturbances to the project area does not require archaeological monitoring. Although
the project site is currently developed, there is still the potential for buried and/or
surface prehistoric and historic resources within the project site. Per Senate Bill 18 (SB
18), a notice was sent to the appropriate Native American tribes with jurisdiction over
the project site, however, no consultation was requested. Therefore, implementation of
32 Guidelines for Completing National Register Forms, National Register Bulletin 16. 1986. United States Department of the Interior,
National Park Service. September 30.
33 HistoricAerials.com. 2019. Division of NETROnline.com by Nationwide Environmental Title Research, LLC. (NETR). Website:
https://www.historicaerials.com/. Accessed November 6, 2019.
33
MM CUL-1 is required. MM CUL-1 states that in the event that any evidence of
archaeological resources is encountered, all work within the vicinity of the find should
stop until a qualified Archaeologist can assess the finds and make recommendations.
Any resulting reports by the qualified Archaeologist should be submitted to the South
Coastal Information Center (SCIC) at San Diego State University and appropriate
Native American representatives as identified by the Native American Heritage
Commission (NAHC).
With inclusion of MM CUL-1, potential project impacts to any previously
undiscovered archaeological resources would be reduced to less than significant levels.
(c) Less than significant impact with mitigation incorporated. As discussed above,
there is some potential for archaeological subsurface resources to occur on the project
site. Similarly, there is a possibility that human remains could be interred underneath
the project site. To address this possibility, MM CUL-2 is required. With inclusion of
this measure, potential project impacts regarding inadvertent discovery of human
remains would be reduced to less than significant levels.
Tribal Cultural Resources
Would the project cause a substantial adverse change in the significance of a tribal
cultural resource, defined in Public Resources Code Section 21074 as either a site,
feature, place, cultural landscape that is geographically defined in terms of the size and
scope of the landscape, sacred place, or object with cultural value to a California Native
American tribe, and that is:
(d) No impact. On October 26, 2018, FCS sent a letter to the NAHC in an effort to
determine whether any sacred sites are listed on its Sacred Lands File for the proposed
project. The response from the NAHC was received on December 21, 2018, and it
indicated that the search of the Sacred Lands File was negative for cultural resources.
A list of eight Native American tribal members who may have additional knowledge of
the project area was included with the results. These tribal members were sent letters
on December 26, 2018, asking for any information they might have concerning cultural
resources on or near the project area. As of the date of this report, no responses have
been received. As such, no impacts would occur.
(e) Less than significant impact. On October 26, 2018, FCS sent a letter to the NAHC
in an effort to determine whether any sacred sites are listed on its Sacred Lands File for
the proposed project. The response from the NAHC was received on December 21,
2018, and it indicated that the search of the Sacred Lands File was negative for cultural
resources. A list of eight Native American tribal members who may have additional
knowledge of the project area was included with the results. These tribal members were
sent letters on December 26, 2018, asking for any information they might have
concerning cultural resources on or near the project area. As of the date of this report,
no responses have been received. As such, impacts would be less than significant.
34
Mitigation Measures:
MM CUL-1 Prior to the issuance of any demolition or grading permit, the Project
Applicant shall demonstrate to the satisfaction of the City Development
Services Department that a program related to potential archaeological
resources uncovered during construction activities on-site has been
established, the program shall include that:
1. The Project Applicant shall retain a qualified professional Archaeologist
approved by the City to be present and monitor all ground-disturbing
activities;
2. The Archaeologist shall halt work in the immediate area in the event that
archaeological resources are identified until the Archaeologist has
evaluated the find and determined if the find is a “unique cultural resource”
as defined in Section 21083.2 (g) of the CEQA statutes;
3. The Project Applicant shall inform the City Development Services
Department of the find;
4. If this determination is positive, the scientifically consequential
information shall be fully recovered by the Archaeologist;
5. The Project Applicant shall stop work in the immediate location of the find
until information recovery has been completed and a report has been filed
with the City; the SCIC at San Diego State University; and, appropriate
Native American representatives;
6. The Project Applicant may continue outside the area of the find; and,
7. The City Development Services Department shall ensure compliance.
MM CUL-2 Prior to the issuance of any demolition or grading permit, the Project
Applicant shall demonstrate to the satisfaction of the City Development
Services Department that a program related to any human remains that might
be encountered during ground-disturbing activities on-site has been
established, the program shall include:
1. The Project Applicant shall halt work in the immediate area of the find;
2. The Project Applicant shall contact the San Diego County Coroner, City
Development Services Department, and Sherriff’s Department;
3. The Project Applicant shall be responsible for ensuring that the Native
American Heritage Commission (NAHC) and the appropriate Native
American representatives are contacted and that the NAHC contacts the
most appropriate most likely descendant (MLD) as maybe directed by
either the San Diego County Coroner, City Development Services
Department, or Sherriff’s Department;
4. The City Development Services Department shall direct the treatment of
the remains pursuant to Coroner and MLD recommendations.
35
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
VI. Energy
Would the project:
c) Result in potentially significant environmental
impact due to wasteful, inefficient, or
unnecessary consumption of energy resources,
during project construction or operation?
d) Conflict with or obstruct a State or local plan
for renewable energy or energy efficiency?
Comments:
(c) The County’s Guidelines for Determining Significance do not explicitly address
energy. Therefore, Appendix F of the CEQA Guidelines was used to assess the proposed
project’s impacts. Appendix F does not prescribe a threshold for the determination of
significance. Rather, Appendix F focuses on reducing and minimizing inefficient,
wasteful, and unnecessary consumption of energy. Therefore, a significant impact would
occur if the project would result in the wasteful, inefficient or unnecessary use of energy.
Construction
Less than significant impact. During construction, the proposed project would result
in energy consumption through the combustion of fossil fuels in construction vehicles,
worker commute vehicles, and construction equipment, and the use of electricity for
temporary buildings, lighting, and other sources. Fossil fuels used for construction
vehicles and other energy-consuming equipment would be used during demolition,
grading, paving, and building construction. The types of equipment could include
gasoline- and diesel-powered construction and transportation equipment, including
trucks, bulldozers, frontend loaders, forklifts, and cranes. Based on CalEEMod
estimations within the modeling output files used to estimate greenhouse gas (GHG)
emissions associated with the proposed project, construction-related vehicle trips
would result in approximately 582,063 VMT, and consume an estimated 37,016 gallons
of gasoline and diesel combined during the construction phase (Appendix I).34
Limitations on idling of vehicles and equipment and requirements that equipment be
properly maintained would result in fuel savings. California Code of Regulations Title
13, Sections 2449(d)(2) and 2485, limit idling from both on-road and off-road diesel-
powered equipment and are enforced by the ARB. In addition, given the cost of fuel,
34 Construction VMT was calculated based on CalEEMod estimations of worker, vendor, and hauling trip days and trip length per
construction phase. Fuel economy values were calculated based on output data from the Emissions Factors Model (EMFAC) database
for worker, vendor, and hauling vehicle categories (ARB 2019). Complete calculations used to estimate fuel consumption are
included in Appendix I.
36
contractors and owners have a strong financial incentive to avoid wasteful, inefficient,
and unnecessary consumption of energy during construction.
Other equipment could include construction lighting, field services (office trailers), and
electrically driven equipment such as pumps and other tools. As on-site construction
activities would be restricted to the daytime hours between 7:00 a.m. and 7:00 p.m., it is
anticipated that the use of construction lighting would be minimal. Singlewide mobile
office trailers, which are commonly used in construction staging areas, generally range
in size from 160 square feet to 720 square feet. A typical 720-square-foot office trailer
would consume approximately 12,195 kilowatt hours (kWh) during the approximately
15-month construction phase (Appendix I). Due to the temporary nature of construction
and the financial incentives for developers and contractors to use energy-consuming
resources in an efficient manner, the construction phase of the proposed project would
not result in wasteful, inefficient, and unnecessary consumption of energy. As such,
impacts would be less than significant.
Operation
Less than significant impact. The operational phase of the proposed project would
consume energy as part of building operations and transportation activities. Building
operations for the proposed project would involve energy consumption for multiple
purposes including, but not limited to, building heating and cooling, lighting, and
electronics, as well as parking lot lighting. Based on CalEEMod estimations within the
modeling output files used to estimate GHG emissions associated with the proposed
project, building operations, including parking lot lighting, would consume
approximately 605,352 kWh per year (kWh/year) of electricity, and an estimated
1,047,450 kilo-British thermal units per year (kBTU/year) of natural gas (Appendix I).
The proposed project’s building would be designed and constructed in accordance with
California Title 24 energy efficiency standards. These standards, widely regarded as the
most advanced energy efficiency standards, would help reduce the amount of energy
required for lighting, water heating, and heating and air conditioning in buildings and
promote energy conservation.
Operational energy would also be consumed during vehicle trips associated with the
project. Fuel consumption would be primarily related to vehicle use by residents,
employees, and visitors associated with the proposed multi-family residential
development. Based on the estimates contained in the CalEEMod output files, project-
related vehicle trips would result in approximately 3.06 million VMT annually; vehicle
trips associated with the existing industrial land use result in approximately 0.25
million VMT annually. Operational fuel consumption of the proposed project would be
an estimated 123,933 gallons of gasoline and diesel combined on an annual basis; fuel
consumption of the existing industrial land use is an estimated 9,928 gallons of gasoline
and diesel combined on an annual basis (Appendix I).35 Thus, net operational fuel
35 The value for operational VMT comes from the CalEEMod output file included in Appendix A. Average fuel economy was calculated
based on output data from the EMFAC database for all vehicle categories (ARB 2019); see Appendix I for complete calculations.
37
consumption would be an estimated 114,005 gallons of gasoline and diesel combined
on an annual basis.36 The Broadway and Moss Metropolitan Transit System (MTS) 932
bus stop is located 0.4 mile east of the project site, and the Palomar Trolley Center
transit station is located 0.8 mile south of the project site, offering two nearby options
for public transportation to and from the site. For these reasons, transportation fuel
consumption would not be wasteful, inefficient, or unnecessary.
The City of Chula Vista further supports energy conservation through voluntary policies,
measures, and recommendations contained within the City of Chula Vista Vision 2020
General Plan and Climate Action Plan (CAP). General Plan, Chapter 9, Environmental
Element, contains the following policies relevant to this project:37
E 6.7: Encourage innovative energy conservation practices and air quality
improvements in new development and redevelopment projects consistent with the
City’s Air Quality Improvement Plan Guidelines or its equivalent, pursuant to the
City’s Growth Management Program.
E 6.13: Encourage programs and infrastructure to increase the availability and
usage of energy-efficient vehicles, such as hybrid electric vehicles, electric
vehicles, or those that run on alternative fuels.
E 6.B.4: Update the building code to support best practices in “green building”
design, construction, and operations.
E 6.B.5: Provide fast-track permitting for projects that implement “green building”
design and construction.
E 6.B.6: Encourage or require all new building construction to incorporate green
roofs and encourage conversions of existing roof space to green roofs to reduce
heat island effect.
E 7.1: Promote development of regulations and building design standards that
maximize energy efficiency through appropriate site and building design and
through the use of energy-efficient materials, equipment, and appliances.
E 7.2: Encourage and support the local research, development, generation, and use
of non-fossil fuel based renewable sources of energy, including wind and solar
resources, that meet local energy needs in an environmentally sensitive manner and
reduce dependence on imported energy.
E 7.3: Develop and provide pertinent information about the benefits of energy
conservation and available energy conservation incentive programs to all segments
of the community.
E 7.4: Pursue and encourage the expansion of local energy conservation, energy
efficiency, and related incentive programs.
E 7.5: Pursue 40% City-wide electricity supply from clean, renewable resources by
2017.
36 Net operational fuel consumption was calculated by subtracting existing fuel consumption from proposed fuel consumption.
37 City of Chula Vista. 2019. City of Chula Vista Vision 2020 General Plan. Chapter 9: Environmental Element. Section 3b. Website:
https://www.chulavistaca.gov/home/showdocument?id=9341. Accessed November 6, 2019.
38
E 7.6: Encourage the construction and operation of green buildings, considering such
TM programs as the Leadership in Energy and Environmental Design (LEED) Green
Building Rating System.
E 7.7: Support tree planting programs that will be implemented to reduce energy
needs.
E 7.8: Ensure that residential and non-residential construction complies with all
applicable City of Chula Vista energy efficiency measures and other green building
measures that are in effect at the time of discretionary permit review and Approval
or building permit issuance, whichever is applicable.
In the City’s CAP, the Climate Change Working Group (CCWG) selected the following
measures, which were adopted by the City Council on April 1, 2008:38
Green Building Standard: Through a building code revision, require new and
renovated buildings to increase their energy efficiency and meet Statewide green
building standards.
Solar and Energy Efficiency Conversion: Provide a cost-effective, streamlined
mechanism for property owners to implement solar and energy efficiency upgrades
and create a municipal code requiring pre-wiring for solar electric systems; Passed
“solar ready” ordinance in 2009 and created PACE financing programs in 2014.
The following are recommendations by the CCWG that were adopted by the City
Council in 2014:
Renewable & Efficient Energy Recommendation 2: Clean Energy Sources,
Part A—Incorporate solar photovoltaic into all new residential and commercial
buildings.
Renewable & Efficient Energy Recommendation 3: Energy Efficiency
Upgrades, Part B—Facilitate more energy upgrades in the community through
incentives and permit streamlining.
These voluntary measures at the City level further support the required State standards,
which ensure that the proposed project would not result in an inefficient, wasteful, or
unnecessary use of energy. Operational energy impacts would be less than significant.
(d) A significant impact would occur if the project would conflict with or obstruct a
State or local plan for renewable energy or energy efficiency.
Construction
Less than significant impact. As described above, the proposed project would result
in energy consumption through the combustion of fossil fuels in construction vehicles,
worker commute vehicles, and construction equipment, and the use of electricity for
38 City of Chula Vista, September 2017. Chula Vista Climate Action Plan. Accessed February 27, 2020.
39
temporary buildings, lighting, and other sources. California Code of Regulations Title
13, Sections 2449(d)(3) and 2485 limit idling from both on-road and off-road diesel-
powered equipment. The proposed project would be required to comply with these
regulations, which are enforced by the ARB. The California Title 24 energy efficiency
standards establish mandatory measures for non-residential buildings, including
material conservation and efficiency. The proposed project would also be required to
comply with these mandatory measures. The City’s local planning documents contain
no policies or measures directly applicable to construction-related energy consumption.
Therefore, it is anticipated that the construction phase of the project would not conflict
with or obstruct State or local plans for renewable energy or energy efficiency.
Construction-related energy impacts would be less than significant.
Operation
Less than significant impact. The operational phase of the proposed project would
consume energy as part of building operations and transportation activities. Building
operations for the proposed project would involve energy consumption for multiple
purposes including, but not limited to, building heating and cooling, lighting, and
electronics, as well as parking lot lighting. The California Title 24 energy efficiency
standards are widely regarded as the most advanced energy efficiency standards. These
standards help reduce the amount of energy required for lighting, water heating, and
heating and air conditioning in buildings and promote energy conservation. The
proposed project would be required to comply with these standards.
At the local level, the City of Chula Vista has established policies, regulations, and
measures to support renewable energy and energy efficiency. Chapter 20.04, Energy
and Water Conservation Regulations, of the City’s Municipal Code contains the
following regulations applicable to the proposed project:
20.04.030: Solar water heater pre-plumbing. All new residential units shall include at
least the plumbing specifically designed to encourage the later installation of a
system which utilizes solar energy as the primary means of heating domestic potable
water. The purpose of this section is to facilitate the safe, cost-effective installation of
residential solar water heating systems, while removing structural and regulatory
barriers. No building permit shall be issued unless the plumbing required pursuant to
this section and the Chula Vista Solar Water Heater Pre-Plumbing Installation
Requirements are incorporated into the approved building plans.39
20.04.040: Solar photovoltaic pre-wiring. All new residential units shall include at
least the electrical conduit specifically designed to encourage the later installation
of a system that utilizes solar photovoltaic or other renewable energy resource as a
means of generating electricity. The purpose of this section is to facilitate the safe,
cost-effective installation of renewable energy systems as residents’ primary
39 City of Chula Vista. 2019. City of Chula Vista Municipal Code. Title 20, Energy and Water Conservation. Chapter 20.04: Energy and
Water Conservation Regulations. Section 20.04.030: Solar Water Heater Preplumbing. Website:
https://chulavista.municipal.codes/CVMC/20.04.030. Accessed November 6, 2019.
40
electricity source, while removing structural and regulatory barriers. No building
permit shall be issued unless the requirements of this section and the Chula Vista
Photovoltaic Pre-Wiring Installation Requirements are incorporated into the
approved building plans.40
The proposed project would be required to comply with these regulations established
in the City’s Municipal Code. As noted in Section 6c, the City of Chula Vista Vision
2020 General Plan and CAP contain multiple voluntary measures supporting renewable
energy and energy efficiency. The proposed project would not conflict with or obstruct
any of these local voluntary measures.
California’s Renewables Portfolio Standard (RPS) requires that 33 percent of electricity
retail sales be served by renewable energy sources by 2020. The proposed project
would be served with electricity and gas provided by San Diego Gas & Electric
(SDG&E).41 SDG&E is required to meet California’s RPS. SDG&E’s 2017 power mix
included 44 percent eligible renewable (2 percent biomass and waste, 21 percent solar,
and 21 percent wind), 39 percent natural gas, and 17 percent unspecified sources of
power.42 SDG&E also offers an EcoChoice Mix that sources 100 percent of its power
mix from eligible renewable energy sources (specifically, 100 percent solar).
The proposed project would not conflict with or obstruct a State or local plan for
renewable energy or energy efficiency. Operational energy impacts would be less than
significant.
Mitigation Measures: None.
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
VII. Geology and Soils
Would the project:
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death
involving:
i) Rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the
State Geologist for the area or based on other
substantial evidence of a known fault? Refer to
Division of Mines and Geology Special
Publication 42.
40 City of Chula Vista. 2019. City of Chula Vista Municipal Code. Title 20, Energy and Water Conservation. Chapter 20.04: Energy and
Water Conservation Regulations. Section 20.04.030: Solar Water Heater Preplumbing. Website:
https://chulavista.municipal.codes/CVMC/20.04.030. Accessed November 6, 2019.
41 San Diego Gas and Electric (SDG&E). 2019. Our Service Area. Website: https://webarchive.sdge.com/our-company/about-us/our-
service-territory. Accessed November 7, 2019.
42 California Energy Commission. 2018. 2017 Power Content Label San Diego Gas and Electric. July. Website:
https://ww2.energy.ca.gov/pcl/labels/2017_labels/SDG_and_E_2017_PCL.pdf. Accessed November 7, 2019.
41
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
ii) Strong seismic ground shaking?
iii) Seismic-related ground failure, including
liquefaction?
iv) Landslides?
b) Result in substantial soil erosion or the loss of
topsoil?
c) 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?
d) 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?
e) 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?
f) Directly or indirectly destroy a unique
paleontological resource or site or unique geologic
feature?
Comments:
The following analysis is based on the Preliminary Geotechnical Report prepared by LGC
Valley, Inc. on July 13, 2018. The report is included as Appendix D of the Draft Initial Study.
(a)(i) No impact. The Alquist-Priolo Earthquake Fault Zoning Act was passed in 1972
to mitigate the hazard of surface faulting to structures for human occupancy. The Act’s
main purpose is to prevent the construction of buildings used for human occupancy on
the surface trace of active faults. The Act requires the State Geologist to establish
regulatory zones, known as “Alquist-Priolo Earthquake Fault Zones,” around the
surface traces of active faults and to issue appropriate maps. If an active fault is found,
a structure for human occupancy cannot be placed over the trace of the fault and must
be set back from the fault (typically 50 feet).
According to the California Department of Conservation’s California Geological
Survey, Earthquake Zones of Required Investigation mapping tool and the project-
specific Preliminary Geotechnical Report (Appendix D), the site is not located within
an identified Alquist-Priolo Earthquake Fault Zone.43
43 California Department of Conservation. Alquist-Priolo Faults. Website:
https://earthquake.usgs.gov/learn/topics/geologicmaps/apfaults.php. Accessed March 29, 2019.
42
The nearest Alquist-Priolo Earthquake Hazard Zone is located approximately 5.25
miles northwest. Therefore, the project would not directly or indirectly cause potential
substantial adverse effects including the risk of loss, injury or death involving the
rupture of a known fault. No impact would occur.
(ii) Less than significant impact. Seismic ground shaking is influenced by the
proximity of the site to an earthquake fault, the intensity of the seismic event, and the
underlying soil composition. As described above in Impact 7(a)(i), there are no active
faults known that pass through the project site. The nearest non-Alquist-Priolo active
fault is the Rose Canyon Fault Zone located approximately 3.8 miles west of the project
site. While the proposed project would construct 141 dwelling units, those dwellings
would be constructed in compliance with standard grading and soil engineering
practices and would be required to adhere to State and local building code standards.
Given these factors, and the fact that the site is not located on an earthquake fault, the
risk from ground shaking would be less than significant.
(iii) Less than significant impact. According to the project-specific Preliminary
Geotechnical Report, the potential for lurching or shallow ground rupture at the site is
low as the native soils are generally dense. Additionally, the City of Chula Vista Vision
2020 General Plan Environmental Element Figure 9-7, Geologic Hazards Map, indicates
the project site is located in an area in need of a detailed geotechnical liquefaction
analysis. However, the project-specific Preliminary Geotechnical Report outlines that a
subsurface investigation found that the potential for liquefaction is not a source of
concern as the water table depth varies between 30 to 33 feet below ground surface and
the type of soils on-site are less prone to liquefaction. As such, impacts from seismic-
related ground failure, including liquefaction, would be less than significant.
(iv) No impact. The project site is flat and is not in the vicinity of slopes that would be
susceptible to landslides. Additionally, the project-specific Preliminary Geotechnical
Report outlines, “based on the relatively flat nature of the site and our review of the
geologic literature pertinent to the site, there are no indications of landslides close to or
within the limits of the site.” As such, there would be no impact.
(b) Less than significant impact. The project site lies in an urbanized area of the City
of Chula Vista. Currently and historically, the site has been used for industrial purposes;
therefore, the ground surface and topsoil has been routinely disturbed by the
construction and paving of the existing surfaces, existing industrial uses, and vehicular
traffic.
The proposed project is expected to disturb the majority of the ground surface area, (+/-)
6.49 acres between 5–12 feet of depth, depending on the portion of the site. Project
grading is expected to include 15,000 cubic yards of raw earthwork to be removed as these
soils are not suitable for construction, and 10,000 cubic yards of imported earthwork fill.
43
Projects that disturb one or more acres of land are required to obtain coverage under
the General Permit for Discharges of Stormwater Associated with Construction
Activity (Construction General Permit), issued by the California State Water Resources
Control Board (State Water Board). The Construction General Permit requires the
development and implementation of a Storm Water Pollution Prevention Plan
(SWPPP). The SWPPP must list Best Management Practices (BMPs) the project would
implement to control erosion and prevent the conveyance of sediments off-site.
Implementation of the conditions of the Construction General Permit would reduce
erosion impacts resulting from project construction to less than significant. Once
construction work is completed, the impervious surfaces and landscaping would
minimize potential erosion and topsoil loss risks. As such, impacts to soil erosion and
loss of topsoil would be less than significant.
(c) Less than significant impact with mitigation incorporated.
Liquefaction or Collapse: As outlined above in Impact 2.7(a)(iii), the City of Chula
Vista Vision 2020 General Plan Environmental Element Figure 9-7, Geologic Hazards
Map, shows the project site as a liquefaction hazard area in need of a detailed
geotechnical liquefaction analysis. The project-specific Preliminary Geotechnical
Report outlines that a subsurface investigation found that the potential for liquefaction
is not a source of concern as the water table depth varies between 30 to 33 feet below
ground surface and the type of soils on-site are less prone to liquefaction. As such,
impacts from seismic-related ground failure, including liquefaction, would be less than
significant.
Landslide: As outlined above in Impact 2.7(a)(iv), the project site is flat and is not in
the vicinity of slopes that would be susceptible to landslides. Additionally, the project-
specific Preliminary Geotechnical Report outlines, “based on the relatively flat nature
of the site and our review of the geologic literature pertinent to the site, there are no
indications of landslides close to or within the limits of the site.” As such, there would
be no impact.
Lateral Spreading: As discussed in the response to liquefaction (see above) the site is
not located in an identified liquefaction hazard area, is relatively flat, and is not in the
vicinity of slopes that would be susceptible to liquefaction (e.g., slope areas that have
sufficient height, slope ratio, and underlying geologic conditions that can result in
liquefaction). Impacts from lateral spreading would be less than significant.
Subsidence: Site preparation will include demolition of the existing buildings, and
removal of on-site trash and surface pavement. Earthwork at the site is anticipated to
consist of removal and realignment of the on-site sewer and storm drain lines, with the
exception of the box culvert in the center of the site, which we anticipate will remain
in place. Earthwork will also include remedial removals of undocumented fill below
the existing buildings and in the areas of the old drainage channel, as well as removing
the top compressible layers of the young alluvial flood-plain deposits. Site grading will
44
include construction of slab-on-grade type foundations, installation of utilities, and
placement of the driveways, parking spaces, and concrete flatwork around the proposed
building.
The earthwork on-site is required to be performed in accordance with the
recommendations in Appendix D, pursuant to MM GEO-1. The recommendations
provided by the City of Chula Vista, and the General Earthwork and Grading
Specifications for Rough Grading included in Appendix D. Implementation of MM
GEO-1 would ensure that grading, building construction, and building materials are
compliant with local, State, and federal code. In case of conflict, the recommendations
in the following sections shall supersede those included as part of Appendix D.
Therefore, by following the proposed project’s Preliminary Geotechnical Report
recommendations, as is required, impacts from subsidence would be less than
significant. As such, impacts would be less than significant.
(d) Less than significant impact with mitigation incorporated. According to the
project-specific Preliminary Geotechnical Report, the proposed project grading would
include 15,000 cubic yards of raw earthwork to be removed and 10,000 cubic yards of
import earthwork fill. The purpose of removing the 15,000 cubic yards of raw
earthwork would be to remediate site soil conditions, as existing soils are unsuitable
for construction which may settle under the addition of water, surcharge of fill and/or
foundation loads. The 10,000 cubic yards of soil that will be brought onto the sight
would have a very low to low expansion potential. Therefore, by following the
proposed project’s Preliminary Geotechnical Report recommendations, as is required
and as included as MM GEO-1, impacts from expansive soils would be less than
significant with mitigation incorporated.
(e) No impact. The project does not propose the use of septic tanks. The proposed
project would connect to the City sanitary sewer system through existing lines for
wastewater disposal. Therefore, implementation of the proposed project would have no
impact to soils, as the project does not propose the use of septic tanks.
(f) Less than significant impact with mitigation incorporated. A significant adverse
effect could occur if grading or excavation activities associated with a project would
disturb paleontological resources or geologic features that presently exist within the
project site.
According to the paleontological records search by staff at the San Diego Natural
History Museum,44 review of published geological maps of the project site indicated
that the proposed project has the potential to impact late Pleistocene-to Holocene-age
young alluvial flood plan deposits, and could also impact the underlying Pleistocene-
age Bay Point Formation.
44 FirstCarbon Solutions (FCS). 2019. Phase I Cultural Resources Assessment 676 Moss Street Project. (Appendix C)
45
The high paleontological sensitivity of the Bay Point Formation in San Diego County
suggests the potential for construction of the proposed project to result in impacts to
paleontological resources. Any proposed excavation activities that extend deep enough
to encounter previously undisturbed deposits of this geologic unit have the potential to
impact the paleontological resources preserved therein, and, in this case,
implementation of a complete paleontological resource mitigation program during
ground-disturbing activities is recommended.
The proposed project is expected to disturb the majority of the ground surface area,
approximately 6.49 acres, between 5- to 12-feet of depth. If excavations extend into
undisturbed high sensitivity geological units, or are greater than 10 feet below the ground
surface, a Paleontological Monitor will be required as described in MM GEO-2.
However, if the project Construction Manager and City Development Services
Department staff determines that the thickness of the low sensitivity surficial sediments
underlying the project site exceeds the maximum cut depths proposed for construction
of the project, paleontological mitigation is not recommended.
Mitigation Measures:
MM GEO-1 Prior to the issuance of grading permits, the Project Applicant shall
demonstrate that all recommendations included in the Preliminary
Geotechnical Report, included as Appendix D of the Draft Initial Study, shall
be implemented during construction activities.
MM GEO-2 The City of Chula Vista assesses and mitigates the potential impacts of private
development and public facilities and infrastructure to paleontological
resources pursuant to the provisions of CEQA. Pursuant to Section 15065 of
the CEQA Guidelines, a lead agency must find that a project may have a
significant effect on the environment where the project has the potential to
eliminate important examples of the major periods of California prehistory,
which includes the destruction of significant paleontological resources.
With the implementation of Mitigation Measure (MM) GEO-2, impacts to any
previously undiscovered paleontological resources would be less than
significant.
Because excavations may extend into undisturbed high sensitivity geological
units, and may be greater than 10 feet below the ground surface in certain
areas of the project site, a Paleontological Monitor will be required.
Prior to the issuance of any demolition or grading permit, the Project
Applicant shall demonstrate to the satisfaction of the City Development
Services Department that a program related to paleontological resources
potentially uncovered during ground-disturbing activities on-site has been
established, the program shall include:
46
1. The Project Applicant shall halt work in the immediate area of the find;
2. The Project Applicant shall notify the City Development Services
Department;
3. The Project Applicant shall retain a qualified professional paleontologist
approved by the City:
The Paleontologist shall assess the discovered material(s).
The Paleontologist shall prepare a survey, study or report evaluating the
find.
The Paleontologist’s survey, study, or report shall contain a
recommendation(s), if necessary, for the preservation, conservation, or
relocation of the find.
The report shall be reviewed and approved by the City Development
Services Department.
The Project Applicant shall comply with the recommendations of the
report as approved by the City.
Project development activities in the immediate area of the find will
resume when copies of the report are submitted in a manner acceptable
to the City Department of Community Development.
A find(s) recovered should be deposited in a manner approved by the
City Department of Community Development.
Prior to the issuance of any building permit, the Project Applicant shall submit
a letter to the City Development Services Department indicating what, if any,
paleontological reports have been prepared for the project site, or a statement
indicating that no material was discovered.
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
VIII. Greenhouse Gas Emissions
Would the project:
a) Generate greenhouse gas emissions, either
directly or indirectly, that may have a significant
impact on the environment?
b) Conflict with any applicable plan, policy or
regulation of an agency adopted for the purpose
of reducing the emissions of greenhouse gases?
Comments:
(a) Less than significant impact with mitigation incorporated. Gases that trap heat
in the atmosphere are referred to as greenhouse gases. The effect is analogous to the
way a greenhouse retains heat. There have been significant legislative and regulatory
activities that directly and indirectly affect climate change and GHGs in California. The
47
primary climate change legislation in California is Assembly Bill 32 (AB 32), the
California Global Warming Solutions Act of 2006, focusing on reducing GHG
emissions in California. The proposed project would generate a variety of GHG
emissions during construction and operation, including several defined by AB 32 such
as carbon dioxide (CO2), methane (CH4), and nitrous oxide.
To describe how much global warming a given type and amount of GHG may cause,
the CO2 equivalent (CO2e) is used. The calculation of the CO2 equivalent is a consistent
methodology for comparing GHG emissions since it normalizes various GHG
emissions to a consistent reference gas, CO2. For example, CH4’s warming potential of
25 indicates that CH4 has 25 times greater warming effect than CO2 on a molecule-per-
molecule basis. A CO2 equivalent is the mass emissions of an individual GHG
multiplied by its global warming potential.
Neither the State of California nor the San Diego County APCD has adopted emission-
based thresholds of significance for GHG emissions under CEQA. This analysis uses
thresholds of significance established based on meeting the 2020 GHG targets set forth
in the AB 32 Scoping Plan. In addition, since operations would occur beyond 2020, the
service population threshold of significance was adjusted to a “substantial progress”
threshold that was calculated based on the SB 32 target of 40 percent below 1990 levels
and the forecasted 2030 service population.45 In the Center for Biological Diversity v.
California Department of Fish and Wildlife, the California Supreme Court stated that
“residential and commercial development, which are designed to accommodate long-
term growth in California’s population and economic activity, this fact gives rise to an
argument that a certain amount of greenhouse gas emissions is as inevitable as
population growth. Under this view, a significance criterion framed in terms of
efficiency is superior to a simple numerical threshold because CEQA is not intended as
a population control measure.” Therefore, consistent with the California Supreme
Court decision, this analysis uses a service population threshold to evaluate GHG
emissions for the proposed project.
Consistent with recommendations provided by the City of Chula Vista, this analysis
uses an efficiency threshold based on the total projected emissions for Chula Vista
divided by the service population (residents plus employees) in 2020 and 2030. As
provided in the 2012 Greenhouse Gas Emissions Inventory, the City’s 1990 GHG
emissions inventory totals approximately 847,166 metric ton (MT) CO2e, and the
projected 2020 emissions would be 1,138,431 MT CO2e.46 The City’s service
population has been estimated to be 370,126 in 2020.47 Therefore, the efficiency
threshold for year 2020 is equal to the 2020 emissions divided by the City’s 2020
45 Association of Environmental Professionals (AEP). Final White Paper Beyond 2020 and Newhall: A Field Guide to New CEQA
Greenhouse Gas Thresholds and Climate Action Plan Targets for California. Website: https://www.califaep.org/images/climate-
change/AEP-2016_Final_White_Paper.pdf. Accessed February 25, 2020.
46 2012 Greenhouse Gas Emission Inventory. City of Chula Vista, Cory Downs. Website:
https://www.chulavistaca.gov/home/showdocument?id=5471
47 San Diego Associations of Governments (SANDAG). 2013. Series 13: 2050 Regional Growth Forecast. October. Website:
https://www.sandag.org/index.asp?classid=12&subclassid=84&projectid=503&fuseaction=projects.detail. Accessed October 25, 2019.
48
service population, which results in 3.1 MT CO2e per service population. Consistent
with the goals of SB 32, the City’s 2030 GHG emission goal is 508,300 MT CO2e48
with an estimated service population of 389,979 (288,978 residents plus 101,001
employees).49 Therefore, the efficiency threshold for year 2030 is 1.3 MT CO2e per
service population.
Although construction-related GHG emissions are temporary in nature, the total
amount of emissions could have a substantial contribution to a project’s total GHG
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 trucks, and worker vehicles. Construction-related GHG emissions were
modeled using the same assumptions in the Air Quality section discussed above. Table
11 presents the project’s total construction-related GHG emissions and amortized
construction emissions.
Table 11: Construction GHG Emissions
Construction Activity
Emissions
(MT CO2e)
Demolition 61
Grading 164
Building Construction-2019 63
Building Construction-2020 466
Paving 21
Architectural Coating 8
Total1 783
Amortized over 30 years2 26
Note:
MT CO2e = metric tons of carbon dioxide equivalent.
1 Figures may not appear to add exactly due to rounding.
2 Construction GHG emissions are amortized over the 30-year life of the project (=783/30). The San Diego
County APCD does not recommend assumptions for project lifetime length; therefore, a 30-year lifetime,
consistent with the SCAQMD’s GHG guidance, was assumed.
Source: South Coast Air Quality Management District (SCAQMD). 2008. Draft Guidance Document—Interim
CEQA Greenhouse Gas (GHG) Significance Threshold. Website: http://www.aqmd.gov/docs/default-
source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance-thresholds/year-2008-2009/ghg-meeting-
6/ghg-meeting-6-guidance-document-discussion.pdf. Accessed August 19, 2019.
Source: CalEEMod Output (see Appendix A).
The construction schedule used in the analysis represents a reasonable “worst-case”
analysis scenario since emission factors for construction equipment decrease as the
48 Note: SB 32 states California plans to reduce GHG emissions 40 percent by 2030 at the 1990 level of emissions.
49 San Diego Associations of Governments (SANDAG). 2011. Series 12: 2050 Regional Growth Forecast- Historical Projection.
October. Website: https://www.sandag.org/index.asp?classid=12&subclassid=84&projectid=355&fuseaction=projects.detail.
Accessed October 25, 2019.
49
analysis year increases, due to improvements in technology and more stringent
regulatory requirements. Therefore, construction emissions would likely decrease if the
construction schedule moves to later years.
Following buildout of the project, long-term operational emissions would be generated
from area-, energy-, and mobile-source emissions. Indirect GHG emissions associated
with water consumption and solid waste disposal would also be generated by the
proposed residential development. The three existing buildings would be removed as part
of the project; therefore, existing emissions were included in the analysis baseline to
estimate the net increase in emissions. Table 12 shows existing emissions modeled using
the 2021 operational year, and Table 13 shows existing emissions modeled using the
2030 operational year. Table 14 shows the project’s annual operational emissions in year
2021 along with the amortized construction emissions. Table 13 shows the project’s
operational emissions in 2030 along with the amortized construction emissions.
Table 12: Existing Emissions—Year 2021
Emissions Source
Emissions
(MT CO2e)
Area 0
Energy 98
Mobile 99
Waste 26
Water 39
Total Existing Emissions1 262
Note:
MT CO2e = metric tons of carbon dioxide equivalent
1 Totals may not appear to add exactly due to rounding.
Source of emissions: CalEEMod Output (see Appendix A).
Table 13: Existing Emissions—Year 2030
Emissions Source
Emissions
(MT CO2e)
Area 0
Energy 89
Mobile 77
Waste 26
Water 36
Total Existing Emissions1 228
Note: MT CO2e = metric tons of carbon dioxide equivalent
1 Totals may not appear to add exactly due to rounding.
Source of emissions: CalEEMod Output (see Appendix A).
50
Table 14: Annual Operational GHG Emissions—Year 2021
Emissions Source
Emissions
(MT CO2e)
Area 63
Energy 182
Mobile 1,241
Waste 33
Water 51
Amortized Construction 26
Total Project Emissions1 1,596
Existing Emissions (262)
Annual Net Project Emissions 1,334
Project Service Population2 475
Service Person/Per Capita GHG Efficiency (MT CO2e/SP) 2.8
City’s proposed efficiency thresholds—2020 (MT CO2e/SP) 3.1
Exceed Threshold? No
Note: MT CO2e = metric tons of carbon dioxide equivalent SP = Service Person
1 Totals may not appear to add exactly due to rounding.
2 The project service population (residents plus employees) is the number of new residents living in the proposed development. As noted in Section 1.4, the number of new residents (475) was calculated by multiplying 141 dwelling units by 3.37 persons/dwelling unit (the average household size in Chula Vista). Source of emissions: CalEEMod Output (see Appendix A).
Table 15: Annual Operational Emissions—Year 2030
Emissions Source Emissions (MT CO2e)
Area 63
Energy 167
Mobile 961
Waste 33
Water 46
Amortized Construction 26
Total Project Emissions1 1,295
Existing Emissions (228)
Annual Net Project Emissions 1,067
51
Table 15 (cont.): Annual Operational Emissions—Year 2030
Emissions Source Emissions (MT CO2e)
Project Service Population2 475
Service Person/Per Capita GHG Efficiency (MT CO2e/SP) 2.3
City’s proposed efficiency thresholds—2030 (MT CO2e/SP) 1.3
Exceed Threshold? Yes
Note:
MT CO2e = metric tons of carbon dioxide equivalent.
1 Totals may not appear to add exactly due to rounding.
2 The project service population (residents plus employees) is the number of new residents
living in the proposed development. As noted in Section 1.4.2, the number of new residents (475) was calculated by multiplying 141 dwelling units by 3.37 persons/dwelling unit (the average household size in Chula Vista).
Source of emissions: CalEEMod Output (see Appendix A).
As shown above, the proposed project’s operational emissions would not exceed the
applicable threshold in the 2021 operational year; however, the project’s GHG
generation would exceed the applicable efficiency threshold for 2030. The project
would need to reduce its GHG emissions by approximately 35 percent in the 2030
operational year to reduce the GHG emissions to a less than significant level. However,
approximately 78 percent of the project’s operational emissions are from mobile
sources. Therefore, since there are limited options to reduce mobile-source GHG
emissions at the project level, the proposed project would be required to purchase
carbon offsets to help reduce the operational emissions to less than significant level.
Implementation of MM GHG-1 would require the purchase of voluntary carbon credits
by the Project Applicant in the amount of approximately 450 MT CO2e per year in 2030
through the remainder of the project’s lifetime (Appendix A).50 Total carbon offsets
required for the project’s lifetime would be approximately 9,450 MT CO2e (Appendix
A).51 With the implementation of MM GHG-1, the project’s GHG emissions would not
exceed the City’s energy efficiency threshold of significance. Impacts would be less
than significant with mitigation incorporated.
(b) Less than significant impact. Significance for this impact is determined by project
compliance to the ARB adopted AB 32 Scoping Plan and the ARB adopted 2017
Climate Change Scoping Plan Update. As described below, the proposed project’s
consistency with the City of Chula Vista’s CAP is shown for informational purposes.
50 The yearly amount of carbon offsets was calculated by multiplying the City’s proposed efficiency threshold (1.30 MT CO2e/SP) by
the project’s service population (475), and then subtracting this from the annual net project emissions (1,067 MT CO2e).
51 The total amount of carbon offsets was calculated by multiplying 450 MT CO2e per year by 21 years, which is the remainder of the
30-year lifetime of the project after 2030. The “project life” of 30 years is consistent with the methodology used by the SCAQMD
GHG guidance (SCAQMD 2008).
52
Consistency with City’s Climate Action Plan
The City of Chula Vista adopted the CAP in September 2017. However, the CAP has
not been adopted in a public process following environmental review; it is not
considered a qualified GHG reduction plan. Therefore, the proposed project’s
consistency with the CAP is included only for informational purposes, and would not
be used to determine significance. Table 16 identifies the measures within the CAP and
the proposed project’s consistency with them.
Table 16: Climate Action Plan Consistency Analysis
Category Policy Objective or Strategy Project Consistency
Waste Reduction
Zero Waste Plan Develop a Zero Waste Plan to
supplement Statewide green waste,
recycling, and plastic bag ban efforts.
Not applicable. The proposed
project would not impair the ability to
the City to develop a Zero Waste
Plan.
Renewable and Energy Efficiency
Energy Education and Enforcement Expand education targeting key
community segments and facilitating
energy performance disclosure.
Not applicable. The proposed
project would not impair the ability of
the City to expand energy education.
Clean Energy Source Incorporate solar photovoltaic into all
new residential and commercial
buildings (on a project level basis).
Consistent. The proposed residential
land uses would be required to comply
with the most current Title 24 and
California Building Standards Code
energy efficiency standards, which
would require the proposed project to
be either solar ready or would include
the installation of solar photovoltaic
systems, depending on the permit
dates.
Energy Efficiency Upgrades Expand the City’s cool roof standards to include re-roofs and western areas.
Not applicable. The proposed project would not impair the ability of the City to expand the City’s cool roof standards.
Energy Efficiency Upgrades Facilitate more energy upgrades in the community through tax breaks, rebates, and more local energy efficiency programming.
Not applicable. The proposed project would not impair the ability of the City to incentivize additional energy upgrades in the community.
Robust Urban Forests Plant more shade trees to save energy, address heat island issues, and improve air quality
Consistent. The proposed project would include shade trees on-site to save energy and reduce heat island issues.
Smart Growth and Transportation
Complete Streets and Neighborhoods Incorporate “Complete Streets”
principles into the Bicycle and
Pedestrian Master Plans and Capital
Improvement Program.
Not applicable. The proposed
project would not impair the ability of
the City to incorporate “Complete
Streets” principles into the Bicycle
and Pedestrian Master Plans and
Capital Improvement Program.
53
Table 16 (cont.): Climate Action Plan Consistency Analysis
Category Policy Objective or Strategy Project Consistency
Complete Streets and Neighborhoods Encourage higher density and
mixed-use development in Smart
Growth areas, especially around
trolley stations and other transit
nodes.
Consistent. The proposed project
would be located close to major
urban residential areas. The
proposed project would be located
close to public transit and the I-5.
Transportation Demand Management Utilize bike facilities, transit
access/passes and other
Transportation Demand
Management and congestion
management offerings.
Not applicable. The proposed
project would not impair the ability of
the City to use Transportation
Demand Management and
congestion management offerings.
Source: City of Chula Vista 2017 CAP.
As shown above, the proposed project would be consistent with the applicable
measures within the City’s CAP.
Consistency with Scoping Plan
The Scoping Plan identifies recommended measures for multiple GHG emission
sectors and the associated emission reductions needed to achieve the year 2020
emissions target—each sector has a different emission reduction target. Most of the
measures target the transportation and electricity sectors. It should be noted that the AB
32 Scoping Plan was developed at a Statewide level and thus many of its measures
listed below are not applicable to individual projects. As shown in Table 17, the
proposed project would be consistent with the applicable strategies, or the strategies
have been determined to not be applicable to the proposed project.
Table 17: Scoping Plan Measures Consistency Analysis
Scoping Plan Reduction Measure Project Consistency
1. California Cap-and-Trade Program Linked to Western Climate
Initiative. Implement a broad-based California Cap-and-Trade
program to provide a firm limit on emissions. Link the
California Cap-and-Trade program with other Western Climate
Initiative Partner programs to create a regional market system
to achieve greater environmental and economic benefits for
California. Ensure California’s program meets all applicable
AB 32 requirements for market-based mechanisms.
Not applicable. Although the cap-and-trade system
has begun, the proposed project is not one targeted by
the cap-and-trade system regulations and therefore
this measure does not apply to the proposed project.
2. California Light-Duty Vehicle Greenhouse Gas Standards.
Implement adopted standards and planned second phase of
the program. Align zero-emission vehicle, alternative and
renewable fuel and vehicle technology programs with long-term
climate change goals.
Not applicable. The future residents would use
vehicles subject to this measure. The reductions
associated with this measure would occur regardless
of the proposed project.
3. Energy Efficiency. Maximize energy efficiency building and
appliance standards; pursue additional efficiency including
new technologies, policy, and implementation mechanisms.
Pursue comparable investment in energy efficiency from all
retail providers of electricity in California.
Consistent. The proposed residential land uses would
be required to comply with the most current Title 24
and California Building Standards Code energy
efficiency standards.
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Table 17 (cont.): Scoping Plan Measures Consistency Analysis
Scoping Plan Reduction Measure Project Consistency
4. Renewable Portfolio Standard. Achieve 50 percent
renewable energy mix Statewide by 2050. Renewable
energy sources include (but are not limited to) wind, solar,
geothermal, small hydroelectric, biomass, anaerobic
digestion, and landfill gas.
Not applicable. This is a Statewide measure that
cannot be implemented by a project applicant or lead
agency. Renewable energy as a percentage of SDG&E
has achieved 43 percent in 2016, exceeding the State’s
renewable portfolio standards mandate of 33 percent by
2020. The proposed project would purchase power that
is comprised of a greater amount of renewable sources.
5. Low Carbon Fuel Standard. Develop and adopt the Low
Carbon Fuel Standard.
Not applicable. This measure would occur at the
Statewide level and all fuel used by the project’s vehicles
would comply with the Low Carbon Fuel Standard.
6. Regional Transportation-Related Greenhouse Gas Targets.
Develop regional GHG emissions reduction targets for
passenger vehicles. This measure refers to SB 375.
Not applicable. The proposed project would not be
related to developing GHG emission reduction targets.
7. Vehicle Efficiency Measures. Implement light-duty vehicle efficiency measures. Not applicable. The standards would be applicable to the light-duty vehicles that would access the project site.
8. Goods Movement. Implement adopted regulations for the use of shore power for ships at berth. Improve efficiency in goods movement activities.
Not applicable. The proposed project would not change any maritime, rail, or intermodal facilities.
9. Million Solar Roofs Program. Install 3,000 megawatt of solar-electric capacity under California’s existing solar programs.
Consistent. This measure is to increase solar throughout California, which is being done by various electricity providers and existing solar programs. The proposed project would be constructed pursuant to the Building Energy Efficiency Standards, which would require the proposed project to be either solar ready or would include the installation of solar photovoltaic systems, depending on the permit dates.
10. Medium/Heavy-Duty Vehicles. Adopt medium and heavy-duty vehicle efficiency measures. Not applicable. This is a Statewide measure that cannot be implemented by a project applicant or lead agency.
11. Industrial Emissions. Require assessment of large industrial sources to determine whether individual sources within a facility can cost-effectively reduce GHG emissions and provide other pollution reduction co-benefits. Reduce GHG emissions from fugitive emissions from oil and gas extraction and gas transmission. Adopt and implement regulations to control fugitive CH4 emissions and reduce flaring at refineries.
Not applicable. The proposed project would not be a stationary source targeted by this measure.
12. High Speed Rail. Support implementation of a high-speed rail system. Not applicable. The proposed project would not preclude the implementation of this strategy.
13. Green Building Strategy. Expand the use of green building practices to reduce the carbon footprint of California’s new and existing inventory of buildings.
Consistent. The proposed project would comply with the California Energy Code, and thus incorporate applicable energy efficiency features designed to reduce project energy consumption.
14. High Global Warming Potential Gases. Adopt measures to reduce high global warming potential gases. Not applicable. This measure is applicable to the high global warming potential gases that would be used by sources with large equipment (such as in commercial refrigerators) that are not part of this residential project.
15. Recycling and Waste. Reduce CH4 emissions at landfills. Increase waste diversion, composting, and commercial recycling. Move toward zero waste.
Consistent. The proposed project would utilize City of Chula Vista waste management and waste recycling services.
55
Table 17 (cont.): Scoping Plan Measures Consistency Analysis
Scoping Plan Reduction Measure Project Consistency
16. Sustainable Forests. Preserve forest sequestration and encourage the use of forest biomass for sustainable energy generation.
Not applicable. The project site is not forested; therefore, no preservation is possible.
17. Water. Continue efficiency programs and use cleaner energy sources to move and treat water. Consistent. The proposed project would comply with the California Energy Code and the California Updated Model Landscape Ordinance. With adherence to these regulations, the proposed project would consume energy and water in an efficient manner.
18. Agriculture. In the near-term, encourage investment in manure digesters and at the five-year Scoping Plan update determine if the program should be made mandatory by 2020.
Not applicable. The proposed project does not include any agricultural land uses. No grazing, feedlot, or other agricultural activities that generate manure occur on-site or are proposed to be implemented by the proposed project.
Source of ARB Scoping Plan Reduction Measure: California Air Resources Board (ARB) 2008. Source of project Consistency or Applicability: FirstCarbon Solutions (FCS) 2019.
As shown above, the proposed project would be consistent with applicable AB 32
Scoping Plan measures.
In addition, SB 32 2017 Scoping Plan extends the goals of AB 32 and set a 2030 goal
of reducing Statewide GHG emissions to 40 percent below 1990 levels by the year
2030. The 2017 Scoping Plan provides a path that will achieve California’s 2030 target.
As shown in Table 18, the 2017 Scoping Plan provides a high-level summary of the
Climate Change Policies and Measures to achieve the 2030 target and discusses the
proposed project’s consistency with the recommended actions.
Table 18: Climate Change Policies and Measures with Consistency Analysis
Recommended Action Project Consistency
Implement SB 350 by 2030:
1. Increase the Renewable Portfolio Standard to 50 percent of retail sales by 2030 and ensure grid reliability.
Not applicable. This is a Statewide measure that cannot be implemented by a project applicant or lead agency. Renewable energy as a percentage of SDG&E has achieved 43 percent in 2016, exceeding the state’s renewable portfolio standards mandate of 33 percent by 2020. The proposed project would purchase power that is comprised of a greater amount of renewable sources.
2. Establish annual targets for Statewide energy efficiency savings and demand reduction that will achieve a cumulative doubling of Statewide energy efficiency savings in electricity and natural gas end uses by 2030.
Consistent. The residential buildings would comply with the California Energy Code, and thus incorporate applicable energy efficiency features designed to reduce project energy consumption.
3. Reduce GHG emissions in the electricity sector through the implementation of Integrated Resource Plans to meet required GHG emissions reduction target.
Not applicable. This measure is specific to electricity utility companies and would not apply to the proposed project. The proposed project would purchase power that is comprised of a greater amount of renewable sources as a result of this measure.
56
Table 18 (cont.): Climate Change Policies and Measures with Consistency Analysis
Recommended Action Project Consistency
Implement Mobile Source Strategy (Cleaner Technology and Fuels):
4. At least 1.5 million zero emission and plug-in hybrid light-duty electric vehicles by 2025. 5. At least 4.2 million zero emission and plug-in hybrid light-duty electric vehicles by 2030. 6. Further increase GHG stringency on all light-duty vehicles beyond existing Advanced Clean Cars regulations. 7. Medium- and heavy-duty GHG Phase 2. 8. Innovative Clean Transit: Transition to a suite of to-be-determined innovative clean transit options. Assumed 20 percent of new urban buses purchased beginning in 2018 will be zero emission buses with the penetration of zero-emission technology ramped up to 100 percent of new sales in 2030. Also, new natural gas buses, starting in 2018, and diesel buses, starting in 2020, meet the optional heavy-duty low-NOX standard. 9. Last Mile Delivery: New regulation that would result in the use of low NOX or cleaner engines and the deployment of increasing numbers of zero-emission trucks primarily for class 3-7 last mile delivery trucks in California. This measure assumes zero emission vehicles comprise 2.5 percent of new Class 3–7 truck sales in local fleets starting in 2020, increasing to 10 percent in 2025 and remaining flat through 2030.
Not applicable. These measures would be implemented at a Statewide level and would affect any new vehicles visiting or serving the proposed project.
10. Further reduce VMT through continued implementation of SB 375 and regional Sustainable Communities Strategies; forthcoming Statewide implementation of SB 743; and potential additional VMT reduction strategies not specified in the Mobile Source Strategy but included in the document “Potential VMT Reduction Strategies for Discussion.”
By 2019, adjust performance measures used to select and
design transportation facilities. Harmonize project
performance with emissions reductions, and increase
competitiveness of transit and active transportation modes
(e.g. via guideline documents, funding programs, project
selection, etc.).
Not applicable. This is a Statewide measure that cannot be
implemented by a project applicant or lead agency. In
addition, the proposed project is not a public transit facility.
By 2019, develop pricing policies to support low-GHG
transportation (e.g. low-emission vehicle zones for heavy
duty, road user, parking pricing, transit discounts).
Not applicable. This is a Statewide measure that cannot be
implemented by a project applicant or lead agency.
Adopt a Low Carbon Fuel Standard with a Carbon Intensity
reduction of 18 percent.
Not applicable. This is a Statewide measure that cannot be
implemented by a project applicant or lead agency. The
proposed project’s vehicles would use fuel consistent with
this measure.
Implement the Short-Lived Climate Pollutant Strategy by 2030:
1. 40 percent reduction in methane and hydrofluorocarbon
emissions below 2013 levels.
2. 50 percent reduction in black carbon emissions below
2013 levels.
Not applicable. This is a Statewide measure that cannot be
implemented by a project applicant or lead agency.
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Table 18 (cont.): Climate Change Policies and Measures with Consistency Analysis
Recommended Action Project Consistency
By 2018, develop Integrated Natural and Working Lands
Implementation Plan to secure California’s land base as a net carbon sink:
1. Protect land from conversion through conservation
easements and other incentives.
2. Increase the long-term resilience of carbon storage in
the land base and enhance sequestration capacity
3. Utilize wood and agricultural products to increase the
amount of carbon stored in the natural and built
environments
4. Establish scenario projections to serve as the
foundation for the Implementation Plan
Not applicable. This is a Statewide measure that cannot be
implemented by a project applicant or lead agency.
Source: California Air Resources Board (ARB). 2017. California’s 2017 Climate Change Scoping Plan. Chapter 5: Achieving Success.
November 2017. Website: https://www.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf. Accessed November 9, 2019.
Source of project consistency or applicability: FCS 2019.
As shown above, the proposed project would be consistent with the Chula Vista CAP,
AB 32, and SB 32 Scoping Plan. Therefore, impacts would be less than significant.
Mitigation Measures:
MM GHG-1 Prior to the occupancy of the proposed project, the Project Applicant shall
provide for the purchase of voluntary carbon credits in a manner approved by
the City Development Services Department pursuant to the following
performance standards and requirements: i. the carbon offsets shall achieve
real, permanent, quantifiable, verifiable, and enforceable reductions as set
forth in Cal. Health & Saf. Code Section 38562(d)(1); and ii. one carbon
offset credit shall mean the past reduction or sequestration of one metric ton of
carbon dioxide equivalent that is “not otherwise required” (CEQA Guidelines
Section 15126.4(c)(3)). The purchase shall be from a verified greenhouse gas
(GHG) emissions credit broker in an amount sufficient to offset operational
GHG emissions of approximately 0 metric ton carbon dioxide equivalent (MT
CO2e) per year until 2030 and 450 MT CO2e per year beginning in 2030 (or a
total amount estimated over the lifetime of the proposed project, which is
estimated to be 9,450 MT CO2e). The purchase shall be verified as occurring
prior to approval of occupancy permits. Copies of emission estimates and
offset purchase contract(s) shall be provided to the City Development Services
Department for review and approval.
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Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
IX. Hazards and Hazardous Materials
Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use,
or disposal of hazardous materials?
b) 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?
c) Emit hazardous emissions or handle hazardous
or acutely hazardous materials, substances, or
waste within one-quarter mile of an existing or
proposed school?
d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a
result, would it create a significant hazard to the
public or the environment?
e) For a project located within an airport land use
plan or, where such a plan has not been adopted,
within two miles of a public airport or public use
airport, would the project result in a safety
hazard or excessive noise for people residing or
working in the project area?
f) Impair implementation of or physically interfere
with an adopted emergency response plan or
emergency evacuation plan?
g) Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or
death involving wildland fires?
Comments:
The following analysis is based on the Phase I Environmental Site Assessment (Phase I ESA)
and Phase II Environmental Site Assessment (Phase II ESA) prepared by Environmental
Management Strategies, Inc. (EMS) in July 2018 and August 2018, respectively. Both the
Phase I ESA and Phase II ESA are included as Appendix E of the Draft Initial Study.
(a) Less than significant impact with mitigation incorporated. The proposed project
involves the demolition of three existing buildings, grading of the approximately 6.49-
acre project site, asphalt/concrete paving of the site, construction of the private internal
circulation system, and construction of 141 dwelling units.
59
A Phase I ESA was prepared for the project by EMS in July 2018 and is included in
Appendix E. The Phase I ESA found that the buildings on-site were constructed prior
to 1980; therefore, asbestos-containing building materials and lead based paint are still
likely to be present on-site. The Phase I ESA recommended a Phase II ESA be
performed at the individual properties of the site due to the presence of Recognized
Environmental Conditions (RECs), Historical Environmental Conditions, and Vapor
Encroachment Conditions.
A Phase II ESA was prepared by EMS on August 14, 2018, and is also included in
Appendix E. A Supplemental Phase II ESA was also prepared by EMS on September
13, 2018. The findings of the Supplemental Phase II ESA do not indicate the site is
unsuitable for the intended residential redevelopment, or that soil remediation is likely
necessary prior to site redevelopment. However, a weak source of tetrachloroethene
(PCE) may exist in soil beneath a clarifier and wash area at 676 Moss Street. It is
anticipated that these structures will be removed as part of redevelopment earthwork.
Implementation of MM HAZ-1 is therefore required. MM HAZ-1 requires soil samples
to be collected from beneath these structures after removal for testing of VOCs. If
present, soil containing elevated concentrations of VOCs must be excavated and
removed from the site. Removal of impacted soil, if present, would likely eliminate the
low potential risk of vapor intrusion that may be caused by this source.
Because the assessment of soil for contamination is dependent on, and limited by,
discrete sampling at specific locations and depths, the possibility of encountering some
soil containing petroleum hydrocarbons or other products during grading or
construction that were not identified by previous sampling activities cannot be
completely ruled out for an industrial site. Therefore, a Soil Management Plan (SMP)
is required to be prepared under MM HAZ-2 to address potentially contaminated soil
that may be encountered during building demolition, grading, or construction activities
at the project site. The SMP would establish procedures for the identification, detection,
excavation, removal, and disposal of any impacted soil discovered during demolition
and grading. Using an SMP is a BMP that facilitates a cost-effective and efficient
process for the removal of impacted soil with minimal impact to site construction and
development activities. The SMP would be submitted to the County Department of
Environmental Health as a part of the Voluntary Assistance Program (VAP) program,
as stated in MM HAZ-3.
Five groundwater monitoring wells were installed on the project site. EMS
recommends these wells remain in place should additional groundwater testing be
necessary. These wells will require proper abandonment once they are no longer
needed. All well-heads and covers should be protected from damage during any project
construction, earthwork, or paving. A permit is required to be obtained from the San
Diego County Department of Environmental Health Monitoring Well Program prior to
abandonment under MM HAZ-1.
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Construction Hazards
During construction of the residential area and related infrastructure, hazardous
materials would be handled on the project site. These hazardous materials would
include gasoline, diesel fuel, lubricants, and other petroleum-based products used to
operate and maintain construction equipment and vehicles. This handling of hazardous
materials would be a temporary activity and coincide with the short-term construction
phase of the proposed project. Although hazardous materials associated with the
operation and maintenance of construction equipment and vehicles may be stored on
the project site, it is expected that only the amounts needed would be kept on-site, and
any handling of such materials will be limited in both quantities and concentrations.
Removal and disposal of hazardous materials from the project site would be conducted
by a permitted and licensed contractor. The site buildings were constructed prior to
1980; therefore, asbestos-containing building materials and lead based paint are still
likely to be present on-site. Any handling, transporting, use, or disposal would comply
with applicable laws, policies, and programs set forth by various federal, State, and
local agencies and regulations, including the EPA, Resource Conservation and
Recovery Act (RCRA), California Department of Transportation (Caltrans), and the
San Diego County Hazardous Materials Division. Required compliance with applicable
hazardous material laws and regulations would ensure that construction-related
hazardous material use would not result in significant impacts.
Operational Hazards
During the operational phase of the project, hazardous materials may be handled on the
project site. Because of the nature of the project, hazardous materials used on-site may
vary, but would likely be limited to fertilizers, herbicides, pesticides, solvents, cleaning
agents, and similar materials used for daily residential operations and maintenance
activities. These types of materials are common and represent a low risk to people and
the environment when used as intended. Therefore, long-term operational impacts
associated with hazardous materials would be less than significant.
(b) Less than significant impact. As noted above in Impact 2.8(a), the proposed project
would involve the routine uses of common low-level hazardous materials associated with
residential uses. Given the small quantities involved and the characteristics of use, the
potential release of such materials is not considered a significant risk to human health or
the environment. As such, impacts would be less than significant.
(c) No impact. The project site is not located within 0.25 mile of an existing or
proposed school. The nearest school to the project site, Harborside Elementary School,
is located approximately 0.26 mile south of the project site. Additionally, the proposed
project, as a residential project, would not emit hazardous emissions or handle large
quantities of hazardous materials. Spills or releases of hazardous materials on the
project site would remain localized and would follow federal, State, and local
guidelines for clean-up. As such, there would be no impact.
61
d) Less than significant with mitigation incorporated. The proposed project would be
located on a site that is included on a list of hazardous materials sites compiled pursuant
to Government Code Section 65962.5. To evaluate whether the proposed project would
create a significant hazard to the public or the environment, EMS conducted Phase I,
Phase II, and Supplemental Phase II ESAs on the project site (Appendix E). The findings
and subsequent recommendations of each ESA is provided below.
Phase I ESA
The primary purpose of a Phase I ESA is to provide a detailed investigation into historic
uses of the project site and conduct a review of reasonably ascertainable regulatory
agency information including contacting regulatory agencies (pursuant to Government
Code § 65962.5), in order to provide direction on any additional site investigation.
The findings of the Phase I ESA included RECs:
Three diesel aboveground storage tanks (ASTs) were observed on the 680 Moss
Street property and are a concern for subsurface contamination.
The Hawthorne Cat equipment wash area at 680 Moss Street is a concern for
subsurface contamination.
The motor oil, transmission oil, and drive train oil and used oil storage area at 680
Moss Street is a concern for subsurface contamination.
Soil staining was observed at the 676 Moss Street, Boat Yard San Diego property
and is a concern for subsurface contamination.
Housekeeping on the Boat Yard San Diego property was very poor with equipment
and chemicals stored haphazardly throughout the yard and is a concern for
subsurface contamination.
The equipment wash area and clarifier located at the 676 Moss Street, Rapid Prep
property are a concern for subsurface contamination.
The Phase I ESA recommended that a Phase II ESA be conducted to further analyze
the findings.
A Phase II ESA was conducted, as outlined below.
Phase II ESA
The primary purpose of the Phase II ESA was to evaluate the potential impact to soil and
soil vapor at the project site from the RECs outlined above. As such, soil boring was
conducted throughout the project site to collect soil and soil vapor samples (Exhibit 10).
The findings of the Phase II ESA included the following:
62
The concentrations of metals detected in soil at the locations and depths sampled do
not appear to present a significant direct or indirect soil contact health risk to
current or potential future human receptors at the project site.
Soil at certain areas of the project site contain low concentrations of total petroleum
hydrocarbons (TPH) as motor oil-range organics and lesser concentrations of
diesel-range organics. The source of TPH may be from limited surface spillage at
the project site or from asphalt debris in in shallow fill soil beneath the project site.
The concentrations of TPH detected in soil at the locations and depths sampled do
not exceed the San Diego Regional Water Quality Control Board (RWQCB)
Environmental Screening Levels (ESLs) for direct soil exposure to humans at
residential sites and are not expected to present a significant direct or indirect soil
contact health risk to current or potential future human receptors at the project site.
VOCs were not detected in any of the soil samples collected by EMS as the project
site. VOCs in soil matrix at the locations and depths sampled by EMS are not
expected to present a significant direct or indirect soil contact health risk to current
or potential future human receptors at the Site.
Low concentrations of 22 VOCs were detected in soil vapor samples collected at the
project site. The occurrence of VOCs in soil vapor is wide-spread across the project
site. The most prevalent VOCs detected in soil vapor were acetone, 2-butanone
(methyl ethyl ketone), BTEX compounds (benzene, toluene, ethylbenzene and
xylene), and PCE. PCE detected in the soil vapor samples at probe locations SLF-5
and SLF-6-5 marginally exceed a future residential soil vapor screening level (SVSL)
of 460 micrograms per cubic meter (μg/m3) determined using current California
Department of Toxic Substances Control (DTSC) 2011 VI Guidance and DTSC June
2018 HERO Note 3 indoor air screening levels. No other VOCs detected in soil
vapor exceed future residential SVSLs based on current DTSC VI guidance.
The wide-spread occurrence of benzene, toluene, ethylbenzene and xylene
compounds (BTEX) in soil vapor suggest releases of gasoline product have
occurred in the area of the project site. This may include on-site and off-site
sources. EMS did not identify a soil source of BTEX, and the distribution of these
VOCs in soil vapor did not identify a specific potential release area or “hot-spot”
on-site. A gasoline underground storage tank (UST) was removed from the
northeast corner of the site; however, the concentrations of BTEX detected in soil
vapor at this location are similar to, or lower than, other areas of the project site
suggesting the removed UST was not a source of VOCs detected in soil vapor.
According to the State Water Board Geotracker online database, multiple sources of
gasoline contamination to soil and groundwater are located up-gradient of the
project site. Three of these release areas are located approximately 0.25 mile
northeast of the project site at the intersection of Broadway and L Street (76 Station
at 898 Broadway; Shell Station at 902 Broadway and Texaco Station at 903
Broadway). According to groundwater monitoring reports prepared for these cases,
63
groundwater flows southwest from the stations towards the project site.
Groundwater beneath and down-grading of these stations has been impacted with
free-phase floating gasoline product. Recent groundwater monitoring reports for
these cases indicate free-phase floating product is still present on groundwater. The
extents of groundwater contamination down-gradient from these sources, and other
up-gradient sources, do not appear to have been completely defined. Groundwater
is located at a depth of approximately 32 feet beneath the project site. Gasoline-
impacted groundwater flowing beneath the project site from up-gradient sources
could be contributing to BTEX compounds detected in soil vapor.
The highest concentrations of PCE in soil vapor were detected at probe locations
SLF-5 and SLF-6. These probes are located adjacent to an equipment wash area and
three-stage clarifier at 676 Moss Street. The wash area and clarifier may have been a
generally weak source for the relatively higher concentrations of PCE detected in soil
vapor near this area. However, PCE, acetone and 2-butanone were detected in soil
vapor across the project site suggesting other sources, including off-project-site
sources, likely exist that may be contributing the detection of this VOC in soil vapor.
The Phase II ESA recommended that, while the project site is not unsuitable for a
residential development, a Supplemental Phase II ESA be conducted to further analyze
the wide-spread occurrence of generally low concentrations of VOCs detected in soil
vapor, as contaminated groundwater from up-gradient sources may be an issue.
A Supplemental Phase II ESA was conducted, as outlined below.
Supplemental Phase II ESA
The primary purpose of the Supplemental Phase II ESA was to evaluate the potential
impact to groundwater at the project site. As such, additional soil boring was conducted
throughout the project site to collect soil and soil vapor samples, as well as the
installation of groundwater wells to collect groundwater samples to test for distribution
of VOCs (Exhibit 11).
The findings of the Supplemental Phase II ESA included the following:
The concentrations of metals detected in soil at the locations and depths sampled
are not expected to present a significant direct or indirect soil contact health risk to
current or potential future human receptors at the site.
Shallow soil at certain areas of the site contain low concentrations of TPH as motor
oil-range organics and lesser concentrations of diesel-range organics. The source of
TPH may be from limited surface spillage at the project site or from asphalt debris
in shallow fill soil beneath the project site. The concentrations of TPH detected in
soil at the locations and depths sampled do not exceed the San Diego RWQCB
ESLs for direct soil exposure to humans at residential sites and are not expected to
64
present a significant direct or indirect soil contact health risk to current or potential
future human receptors at the project site.
VOCs were not detected in any of the soil samples collected by EMS as the project
site. VOCs in soil matrix at the locations and depths sampled by EMS are not
expected to present a significant direct or indirect soil contact health risk to current
or potential future human receptors at the project site.
Except for low concentrations of chloromethane, VOCs were not detected in
groundwater samples collected from the five groundwater monitoring wells at the
project site. Chloromethane is not considered a project site-related VOC or a
contaminant of concern for this project site. These results demonstrate that this
project site is not a source of VOC impact to groundwater and does not appear to
have been impacted by potential un-gradient, off-project-site sources of VOC
groundwater contamination.
Low concentrations of 23 VOCs were detected in soil vapor samples collected at
the project site. The occurrence of VOCs in soil vapor is wide-spread across the
project site. EMS did not identify a soil source of VOCs and the distribution of
these VOCs in soil vapor did not identify a specific potential release area or “hot-
spot” on the project site. VOC detected in soil vapor may be from both on and off-
project-site sources.
PCE detected in two soil vapor samples at two locations (SLF-5 and SLF-6) near a
clarifier and equipment wash area at 676 Moss Street marginally exceed a future
residential SVSLs 460 micrograms per cubic meter (μg/m3) determined using
current DTSC 2011 VI Guidance and DTSC June 2018 HERO Note 3 indoor air
screening levels. These results suggest soil beneath these structures may be a weak
source of the relatively higher concentrations of PCE detected in soil vapor near
this area. No other VOCs detected in soil vapor across the project site exceed future
residential SVSLs based on current DTSC VI guidance. These results demonstrate
the potential vapor intrusion risk to existing or future buildings from VOCs present
in soil vapor beneath the project site is low.
The Supplemental Phase II ESA recommended that mitigation needs to be incorporated
in order to ensure safety of the project site for development. Implementation of MM
HAZ-2 would ensure that there is an SMP in place that establishes procedures in the
event that soils containing petroleum hydrocarbons or other products are encountered
during building demolition, grading or construction activities; the SMP would establish
procedures for the identification, detection, excavation, removal and disposal of any
impacted soil. MM HAZ-2 would ensure that, after the demolition of on-site structures,
testing for VOCs be conducted on the soil the structures were on, if VOCs are present,
soil containing elevated concentrations of VOCs would be excavated and removed
from the project site; removal of impacted soil, if present, would likely eliminate the
low potential risk of vapor intrusion that may be caused by this source. Additionally,
the Supplemental Phase II ESA also recommended that the five groundwater
65
monitoring wells currently installed on the project site remain in place should
additional groundwater testing be necessary. Implementation of MM HAZ-1 would
require the project to retain the five groundwater monitoring wells on-site and ensure
that the proper abandonment process occurs when they are no longer needed.
Therefore, the proposed project pursuant to Government Code Section 65962.5, with
implementation of MM HAZ-1 and HAZ-2, impacts would be less than significant.
(e) No impact. The project site is neither located within an airport land use plan nor is
it located within 2 miles of a public airport or public use airport. The closest public
airport to the project site is Brown Field Municipal Airport in San Diego, approximately
5.82 miles to the southeast. Because of its distance from the airports runways, the
project site is located well outside of the airport’s 60 A-weighted decibel (dBA)
community noise equivalent level (CNEL) noise contours. Therefore, implementation
of the proposed project would not expose persons residing or working in the project
site to excessive noise levels associated with public airport noise. As such, no impact
would occur.
(f) No impact. The City of Chula Vista does not have an adopted emergency response
plan or emergency evacuation plan. However, the City of Chula Vista Fire Department
outlines the following scenarios that require disaster preparedness: wildfire,
earthquakes, flood, terrorism, and tsunami. The only scenario with an evacuation routes
map is the tsunami scenario. The evacuation routes for a tsunami are along the coast
and direct evacuees to hear inland. The nearest evacuation route to the project site is J
Street, located approximately 0.6 mile north of the project site. Additionally, according
to the tsunami evacuation map, the project site would not be affected by a tsunami.
Therefore, the proposed project would not impair implementation of or physically
interfere with an adopted emergency response plan or emergency evacuation plan. As
such, there would be no impact.
(g) No impact. According to the CAL FIRE California Fire Hazard Severity Zones Maps,
the project site is not located in a Fire Hazard Severity Zone in neither a Local
Responsibility Area, nor the State Responsibility, nor Federal Responsibility Area. The
proposed project would be completely surrounded by urbanized areas and/or irrigated
lands and no wildlands are adjacent to the project. Additionally, the proposed project’s
design would be subject to compliance with the requirements in the California Building
Standards Commission California Fire Code. Therefore, the proposed project would not
directly or indirectly expose people or structures to a significant risk of loss, injury or
death involving wildland fires, including where wildlands are adjacent to urbanized areas
or where residences are intermixed with wildlands. As such, there would be no impact.
Mitigation Measures:
MM HAZ-1 Prior to the issuance of any demolition or grading permit, the Project Applicant
shall demonstrate to the satisfaction of the City Development Services
66
Department that the five groundwater monitoring wells on the project site will
remain in place should additional groundwater testing be necessary. The Project
Applicant will abandon the wells when they are longer needed in a manner
approved by the City Development Services Department and San Diego County
Department of Environmental Health Monitoring Well Program.
MM HAZ-2a Prior to the issuance of any grading permit and subsequent to the demolition
of on-site structures, the Project Applicant shall conduct soil testing on the
soils the structures were on. If volatile organic compounds (VOCs) are
present, soil containing elevated concentrations of VOCs shall be excavated
and removed from the project site. The excavation and removal of soil to be
outlined in the Soil Management Plan (SMP) approved by the San Diego
County Department of Environmental Health.
MM HAZ-2b Prior to issuance of any demolition permit, the Project Applicant shall obtain a
permit from the San Diego County Hazardous Materials Division. The permits
shall provide that hydrocarbons or “other products,” including asbestos and
lead based paints, that might be encountered during building demolition,
grading, or construction activities, are disposed of in a manner approved by
the City Development Services Department.
MM HAZ-3 Prior to the issuance of any site development permits (demolition, grading,
building, construction), the Project Applicant shall enter into the County of
San Diego Department of Environmental Health Voluntary Assistance
Program (VAP). Written Confirmation of VAP participation and compliance
shall be received from San Diego County Department of Environmental
Health prior to any site development activities.
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
X. Hydrology and Water Quality
Would the project:
a) Violate any water quality standards or waste
discharge requirements or otherwise
substantially degrade surface or groundwater
quality?
b) Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge
such that the project may impede sustainable
groundwater management of the basin?
c) 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:
67
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
(i) result in substantial erosion or siltation on-
or off-site;
(ii) substantially increase the rate or amount of
surface runoff in a manner which would
result in flooding on- or offsite;
(iii) create or contribute runoff water which
would exceed the capacity of existing or
planned stormwater drainage systems or
provide substantial additional sources of
polluted runoff; or
(iv) impede or redirect flood flows?
d) In flood hazard, tsunami, or seiche zones, risk
release of pollutants due to project inundation?
e) Conflict with or obstruct implementation of a
water quality control plan or sustainable
groundwater management plan?
Comments:
Information and analysis for Hydrology and Water Quality impacts are based on the Priority
Development Project Storm Water Quality Management Plan (SWQMP) prepared by Michael
Baker International on November 19, 2018, included in Appendix F. The topography of the
project site is relatively flat with current elevations that range from 37 feet on the north-
westerly side of site to 32 feet on the south-easterly side. The existing drainage flows from
northeast to west towards Industrial Boulevard. The project site is currently 1.3 percent
pervious and 98.7 percent impervious. Implementation would increase the percentage of
pervious area to 17 percent and reduce the impervious area to 83 percent. The proposed project
would be designed to match the existing drainage conditions on-site via surface flow and on-
site drainage system. Stormwater would be directed away from the proposed project and
conveyed to the existing double box culvert that runs from east to west underneath the site.
There also multiple inlets (some covered while others utilized) that connect to this underground
culvert that can be found on-site.
(a) Less than significant impact. As part of Section 402 of the Clean Water Act, the
EPA has established regulations under the National Pollutant Discharge Elimination
System (NPDES) program to control direct stormwater discharges. In the City of Chula
Vista, the San Diego RWQCB administers the NPDES permitting program and is
responsible for developing NPDES permitting requirements. The NPDES program
regulates industrial pollutant discharges, including construction activities. The below
table outlines the City of Chula Vista Vision 2020 General Plan policies and objectives
that the proposed project would be consistent with.
68
Table 19: Hydrology Consistency with the City Chula Vista Vision 2020 General Plan
General Plan Objective/Policy
Number Policy Objective or Strategy Project Consistency
Policy E-2.4
Ensure compliance with current federal and
state water quality regulations, including the
implementation of applicable NPDES
requirements and the City’s Pollution
Prevention Policy.
The proposed project would be consistent
with the policy by integrating new
stormwater BMPs to comply with all
NPDES requirements and the City’s
Pollution Prevention Policy. The proposed
project would benefit water quality by
removing sources of heavy metals, oils,
and chemicals on the site.
Policy E-2.5
Encourage and facilitate construction and
land development techniques that minimize
water quality impacts from urban
development.
The proposed project would be consistent
with this policy because it would reduce,
minimize, and treat stormwater pollution
through the use of permanent treatment
control and temporary sediment control
BMPs.
Source(s): Michael Baker International. 2019. 676 Moss Street General Plan Amendment Consistency Analysis. December 17.
Michael Baker International. 2019. 676 Moss Street General Plan Amendment Justification Report. December 17. (Appendix J).
Implementation of the proposed project would require compliance with all the NPDES
requirements including the submittal and certification of plans and details showing both
construction and post-construction BMPs that are integrated into the design of the
project. Additionally, Appendix F of the Draft Initial Study contains an SWQMP, that
outlines construction and non-stormwater discharge, erosion control, sediment controls
(fiber rolls, gravel bags) and source control (construction waste management, litter
control, stockpile pollutants) BMPs, which will be required to be integrated into the
design of the proposed project. The SWQMP is required to be reviewed and approved
by the City Engineer. Impacts related to water quality are considered to be less than
significant with the compliance of all applicable permitting requirements.
(b) Less than significant impact. According to the San Diego County Water
Authority’s 2015 Urban Water Management Plan (2015 UWMP), which provides water
to the Sweetwater Authority who in turn provides water to the project site area, the
Sweetwater Authority’s 2020 water supply is planned to come from a combination of
75.2 percent imported water (supplied by the Metropolitan Water District of Southern
California) and 24.8 percent local water supply (approximately 4.1 percent of which is
groundwater). The 2015 UWMP anticipates having adequate water supplies through
the year 2040, with groundwater production remaining stable, groundwater recovery
supplies increasing yearly, and groundwater replenishment increasing yearly.
The project site does not serve as a primary area of groundwater recharge in its current
condition. The construction of the proposed project would create less impervious area
(approximately 47,045 square feet) than what is currently on the site, as such, according
the SWQMP the proposed project would include areas where stormwater will flow from
impervious to pervious areas. The proposed project would comply with the conditions
69
set forth by the San Diego RWQCB NPDES permitting program. Additionally, the
construction of stormwater facilities and the implementation of the WQMP will ensure
that adverse project impacts to groundwater supplies will be less than significant.
(c)(i) Less than significant impact. The project site lies in an urbanized area of the City
of Chula Vista. Currently and historically, the site has been used for industrial purposes;
therefore, the ground surface has been routinely disturbed by vehicular traffic.
The proposed project is expected to disturb the majority of the ground surface area (+/-)
6.49 acres between 5–12 feet of depth, depending on the portion of the site. Project
grading is expected to include 15,000 cubic yards of raw earthwork to be removed as
these soils are not suitable for construction, and 10,000 cubic yards of imported
earthwork fill.
Projects that disturb 1 or more acres of land are required to obtain coverage under the
General Permit for Discharges of Stormwater Associated with Construction Activity
(Construction General Permit), issued by the State Water Board. The Construction
General Permit requires the development and implementation of a SWPPP. The SWPPP
must list BMPs the proposed project would implement to control erosion and prevent the
conveyance of sediments off-site. Implementation of the conditions of the Construction
General Permit would reduce erosion or siltation impacts resulting from project
construction to less than significant. Once construction work is completed, the impervious
surfaces and landscaping would minimize potential erosion and topsoil loss risks.
In addition to the required permits and SWPPP, the City of Chula Vista has
implemented objectives and policies, outlined within the City Chula Vista Vision 2020
General Plan. The proposed project’s consistency with these objectives and policies is
discussed in the following table:
Table 20: Hydrology Consistency with the City Chula Vista Vision 2020 General Plan
General Plan Objective/Policy Number Policy Objective or Strategy Project Consistency
Objective PFS-1 Ensure adequate and reliable water, sewer,
and drainage service and facilities
The proposed project would be consistent
with the objective because it would have
access to adequate water and sewer
service. The proposed project would
implement stormwater treatment and
retention BMPs to appropriately handle
stormwater flows.
Policy PFS-1.4
For new development, require on-site
detention of stormwater flows such that,
where practical, existing downstream
structures will not be overloaded. Slow runoff
and maximize on-site infiltration of runoff.
The proposed project implements this
policy by proposing a combination of
stormwater detention and filtration BMPs.
Drainage on the site would be improved
from its current condition, which is nearly
completely impervious.
70
Table 20 (cont.): Hydrology Consistency with the City Chula Vista Vision 2020
General Plan
General Plan Objective/Policy Number Policy Objective or Strategy Project Consistency
Policy PFS-2.2
As part of project construction and design,
assure that drainage facilities in new
development incorporate stormwater runoff
and sediment control, including state-of-the-
art technologies, where appropriate.
The proposed project implements this
policy by proposing a combination of
stormwater detention and filtration BMPs.
Drainage on the site would be improved
from its current condition, which is nearly
completely impervious.
Source(s): Michael Baker International. 2019. 676 Moss Street General Plan Amendment Consistency Analysis. December 17.
Michael Baker International. 2019. 676 Moss Street General Plan Amendment Justification Report. December 17. (Appendix J).
Because the proposed project would be consistent with the above policies and
objectives, and the proposed project would comply with the applicable permit
requirements laid out by the City of Chula Vista, impacts to soil erosion or siltation
would be less than significant.
(ii) Less than significant impact. The existing drainage conveyance is urban. According
to the project-specific SWQMP, the existing site drainage patterns would not be altered
and no diversion of flow is proposed. All proposed on-site storm drains would connect
to an existing 12-foot-wide by 10-foot-deep double culvert channel that runs underneath
the project site. Three on-site inlets collect stormwater and would drain from the double
culvert to be conveyed into Telegraph Canyon Creek. The stormwater would ultimately
be discharged north-westerly into the San Diego Bay and into the Pacific Ocean.
Additionally, the proposed project would decrease the amount of impervious surfaces.
Therefore, the proposed project would not increase the rate or amount of surface runoff
that would result in flooding on or off-site, impacts would be less than significant.
(iii) Less than significant impact. According the site specific SWQMP, on-site
stormwater runoff would flow towards inlets across the site, where the stormwater
would be directed towards water quality detention vaults for treatment via a storm drain
network. The project site runoff would be directed to proposed inlets and pipes via
precise grading. Additionally, three proposed sub-grade proprietary BMPs (Bio Clean
Modular Wetlands System [MWS] or similar) would be included for water quality
treatment. After undergoing treatment via the proposed BMPs, project site runoff would
be connected to the culvert from the proposed storm drain.
All proposed on-site storm drains would connect to an existing 12-foot-wide by 10-
foot-deep double box culvert channel that runs underneath the site conveying
stormwater along Telegraph Canyon Creek and ultimately discharging north-westerly
into the San Diego Bay which is linked to the Pacific Ocean. Therefore, the proposed
project would not create or contribute runoff water that would exceed capacity of
existing or planned stormwater drainage systems or provide substantial additional
sources of polluted runoff; impacts are less than significant.
71
(iv) No impact. The proposed project would be comprised of relatively flat parcels
located in an urbanized area surrounded by commercial, residential, and light industrial
uses. Furthermore, the project site is located in Federal Emergency Management
Agency (FEMA) Zone X: a zone that corresponds to areas outside of the 500-year flood
or areas protected from the 100-year flood by levees. In other words, Zone X is defined
as areas with a 0.2 percent annual chance of flood (i.e., a 500-year flood hazard area).
These conditions preclude the possibility of subjecting people or structures to
significant risks related to post-fire slop instability and landslides. Furthermore, the
underground storm drain box culvert that transects the project site is classified as Zone
A, a 100-year flood zone, and would be considered a Special Flood Hazard Area
(SFHA). However, as outlined in the FEMA Flood Insurance Rate Map (FIRM), the
100-year flood would be contained in the underground storm drain box culvert, it is
meant to operate as a flood channel. As the proposed project would not modify the
underground box culvert and would allow the underground storm drain box culvert to
operate in the same condition it currently does and remain in place, there would be no
impact from project implementation.
Therefore, the proposed project would not 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 that would impede or
redirect flood flows.
(d) Less than significant impact with mitigation incorporated. According to the
City of Chula Vista Vision 2020 General Plan, Figure 9-8: Flood and Dam Inundation
Hazards Map, the project site is not located in a dam inundation area. The nearest dam
inundation area is located approximately 1.15 miles south of the project site, near Otay
Valley Regional Park along the Otay River, which is a dam inundation area that would
flood in the event of failure from the Savage (Lower Otay) Dam. Therefore, the
proposed project would not expose people or structures to a significant risk of loss,
injury or death involving flooding, including flooding as a result of the failure of a
levee or dam. Furthermore, the project site is not located in a flood hazard area as
defined by the FEMA FIRMs (1997) as an SFHA inundated by a 100-year flood.
A tsunami is a sea wave generated by an earthquake, landslide, volcanic eruption, or
even by a large meteor hitting the ocean. An event such as an earthquake creates a large
displacement of water resulting in a rise or mounding at the ocean surface that moves
away from this center as a sea wave. Tsunamis generally affect coastal communities
and low-lying (low-elevation) river valleys in the vicinity of the coast. The site is
located approximately 0.7 mile east from the San Diego Bay at an elevation of
approximately 29–34 feet above sea level. Buildings closest to the ocean and near sea
level are most at jeopardy. According to the project-specific Preliminary Geotechnical
Report, due to the elevation of the site with respect to sea level and its distance from
large open bodies of water, the potential of seiches is considered to be low. Additionally,
according to the City of Chula Vista Disaster Preparedness “Your tsunami evacuation
72
map,”52 the project site is not located in a Potential Tsunami Flood Area. As such, there
would be no impact from inundation by tsunami.
Potential risk from mudflow (mudslide, debris flow) exists on sites where slopes are
prevalent. However, the project site does not contain any significant slopes, in addition,
standard grading and soil engineering practices would be required for compliance with
State and local building code standards. As such, there would be no impact from
inundation by tsunami.
A seiche is an earthquake or slide-induced wave that can be generated in an enclosed
body of water. The nearest body of water to the project site is the San Diego Bay,
located approximately 0.7 mile to the west. According to the project-specific
Preliminary Geotechnical Report and City of Chula Vista Vision 2020 General Plan,
due to the elevation (29–34 feet above mean sea level) of the site with respect to sea
level and its distance from large open bodies of water, the potential of seiches is
considered to be low. As such, there would be no impact from inundation by seiche.
Therefore, project implementation would not expose people or structures to potential
hazards from inundation by flood hazard, seiche, or tsunami. Additionally, with
implementation of MM HAZ-1 and HAZ-2, any pollutants on-site would be removed
as part of redevelopment earthwork. Soil samples would be required to be collected
from beneath the structures for testing of VOCs. If present, soil containing elevated
concentrations of VOCs would be required to be excavated and removed from the site.
Thus, impacts would be less than significant with mitigation incorporated.
(e) Less than significant impact. The proposed project would be served by the City’s
stormwater drainage system. Construction activities such as grading, paving, site
improvements, and typical household activity could introduce additional pollutants and
sediment into water runoff and flow into nearby storm drains. As part of the project, a
SWQMP was prepared in compliance with the NPDES requirements of the Clean Water
Act. The SWQMP contains proposed BMPs such as three proposed sub-grade
proprietary BMPs (Bio Clean MWS or similar) that would be included for water quality
treatment. The proposed project would also include construction and non-stormwater
discharge, erosion control, sediment controls (fiber rolls, gravel bags) and source
control (construction waste management, litter control, stockpile pollutants) BMPs,
which will be required to be integrated into the design of the project. Finally, continuous
use and operation of the site would not create or contribute runoff water that would
exceed the capacity of existing stormwater drains on the project site with
implementation of BMPs. Therefore, impacts would be less than significant.
Mitigation Measures: Implementation of MM HAZ-1 and MM HAZ-2 is required.
52 City of Chula Vista. Disaster Preparedness. Website: https://www.chulavistaca.gov/departments/fire-department/emergency-
management/disaster-preparedness. Accessed March 29, 2019.
73
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
XI. Land Use and Planning
Would the project:
a) Physically divide an established community?
b) 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?
Comments:
(a) No impact. The physical division of an established community typically refers to the
construction of a linear feature, such as an interstate highway or railroad tracks, or
removal of a means of access, such as a local bridge that would impact mobility within
an existing community of between a community and outlying area. The proposed project
does not involve any such features and would not remove any means of access or impact
mobility. Furthermore, no streets or sidewalks would be permanently closed as a result
of the development of the project; the proposed project would instead connect the
community through the inclusion of sidewalks on the north side of Moss Street. As such,
the proposed project would not physically divide an established community. Thus, there
would be no impact.
(b) Less than significant impact with mitigation incorporated. The proposed project
would require approval of a General Plan Amendment from Limited Industrial to High
Density Residential and a Zone Change from I-L to R-3. The project site is bounded by
residential land uses to the south and east, and light industrial uses to the north and
west. The proposed project would be compatible with the surrounding residential land
uses. The southern portion of the Chula Vista Bayfront Master Plan Area is located
approximately 1,000 feet to the west of the project site. The Bayfront Master Plan
would develop an industrial business park and an RV park across the I-5 from the
project site. Additional improvements proposed as a part of the Bayfront Master Plan
would include hotels and offices, mixed use commercial parks, and open spaces. No
features of this proposed project would conflict or interfere with the development of
the Bayfront Master Plan.
Furthermore, according to the City Chula Vista Vision 2020 General Plan, the following
objectives and policies apply to the proposed project. The following table outlines the
project’s consistency with these objectives and policies.
74
Table 21: Land Use and Planning Consistency with the City Chula Vista Vision 2020
General Plan
General Plan Objective/Policy Number Policy Objective or Strategy Project Consistency
Objective GPI-2 Provide consistency between the City of Chula Vista Vision 2020 General Plan and subsequent documents, plans, projects, and development.
The proposed project would be inconsistent with the designated zoning of the parcel. A zone change application would be submitted concurrently with the General Plan Amendment Application. If the zone change is completed successfully, the proposed project would be consistent with this objective. The proposed project would be compatible with potential redevelopment on the nearby limited industrial property. It would be compatible with and supportive of a potential trolley station at L Street and would act as an effective transitional use between the single-family residential and higher intensity transit-focused or commercial uses along L Street.
Policy GPI-2.1 Pursue zoning in the City that is consistent with the land use designations of the adopted City of Chula Vista Vision 2020 General Plan.
The proposed project would be consistent with the policy because a zone change would be processed at the same time. Upon successful processing of the General Plan Amendment and zone change, the land uses would align and be consistent with this policy.
Objective LUT-1 Provide a balance of residential and non-residential development throughout the City that achieves a vibrant development pattern, enhances the character of the City, and meets the present and future needs of all residents and businesses.
The proposed project would be consistent with and help provide additional, high-density residential units to meet the current and future housing demands in the City. The proposed project would help enhance the character of the neighborhood by creating more compatible land uses and improving the frontage of Moss Street.
Policy LUT-1.2 Coordinate planning activities and resources to balance land uses, amenities, and civic facilities in order to sustain or improve the quality of life.
The proposed project would be consistent with and create a more balanced set of land uses by adding high-density housing in an area with excellent access to existing and planned civic and public facilities.
Policy LUT-1.4 Seek to achieve an improved balance between jobs and housing in Chula Vista. The proposed project would be consistent with the policy and directly help increase the availability of housing in the City. The proposed project would result in the removal of approximately 30 to 40 jobs and add 141 dwelling units, which would not be enough to significantly alter the jobs-housing balance in the City.
Policy LUT-1.5 Endeavor to create a mixture of employment
opportunities for citizens at all economic
levels.
The proposed project would remove some
employment opportunities; however, the
broader goals of the City of Chula Vista
Vision 2020 General Plan are still
implemented by providing an effective mix of
land uses in the Southwest Planning Area.
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Table 21 (cont.): Land Use and Planning Consistency with the City Chula Vista Vision
2020 General Plan
General Plan Objective/Policy Number Policy Objective or Strategy Project Consistency
Policy LUT-1.6 Attract and maintain land uses that generate
revenue for the City of Chula Vista, while
maintaining a balance of other community
needs, such as housing, jobs, open space,
and public facilities.
The proposed project would be consistent
because it is expected to significantly increase
revenues from existing levels. The existing
property generates approximately $39,300 of
net revenue for the City each year, while the
project is anticipated to generate $76,100 of
net revenue a year. The site currently
generates roughly $48,100 in gross revenue,
while the proposed project would generate
roughly $302,300 in gross revenue, a six-fold
increase.53
Policy LUT-1.7 Provide high-quality public facilities,
services, and other amenities within close
proximity to residents.
The proposed project would be consistent
because it would be located within walking
distance to transit, public services, and
amenities, including schools, parks, bus
stops, and other public facilities.
Policy LUT-1.8 Pursue higher density residential categories
and retail demand that are not being met
within the City.
The proposed project would directly implement
this policy by providing high-density (20
dwelling units per acre), market-rate, for-sale
housing in the City. Many of the nearby high-
density developments are for-rent, and this
proposed project would provide an additional
option for those looking for high-density living
with opportunities for homeownership.
Policy LUT-1.9 Provide opportunities for development of
housing that respond to diverse community
needs in terms of density, size, location, and
cost.
The proposed project would directly
implement this policy by providing a mix of
unit types and sizes to accommodate diverse
housing needs in the City. The variation in the
number of bedrooms, bathrooms, options,
and private open space all factor into
providing a range of home prices and housing
choices. The City’s Housing Division has
stated no affordable units are required in the
development due to the high concentration of
moderate to affordable housing in the area.
Policy LUT-1.10 Maintain an adequate supply of land
designated and zoned for residential use at
appropriate densities to meet housing
needs, consistent with the objective of
maintaining a balance of land uses.
The proposed project would directly
implement this policy by creating new
residential uses at densities compatible with
the adjacent uses, strengthening the balance
of land uses in the immediate surroundings.
The RH designation represents the highest
and best use of the site.
Policy LUT-1.19 Evaluate land use intensities in conjunction
with the review of any zone change and/or
General Plan Amendment to permit density
or modify intensity. Factors to be considered
The proposed project would be consistent
because there are no environmental,
circulation, or other constraints. The proposed
project would meet and match high-density
53 Wery, D. K. (2019). 676 Moss Street General Plan Consistency Analysis, Revised December 17, 2019. Michael Baker International
76
Table 21 (cont.): Land Use and Planning Consistency with the City Chula Vista Vision
2020 General Plan
General Plan Objective/Policy Number Policy Objective or Strategy Project Consistency
include, but are not limited to, the maximum
intensity allowed for the applicable land use
designation in the City of Chula Vista Vision
2020 General Plan, traffic circulation
patterns, environmental constraints, and
compatibility with surrounding land uses.
residential to the east and complement and
strengthen the single-family neighborhood
south of Moss Street. The proposed project
would not have any direct growth inducing
effects on the neighboring industrial properties
because the properties do not share access or
utilities. The high-density residential is
compatible with adjacent limited industrial uses
and would not create any environmental
constraints for neighboring properties.
Objective LUT-4 Establish policies, standards, and
procedures to minimize blighting influences
and maintain the integrity of stable
residential neighborhoods.
The proposed project would directly
implement this objective because it would
remove a blighted and incompatible industrial
property adjacent to residential uses. The
RH/R3 designation is naturally compatible
with the existing RLM/R1 and RH/R3
residential developments adjacent to the site.
Policy LUT-4.2 Protect existing, stable, single-family
neighborhoods through zoning or other
regulations that discourage the introduction
of higher density residential or other
incompatible or potentially disruptive land
uses and/or activities.
The proposed project would be consistent
because it does not add an incompatible or
potentially disruptive land use. The proposed
project would be located across the street
from a single-family neighborhood and would
work to increase the integrity of the
residential neighborhood by removing less
compatible industrial uses and aligning
residential uses on Moss Street.
Policy LUT-4.3 Require that new development, or
redevelopment, through consideration of site
and building design, and appropriate
transition and edge treatments does not
negatively affect the nature and character of
nearby established neighborhoods or
development.
The proposed project would be consistent
with and implement this policy by creating a
more natural transition to a residential
neighborhood by removing industrial uses.
The proposed project would ensure land
uses on both sides of Moss Street are
aligned, preventing isolated and illogical
uses. The frontage improvements on Moss
Street would improve the nature and
character of the nearby established
neighborhood. The existing industrial and
multi-family uses would be adequately
screened and buffered from the project site
through fencing and landscaping.
Objective LUT-5 Designate opportunities for mixed use areas
with higher density housing that is near
shopping, jobs, and transit in appropriate
locations throughout the City.
The proposed project would be consistent
with this objective. While the project site is not
within a mixed-use area, it would be located
close to different shopping, transit, and other
public services. The proposed project would
be within 0.3 mile of the MTS 932 bus route
and within 0.65 mile of the Palomar Street
Trolley. The proposed project would be
supportive of existing transit and mixed-use
77
Table 21 (cont.): Land Use and Planning Consistency with the City Chula Vista Vision
2020 General Plan
General Plan Objective/Policy Number Policy Objective or Strategy Project Consistency
areas by adding residents within walking
distance. The high-density housing would be
supportive of the City of Chula Vista Vision
2020 General Plan South Broadway Corridor
objectives and goals.
Objective LUT-6 Ensure adjacent land uses are compatible
with one another.
The proposed project would be consistent
with the objective because it would not
create any new and incompatible land use
transitions. The proposed project would
create more compatible land uses on Moss
Street by removing industrial lands and
replacing it with high-density housing, which
already occupies the eastern half of Moss
Street. The proposed project would be
compatible with the industrial use at 694
Moss Street, the single-family area south of
Moss Street, and the multi-family Villa
Marina Apartments to the east. The
proposed project would create aligned land
uses on both sides of Moss Street between
Broadway and Industrial Boulevard.
Objective LUT-7 Appropriate transitions should be provided
between land uses
The proposed project would be consistent
with this policy. The proposed project would
not create any new land use transitions and
would minimize the inconsistency of land
uses on the north side of Moss Street. The
existing boundary from RH to IL would be
shifted approximately 600 feet west (the
width of the project site). Additionally, the
proposed project would provide a natural
transition from the single-family
neighborhood to the limited industrial site
north of the project site.
Policy LUT-7.2 Require new or expanded uses to provide
mitigation or buffers between existing uses
where significant adverse impacts could
occur.
The proposed project would be consistent
with this policy because it would not cause
significant adverse impacts to the neighboring
industrial sites or the adjacent apartment
complex. Existing impacts that adversely
affect the neighboring uses would be removed
in favor of more compatible, residential uses.
The proposed project would provide adequate
fencing and landscaping as a buffer along the
property line and would not affect the viability
of adjacent industrial lands.
78
Table 21 (cont.): Land Use and Planning Consistency with the City Chula Vista Vision
2020 General Plan
General Plan Objective/Policy Number Policy Objective or Strategy Project Consistency
Objective LUT-11 Ensure that buildings and related site improvements for public and private development are well-designed and compatible with surrounding properties and districts
The proposed project would be consistent with this objective because it proposes thoughtful and modern architecture that would integrate well into the existing neighborhood. The provision of 346 parking spaces ensures the neighboring single-family homes would not be impacted by parking, and the improved frontage would increase pedestrian accessibility and mobility for residents in the area. Sixty-four guest spaces would be provided, as well as 282 private garage spaces.
Objective LUT-17 Plan and coordinate development to be compatible and supportive of planned transit. The proposed project would be consistent with this policy. The high-density residential designation proposed for the project site is reflective of comparable land uses within 0.25 mile of the E and H Street Trolley Stations. If an L Street Station was proposed or desirable, the proposed condominiums at 676 Moss Street would complement and strengthen the viability of the station. The high-density residential would be compatible with other potential transit-supportive uses, such as Mixed-Use Transit Focus, Urban Core Residential, and Commercial Visitor.
Policy LUT-17.2 Direct higher intensity and mixed-use developments to areas within walking distance of transit, including San Diego Trolley Stations along E, H, and Palomar Streets, and new stations along future transit lines, including Bus Rapid Transit.
The proposed project would be consistent because it would be within 0.3 mile of an MTS 932 bus stop and within 0.65 mile (15-20 minute walk) of the Palomar Street Station.
Objective LUT-35 Revitalize and protect existing stable residential neighborhoods in the Southwest Planning Area from adverse land use impacts
The proposed project would directly implement the objective by enhancing the existing residential neighborhood through the replacement of less compatible land uses with more compatible land uses. The proposed General Plan Amendment would protect the adjacent residential communities from potentially noxious uses and would directly reduce adverse land use impacts. The proposed condominiums would be a better neighbor to both the neighboring industrial and the adjacent residential than the existing industrial uses.
Objective LUT-36 Provide additional housing opportunities to accommodate anticipated population needs. The proposed project would directly implement the goal of providing additional housing opportunities by creating for-sale, high-density residential units in an area well served by public transit and retail facilities. The Housing Division has stated this proposed project is not required to include
79
Table 21 (cont.): Land Use and Planning Consistency with the City Chula Vista Vision
2020 General Plan
General Plan Objective/Policy Number Policy Objective or Strategy Project Consistency
affordable housing nor pay the in-lieu affordable housing fee due to the concentration of affordable housing in the area and the objective of adding higher income households. Higher density housing is needed, and the site is an excellent location for it based on adjacency to other residential areas and its ability to act as a transitional use to industrial uses.
Policy GM 2.1 Achieve and maintain a balance of land uses within the City that assures residential development is complemented by expanded local employment opportunities, retail and commercial services, and recreation and entertainment venues; and that the City-wide mix of land uses provides fiscal balance between those that produce revenues and those that require public expenditures.
The proposed project would be consistent with the goal of achieving a balance of complementing land uses for employment and residential. While the proposed project removes land uses that are potentially revenue generating, the proposed reduction in industrially designated lands would be very small (less than 0.4 percent) and would not have a significant effect on the Citywide mix and balance of uses. The Fiscal Impact Assessment projected the high-density residential would produce approximately 90 percent more annual positive revenue for the City than the existing industrial uses. Annual gross revenue would increase from roughly $48,000 to $302,000. Additionally, the Chula Vista Bayfront Project is proposed immediately west-northwest of the site. The Bayfront Project would create 6,000 permanent jobs and designated spaces for entertainment, retail, and open space, ensuring a balance of land uses in the Southwest Planning Area. The high-density residential at 676 Moss Street would help support and complement the Bayfront Project by providing housing.
Objective GM-3 Create and preserve vital neighborhoods The proposed project would directly implement the policy by increasing the integrity of the existing residential neighborhood through creating more compatible and consistent land uses along Moss Street. The residential neighborhood would be strengthened through the removal of the blighted and unsightly industrial uses. The proposed project would act as a natural transition from the single-family residential to the limited industrial north of the site. Additionally, the frontage improvement and sidewalk construction would make the neighborhood more accessible and friendlier to pedestrians.
Source: Michael Baker International. 2019. 676 Moss Street General Plan Amendment Consistency Analysis. December 17.
Michael Baker International. 2019. 676 Moss Street General Plan Amendment Justification Report. December 17. (Appendix J).
80
Therefore, with discretionary approval from the City, the proposed project would be
consistent with surrounding land uses and impacts would be less than significant.
The analysis contained in this Draft Initial Study addresses the potential conflict with
any applicable land use plan, policy, or regulation of an agency with jurisdiction over
the project adopted for the purpose of avoiding or mitigating an environmental effect.
Based on this analysis, it was determined that the proposed project would potentially
have significant impacts on air quality, biological resources, cultural resources, geology
and soils, and hazards and hazardous materials. The proposed project is located in the
SCAQMD and MM AIR-1 is required to reduce emissions to below the maximum daily
thresholds. MM BIO-1 is required to reduce impacts to nesting birds. MM CUL-1 and
MM CUL-2 are required to reduce impacts to any inadvertent culturally significant
discoveries. MM GEO-1 and MM GEO-2 are required to reduce impacts related to
expansive soils and paleontological resources, respectively. MM GHG-1 is required
purchase of voluntary carbon credits by the Project Applicant. MM HAZ-1, MM HAZ-
2, and MM HAZ-3 are required to reduce the impacts of any potential hazardous
materials on-site. MM NOI-1 is required to reduce traffic and railroad noise impacts to
the proposed project. MM NOI-2 is required to reduce the impacts of construction
noise. Therefore, based on the analysis conducted in the Draft Initial Study, it was
determined that the proposed project was not in conflict with any adopted land use
plans, policies, or regulations adopted for the purpose of avoiding or mitigating an
environmental effect.
Mitigation Measures:
Implementation of the following mitigation measures is required:
MM AIR-1
MM BIO-1
MM CUL-1 and MM CUL-2
MM GEO-1 and MM GEO-2
MM GHG-1
MM HAZ-1,MM HAZ-2, and MM HAZ-3
MM NOI-1 and NOI-2
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
XII. Mineral Resources
Would the project:
a) Result in the loss of availability of a known
mineral resource that would be of value to the
region and the residents of the State?
81
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
b) Result in the loss of availability of a locally-
important mineral resource recovery site
delineated on a local general plan, specific plan
or other land use plan?
Comments:
(a) No impact. According to the California Department of Conservation California
Geological Survey and the City of Chula Vista Vision 2020 General Plan, Figure 9-4
MRZ-2 Area map, the project site is not located within a Mineral Resource Zone. 54,55
Therefore, the proposed project would not result in the loss of availability of a known
mineral resource that would be of value to the region and the residents of the State. As
such, there would be no impact.
(b) No impact. As outlined above in Impact 2.11(b), the City of Chula Vista Vision 2020
General Plan, Figure 9-4 MRZ-2 Area Map, the project site is not located in a Mineral
Resource Zone.56 Therefore, the proposed project would not result in the loss of
availability of a locally-important mineral resource recovery site delineated on a local
general plan, specific plan or other land use plan. As such, there would be no impact.
Mitigation Measures: None.
Issues :
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
XIII. Noise
Would the project result in:
a) 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?
b) 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?
54 California Department of Conservation. 1996. California Geological Survey, Urbanization of Designated Areas Otay Valley, Tijuana
River, and Border Highlands Resource Area. Open File Report (OFR) 96-04, Plate 14. Website:
ftp://ftp.consrv.ca.gov/pub/dmg/pubs/ofr/OFR_96-04. Accessed November 9, 2019.
55 City of Chula Vista. 2019. City of Chula Vista Vision 2020 General Plan. Chapter 9: Environmental Element. Website:
https://www.chulavistaca.gov/home/showdocument?id=9341. Accessed November 9, 2019.
56 Ibid.
82
Issues :
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
c) Generation of excessive groundborne vibration
or groundborne noise levels?
d) 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?
Comments:
This Noise Impact Analysis has been prepared by FCS to determine the off-site and on-site noise
impacts associated with the proposed project. The noise monitoring locations, measurements,
and modeling input and output files are included in Appendix G of this Draft IS/MND.
Characteristics of Noise
Noise is defined as unwanted sound. Sound levels are usually measured and expressed in
decibels (dB), with 0 dB corresponding roughly to the threshold of hearing. Most of the sounds
that we hear in the environment do not consist of a single frequency, but rather a broad band
of frequencies, with each frequency differing in sound level. The intensities of each frequency
add together to generate a sound. Noise is typically generated by transportation, specific land
uses, and ongoing human activity.
The standard unit of measurement of the loudness of sound is the dB. The 0 point on the dB
scale is based on the lowest sound level that the healthy, unimpaired human ear can detect.
Changes of 3 dB or less are only perceptible in laboratory environments. A change of 3 dB is
the lowest change that can be perceptible to the human ear in outdoor environments. While a
change of 5 dBA is considered to be the minimum readily perceptible change to the human ear
in outdoor environments.
Since the human ear is not equally sensitive to sound at all frequencies, the dBA was derived to
relate noise to the sensitivity of humans, it gives greater weight to the frequencies of sound to
which the human ear is most sensitive. The A-weighted sound level is the basis for a number of
various sound level metrics, including the day/night sound level (Ldn) and the Community Noise
Equivalent Level (CNEL), both of which represent how humans are more sensitive to sound at
night. In addition, the equivalent continuous sound level (Leq) is the average sound energy of
time-varying noise over a sample period and the Lmax is the maximum instantaneous noise level
occurring over a sample period.
83
Existing Noise Sources
The proposed project would replace several industrial uses currently on the site. Surrounding the
project site are commercial and industrial land uses to the north, a school bus parking lot to the
northwest, multi-family residential homes to the east, single-family residential homes to the
south (across Moss Street), and manufacturing land uses to the southwest. To the west of the site,
running in north-south directions, are railroad tracks, Industrial Boulevard, and I-5.
The existing noise levels on the project site were documented through a noise monitoring effort
performed at the project site. Noise monitoring location and measurements are described in detail
in Appendix G. Three short-term noise measurements (15 minutes each) were taken on
Wednesday, December 12, 2018, starting at 1:05 p.m. and ending at 2:36 p.m., during the midday
peak noise hour.
The short-term measurement (ST-1) was conducted at the eastern boundary of the project site,
approximately 250 feet north of Moss Street, at the northern end of the carport. The resulting
measurement showed that ambient noise levels at this location averaged 60.1 dBA Leq. As was
observed by the technician at the time of the noise measurement, the dominant noise source in
the project vicinity was heavy machinery operating on the adjacent industrial site.
The second short-term measurement (ST-2) was conducted at the southern boundary of the
project site, on the southwest corner of Moss Street and Colorado Avenue. The resulting
measurement showed that ambient noise levels at this location averaged 70.1 dBA Leq. As was
observed by the technician at the time of the noise measurement, the dominant noise sources in
the project vicinity were from vehicular traffic along Moss Street and railway signals.
The short-term measurement (ST-3) was conducted on the western boundary of the project site,
adjacent to the railroad approximately 280 feet north of Moss Street. The resulting measurement
showed that ambient noise levels at this location averaged 69.6 dBA Leq. As was observed by the
technician at the time of the noise measurement, the dominant noise sources in the project
vicinity were from vehicular traffic on I-5, Industrial Boulevard, and Moss Street, and train noise
from the MTS.
Regulatory Framework
The project site is located within the City of Chula Vista. The City of Chula Vista addresses
noise in the Noise Section of the Environmental Element of their Vision 2020 General Plan57
and in the City of Chula Vista Municipal Code.58
City of Chula Vista Vision 2020 General Plan
The City of Chula Vista establishes Exterior Land Use/Noise Compatibility Guidelines (shown
in Table 22) in its Vision 2020 General Plan. The land use category listed in the City’s Exterior
57 City of Chula Vista. 2005. City of Chula Vista Vision 2020 General Plan. Environmental Element. December. Website:
https://www.chulavistaca.gov/departments/development-services/planning/general-plan. Accessed November 16, 2018.
58 City of Chula Vista, 2018. Chula Vista Municipal Code. Website:
https://www.codepublishing.com/CA/ChulaVista/#!/ChulaVistaNT.html. Accessed November 16, 2018.
84
Land Use/Noise Compatibility Guidelines that most closely applies to the proposed project is
residential. Under this designation, 65 dBA CNEL is generally considered to be the noise level
that is compatible for this type of new land use development. Furthermore, the consistency of
the proposed project with the City of Chula Vista Vision 2020 General Plan policies and
objectives is shown in Table 23.
Table 22: Exterior Land Use/Noise Compatibility Guidelines
Category
Annual CNEL in Decibels
50 55 60 65 70 75
Land Use
Residential
Schools, Libraries, Daycare Facilities, Convalescent
Homes, Outdoor Use Areas, and Other Similar Uses
Considered Noise Sensitive
Neighborhood Parks, Playgrounds
Community Parks, Athletic Fields
Offices and Professional
Places of Worship (excluding outdoor use areas)
Golf Course
Retail and Wholesale Commercial, Restaurants, Movie
Theaters
Industrial, Manufacturing
Table 23: Noise Consistency with the City of Chula Vista Vision 2020 General Plan
General Plan Objective/Policy Number Policy Objective or Strategy Project Consistency
Objective E-21 Protect people from excessive noise
through careful land use planning and the
incorporation of appropriate mitigation
techniques.
This proposed project is consistent with
the objective of protecting people from
excessive noise. Though there is a railroad
adjacent to the site, setbacks and a
soundwall will be employed to decrease
noise impacts to the proposed
development. The site is not anticipated to
generate any permanent and significant
sources of noise that will impact the
neighboring residents. The proposed
project will shield and reduce noise
impacts for adjacent residential properties.
Source(s): Michael Baker. 2019. 676 Moss Street General Plan Amendment Consistency Analysis. December 17.
Michael Baker. 2019. 676 Moss Street General Plan Amendment Justification Report. December 17.
85
City of Chula Vista Municipal Code
The City of Chula Vista establishes its noise performance standards in the noise ordinances of
its Municipal Code. The City has established an exterior noise limit of 50 dBA Leq hourly
average during nighttime hours, and a limit of 60 dBA Leq hourly average during daytime hours
for receiving multi-family residential land uses. However, the City provides an exemption to
these noise standards for construction and demolition activities.
In addition, the Municipal Code restricts noise producing construction activities to the hours
of 7:00 a.m. to 10:00 p.m. on Mondays through Fridays, and 8:00 a.m. to 10:00 p.m. on
Saturdays and Sundays.
Impact Analysis
(a) Noise Land Use Compatibility
Less than significant impact with mitigation incorporated. The City of Chula Vista
establishes Exterior Land Use-Noise Compatibility Guidelines in the Noise Element of
its General Plan.59 These guidelines reflect the levels of noise exposure that are
generally considered to be compatible with various types of land uses. These standards
are shown previously in Table 23. For a discussion of the characteristics of noise and
further information regarding the applicable noise regulatory framework, refer to the
Noise impact discussion in Section XIII of this document.
The land use category listed in the City’s Exterior Land Use/Noise Compatibility
Guidelines that most closely applies to the proposed project is “Residential.” Under
this designation, noise environments up to 65 dBA CNEL are generally considered
compatible for this type of new land use development.
The dominant noise sources in the project vicinity were from vehicular traffic on I-5,
Industrial Boulevard, and Moss Street, and train noise from the MTS. To document noise
levels from these sources, an ambient noise monitoring effort was conducted and traffic
noise modeling was performed.
The Federal Highway Administration (FHWA) highway traffic noise prediction model
(FHWA RD-77-108) was used to evaluate opening year and buildout traffic noise
conditions in the vicinity of the project site. The projected traffic noise levels along
roadways adjacent to the project site were analyzed to determine compliance with the
City’s land use compatibility standards. The resultant noise levels were weighed and
summed over a 24-hour period in order to determine the CNEL values. The traffic noise
modeling input and output files are included in Appendix G of this document. Table 24
shows a summary of the traffic noise levels for Existing, Existing Plus Project, year 2045
Without Project, and year 2045 Plus Project conditions as measured at 50 feet from the
centerline of the outermost travel lane.
59 City of Chula Vista. 2005. City of Chula Vista Vision 2020 General Plan. Environmental Element. December. Website:
https://www.chulavistaca.gov/departments/development-services/planning/general-plan. Accessed November 16, 2018.
86
Table 24: Traffic Noise Model Results Summary
Roadway Segment
CNEL (dBA) 50 feet from Centerline of Outermost Lane
Existing (dBA) CNEL
Existing Plus Project (dBA) CNEL
Year 2045
Without Project (dBA) CNEL
Year 2045
Plus
Project (dBA) CNEL
Industrial Boulevard—L Street to I-5 interchange 65.0 65.2 66.1 66.2
Industrial Boulevard—I-5 interchange to Moss Street 65.7 65.9 69.2 69.3
Industrial Boulevard—Moss Street to Naples Street 63.0 63.1 66.2 66.2
Moss Street—Industrial Boulevard to Colorado Avenue 60.0 60.0 60.4 60.4
Moss Street—Colorado Avenue to Woodlawn Avenue 59.7 59.7 60.1 60.1
I-5—north of Palomar Street 80.1 80.1 80.6 80.6
Note:
1 Modeling results do not take into account mitigating features such as topography, vegetative screening, fencing, building design, or
structure screening. Rather it assumes a worst case of having a direct line of site on flat terrain.
Source: FCS 2018.
The highest traffic noise levels on roadway segments adjacent to the project site would
occur along Industrial Boulevard under year 2045 Plus Project traffic conditions. Under
these traffic conditions, projected traffic noise levels along Industrial Boulevard
between the I-5 interchange and Moss Street, would range up to 69.3 dBA CNEL as
measured at 50 feet from the centerline of the outermost travel lane. Traffic noise levels
from the I-5 adjacent to the project site would range up to 80.6 dBA CNEL as measured
at 50 feet from the centerline of the outermost travel lane. The façade of the nearest
proposed residential building at the project site would be setback approximately 140
feet from the centerline of Industrial Boulevard. In addition, the project proposes
construction of a minimum 6-foot high soundwall along the entire western border of
the project site. At this distance and with shielding provided by the soundwall, traffic
noise levels from traffic on I-5 and Industrial Boulevard would range up to
approximately 55 dBA CNEL at the ground floor façade of the nearest proposed
residential building. However, second and third floor façades and balconies on this
closest building unit would still have a direct line of sight to the roadway, and would
be exposed to traffic noise levels ranging up to 61 dBA CNEL.
The MTS railroad line is also located west of the project site between Industrial
Boulevard and the project site. The façade of the nearest proposed residential building at
the project site would be setback approximately 55 feet from the centerline nearest
through-travel of the railroad track. In order to provide a conservative estimate of the
potential railroad noise impacts to the proposed project, the CREATE railroad noise
model was used.60 The model assumed a maximum of eight light rail train passings per
60 HMMH, Inc., 2006. CREATE Noise Model Based on Federal Transit Administration (FTA) General Transit Noise Assessment,
Developed for the Chicago CREATE Project.
87
hour during the day, and one freight train passing per hour every night. This is a
conservative estimate, because, based on available data, there are typically only four
freight train passings total per night. The modeling assumed trains traveling an average
of 40 miles per hour (mph), with no shielding or barriers assumed. The modeling
input/output data is provided in Appendix G of this document. The modeling results show
that these modeled train activities would result in an average 67 dBA CNEL as measured
at the nearest façade on the project site, without shielding.
The methodology of the FTA for calculating locomotive warning horn noise levels61
was also used to calculate potential impacts from the freight train horn use on their
approach to the Moss Street at-grade crossing. The modeling input/output files are
provided in Appendix G of this document. The calculations assumed up to four freight
train passings per night, The results show that the calculated train horn noise levels are
74.7 dBA CNEL as measured 50 feet from the railroad tracks, or 73.9 dBA CNEL at
the nearest façade of the proposed project, with no reduction for shielding.
It should be noted that the project proposes to construct a 6-foot-high soundwall along
the entire western border of the project site. This would effectively block the line of
sight from roadway noise sources and the first floor (ground level) of the proposed
residential units, resulting in a minimum 6 dBA reduction in traffic noise levels.
However, because part of the noise source from trains is above the train tracks (engine
noise, rail-car rattling noise, etc.) this wall would be expected to result in only a 5 dBA
reduction in railroad noise levels as measured at the first floor level of the proposed
residential units.
The combined traffic and railroad noise levels as measured at the nearest upper floor
façades (second floors and above) and at the nearest ground floor façade, are
summarized in Table 25 below.
Table 25: Combined Traffic and Railroad Noise Model Results Summary
Roadway/Railway Segment
Calculated CNEL (dBA) as
Measured at the Nearest Upper Floor Façade
Calculated CNEL (dBA) as
Measured at the Nearest Ground Floor Façade
Industrial Boulevard—I-5 interchange to Moss Street 61.3 55.3
I-5—north of Palomar Street 64.1 58.1
MTS and Freight-line Railroad Activity 67.0 62.0
Freight-line Railroad Horn Noise 73.9 68.9
Combined Traffic and Railroad Noise Levels 75.2 70.1
Source: FCS 2019.
61 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual, September.
88
Based on these results, the nearest ground-floor façades would be exposed to combined
mobile source noise levels ranging up to 70.1 dBA CNEL. These calculated combined
traffic and railroad noise levels are in excess of the City’s exterior land use
compatibility standard of 65 dBA CNEL. At a distance of 110 feet from the railroad
centerline, these noise levels would attenuate to below 65 dBA CNEL as measured at
ground-floor areas. Therefore, effective mitigation must be incorporated into the
project for all ground level façades within 110 feet of the railroad tracks to ensure that
the interior noise level standard of 45 dBA CNEL is achieved and maintained. Based
on the EPA’s Protective Noise Levels, with a combination of walls, doors, and
windows, standard construction in accordance with building code requirements for
multi-family residential developments would provide 25 dBA in exterior-to-interior
noise reduction with windows closed and 15 dBA or more with windows open. With
windows open, the interior noise levels of the proposed units nearest to and facing the
railroad line would not meet the State’s interior noise standard of 45 dBA CNEL for
indoor sleeping areas (70.1 dBA–15 dBA = 55.1 dBA). Even inclusion of alternate
ventilation systems such as mechanical air conditioning which would allow windows
to remain closed for prolonged periods of time, would not sufficiently reduce traffic
and railroad noise levels to meet the interior noise level standard of 45 dBA CNEL
(70.1 dBA–25 dBA = 45.1 dBA). Therefore, upgraded wall and window assemblies
would be required for all ground floor façades that face the railroad and that are located
within 110 feet of the railroad tracks. The combined wall and window assembly should
be upgraded from standard building code requirements to have a minimum Standard
Transmission Class (STC) rating of 28-STC. This will provide sufficient noise
reduction, with an adequate margin of safety, to ensure the 45 dBA CNEL interior noise
level standard is maintained (70.1 dBA–28 dBA = 42.1 dBA). Prior to issuance of
building permits, the applicant shall have a professional acoustic consultant review the
final design plans to provide assurance to City staff that the design would provide the
required STC rating.
Second and third floor façades of the closest building (Building 1 shown on Exhibit 12)
with direct line of sight to the railroad tracks would be exposed to combined traffic and
railroad noise levels ranging up to 75.2 dBA CNEL. These calculated unshielded
combined traffic and railroad noise levels are in excess of the City’s exterior land use
compatibility standard of 65 dBA CNEL as measured at the nearest proposed façade of
the residential units. At a distance of 180 feet from the railroad centerline, these
unshielded noise levels would attenuate to below 65 dBA CNEL. Therefore, effective
mitigation must be incorporated into the project for all upper level façades with a direct
line of sight to and located within 180 feet of the railroad tracks (Buildings 1, 2, and 3
shown on Exhibit 12) to ensure that the interior noise level standard of 45 dBA CNEL is
achieved and maintained. Based on the EPA’s Protective Noise Levels, with a
combination of walls, doors, and windows, standard construction in accordance with
building code requirements for multi-family residential developments would provide 25
dBA in exterior-to-interior noise reduction with windows closed and 15 dBA or more
with windows open. With windows open, the interior noise levels of the proposed units
89
nearest to and facing the railroad line would not meet the State’s interior noise standard
of 45 dBA CNEL for indoor sleeping areas (75.2 dBA–15 dBA = 60.2 dBA). Even
inclusion of alternate ventilation systems such as mechanical air conditioning which
would allow windows to remain closed for prolonged periods of time, would not
sufficiently reduce traffic and railroad noise levels to meet the interior noise level
standard of 45 dBA CNEL (75.2 dBA–25 dBA = 50.2 dBA). Therefore, upgraded wall
and window assemblies would be required for all upper façades (second floor and above)
that have a direct line of sight of the railroad tracks and that are located within 180 feet
of the railroad tracks. The combined wall and window assembly should be upgraded from
standard building code requirements to have a minimum STC rating of 33-STC. This will
provide sufficient noise reduction, with an adequate margin of safety, to ensure the 45
dBA CNEL interior noise level standard is maintained (75.2 dBA–33 dBA = 42.2 dBA).
Prior to issuance of building permits, the applicant shall have a professional acoustic
consultant review the final design plans to provide assurance to City staff that the design
would provide the required STC rating. Therefore, implementation of MM NOI-1 is
required to ensure the project would not conflict with the City’s adopted Exterior Land
Use-Noise Compatibility Guidelines and policy and would reduce combined traffic and
railroad noise impacts to the proposed project to be less than significant.
It should also be noted, as shown in Exhibit 12, proposed rooftop deck areas nearest to
the railroad would be exposed to combined mobile source noise levels in excess of 65
dBA CNEL. The shielding provided by the proposed parapet wall that would block a
direct line of sight to the outdoor use areas of these rooftop decks would reduce the
combined mobile source noise levels to 69 dBA CNEL at the nearest rooftop deck.
Combined mobile source noise levels would attenuate to below 65 dBA CNEL for
rooftop decks located more than 90 feet from the railroad tracks. However, as indicated
in the discussion above, implementation of MM NOI-1 would ensure that the interior
noise level standard is met in all proposed residential units.
Finally, as is also shown in Exhibit 12, proposed ground-floor outdoor use areas nearest
to the railroad would be exposed to combined mobile source noise levels ranging up to
70 dBA CNEL, exceeding the City’s exterior land use compatibility standard of 65 dBA
CNEL. At a distance of 110 feet from the railroad centerline, these noise levels would
attenuate to below 65 dBA CNEL as measured at ground-floor outdoor use areas. As
shown in Exhibit 12, these impacted areas have been excluded from the project’s open
space calculations.
However, all outdoor use areas located more than 110 feet from the railroad centerline
would experience combined traffic noise levels below 65 dBA CNEL, meeting the
City’s exterior land use compatibility standard. In addition, all proposed courtyard areas
and courtyard-facing patios and balconies within 110 feet of the railroad centerline
would be shielded by the proposed structures and would experience combined traffic
noise levels of less than 65 dBA CNEL, also meeting the City’s exterior land use
compatibility standard. Therefore, as shown in Exhibit 12, the calculated open space
90
areas that would meet the City’s exterior noise standard totals 76,434 square feet (more
than 542 square feet per home). The City’s minimum requirement is 504 square feet
per home.
Thus, the project provides more than the City’s minimum required noise-protected
outdoor use area and no mitigation is required for the attenuation of exterior noise
impacts at outdoor use areas.
(b) Short Term Construction Impacts
Less than significant impact with mitigation incorporated. A significant impact
would occur if construction activities would result in generation of a substantial
temporary increase in ambient noise levels that would result in annoyance or sleep
disturbance of nearby sensitive receptors. Noise impacts from construction activities
associated with the proposed project would be a function of the noise generated by
construction equipment, equipment location, sensitivity of nearby land uses, and the
timing and duration of the construction activities.
Two types of short-term noise impacts would occur during site preparation and project
construction. The first type would result from the increase in traffic flow on local streets,
associated with the transport of workers, equipment, and materials to and from the project
site. The transport of workers and construction equipment and materials to the project
site would incrementally increase noise levels on access roads leading to the site. Because
workers and construction equipment would use existing routes, noise from passing trucks
would be similar to existing vehicle-generated noise on these local roadways. Typically,
a doubling of the Average Daily Traffic (ADT) hourly volumes on a roadway segment is
required in order to result in an increase of 3 dBA in traffic noise levels; which, as
discussed in the characteristics of nose discussion above, is the lowest change that can
be perceptible to the human ear in outdoor environments. Project-related construction
trips would not be expected to double the hourly traffic volumes along any roadway
segment in the project vicinity. For these reasons, short-term intermittent noise from
trucks would be minor when averaged over an hour or longer intervals. Therefore, short-
term construction-related noise impacts associated with worker commute and equipment
transport to the project site would not exceed applicable significance thresholds and
would be less than significant.
The second type of short-term noise impact is related to noise generated during
construction on the project site. Construction noise levels are rarely steady in nature
and, often, fluctuate depending on the type and number of equipment being used at any
given time. In addition, there could be times where large equipment is not operating
and noise would be at or near normal ambient levels. Construction is completed in
discrete steps, each of which has its own mix of equipment and its own noise
characteristics. These various sequential phases would change the character of the noise
generated on the site and, therefore, the noise levels surrounding the site as construction
progresses. Despite the variety in the type and size of construction equipment,
91
similarities in the dominant noise sources and patterns of operation allow construction
related noise ranges to be categorized by work phase.
The site preparation phase, which includes excavation and grading activities, tend to
generate the highest noise levels because the noisiest construction equipment is
earthmoving equipment. Earthmoving equipment includes excavating machinery and
compacting equipment, such as bulldozers, draglines, backhoes, front loaders, roller
compactors, scrapers, and graders. Typical operating cycles for these types of
construction equipment may involve 1 or 2 minutes of full power operation followed
by 3 or 4 minutes at lower power settings.
Construction of the proposed project is expected to require the use of front-end loaders,
excavators, haul trucks, water trucks, concrete mixer trucks, and pickup trucks. The
maximum noise level generated by each concrete mixing truck is assumed to be 85
dBA Lmax at 50 feet from this equipment.62 Each front-end loader would also generate
85 dBA Lmax at 50 feet. The maximum noise level generated by excavators is
approximately 85 dBA Lmax at 50 feet. Each doubling of sound sources with equal
strength increases the noise level by 3 dBA.
A conservative reasonable assumption is that this equipment would operate
simultaneously and continuously over at least a 1-hour period in the vicinity of the
closest existing residential receptors, but would move linearly over the project site as
they perform their earth moving operations, spending a relatively short amount of time
adjacent to any one receptor. Assuming that each piece of construction equipment
operates at some distance from the other equipment, a reasonable worst-case combined
noise level during this phase of construction would be 90 dBA Lmax at a distance of 50
feet from the acoustic center of a construction area. The acoustical center reference is
used because construction equipment must operate at some distance from one another
on a project site, and the combined noise level as measured at a point equidistant from
the sources (acoustic center) would be the worst-case maximum noise level. These
operations would be expected to result in a reasonable worst-case hourly average of 86
dBA Leq at a distance of 50 feet from the acoustic center of a construction area.
The closest noise-sensitive receptors to the proposed project site are multi-family
residences located directly east of the project site. The closest residence would be
located approximately 110 feet from the acoustic center of construction activity where
multiple pieces of heavy construction equipment would potentially operate at the
project site. At this distance, worst-case construction noise levels could range up to
approximately 83 dBA Lmax, intermittently, and could have an hourly average of up to
79 dBA Leq, at the façade of the nearest multi-family residential home.
The next closest noise-sensitive receptors to the proposed project site are single-family
residences located directly south of the project site. The closest residence would be
62 Federal Highway Administration (FHWA). 2006. Highway Construction Noise Handbook. August.
92
located approximately 130 feet from the acoustic center of construction activity where
multiple pieces of heavy construction equipment would potentially operate at the project
site. At this distance, worst-case construction noise levels could range up to
approximately 82 dBA Lmax, intermittently, and could have an hourly average of up to 78
dBA Leq, at the façade of the nearest single-family residential home.
Although there could be a relatively high single event noise exposure potential causing
an intermittent noise nuisance, the effect of construction activities on longer-term
(hourly or daily) ambient noise levels would be small but could result in a temporary
increase in ambient noise levels in the project vicinity that could result in annoyance or
sleep disturbance of nearby sensitive receptors. Limiting construction activities to the
daytime hours would reduce the effects of noise levels produced by these activities on
longer-term (hourly or daily) ambient noise levels, and would reduce potential impacts
that could result in annoyance or sleep disturbances at nearby sensitive receptors.
Therefore, noise producing construction activities shall be restricted to the daytime
hours of 7:00 a.m. to 10:00 p.m. on Mondays through Fridays, and 8:00 a.m. to 10:00
p.m. on Saturdays and Sundays. Restricting construction activities to these stated time-
periods, as well as implementing the best management noise reduction techniques and
practices outlined in MM NOI-2, would ensure that construction noise would not result
in a substantial temporary increase in ambient noise levels that would result in
annoyance or sleep disturbance of nearby sensitive receptors. Therefore, with
implementation of MM NOI-2, temporary construction noise impacts would be
reduced to less than significant.
Operational/Stationary Source Noise Impacts
Less than significant impact. A significant impact would occur if operational noise
levels generated by stationary noise sources at the proposed project site would result in
a substantial permanent increase in ambient noise levels in excess of any of the noise
performance thresholds established in the City’s Municipal Code. As noted in the
characteristics of noise discussion, audible increases in noise levels generally refer to a
change of 3 dBA or more, as this level has been found to be barely perceptible to the
human ear in outdoor environments. A change of 5 dBA is considered the minimum
readily perceptible change to the human ear in outdoor environments. Therefore, for
purposes of this analysis, an increase of greater than 3 dBA above existing ambient
noise levels would be considered a substantial permanent increase in ambient noise
levels.
The City has established an exterior noise limit of 50 dBA Leq hourly average during
nighttime hours, and a nose limit of 60 dBA Leq hourly average during daytime hours,
for receiving multi-family residential land uses. However, the City notes that if the
existing ambient noise level exceeds these standards, the ambient noise level shall be
considered the standard.
93
The proposed project would generate noise from parking lot activities and from new
exterior mechanical equipment sources, such as mechanical ventilation systems on
proposed multi-family residential uses.
Parking Lot Activities
Parking lot activities include vehicles cruising at slow speeds, doors shutting, or cars
starting, would generate noise levels of approximately 60 dBA to 70 dBA Lmax at 50
feet. A conversation between two persons at a distance of 3 to 5 feet apart would
generate a noise level of 60 dBA Leq at 5 feet, or approximately 40 dBA Leq as measured
at 50 feet. The closest noise-sensitive receptor to the proposed parking areas at the
project site is a single-family residence located along Moss Street east of Colorado
Avenue. This residence is located approximately 130 feet from the acoustic center of
the nearest proposed parking area on the project site. At this distance, parking lot
activity would result in intermittent noise levels ranging up to 62 dBA Lmax at the
property line of the nearest residence. The existing measured ambient noise level at the
nearest residential receptor is documented by the short-term noise measurement ST-2
to range up to 70.1 dBA Leq, with maximum noise levels of 92.3 dBA Lmax. Therefore,
parking lot noise levels would not exceed existing ambient noise levels as measured at
the nearest residential receptor, and would not result in a substantial permanent increase
in ambient noise levels in the project vicinity. Therefore, the impact of noise produced
by project-related parking lot activities to off-site sensitive receptors would be less than
significant.
Mechanical Equipment Operations
At the time of preparation of this analysis, details were not available pertaining to
proposed mechanical ventilation systems for the proposed project; therefore, a
reference noise level for typical mechanical ventilation systems was used. Noise levels
from typical residential mechanical ventilation equipment are anticipated to range up
to approximately 60 dBA Leq at a distance of 25 feet. Proposed mechanical ventilation
systems could be located as close as 70 feet from the nearest off-site noise-sensitive
receptor, which are the multi-family residential homes located east of the project site.
Additionally, the proposed 6-foot high soundwall around the project site will block the
line of site between mechanical ventilation noise and the nearest residential receptor,
providing a minimum 6 dBA of noise shielding attenuation. At this distance and with
the attenuation provided by shielding, noise generated by mechanical ventilation
equipment would be reduced to below 45 dBA Leq at the nearest multi-family
residential receptor. These noise levels would not exceed the City’s nighttime noise
performance threshold of 45 Leq at the property line of the nearest existing noise-
sensitive land use. In addition, the existing measured ambient noise level at the nearest
residential receptor is documented by the short-term noise measurement ST-1 averaged
60.1 dBA Leq. Therefore, noise levels from proposed mechanical ventilation equipment
operations would not exceed existing ambient noise levels as measured at the nearest
residential receptor, and would not result in a substantial permanent increase in ambient
noise levels in the project vicinity. Therefore, the impact of noise produced by proposed
94
mechanical ventilation equipment operations to off-site sensitive receptors would be
less than significant.
Operational/Mobile Source Noise Impacts
Less than significant impact. A significant impact would occur if implementation of
the proposed project would result in a substantial increase in traffic noise levels compared
with traffic noise levels existing without the project. As noted in the characteristics of
noise discussion, audible increases in noise levels generally refer to a change of 3 dBA
or more, as this level has been found to be barely perceptible to the human ear in outdoor
environments. A change of 5 dBA is considered the minimum readily perceptible change
to the human ear in outdoor environments. Therefore, for purposes of this analysis, an
increase of greater than 3 dBA above existing traffic noise levels would be considered a
substantial permanent increase in traffic noise levels.
The FHWA highway traffic noise prediction model (FHWA RD-77-108) was used to
evaluate opening year and buildout traffic noise conditions in the project vicinity. The
resultant noise levels were weighed and summed over a 24-hour period in order to
determine the CNEL values. The traffic noise modeling input and output files are
included in Appendix G of this document. Table 26 shows a summary of the traffic
noise levels for Existing, Existing Plus Project, year 2045 Without Project, and year
2045 Plus Project conditions as measured at 50 feet from the centerline of the outermost
travel lane.
Table 26: Traffic Noise Model Results Summary
Roadway Segment
CNEL (dBA) 50 feet from Centerline of Outermost Lane
Existing (dBA) CNEL
Existing Plus Project (dBA) CNEL
Increase
over Existing (dBA) CNEL
Year 2045
Without
Project (dBA) CNEL
Year 2045
Plus
Project (dBA) CNEL
Increase
over Year
2045
Without Project (dBA) CNEL
Industrial Boulevard—L Street to
I-5 interchange
65.0 65.2 0.2 66.1 66.2 0.1
Industrial Boulevard—I-5
interchange to Moss Street
65.7 65.9 0.2 69.2 69.3 0.1
Industrial Boulevard—Moss
Street to Naples Street
63.0 63.1 0.1 66.2 66.2 0.0
Moss Street—Industrial
Boulevard to Colorado Avenue
60.0 60.0 0.0 60.4 60.4 0.0
Moss Street—Colorado Avenue
to Woodlawn Avenue
59.7 59.7 0.0 60.1 60.1 0.0
I-5—north of Palomar Street 80.1 80.1 0.0 80.6 80.6 0.0
Note:
1 Modeling results do not take into account mitigating features such as topography, vegetative screening, fencing, building design, or
structure screening. Rather it assumes a worst case of having a direct line of site on flat terrain.
Source: FCS 2019.
95
The highest traffic noise level increase with project implementation would occur along
Industrial Boulevard between L Street and Moss Street under Existing Plus Project
conditions. Along this roadway segment, the proposed project would result in an
increase of 0.2 dBA. This increase is below a 3 dBA increase that would be considered
a substantial permanent increase in traffic noise levels compared with traffic noise
levels that would exist without the project. Therefore, project-related traffic noise
impacts on existing traffic noise levels in the project vicinity would be less than
significant.
(c) Less than significant impact. A significant impact would occur if the project would
generate groundborne vibration or groundborne noise levels in excess of established
standards. The City of Chula Vista has not adopted criteria for groundborne vibration
impacts. Therefore, for purposes of this analysis, the FTA’s vibration impact criteria are
utilized. The FTA has established industry accepted standards for vibration impact
criteria and impact assessment. These guidelines are published in its Transit Noise and
Vibration Impact Assessment Manual.63
Although groundborne vibration can be felt outdoors, it is typically only an annoyance
to people indoors where the associated effects such as the shaking of a building can be
notable. When assessing annoyance from groundborne vibration, vibration is typically
expressed as root mean square (rms) velocity in units of decibels of 1 micro-inch per
second. To distinguish these vibration levels referenced in decibels from noise levels
referenced in decibels, the unit is written as “VdB.”
In extreme cases, excessive groundborne vibration has the potential to cause structural
damage to buildings. Common sources of groundborne vibration include construction
activities such as blasting, pile driving and operating heavy earthmoving equipment.
However, construction vibration impacts on building structures are generally assessed
in terms of peak particle velocity (PPV). For purposes of this analysis, project related
impacts are expressed in terms of PPV.
Short-term Construction Vibration Impacts
Of the variety of equipment that would be used during construction, large vibratory
rollers would produce the greatest groundborne vibration levels. Impact equipment
such as pile drivers is not expected to be used during construction of this project. Large
vibratory rollers produce groundborne vibration levels ranging up to 0.201 inch per
second (in/sec) PPV at 25 feet from the operating equipment.
The nearest off-site structures to the project site construction footprint are the Villa
Marina Apartments located east of the project site. This nearest off-site structure would
be located approximately 60 feet from the nearest construction footprint where the
heaviest construction equipment would potentially operate. At this distance,
groundborne vibration levels would range up to 0.054 in/sec PPV from operation of the
63 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual. September.
96
types of equipment that would produce the highest vibration levels. This is well below
the FTA’s Construction Vibration Impact Criteria of 0.2 in/sec PPV for buildings of
non-engineered timber and masonry. Therefore, the impact of groundborne vibration
levels on off-site receptors would be less than significant.
Operational Vibration Impacts
The proposed project does not include any permanent noise sources that would expose
persons in the project vicinity to groundborne vibration levels that could be perceptible
without instruments at any existing sensitive land use in the project vicinity. Existing
sources of groundborne vibration in the project vicinity include railroad activity along
the San Diego & Imperial Valley Railroad, located approximately 50 feet west of the
façade of the closest proposed multi-family residential building at the project site.
According to the FTA’s vibration impact assessment guidelines, the groundborne
vibration impact criteria for residential land uses exposed to frequent (defined to be
greater than 70) daily by-pass rail events is 72 VdB. The FTA’s generalized ground
surface vibration equation is as follows:
Lv = 92.28 + 14.81 log(D)–14.17log(D)2 + 1.65Log(D)3
Where Lv is the velocity level (VdB), and D is the distance in feet. The nearest façade
is 55 feet from the railroad tracks. The above formula is for trains traveling at 50 mph,
so the FTA adjustment for trains traveling at 40 mph is “-1.9.” The FTA guidelines
provide a further adjustment of “-5.0” for coupling to a building foundation for wood-
frame structures.64
Utilizing the FTA’s vibration impact screening methodology, the calculated vibration
level at 55 feet from the rail line for the projected rail by-pass events (including freight
train passings), with trains traveling up to 40 mph, would be 70.4 VdB. Therefore,
projected groundborne vibration levels from rail activity adjacent to the project site
would be less than the FTA’s vibration impact screening criteria of 72 VdB as measured
at the nearest proposed façade. Therefore, the impact of groundborne vibration levels
from rail activity on proposed on-site receptors would be less than significant.
(d) No impact. The nearest airport to the project site is the Brown Field Municipal
Airport, which is located more than 5.9 miles southeast of the project site. Because of
its distance from the airport’s runways, the project site is located well outside of the
airport’s 60 dBA CNEL noise contours. No private airstrips are located within 2 miles
of the project site. Therefore, implementation of the project would not expose persons
residing or working in the project site to excessive noise levels associated with private
airstrip or public airport noise. No impacts would occur.
64 See FTA reference pages in Appendix G, with annotated calculations for the project shown.
97
Mitigation Measures:
MM NOI-1 To reduce potential interior noise impacts, the Project Applicant shall
demonstrate to the satisfaction of the City Development Services Department
that:
Each of the proposed multi-family residential units shall be supplied with
an alternative form of ventilation, such as air conditioning or noise-
attenuated passive ventilation systems, that would allow an occupant the
option of controlling noise by keeping the windows shut (as the interior
noise standard would not be met with open windows).
The Developer shall provide upgraded wall and window assemblies for all
ground floor façades that directly face and that are located within 110 feet
of the railroad tracks. The combined wall and window assembly shall be
upgraded from standard building code requirements to have a minimum
Standard Transmission Class (STC) rating of 28-STC.
The Developer shall provide upgraded wall and window assemblies for all
upper façades (second floor and above) that have a direct line of sight of
the railroad tracks and that are located within 180 feet of the railroad
tracks. The combined wall and window assembly shall be upgraded from
standard building code requirements to have a minimum Standard
Transmission Class (STC) rating of 33-STC. Prior to issuance of building
permits, the applicant shall have a professional acoustic consultant review
the final design plans to provide assurance to City staff that the design
would provide the required STC rating.
MM NOI-2 To reduce potential construction noise impacts, the Project Applicant shall
demonstrate to the satisfaction of the City Development Services Department
that:
The Construction Contractor shall ensure that all equipment driven by
internal combustion engines shall be equipped with mufflers that are in
good condition and appropriate for the equipment.
The Construction Contractor shall ensure that unnecessary idling of internal
combustion engines (i.e., idling in excess of 5 minutes) is prohibited.
The Construction Contractor shall utilize “quiet” models of air compressors
and other stationary noise sources where such market available technology
exists.
The Construction Contractor shall ensure that stationary noise-generating
equipment shall be located as far as practicable from sensitive receptors and
placed so that emitted noise is directed away from the nearest residential
land uses at all times during project grading and construction.
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The Construction Contractor shall designate a Noise Disturbance
Coordinator who would be responsible for responding to any local
complaints about construction noise. The Noise Disturbance Coordinator
would determine the cause of the noise complaints (starting too early, bad
muffler, etc.) and establishment reasonable actions necessary to correct the
problem. The Construction Contractor shall visibly post a telephone number
for the Noise Disturbance Coordinator at the construction site.
The Construction Contractor shall limit noise producing construction
activities to the hours between 7:00 a.m. and 10:00 p.m. on Mondays through
Fridays, and between 8:00 a.m. and 10:00 p.m. on Saturdays and Sundays.
Prior to the issuance of each certificate of occupancy, the Construction
Contractor shall demonstrate, to the satisfaction of the City Development
Services Department, compliance with MM NOI-2.
Condition of Approval
COA NOI-1 Prior to issuance of building permits, the Project Applicant shall submit a
noise analysis to the City Development Services Department demonstrating
that there are no impacts to surrounding properties from HVAC equipment.
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
XIV. Population and Housing
Would the project:
a) Induce substantial unplanned population growth
in an area, either directly (for example, by
proposing new homes and businesses) or
indirectly (for example, through extension of
roads or other infrastructure)?
b) Displace substantial numbers of existing people
or housing, necessitating the construction of
replacement housing elsewhere?
Comments:
(a) Less than significant impact. The project proposes a residential development,
consisting of 141 dwelling units, 97 3-story court townhomes and 44 3-story row
townhomes.
The City of Chula Vista Vision 2020 General Plan outlines objectives and policies
related to the expansion and maintenance of adequate housing within the City.
Consistency with these policies and objectives is outlined in the table below:
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Table 27: General Plan Consistency
General Plan
Objective/Policy Number Policy Objective or Strategy Project Consistency
Objective H-1 Enforce maintenance of safe and decent
housing, enhance the quality of existing
housing, and maintain the integrity of
residential neighborhoods.
The proposed project would directly implement
the objective by enhancing the character of the
existing residential neighborhood. The
proposed project would increase the integrity of
the neighborhood as residential by creating
consistent land uses along Moss Street and
removing noxious and blighted industrial uses
from a residential neighborhood.
Policy H-5.2 Support efforts to increase homeownership
rates, particularly in the Northwest and
Southwest Planning areas, meeting or
exceeding the regional average as a means
to build individual wealth and stabilize
existing residential neighborhoods.
The proposed project would directly support
efforts to increase homeownership rates as a
means to build wealth and stabilize existing
residential neighborhoods by offering for-sale
housing in the Southwest Planning Area.
Policy E-6.1 Encourage compact development featuring a
mix of uses that locate residential areas
within reasonable walking distance to jobs,
services, and transit.
The proposed project would directly implement
this policy through its location in a walkable
and transit accessible neighborhood of the
City. The project site would have easy access
to bus stops serviced by the MTS 932 Line
(0.25 mile away) as well as the Palomar and H
Street MTS Trolley Stations (0.65 mile and 1
mile away, respectively).
Additionally, it is within walking distance of the
South Broadway mixed-use area and other
retail locations (0.25 to 0.5 mile).
Source(s): Michael Baker International. 2019. 676 Moss Street General Plan Amendment Consistency Analysis. December 17.
Michael Baker International. 2019. 676 Moss Street General Plan Amendment Justification Report. December 17. (Appendix J).
According to the United States Census Bureau’s 2013–2017 American Community
Survey 5-year Estimates Tables DP05 and S2504, the population of the City of Chula
Vista is 264,101 and the number of occupied housing units is 78,476, for an average
household size of 3.37 persons per dwelling unit.65 Therefore, as the proposed project
would develop 141 dwelling units, the proposed project would increase the City of
Chula Vista’s population by 475; less than 0.2 percent of the City’s current population.
As the proposed project would increase the City’s population by less than 0.2 percent,
the proposed project would not induce substantial unplanned population growth in an
area directly despite proposing new homes. Additionally, according to SANDAG, the
anticipated population growth by 2020 is 267,418.66 Thus, the increase in the
population as a result of the implementation of the project is within the SANDAG
anticipated population growth.
65 United States Census Bureau. 2018. QuickFacts Chula Vista City, California. July 1. Website:
https://www.census.gov/quickfacts/chulavistacitycalifornia. Accessed November 7, 2019.
66 San Diego Association of Governments (SANDAG). 2011. Fast Facts Chula Vista. October. Website:
https://www.sandag.org/resources/demographics_and_other_data/demographics/fastfacts/chul.htm. Accessed November 7, 2019.
100
While the proposed project would include an interior circulation system of roads and
sidewalks, as well as associated residential infrastructure improvements (including, but
not limited to electric, water, and sewer infrastructure) the improvements would be
private in nature and only used by the proposed project’s residents. As the proposed
project’s infrastructure improvements would be private in nature, the proposed project
would not induce substantial population growth in an area indirectly through extension
of roads or other infrastructure.
Lastly, while the proposed project includes the addition of a public sidewalk on the
north side of Moss Street, where there currently is not a sidewalk, a sidewalk is not
expected to induce a substantial unplanned increase in population.
As such, impacts would be less than significant.
(b) No impact. There are no existing dwelling units on the project site. Therefore, no
existing people or housing would be displaced by the development of the proposed
project. As such, no impacts would occur.
Mitigation Measures: None.
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
XV. Public Services
Would the project result in substantial adverse physical impacts associated with the provision of new or
physically altered governmental facilities, need for new or physically altered governmental facilities, the
construction of which could cause significant environmental impacts, in order to maintain acceptable
service ratios, response times or other performance objectives for any of the public services:
a) Fire protection?
b) Police protection?
c) Schools?
d) Parks?
e) Other public facilities?
Comments:
Would the project result in substantial adverse physical impacts associated with the provision
of new or physically altered governmental facilities, need for new or physically altered
governmental facilities, the construction of which could cause significant environmental
impacts, in order to maintain acceptable service ratios, response times or other performance
objectives for any of the public services:
(a) Less than significant impact. The City of Chula Vista Fire Department (CVFD)
currently provides fire protection to the project site and would continue to do so in the
101
future. The proposed project would develop 141 new dwelling units on the project site,
which would add an estimated 475 persons to the City’s population, which is less than
0.2 percent of the total current population of the City. CVFD Station No. 5 is located
1.3 miles from the project site at 391 Oxford Street. Using an average travel speed of
25 mph, it would take a fire engine less than 3 minutes and 7 seconds to reach the
project site from CVFD Station No. 5.
According to the City of Chula Vista 2017 Growth Management Oversight
Commission (GMOC) Recommendations/Implementing Actions Summary, the CVFD
response time threshold standard is to respond to calls throughout the City within 7
minutes in at least 80 percent of the cases.67 Currently, CVFD Station No. 5 is meeting
the threshold, with 85 percent of all calls responded to within 7 minutes.
Given the proposed project’s proximity to CVFD Station No. 5, the proposed project
would be able to be served within the existing threshold standard without
compromising response times, and impacts to service times would be less than
significant.
The proposed project’s design would be subject to compliance with the requirements
in the California Building Standards Commission California Fire Code. The proposed
project plans would be reviewed and approved by City Staff including CVFD Staff,
which would ensure adequate emergency access, fire hydrant availability, and
compliance with all applicable codes and standards. Furthermore, Policy PFS-6.1
within the City’s General Plan, requires new development and redevelopment projects
to demonstrate adequate access for fire and police vehicles. Compliance with the City’s
permit process and Municipal Code requirements would ensure that project
implementation would result in a less than significant impact to fire protection services.
(b) Less than significant impact. The City of Chula Vista Police Department (CVPD)
currently provides police protection to the project site and would continue to do so in
the future. The proposed project would develop 141 new dwelling units on the project
site, which would add an estimated 475 persons to the City’s population, which is less
than 0.2 percent of the total current population of the City. CVPD Headquarters is
located 2.35 miles from the project site at 315 Fourth Avenue. Using an average travel
speed of 25 mph, it would take a fire engine less 6 minutes to reach the project site
from CVPD Headquarters.
According to the GMOC Recommendations/Implementing Actions Summary, the
CVPD response time threshold standard is two-fold: (1) respond to at least 81 percent
of Priority 1 calls within 7 minutes 30 seconds and maintain an average response time
of 6 minutes or less; and (2) respond to all Priority 2 calls within 12 minutes or less.
Currently, neither threshold is being met, with Priority 1 calls missing the standard by
67 City of Chula Vista. Growth Management Oversight Commission. 2017. Website: https://www.chulavistaca.gov/departments/city-
clerk/boards-commissions/boards-commissions-list/growth-management-oversight-commission. Accessed March 29, 2019.
102
31 seconds, and Priority 2 calls missing the standard by 1 minute and 50 seconds. The
City has recommended the City Manager to support the CVPD in implementing their
2014 Strategic Plan to increase staffing levels and purchase new equipment in order to
improve response times.
Included in the City of Chula Vista’s Strategic Plan is Initiative 4.3.2 to restore and
enhance public safety service capacity. The Strategic Plan recognizes that response time
thresholds have not met GMOC standards. This is largely due to staffing issues, which
have degraded the CVPD’s capacity to provide quality public safety support. As a
result, the City has engaged a consultant to thoroughly examine police staffing. The
consultant’s study was delivered in April 2012 and the City Council adopted a police
budget based partly on its findings and recommendations. As such, hiring efforts are
currently underway and will be continually monitored.68
The proposed project plans would be reviewed and approved by the City and the
CVPD, which would ensure adequate safety and crime prevention measures are
provided. Compliance with the City’s discretionary review process would ensure that
project implementation would result in a less than significant impact to police services.
c) Less than significant impact. The City of Chula Vista is served by the Chula Vista
Elementary School District (CVESD) and the Sweetwater Union High School District
(SUHSD). The proposed project would develop 141 new dwelling units on the project
site, which would add an estimated 475 persons to the City’s population, which is less
than 0.2 percent of the total current population of the City. Using a standard student
generation rate from the CVESD School Facilities Needs Analysis of 0.3141
student/multi-family dwelling unit, the proposed project would add 54 students to the
CVESD and SUHSD.69
According to the GMOC Recommendations/Implementing Actions Summary, the
threshold standard for potential impacts to schools would be whether or not the school
districts can accommodate the population increase from the City’s annual 5-year
residential growth forecast. Both school districts reported to the GMOC that with
current and ongoing improvements to schools in both districts, school facilities would
be able to accommodate additional students from population increases. Therefore,
impacts would be less than significant.
Additionally, impacts to schools would be offset through payment of fees in accordance
with City of Chula Vista Municipal Code Chapter 17.11: School Facilities Dedication
and Fees, with the total fee amounts to be determined by City Staff. As such, by
providing fee payments, as required by the City, impacts would be less than significant.
68 City of Chula Vista. 2019. Strategic Plan. Website: https://www.chulavistaca.gov/home/showdocument?id=2510. Accessed
November 7, 2019.
69 Chula Vista Elementary School District (CVESD). 2010. Special District Financing & Administration. School Facilities Needs
Analysis. June. Website: http://schools.cvesd.org/district/district/Documents/Business%20Services%20and%20Support%20
(Lisa%20Brannen)/School%20Facilities%20Needs%20Analysis%20(2010).pdf. Accessed November 7, 2019.
103
(d) Less than significant impact. The proposed project would develop 141 new
dwelling units on the project site, which would add an estimated 475 persons to the
City’s population, which is less than 0.2 percent of the total current population of the
City. This would yield a nominal increase in demand for recreational facilities;
however, additional parkland would be required to be consistent with the City of Chula
Vista Parks and Recreation Master Plan to account for future park usage at build out
inventory. Section 17.10.040 of the City of Chula Vista Municipal Code requires a
parkland dedication of 341 square feet per unit or 1 acre per 128 units.70 Therefore, the
proposed project would generate parkland obligations and would be required to
dedicate 1.103 acres of parkland through the payment of a park facility fee in
accordance to the Chula Vista Park Land Development Ordinance, Chapter 17.10.070
of the City’s Municipal Code.71 As such, by providing fee payments, as required by the
City, impacts would be less than significant.
According to the GMOC Recommendations/Implementing Actions Summary, the
City’s threshold for providing park facilities is to provide 3 acres of neighborhood and
community parkland with appropriate facilities per 1,000 residents east of I-805.
Currently, the City does not meet that threshold, falling short by 0.22 acre per 1,000
residents. However, one of the funding sources for parks includes City Fees and
parkland obligations for new developments such as those outlined in Chapter 17.10:
Parklands and Public Facilities of the City of Chula Vista Municipal Code, which the
Project Applicant would provide payment for, as required. As such, impacts would be
less than significant.
(e) Less than significant impact. The proposed project would develop 141 new
dwelling units on the project site, which would add an estimated 475 persons to the
City’s population, which is less than 0.2 percent of the total current population of the
City. This would be expected to yield an increase in demand for libraries and other
public facilities. Additional development fees, as determined by the City of Chula Vista,
such as development impacts fees (Chapter 3.56: Development Impact Fees in Western
Chula Vista), would be paid by the Project Applicant to pay a fair-share for potential
impacts from the proposed project.
As such, by providing fee payment, impacts would be less than significant.
Mitigation Measures: None.
70 City of Chula Vista. 2014. City of Chula Vista Municipal Code. Title 17, Environmental Quality. Chapter 17.10: Parklands and Public
Facilities. Section 17.10.040: Area to be Dedicated—Required When—Amounts for Certain Uses. Website:
https://chulavista.municipal.codes/CVMC/17.10.040. Accessed November 7, 2019.
71 City of Chula Vista. 2014. City of Chula Vista Municipal Code. Title 17, Environmental Quality. Chapter 17.10: Parklands and Public
Facilities. Section 17.10.070: In-lieu Fees for Land Dedication and/or Park Development Improvements. Website:
https://chulavista.municipal.codes/CVMC/17.10.070. Accessed November 7, 2019.
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Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
XVI. Recreation
a) Would the project increase the use of existing
neighborhood and regional parks or other
recreational facilities such that substantial
physical deterioration of the facility would occur
or be accelerated?
b) Does the project include recreational facilities or
require the construction or expansion of
recreational facilities, which might have an
adverse physical effect on the environment?
Comments:
(a) Less than significant impact. As discussed above in Impact 2.15(d), the proposed
project would develop 141 new dwelling units on the project site. The proposed project
would provide approximately 75,111 square feet of open space, or 533 square feet per
unit, including approximately 36,864 square feet of common open space area, which
would include a community recreational area with barbeque counter, tot lot, and overhead
structure with Americans with Disabilities Act (ADA) compliant seating for social
gatherings and special events. The development of 141 new dwelling units would add an
estimated 475 persons to the City’s population. This would yield a nominal increase in
the demand for recreational facilities; however, additional parkland would be required to
be consistent with the City of Chula Vista Parks and Recreation Masterplan to account
for future park usage at build out inventory.
Section 17.10.040 of the City of Chula Vista Municipal Code requires a parkland
dedication of 341 square feet per unit or 1 acre per 128 units.72 Therefore, the proposed
project would generate parkland obligations and would be required to dedicate 1.103
acres of parkland through the payment of a park facility fee in accordance to the Chula
Vista Park Land Development Ordinance, Chapter 17.10.070 of the City’s Municipal
Code.73 As such, by providing fee payments, as required by the City, impacts would be
less than significant.
(b) Less than significant impact. As outlined above in Impact 2.15(a), the proposed
project would include private and common open space for residents. The proposed
project would provide approximately 75,111 square feet of open space, or 533 square feet
per unit, including approximately 36,864 square feet of common open space area, which
would include a community recreational area with a barbeque counter, tot lot, and
overhead structure with ADA compliant seating for social gatherings and special
72 City of Chula Vista. 2014. City of Chula Vista Municipal Code. Title 17, Environmental Quality. Chapter 17.10: Parklands and Public
Facilities. Section 17.10.040: Area to be Dedicated—Required When—Amounts for Certain Uses. Website:
https://chulavista.municipal.codes/CVMC/17.10.040. Accessed: November 7, 2019
73 City of Chula Vista. 2014. City of Chula Vista Municipal Code. Title 17, Environmental Quality. Chapter 17.10: Parklands and Public
Facilities. Section 17.10.070: In-lieu Fees for Land Dedication and/or Park Development Improvements. Website:
https://chulavista.municipal.codes/CVMC/17.10.070. Accessed: November 7, 2019.
105
events. These facilities would only be available to residents of the proposed project and
would be maintained through private funds to ensure no adverse physical effect on the
environment. As such, impacts would be less than significant.
Mitigation Measures: None.
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
XVII. Transportation
Would the project:
a) Conflict with a program plan, ordinance or
policy of the circulation system, including
transit, roadway, bicycle and pedestrian
facilities?
b) Would the project conflict or be inconsistent
with CEQA Guidelines Section 15064.3,
subdivision (b)?
c) Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm
equipment)?
d) Result in inadequate emergency access?
Comments:
A TIA Report was prepared by LLG on April 15, 2020, to assess project-related impacts
(Appendix H).74 The purpose of the TIA was to identify potential traffic-related impacts
associated with the proposed project.
(a) Less than significant impact.
The City Chula Vista Vision 2020 General Plan outlines multiple objectives and
policies that aim to reduce traffic and promote the use of an organized and balanced
transportation system within the City. The following objectives and policies are
outlined within the City Chula Vista Vision 2020 General Plan and are pertinent to the
proposed development. Project consistency with these objectives and policies is
analyzed in the table below:
74 Linscott, Law & Greenspan, Engineers (LLG). 2020. Transportation Impact Analysis 676 Moss Street. April 15.
106
Table 28: Transportation Consistency with the City Chula Vista Vision 2020 General
Plan
General Plan
Objective/Policy Number Policy Objective or Strategy Project Consistency
Objective LUT-18 Reduce traffic demand through Transportation Demand Management strategies, increased use of transit, bicycles, walking, and other trip reduction measures.
The proposed project would be consistent with this objective because it would be located within walking distance to many public facilities, transit stops, and commercial areas. The proposed project would improve the frontage along Moss Street and add a sidewalk, which would help encourage pedestrian travel throughout the neighborhood. The proposed project would be roughly a 5-minute walk or 2-minute bicycle ride to the MTS 932 bus stop and an 18-minute walk or 6-minute bicycle ride to the Palomar Street trolley station.
Objective LUT-23 Promote the use of a balanced
transportation system that maximizes
safe and non-polluting alternatives for
mobility
The proposed project would directly implement the
objective by improving pedestrian mobility on Moss
Street. The proposed project would be located
within walking distance to retail, transit, and public
facilities.
Policy LUT-23.1 Encourage the use of bicycles and
walking as alternatives to driving by
providing safe routes.
The proposed project would implement the policy
by creating high-density housing that would be
accessible to transit, retail, and public facilities. The
proposed project would connect the sidewalk on
Moss Street, which would increase pedestrian
access and safety for residents in the
neighborhood.
Source: Michael Baker International. 2019. 676 Moss Street General Plan Amendment Consistency Analysis. December 17.
Michael Baker International. 2019. 676 Moss Street General Plan Amendment Justification Report. December 17. (Appendix J).
Existing Street Network
Moss Street is a 2-lane road with residential and industrial uses and is classified as a
Class III Collector west of Broadway on the City of Chula Vista Circulation Plan.
Between Industrial Boulevard and Broadway, curb, gutter, and sidewalks are generally
provided.
I-5 is a north-south oriented freeway that extends from the U.S.-Mexico border to the
U.S.-Canada border. In the project vicinity, I-5 consists of four mixed-flow travel lanes
in each direction. I-5 has an interchange at Palomar Street. It also has interchanges at
L Street and Main Street to the north and south of Palomar Street, respectively. The I-
5 northbound ramps at L Street connect directly to Industrial Boulevard north of
Palomar Street, while the southbound ramps connect directly to Bay Boulevard. A high-
occupancy vehicle (HOV) lane was recently added to the I-5 northbound on-ramp at L
Street/Industrial Boulevard.
Industrial Boulevard is a 2-lane north-south roadway running parallel to and on the
west side of the railroad tracks. It is generally undivided except for the segment
between Palomar Street and Ada Street where a median divider is provided. It is
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classified as a Class II Collector in the City of Chula Vista Circulation Plan. On-street
parking is not allowed on both sides north of Palomar Street and south of Ada Street.
Between Palomar Street and Ada Street, on-street parking is allowed on the west side
but not on the east side. Sidewalks are generally provided on the both sides. The posted
speed limit is 40 mph. The west side of Industrial Boulevard between Palomar Street
and Moss Street is generally fronted by motorhomes. South of Palomar Street, the west
side of Industrial Boulevard has low- to medium-density residential areas.
Broadway is classified as a 4-lane Major Road to the south of L Street in the City of
Chula Vista Circulation Plan. It is currently built as a 4-lane Major Road in the project
vicinity. Curb, gutter and sidewalks are provided. Curbside parking is permitted.
Bay Boulevard is a 2-lane road with commercial uses and is classified as a Class II
Collector on the City of Chula Vista Circulation Plan. Between L Street and Palomar
Street, curb, gutter and sidewalks are generally provided on the east side. On-street
parking is prohibited on both sides of Bay Boulevard between L Street and Palomar
Street.
L Street is a 4-lane, east-west roadway with two-way left turn medians between Bay
Boulevard and Broadway. It is classified as a 4-lane Gateway Street between Bay
Boulevard and Broadway in the City of Chula Vista Circulation Plan. On-street parking
is prohibited on both sides. Sidewalks are provided on both sides. The posted speed
limit is 35 mph.
Existing Bicycle Network
Class 2 Bicycle Lanes are currently provided on both sides of Industrial Boulevard
between the I-5 northbound ramp intersection and Ada Street; on both sides of Bay
Boulevard within the project vicinity.
Existing Pedestrian Conditions
Pedestrian sidewalks are generally provided on both sides of Moss Street between
Industrial Boulevard and Broadway, on both sides of Industrial Boulevard between
Moss Street and Palomar Street, and on the west side of Industrial Boulevard between
Moss Street and L Street.
Palomar Street Grade Separation Project
A Project Study Report was prepared by SANDAG, in conjunction with the City of
Chula Vista, to grade separate the Palomar Street dual-track crossing of the Blue Line
Light Rail Trolley (LRT) at Industrial Street. The LRT is operated by the MTS. The
dual tracks are also used by freight trains.
This proposed grade separation would:
Provide significant safety enhancements.
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Reduce vehicular delays and congestion.
Increase multi-modal mobility.
The Palomar Street/Industrial Boulevard at-grade intersection would be eliminated and
grade separated as part of the Palomar Street Grade Separation project.
The Palomar Street Grade Separation project would also reconfigure the Oxford Street
Connector to eliminate its direct connection to Palomar Street and connect instead to
the existing Palomar Village Driveway, thereby combining the Oxford Street Connector
traffic with the Palomar Village Driveway traffic. The Palmar Street Grade Separation
project would add wider sidewalks for pedestrians, provide direct access to the Trolley
Station via ramps, stairs, and provide a pedestrian pathway across the new bridge. The
following pedestrian facilities would mitigate any potential pedestrian circulation
impacts due to grade separating Palomar Street and Industrial Boulevard:
Pedestrian sidewalks would be provided on both sides of the Industrial Boulevard
bridge and Palomar Street underpass. The sidewalks along the underpass will be
elevated from the underpass street level to provide lower grades for the sidewalks
and separation from vehicular traffic.
Pedestrian stairs would be constructed to connect both sides of the Palomar Street
underpass to the east side of the Trolley and Freight Tracks bridge.
Pedestrian sidewalks would connect both sides of Palomar Street in the vicinity of
Trenton Avenue to the west side of the Industrial Boulevard bridge.
A pedestrian pathway on the east side of the Trolley and Freight Tracks bridge
would connect the Trolley Station to the reconfigured Oxford Street Connector. A
pedestrian ramp would connect the pathway from the bridge to the reconfigured
connector.
A pedestrian sidewalk would be constructed on the west/south side of the
reconfigured Oxford Street Connector. The Build Alternative would also add Class
2 Bicycle Lanes along Palomar Street within the project footprint and maintain
existing Class 2 Bicycle Lanes along Industrial Boulevard.
Another City of Chula Vista project would add Class 2 Bicycle Lanes (at-grade) along Palomar
Street between Industrial Boulevard and Broadway, in addition to pedestrian signal upgrades
to three traffic signals on Palomar Street: Transit Center Place (Murrell Drive), Plaza Entrance
(Shopping Center Driveway) and Broadway. The Palomar Grade Separation project would
restore the Class 2 Bicycle Lanes on the below-grade segment of Palomar Street within the
project footprint.
(b) Less than significant impact. The TIA analyzed the potential transportation impacts due
to the project on vehicle miles traveled (VMT) to satisfy the CEQA Guidelines, which utilize
VMT as a measure of effectiveness. The project site is located approximately 1 mile north of
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the Palomar Street Transit Center, and 0.2 mile west of Broadway, which is a commercial
corridor identified as a “high quality transit corridor” (HQTC) in the City’s VMT screening
map. The project is located within the “Residential Projects” category, and OPR allows a
screening map to be the basis of the VMT impact evaluation. As a residential project, the VMT
is evaluated in terms of “VMT per capita.” The project VMT per capita is obtained from the
screening map, and then compared to VMT thresholds established by the City to determine the
significance of the project’s impacts.
Given that the City of Chula Vista has not yet adopted VMT thresholds, the OPR Advisory
describes the analysis for the following circumstance, which was used for the project’s VMT
analysis:
Residential Projects: A proposed project exceeding a level of 15 percent below
existing VMT per capita may indicate a significant transportation impact. Existing
VMT per capita may be measured as Regional VMT per capita or as City VMT per
capita.
Thus, for this analysis, the minimum threshold of significance for determination of the project’s
transportation impact is 15 percent or less of the regional VMT per capita. Any reduction in
comparative VMT more than 15 percent is considered not significant.
Prior to any detailed project-specific VMT modeling, OPR allows for the use of a “map-based
screening” to identify if a project would result in a less than significant impact. The City of
Chula Vista’s screening map was utilized for the project. This map provides VMT per capita
for census tracts throughout the City. VMT per capita is generally considered an efficiency
metric representing land use mixture and density, transit availability and other considerations
that may affect traffic generation and/or trip distance. In general, higher density and mix of
land uses with access to mobility options are expected to generate lower VMT.
The City of Chula Vista’s VMT Screening Tool is found online at:
http://cvgis.maps.arcgis.com/apps/webappviewer/index.html?id=f0d05a4a014841d588bb668
91500b34d75
This screening map allows for a search by address of properties within the City of Chula Vista.
The data presented in the screening map includes:
Census Tract
VMT per capita
Percent of regional mean
Residents
Description of VMT results
75 The data represented on this map follows the OPR guidance and displays VMT efficient areas that are 85 percent or less of the
SANDAG regional average. The data shown is based on the SANDAG Activity Based Model #1 (ABM1) for the base year of the
model (2012). Chula Vista is currently developing guidance for determining transportation impacts within Chula Vista and these
maps may change to align with City specific guidance.
110
The VMT per capita at the project site is 10.80 miles, which is 61.36 percent of the regional
average (17.60 miles). The result is that the project is greater than the 15 percent reduction
over regional VMT per capita significance threshold.
Table 29 presents a summary of the screening map data.
Table 29: Project VMT Findings – City of Chula Vista Screening Tool
Scenario Regional Baseline VMT per capita
Significance
Threshold (85% of
Regional Average VMT per capita)
676 Moss
Street
Project
VMT per capita
Transportation
Impact? (Over Threshold?)
Resident VMT per capita 17.60 14.96 10.80 No
Source: City of Chula Vista VMT Screening Tool (February 2020).
Based on the screening map review and the project’s location in a high efficiency area and the
resultant 10.80 VMT per capita, the project is 61.36 percent of the regional average VMT per
capita, which is below the 85 percent minimum threshold of significance. As an urban infill
development, the project is consistent with the legislative intent of SB 743.
(c) Less than significant impact. Final project site plans would be subject to City review and
approval, which would ensure that project driveway intersections and internal circulation are
safe, with adequate sight distance, driveway widths and stop signs where necessary for entering
and exiting the site. This would prevent any impacts due to a geometric design feature. The
project site is surrounded by commercial/industrial and residential uses and would not create
hazards due to incompatible uses. Impacts would be less than significant.
(d) Less than significant impact. Access to the project site would be provided via a single
unsignalized driveway on Moss Street, located approximately 300 feet east of Industrial
Boulevard. The project access driveway would be on the northern side of Moss Street and
Colorado Street intersection. The project access driveway design (width, grade, slope, and
vertical clearance) shall be provided to the City and/or Fire Authority for review and approval.
As part of the review process, the local City Traffic Engineer would be required to be consulted
for minimum width and parking restrictions to ensure compliance with minimum standard
requirements for adequate access. Therefore, impacts would be less than significant.
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Mitigation Measures: None.
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
XVIII. Utilities and Service Systems
Would the project:
a) Require or result in the relocation or construction
of new or expanded water, wastewater treatment
or stormwater drainage, electric power, natural
gas, or telecommunications facilities, the
construction or relocation of which could cause
significant environmental effects?
b) Have sufficient water supplies available to serve
the project and reasonably foreseeable future
development during normal, dry and multiple
dry years?
c) Result in a determination by the wastewater
treatment provider which serves or may serve the
project that it has adequate capacity to serve the
project’s projected demand in addition to the
provider’s existing commitments?
d) Generate solid waste in excess of State or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment
of solid waste reduction goals?
e) Comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste?
Comments:
The following analysis is based on the Priority Development Project SWQMP prepared by
Michael Baker International on November 19, 2018, included in Appendix F.
(a) Less than significant impact. The proposed project would result in the
construction of 141 single-family dwelling units. The increase in wastewater generation
would result in an incremental increase in the demand for wastewater conveyance and
treatment facilities. According to the Sweetwater Authority 2015 UWMP, the projected
water demands are based on an assumed average water demand of 105 gallons per
capita per day (GPCD).76 As previously discussed in Section 2.14, the proposed project
is anticipated to accommodate 475 residents. Thus, the proposed project would require
49,875 gallons of water a day. On an annual basis, this equates to 55.85 acre-feet. The
UWMP indicates that annual water supplies are anticipated to range from 22,488-acre-
feet to 26,218 acre-feet between 2020 and 2040. Thus, a “worst-case” water demand of
76 RMC Water and Environment. 2016. Sweetwater Authority 2015 Urban Water Management Plan. June 27. Website:
https://www.sweetwater.org/DocumentCenter/View/84/2015-Urban-Water-Management-Plan-PDF. Accessed November 7, 2019.
112
55.85 acre-feet would represent less than 0.1 percent of the project water supply totals
forecasted under all water year scenarios between 2020 and 2040. Therefore, adequate
water supplies would be available to serve the project from existing and planned
supplies.
The increase in wastewater generation would result in an incremental increase in the
demand for wastewater conveyance and treatment facilities. As discussed in Impact
2.17(a), the proposed project would generate 28,309 gallons of effluent on a daily basis.
The Point Loma Wastewater Treatment Plan has an existing available capacity of 65
million gallons per day (mgd). Thus, the addition of 28,309 gallons of wastewater per
day would represent less than 0.1 percent of the 65 mgd of available capacity.
Therefore, the Point Loma Wastewater Treatment Plan has adequate remaining capacity
to serve the proposed project. The project’s wastewater would be carried off-site
through connections with existing sewer system lines surrounding the project site.
Additionally, the Project Applicant would be required to pay Sewer Fees and additional
Development Impact Fees in accordance with City of Chula Vista Municipal Code
As such, impacts related to relocation or expansion of existing water or wastewater
treatment facilities would be less than significant.
As previously mentioned, all proposed on-site storm drains would connect to an
existing 12-foot-wide by 10-foot-deep double culvert channel that runs underneath the
project site. As such, the proposed project would not result in the construction or
relocation of stormwater drainage facilities. Impacts would be less than significant.
Consequently, the project would connect to existing facilities for electric power and
natural gas through SDG&E. Telecommunications for the project would be served by
existing facilities through AT&T. Therefore, the proposed project would not require the
relocation or construction of new or expanded facilities for water, wastewater
treatment, storm drainage, electric power, natural gas, or telecommunications. Impacts
would be less than significant.
(b) Less than significant impact. According to the Sweetwater Authority’s 2015 UWMP,
the per capita usage of water in Western Chula Vista is 105 gallons per day, as the proposed
project would add 475 people to the population, the proposed project would require
49,875 gallons of water a day. On an annual basis, this equates to 55.85 acre-feet.77 (Note
that these figures do not “net out” existing water use and, thus, overstate the actual increase
in consumption.) The UWMP indicates that annual water supplies are anticipated to range
from 22,488-acre-feet to 26,218-acre-feet between 2020 and 2040. Thus, a “worst-case”
water demand of 55.85-acre-feet would represent less than 0.1 percent of the project water
supply totals forecasted under all water year scenarios between 2020 and 2040.
77 Calculation: 49,875 gallons per day/325,851 gallons in an acre foot = 0.153 acre-feet x 365 days a year = 55.845 acre-feet/year
113
Accordingly, adequate water supplies would be available to serve the project from existing
and planned supplies. Impacts would be less than significant.
(c) Less than significant impact. As discussed in Impact 2.17(a), the proposed project
would generate 28,309 gallons of effluent on a daily basis. According to the City of
San Diego, the Point Loma Wastewater Treatment Plant, which serves the project site,
has an additional capacity of 65 mgd. Thus, the addition of 28,309 gallons of
wastewater per day would represent less than 0.1 percent of the available capacity of
65 mgd. Therefore, the existing wastewater treatment facilities would have adequate
capacity to serve the project. As such, impacts would be less than significant.
(d) Less than significant impact. According to the City of Chula Vista’s Recycling
and Solid Waste Planning Manual, multi-family complexes, with bedrooms per unit of
2 to 4 bedrooms, generate 0.4 cubic yards of solid waste per unit per week. The
proposed project would develop 141 single-family dwelling units. As such,
implementation of the proposed project would generate 2,932.8 cubic yards of solid
waste on an annual basis.78 According to the City of Chula Vista, the City is served by
the Otay Landfill. According to the San Diego County Integrated Waste Management
Plan 5-Year Review Report 2017, approved on January 2018, solid waste from the City
of Chula Vista is landfilled at the Otay Landfill (Closure Date 2030) after the closure
of the Otay Landfill, the project site area will be served by the Sycamore Landfill
(Closure Date: 2054, with plans to extend the date of closure through expansion). The
two landfills have 131.1 million cubic yards of remaining capacity. Therefore, there is
more than adequate landfill capacity in the region to serve the City of Chula Vista’s
disposal needs for the foreseeable future. The proposed project would not generate solid
waste in excess of State or local standards or in excess of the capacity of local
infrastructure, or otherwise impair the attainment of solid waste reduction goals.
Impacts would be less than significant.
(e) Less than significant impact. In 1989, the Legislature adopted the California
Integrated Waste Management Act of 1989 (AB 939), in order to “reduce, recycle, and
re-use solid waste generated in the state to the maximum extent feasible.” AB 939
established a waste management hierarchy: Source Reduction, Recycling, Composting,
Transformation, and Disposal. The law also required that each county prepare a new
Integrated Waste Management Plan and each city prepare a Source Reduction and
Recycling Element (SRRE) by July 1, 1991. The SRRE is required to identify how each
jurisdiction will meet the mandatory State waste diversion goal of 50 percent by the
year 2000. The Act mandated that California’s 450 jurisdictions (cities, counties, and
regional waste management compacts) implement waste management programs aimed
at a 25 percent diversion rate by 1995 and a 50 percent diversion rate by 2000. If the
50 percent goal was not met by the end of 2000, the jurisdiction was required to submit
78 Calculation: 141 single-family dwelling units x 0.4 cubic yards x 52 weeks a year = 2,932.8 cubic yards/year.
114
a petition for a goal extension to the California Department of Resources Recycling
and Recovery (CalRecycle).
SB 2202 made a number of changes to the municipal solid waste diversion
requirements under the Integrated Waste Management Act. These changes included a
revision to the statutory requirement for 50 percent diversion of solid waste to clarify
that local governments shall continue to divert 50 percent of all solid waste on and after
January 1, 2000.
SB 1016 introduced a per capita disposal measurement system that measures the 50
percent diversion requirement using a disposal measurement equivalent. The Bill
repealed the State Water Board’s 2-year process, requiring instead that the Board make
a finding whether each jurisdiction was in compliance with the Act’s diversion
requirements for calendar year 2006 and to determine compliance for the 2007 calendar
year and beyond, based on the jurisdiction’s change in its per capita disposal rate. The
Board is required to review a jurisdiction’s compliance with those diversion
requirements in accordance with a specified schedule, which is conditioned upon the
Board finding that the jurisdiction complies with those requirements or has
implemented its SRRE and household hazardous waste element. The Bill requires the
Board to issue an order of compliance if the Board finds that the jurisdiction has failed
to make a good faith effort to implement its SRRE or its household hazardous waste
element, pursuant to a specified procedure.
The per capita disposal rate is a jurisdiction‐specific index, which is used as one of
several “factors” in determining a jurisdiction’s compliance with the intent of AB 939,
and allows CalRecycle and jurisdictions to set their primary focus on successful
implementation of diversion programs. Meeting the disposal rate targets is not
necessarily an indication of compliance. CalRecycle reports that the City of Chula
Vista’s Disposal Rate Targets for Reporting Year 2017 are 5.3 pounds per day per
resident and 22.8 pounds per day per employee.
The proposed project is expected to be serviced by Republic Services. Any changes in
locations for trash carts and bulky pickup, sufficient clearance, and appropriate routing
for trucks would be coordinated by the City and Republic Services.
Participation in the City’s recycling programs during project construction and
operation, including CalRecycle’s requirements, would ensure that the project would
not conflict with federal, State, and local management and reduction statutes and
regulations related to solid waste. In addition, the proposed project would comply with
the City of Chula Vista’s Recycling and Solid Waste Planning Manual. Furthermore,
the proposed project would meet or exceed standards set forth in California Green
Building Standards Code (CCR, Title 24, Part 11—CALGreen). Additionally, please
refer also to the discussion in Impact 17(f).
As such, impacts would be less than significant.
115
Mitigation Measures: None.
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
XIX. Wildfire
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones,
would the project:
a) Substantially impair an adopted emergency
response plan or emergency evacuation plan?
b) Due to slope, prevailing winds, and other
factors, exacerbate wildfire risks, and thereby
expose project occupants to, pollutant
concentrations from a wildfire or the
uncontrolled spread of a wildfire?
c) Require the installation or maintenance of
associated infrastructure (such as roads, fuel
breaks, emergency water sources, power lines or
other utilities) that may exacerbate fire risk or
that may result in temporary or ongoing impacts
to the environment?
d) Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
Comments:
(a) No impact. According to the CAL FIRE California Fire Hazard Severity Zones Maps,
the project site is not located in a Fire Hazard Severity Zone in neither a Local
Responsibility Area, nor the State Responsibility, nor Federal Responsibility Area.79 The
City of Chula Vista does not have an adopted emergency response plan or emergency
evacuation plan. However, the City of Chula Vista Fire Department outlines the following
scenarios that require disaster preparedness: wildfire, earthquakes, flood, terrorism, and
tsunami. The only scenario with an evacuation routes map is the tsunami scenario. The
evacuation routes for a tsunami are along the coast and direct evacuees to hear inland. The
nearest evacuation route to the project site is J Street, located approximately 0.6 mile north
of the project site. Additionally, according to the tsunami evacuation map, the project site
would not be affected by a tsunami. Therefore, the proposed project would not impair
implementation of or physically interfere with an adopted emergency response plan or
emergency evacuation plan. As such, there would be no impact.
(b) No impact. According to the CAL FIRE California Fire Hazard Severity Zones
Maps, the project site is not located in a Fire Hazard Severity Zone in neither a Local
79 California Department of Forestry and Fire Protection (CAL FIRE). California Important Farmland Finder. Website:
https://maps.conservation.ca.gov/DLRP/CIFF/. Accessed February 27, 2020.
116
Responsibility Area, nor the State Responsibility, nor Federal Responsibility Area.
Urban levels of fire protection would be provided to the project area. In addition, the
project would adhere to building codes and any conditions included through review by
the fire department. Therefore, the proposed project would not exacerbate wildfire
risks, and thereby expose project occupants to, pollutant concentrations from a wildfire
or the uncontrolled spread of a wildfire and there would be no impact.
(c) No impact. According to the CAL FIRE California Fire Hazard Severity Zones
Maps, the project site is not located in a Fire Hazard Severity Zone in neither a Local
Responsibility Area, nor the State Responsibility, nor Federal Responsibility Area. The
proposed project would demolish the existing light industrial use buildings to develop
a new multi-family housing community. The proposed residential uses would not
include any features that would have the potential to exacerbate fire risk or result in
temporary or ongoing impacts to the environment. The proposed project would provide
access with adjoining uses and suitable access for emergency vehicles. The project area
will include a fire lane compliant with Fire Department requirements for adequate
access. Emergency access to the site would be maintained during construction. As such,
there would be no impact.
(d) No impact. According the CAL FIRE California Fire Hazard Severity Zones Maps,
the project site is not located in a Fire Hazard Severity Zone in neither a Local
Responsibility Area, nor the State Responsibility, nor Federal Responsibility Area. The
proposed project is comprised of relatively flat parcels located in an urbanized area
surrounded by commercial, residential and light industrial uses. The FEMA FIRM No.
06073C2152F. Furthermore, the project site is located in Zone X: a zone that
corresponds to areas outside of the 500-year flood or areas protected from the 100-year
flood by levees. In other words, Zone X is defined as areas with a 0.2 percent annual
chance of flood (i.e., a 500-year flood hazard area). These conditions preclude the
possibility of subjecting people or structures to significant risks related to post-fire slop
instability and landslides. Furthermore, the underground storm drain box culvert that
transects the project site is classified as Zone A, a 100-year flood zone, and would be
considered a Severe Fire Hazard Area. However, as outlined in the FIRM Map, the 100-
year flood would be contained in the underground storm drain box culvert, it is meant
to operate as a flood channel. As the proposed project does not propose to modify the
underground box culvert and would allow the underground storm drain box culvert to
operate in the same condition it currently does and remain in place, there would be no
impact from project implementation.
Therefore, the proposed project would not place structures within a 100-year flood
hazard area, exposing people or structures to risks including downslope or downstream
flooding or landslides. As such, there would be no impact.
Mitigation Measures: None.
117
Environmental Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
XX. Thresholds
Will the proposal adversely impact the City’s Threshold Standards?
a. Library
The City shall construct 60,000 gross square feet
(GSF) of additional library space, over the June
30, 2000 GSF total, in the area east of Interstate
805 by buildout. The construction of said
facilities shall be phased such that the City will
not fall below the city-wide ratio of 500 GSF per
1,000 population. Library facilities are to be
adequately equipped and staffed.
b. Police
i. Emergency Response: Properly equipped and
staffed police units shall respond to 8% of
“Priority One” emergency calls within seven
(7) minutes and maintain an average response
time to all “Priority One” emergency calls of
5.5 minutes or less.
ii. Respond to 57% of “Priority Two” urgent calls
within seven (7) minutes and maintain an
average response time to all “Priority Two”
calls of 7.5 minutes or less.
c. Fire and Emergency Medical
Emergency response: Properly equipped and
staffed fire and medical units shall respond to
calls throughout the City within 7 minutes in
80% of the cases (measured annually).
d. Traffic
The Threshold Standards require that all
intersections must operate at a Level of Service
(LOS) “C” or better, with the exception that
Level of Service (LOS) “D” may occur during
the peak two hours of the day at signalized
intersections. Signalized intersections west of I-
805 are not to operate at a LOS below their 1991
LOS. No intersection may reach LOS “E” or “F”
during the average weekday peak hour.
Intersections of arterials with freeway ramps are
exempted from this Standard.
e) Parks and Recreation Areas
The Threshold Standard for Parks and
Recreation is 3 acres of neighborhood and
community parkland with appropriate
facilities/1,000 population east of I-805.
118
Environmental Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
f) Drainage
The Threshold Standards require that storm
water flows and volumes not exceed City
Engineering Standards. Individual projects will
provide necessary improvements consistent with
the Drainage Master Plan(s) and City
Engineering Standards.
g) Sewer
The Threshold Standards require that sewage
flows and volumes not exceed City Engineering
Standards. Individual projects will provide
necessary improvements consistent with Sewer
Master Plan(s) and City Engineering Standards.
h) Water
The Threshold Standards require that adequate
storage, treatment, and transmission facilities are
constructed concurrently with planned growth
and that water quality standards are not
jeopardized during growth and construction.
Applicants may also be required to participate in
whatever water conservation or fee off-set
program the City of Chula Vista has in effect at
the time of building permit issuance.
Comments
Refer to discussions above.
Mitigation: None.
119
Issues:
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
XXI. Mandatory Findings of Significance
a) Does the project have the potential to
substantially degrade the quality of the
environment, substantially reduce the habitat of a
fish or wildlife species, cause a fish or wildlife
population to drop below self-sustaining levels,
threaten to eliminate a plant or animal
community, substantially reduce the number or
restrict the range of a rare or endangered plant or
animal, or eliminate important examples of the
major periods of California history or prehistory?
b) Does the project have impacts that are individually
limited, but cumulatively considerable?
(“Cumulatively considerable” means that the
incremental effects of a project are considerable
when viewed in connection with the effects of past
projects, the effects of other current projects, and
the effects of probable future projects)?
c) Does the project have environmental effects,
which will cause substantial adverse effects on
human beings, either directly or indirectly?
Comments:
(a) Less than significant with mitigation incorporated. With implementation of MM
BIO-1, the proposed project would not substantially degrade the quality of the
environment, substantially reduce the habitat of fish or wildlife species, cause a fish or
wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or
animal community, or reduce the number or restrict the range of a rare or endangered
plant or animal. Implementation of MM BIO-1 would reduce potential impacts to
nesting birds from project implementation to a less than significant level.
With implementation of MM CUL-1 and MM CUL-2 the proposed project would not
eliminate important examples of the major periods of California history or prehistory.
Implementation of MM CUL-1 and MM CUL-2 would ensure that the historical
integrity of important examples of major periods of California history are preserved.
(b) Less than significant with mitigation incorporated. The proposed project could
result in potentially significant project-level impacts related to air quality, biological
resources, cultural resources, geology and soils, GHG emissions, hazards and
hazardous materials, hydrology, land use and planning, and noise. However, MM AIR-
1, MM BIO-1, MM CUL-1, MM CUL-2, MM GEO-1, MM GEO-2, MM GHG-1, MM
120
HAZ-1, MM HAZ-2, MM HAZ-3, MM-NOI-1, and NOI-2 shall be implemented as
part of the proposed project. These mitigation measures will, amongst other things,
reduce impacts to nesting birds, reduce impacts to any inadvertent culturally significant
discoveries, reduce impacts to expansive soils and paleontological resources, require
the purchase of voluntary carbon credits by the Project Applicant, remove potential
hazardous material release from past projects, and reduce noise impacts from the
proposed project. The mitigation measures would reduce each impact to a level of less
than significant.
All other impacts of the proposed project were determined either to have no impact or
to be less than significant without the need for mitigation. Cumulatively, the proposed
project would not result in any significant impacts that would substantially combine
with impacts of other current or probable future impacts. Therefore, the proposed
project, in conjunction with other future development projects, would not result in any
cumulatively considerable impacts.
(c) Less than significant impact.
All potential impacts of the proposed project have been identified. Compliance with
applicable existing laws and regulations and implementation of recommended
mitigation (and improvement) measures would ensure that the project would not result
in substantial adverse effects on human beings either directly or indirectly. Therefore,
impacts would be less than significant and no additional mitigation measures are
required.
Mitigation Measures: Implement MM AIR-1, MM BIO-1, MM CUL-1, MM CUL-2, MM
GEO-1, MM GEO-2, MM GHG-1, MM HAZ-1, MM HAZ-2, MM HAZ-3, MM-NOI-1, and
NOI-2.
121
XXII PROJECT REVISIONS OR MITIGATION MEASURES
Project mitigation measures are indicated above.
XXIII AGREEMENT TO IMPLEMENT MITIGATION MEASURES
By signing the line(s) provided below, the Project Applicant(s) and/or Operator(s) stipulate
that they have each read, understood, and have their respective company’s authority to and do
agree to the mitigation measures contained herein, and will implement same to the satisfaction
of the Environmental Review Coordinator. Failure to sign the line(s) provided below shall
indicate the Project Applicant(s) and/or Operator(s) desire that the proposed project be held in
abeyance without approval.
James O’Malley, Vice President – Development
Shopoff Land Fund-Moss Street, LLC
Date:
122
XXIV ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED:
The environmental factors checked below would be potentially affected by the proposed
project, involving at least one impact that is a “Potentially Significant Impact” or “Less
Than Significant with Mitigation Incorporated” as indicated by the checklist on the previous
pages.
Aesthetics Agriculture and Forestry Resources Air Quality
Biological Resources Cultural and Tribal Cultural
Resources
Energy
Geology/Soils Greenhouse Gas Emissions Hazards/Hazardous Materials
Hydrology/Water Quality Land Use/Planning Mineral Resources
Noise Population/Housing Public Services
Recreation Transportation Utilities/Services Systems
Wildfire Mandatory Findings of Significance
XXV Determination:
On the basis of this initial evaluation:
I find that the proposed project COULD NOT have a significant effect on the
environment, and a NEGATIVE DECLARATION will be prepared.
I find that although the proposed project could have a significant effect on the environment,
there will not be a significant effect in this case because revisions in the project have been
made by or agreed to by the project proponent. A MITIGATED NEGATIVE
DECLARATION will be prepared.
I find that the proposed project MAY have a significant effect on the environment, and an
ENVIRONMENTAL IMPACT REPORT is required.
I find that the proposed project MAY have a “potentially significant impact” or
“potentially significant unless mitigated” impact on the environment, but at least one
effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal
standards, and 2) has been addressed by mitigation measure based on the earlier analysis
as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is
required, but it must analyze only the effects that remain to be addressed.
I find that although the proposed project could have a significant effect on the
environment, because all potentially significant effects (a) have been analyzed adequately
in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and
(b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE
DECLARATION, including revisions or mitigation measures that are imposed upon the
proposed project, nothing further is required.
City of Chula Vista Date
123
XXVI List of Preparers
FirstCarbon Solutions
250 Commerce, Suite 250
Irvine, CA 92602
Phone: 714.508.4100
Fax: 714.508.4110
Project Director ......................................................................................................... Kerri Tuttle
Project Manager .......................................................................................................... Cecilia So
Environmental Analyst......................................................................................... Kevin Bolland
Environmental Analyst........................................................................................ Brittany Hagen
Environmental Analyst............................................................................................ Eric Soycher
Senior Air Quality Manager ....................................................................................... George Lu
Air Quality Scientist ......................................................................................... Kimber Johnson
Senior Editor ............................................................................................................ Susie Harris
GIS/Graphics................................................................................................. Karlee McCracken
Reprographics ....................................................................................................... Octavio Perez
Technical Subconsultants
Linscott, Law & Greenspan, Engineers (LLG)—Traffic and Transportation Specialists
4542 Ruffner Street Suite 100
San Diego, CA 92111
Phone: 858.300.8800
Fax: 858.300.8810
Environmental Management Strategies, Inc. (EMS), Hazards and Hazardous Materials
Specialists
8 Goodyear, Suite 125
Irvine, CA 92618
Phone: 949.679.9500
Fax: 949.679.9501
LGC Valley, Inc., Geotechnical Specialists
28532 Constellation Road
Valencia, CA 91355
Phone: 661.702.8474
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805
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Mexico
5
805
SutherlandLake
Batiquitos Lagoon
Lake Hodges
El CapitanReservoir
San VicenteReservoir
SweetwaterReservoir
Lower OtayReservoir
P a c i f i c O c e a n
ClevelandNationalForest
ClevelandNationalForest
ClevelandNationalForest
ClevelandNationalForest
San Marcos EscondidoCarlsbad
Encinitas
Ramona
Solana Beach Poway
Santee Lakeside
BostoniaSan Diego
El Cajon
La Mesa
Casa deOro-MountHelix
Lemon Grove
Spring Valley
BonitaNational City
Coronado Chula Vista
ImperialBeach
Exhibit 1Regio nal Lo catio n Map
5 0 52.5
Miles
Text Project Site
So urce: Census 2000 Data, The CaSIL
CITY OF CHULA VISTA • 676 MOSS STREETINITIAL STUDY/MITIGATED NEGATIVE DECLARATION34260024 • 03/2019 | 1_ regio nal.mxd
Project Site
San Diego County
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34260024 • 04/2019 | 2_APN_map.mxd
Exhibit 2Assessor Parcel Numbers Map
Source: ESRI Aerial Imagery. San Diego County GIS Data.
CITY OF CHULA VISTA • 676 MOSS STREETINITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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Project Site
Parcels
618-01-03200
618-01-03100618-01-02601618-01-02602
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34260024 • 03/2019 | 3_GPLU.mxd
Exhibit 3City o f Chula VistaGeneral Plan Land Use Map
So urce: ESRI Aerial Imagery. City o f Chula Vista and San Diego Co unty GIS Data.
CITY OF CHULA VISTA • 676 MOSS STREETINITIAL STUDY /MITIGATED NEGATIVE DECLARATION
5
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Project SiteGeneral Plan Land Use Designations
CR - Commercial Retail
FWY - Freeway
I - General Industrial
IL - Limited Industrial
MUR - Mixed Use Residential
OS - Open Space
PQ - Public & Quasi Public
RH - Residential High
RMH - Residential Medium/High
RM - Residential Medium
RLM - Residential Low/Medium
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34260024 • 03/2019 | 4_zo ning.mxd
Exhibit 4City o f Chula Vista Z o ning Map
So urce: ESRI Aerial Imagery. City o f Chula Vista and San Diego Co unty GIS Data.
CITY OF CHULA VISTA • 676 MOSS STREETINITIAL STUDY/MITIGATED NEGATIVE DECLARATION
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Project SiteZone Designations
General Industrial
Limited Industrial
Limited Industrial Precise Plan
Residential High
Residential Medium
Residential Low - Medium
Mixed Use - Residential
Mixed Use - Transit Focus Area
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34260024 • 02/2020 | 5_conceptual_site_plan.cdr
Exhibit 5
Conceptual Site Plan
CITY OF CHULA VISTA • 676 MOSS STREET
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
Source: WHA Architects, Planners, Designers, February 18, 2020.
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CITY OF CHULA VISTA • 676 MOSS STREET
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
Source: WHA Architects, Planners, Designers, March 26, 2020.
Exhibit 6
Conceptual Open Space Plan
34260024 • 04/2020 | 6_conceptual_open_space_plan.cdr
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34260024 • 02/2020 | 7_conceptual_landscape_plan.cdr
Exhibit 7
Conceptual Landscape Plan
CITY OF CHULA VISTA • 676 MOSS STREET
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
Source: WHA Architects, Planners, Designers, February 18, 2020.
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34260024 • 02/2020 | 8_project_lighting_plan.cdr
Exhibit 8
Project Lighting Plan
CITY OF CHULA VISTA • 676 MOSS STREET
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
Source: Studio Pad Landscape Architecture, February 19, 2020.
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34260024 • 01/2020 | 9_vegetation_map.mxd
Exhibit 9Vegetation Map
Source: Google Earth Aerial Imagery.
CITY OF CHULA VISTA • 676 MOSS STREETINITIAL STUDY/MITIGATED NEGATIVE DECLARATION
M o s s S t
A r i z o n a S t
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Ornamental Trees
Urban / Developed
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34260024 • 01/2020 | 10_Phase II_ESA_Soil_Soil_vapor_sampling_loc.cdr
Exhibit 10
Phase II ESA Soil and Soil Vapor Sampling Locations
CITY OF CHULA VISTA • 676 MOSS STREET
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
Source: Environmental Management Strategies, Inc., August 2018.
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34260024 • 01/2020 | 11_supp_Phase II_ESA_Soil_Soil_vapor_groundwater_sampling_loc.cdr
Exhibit 11
Supplemental Phase II ESA Soil,
Soil Vapor, and Groundwater Sampling Locations
CITY OF CHULA VISTA • 676 MOSS STREET
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
Source: Environmental Management Strategies, Inc., August 2018.
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34260024 • 04/2020 | 12_combined_mobile_source_noise_contours.cdr
Exhibit 12
Combined Mobile Source Noise Contours
CITY OF CHULA VISTA • 676 MOSS STREET
INITIAL STUDY/MITIGATED NEGATIVE DECLARATION
Source: WHA Architects, Planners, Designers, March 26, 2020.
75.2
70.1
65 dBA CNEL Noise Contour
for Rooftop Decks 65 dBA CNEL Noise Contour for Upper Floor Facades with
Line of Sight to Railroad (no Shielding)
65 dBA CNEL Noise Contour for Ground Floor Areas (with Shielding)
75.2
70.1
Combined Traffic and Railroad Noise
Levels (dBA CNEL) at Upper Floors
(Top Number) and at Ground Floor
( Bottom Number) at Nearest Facade
to Railroad.
110.0’
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676 MOSS STREET PROJECT
State Clearinghouse No. 2020049053
Responses to Comments
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i
Table of Contents
Section 1: Introduction ........................................................................................................ 1-1
Section 2: Responses to Written Comments ...................................................................... 2-1
List of Authors ........................................................................................................... 2-1
Responses to Comments ............................................................................................ 2-1
Section 3: Errata ................................................................................................................ 3-1
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1
SECTION 1: INTRODUCTION
Although not required by the California Environmental Quality Act (CEQA) and CEQA
Guidelines, the City of Chula Vista has evaluated the comments received on the 676 Moss
Street Project Draft Initial Study/Mitigated Negative Declaration (Draft IS/MND). The
Responses to Comments and Errata, which are included in this document, together with the
Draft IS/MND, Draft IS/MND appendices, and the Mitigation Monitoring and Reporting
Program (MMRP), comprise the Final IS/MND for use by the City of Chula Vista in its review
and consideration of the 676 Moss Street Project.
This document is organized into three sections:
• Section 1—Introduction.
• Section 2—Responses to Written Comments: Provides a list of the agencies,
organizations, and individuals who commented on the Draft IS/MND. Copies of all of
the letters received regarding the Draft IS/MND and responses thereto are included in
this section.
• Section 3—Errata: Includes an addendum listing refinements and clarifications to the
Draft IS/MND, which have been incorporated using strikeout and underline text.
The Final IS/MND includes the following contents:
• Draft IS/MND (provided under separate cover)
• Draft IS/MND appendices (provided under separate cover)
• Responses to Written Comments and Errata (Sections 2 and 3 of this document)
• Mitigation Monitoring and Reporting Program (provided under separate cover)
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SECTION 2: RESPONSES TO WRITTEN COMMENTS
List of Authors
A list of public agencies, organizations, and individuals that provided comments on the Draft
Initial Study/Mitigated Negative Declaration (IS/MND) is presented below. Each comment has
been assigned a code. Individual comments within each communication have been numbered
so comments can be crossed-referenced with responses. Following this list, the text of the
communication is reprinted and followed by the corresponding response.
Author Author Code
State Agencies
None ........................................................................................................................................ n/a
Local Agencies
None ........................................................................................................................................ n/a
Organizations
None ........................................................................................................................................ n/a
Individuals
Acerro, Theresa ........................................................................................................... ACERRO
Colclasure, Kenn ............................................................................................... COLCLASURE
Moore, Greg .................................................................................................................. MOORE
Stack, Robert ................................................................................................................... STACK
Responses to Comments
Introduction
In accordance with the California Environmental Quality Act (CEQA) Guidelines Section
15088, the City of Chula Vista, as the lead agency, evaluated the comments received on the
Final IS/MND (State Clearinghouse No. 2020049053) for the 676 Moss Street Project, and has
prepared the following responses to the comments received. This Response to Comments
document becomes part of the Final IS/MND for the project in accordance with CEQA
Guidelines Section 15132.
Comment Letters and Responses
The comment letters reproduced in the following pages follow the same organization as used
in the List of Authors.
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Warning:
External
Email
From: THERESA ACERRO [mailto:thacerro@yahoo.com]
Sent: Sunday, May 03, 2020 6:11 PM
To: Oscar Romero
Subject: comments on MND for Moss project
Comments on the MND for: 1. Project Name: 676 Moss Street
Project 2. Project Location: 676 Moss Street, Chula Vista,
California 3. Assessor’s Parcel No.: 618-010-2601, 618-010-2602, 618-
010-3100, and 618-010-3200 4. Project Applicant: Shopoff Land Fund-
Moss Street, LLC 2 Park Plaza, Suite 700, Irvine, California 92614 Contact:
James O’Malley 949.417.1396 5. Date of Draft Document: April 27, 2020
6. Case No: IS18-0004 7. Date of Final Document: TBD
ACERRO
Page 1 of 4
This document is totally inadequate since it totally ignores
the impact of the proposed project on the current users of the
property. It is a classic confirmation of exactly how unfriendly the
city of Chula Vista is to businesses. As well as how it ignores the
economic consequences of proposed changes to the General Plan
and historic zoning. This is not vacant property. There are 5
important thriving businesses most of whom have been here for
over 20 years in some case more than 30 years providing high
quality jobs and services to developers, the Navy, public agencies
and individuals in our community and nationally.
One of them Hawthorn has bought a piece of property on
Hollister and is preparing to move by August after almost 30 years
in CV they will now enrich the city of San Diego. From their
website:https://www.hawthornecat.com/why-hawthorne Cat
Connect Delivers Results.
Our goal at Hawthorne Cat is to help you keep your fleet running like new. We partner
with you to deliver the on-going service and support you want, when you want it.
With Cat®Connect, you can maximize the uptime of your equipment fleet and
improve the efficiency of your jobsite by monitoring and managing your equipment
fleet in real-time.
Parts. Service. Convenience.
Hawthorne Cat offers an outstanding parts and service department. We have over 1.4
million Cat certified parts in stock and ready for pick up. You can even order your
parts online through Parts.Cat.Com. Our fleet of 30 service trucks are available to
ensure your equipment is ready to go when you are. Hawthorne Cat’s goal is to make
maintaining your equipment as easy as it was buying it in the first place.
A Solid Return.
And, you can buy with the knowledge that our equipment retains its value over time.
You will be glad you purchased Cat equipment come trade-in or trade-up time.
Hawthorne Cat offers the best selection of quality used equipment and customers can
also participate in our consignment program to sell low-hour, well maintained Cat
equipment they no longer need.
The other businesses here are still here even in the face of eviction
because there are no other lots in Chula Vista like these lots on Moss.. All the
businesses here have many workers who are considered highly skilled like diesel
mechanics, electricians, hydraulic techs, fiberglass technicians, fine wood workers,
painters, upholstery, heavy equipment repair and all businesses here are extremely
ACERRO
Page 2 of 4
unique and all private family owned. Hawthorne is wealthy so they quickly bought the
land on Hollister.
The storage business here Southwest Mobile Storage who rent and build to
order steel containers is in a unique situation here because the containers are
unsightly and can’t be seen stored way back on this lot. From their web
page:https://swmobilestorage.com/:“Established in 1995, Southwest Mobile Storage
is the industry leader in mobile storage containers, portable offices, and custom storage solutions.
Our experienced, licensed, and certified fabricators, engineers, and designers can customize your
shipping container to meet your exact specifications.
Rapid Prep needs this very unique power distribution and they rent all the equipment
to keep the air clean for navy and road
construction www.rapidprep.com/equipment::Rapid Prep is your total solutions
provider, with the most highly trained service personnel in the abrasive equipment
market. High productivity can only come with aggressive preventive maintenance and
on-site rapid response to service calls. Our experienced and professional customer
service and sales staff are ready to help you. Contact one of our Chula Vista, CA
representatives today for more information on our abrasive equipment. Rapid Prep’s
sales and service team are knowledgeable and prepared to assist you for all your
equipment and service needs. From large scale projects to small requests for
sandblasting abrasives or dust collector filters, Rapid Prep can deliver.The Rapid
Prep advantage
Highly trained staff with over 100 years of experience
24-hour service from start up to demobilization
Tel:800-553-3625 Info@kleenblast.com
Kleen Blast Abrasives has provided customers with quality abrasives, as well as
sandblasting equipment and supplies, since 1962. Our Kleen Blast brand grit is dust
and silica free, economical, fast cutting, and environmentally safe.
Here on our website,https://kleenblast.com/we hope you find all the information
you need to plan your resurfacing project and the materials and equipment necessary
to get the job done right. If you can’t find it, please call us today and we’ll be glad to
answer your questions.
San Diego Boat Yard and San Diego Boat
Electric:Most critically the boatyard is working on and needs up to nine months
more to finish a $100,000 custom yacht that can’t be moved until
finished.http://www.boatyardsandiego.com boat building, repower, repaint
http://www.sandiegoboatelectric.com est 1983 Drawings, repairs to propulsion controls and
switchboards. Electronics and Electrical Engineering for Navy, Pleasure, Commercial,
Industrial.Since 1983 Yachts commercial, pleasure, sail power repair. Helms,
engine rooms, below decks, panels, electronics and propulsion controls and
$&(552
3DJHRI
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engineering.
Greg Moore is Top Talent direct to your vessel.We finished helping to install two
new Cat. 1700HP engines on a navy ship. We transformed the ship from analog to
digital.
.These are all important businesses providing services to public
agencies, individuals, and the Navy.One of them has found another lot, but the
others have specialized needs that the current location provides. This applicant is
being sued by some of its investors and investigated by the government for a possible
Ponzi scheme. Businesses provide jobs- in these cases highly trained and well paid
jobs-and sales taxes to the city. More housing demands more services from the city,
which the city can’t afford to provide and more commuter traffic to jobs outside of the
city. The noise from the nightly freight train and the trolley is quite loud. I live off of
Hilltop and occasionally the freight train wakes me up. There is also a lot of traffic
congestion now on this street now because this is the preferred way to enter I-5, and
this has not been analyzed by the MND. The entrance/exit from the south to the north
is actually on Industrial closer to Moss than L street.
Sincerely,
Theresa Acerro
President, Southwest Chula Vista Civic Association
$&(552
3DJHRI
2-7
Individuals
Theresa Acerro (ACERRO)
Response to ACERRO-1
This comment pertains to business and economic considerations. The comment does not raise
any CEQA issues or question the environmental analysis, and therefore no response is
necessary. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project.
Response to ACERRO-2
This comment pertains to business considerations. The comment does not raise any CEQA
issues or question the environmental analysis, and therefore no response is necessary. This
comment will be provided to the City decision makers for their review and consideration in
determining whether to approve the project.
Response to ACERRO-3
This comment states that the businesses utilizing the project have specialized needs that the
current location provides. This comment will be provided to the City decision makers for their
review and consideration in determining whether to approve the project.
Regarding zoning and industrial land uses, the Draft IS/MND includes a consistency analysis
to determine the proposed project’s land use and planning consistency with the City of Chula
Vista Vision 2020 General Plan. According to this analysis, the proposed project would be
consistent with and help provide additional, high-density residential units to meet the current
and future housing demands in the City. The analysis also found that, consistent with General
Plan Objective LUT-1 and Policy LUT-4.3, the proposed project would help enhance the
character of the neighborhood by creating more compatible land uses and improving the
frontage of Moss Street. Additionally, the existing industrial and multi-family uses would be
adequately screened and buffered from the project site through fencing and landscaping, and
noxious and blighted industrial uses would be removed from a residential neighborhood. No
further analysis is required.
Response to ACERRO-4
The comment pertains to jobs provided by the current operations on the site. According to the
Draft IS/MND’s analysis of land use and planning consistency with the City of Chula Vista
Vision 2020 General Plan, the proposed project would be consistent with Policy LUT-1.4,
which is a policy designed to achieve an improved balance between jobs and housing in City.
The project consistency analysis found that the proposed project would be consistent with the
policy and directly help increase the availability of housing in the City. As discussed in Table
21, Land Use and Planning Consistency with the City Chula Vista Vision 2020 General Plan,
of the Draft IS/MND, the proposed project would result in the removal of approximately 30 to
40 jobs and add 141 dwelling units, which would not be enough to significantly alter the jobs-
housing balance in the City. According to the analysis presented in Section XI, Land Use and
Planning, of the Draft IS/MND, the project helps to achieve an improved balance between jobs
and housing in the City of Chula Vista, consistent with Policy LUT-1.4. Furthermore, the
2-8
analysis presented in Section XI, Land Use and Planning, of the Draft IS/MND analysis
determined that the proposed project would be consistent with Policy GM 2.1, which aims to
achieve and maintain a balance of land uses within the City that assures residential
development is complemented by expanded local employment opportunities, retail and
commercial services, and recreation and entertainment venues; and that the City-wide mix of
land uses provides fiscal balance between those that produce revenues and those that require
public expenditures.
The proposed project would be consistent with the goal of achieving a balance of
complementing land uses for employment and residential by helping support and complement
the Chula Vista Bayfront Project, which would create 6,000 permanent jobs, by providing
housing near the project.
Response to ACERRO-5
This comment pertains to noise from the freight train near the project site and traffic
congestion, which the comment states has not been analyzed within the Draft IS/MND.
A Tra nsportation Impact Analysis, which was prepared for the project by Linscott, Law &
Greenspan, Engineers (LLG) for the project on April 15, 2020, included an analysis of trip
generation rates from the proposed project. The Transportation Impact Analysis concluded that
the proposed project would have no significant transportation impacts for the purposes of
CEQA, and that no vehicle miles traveled (VMT)-related mitigation measures are required.
The Transportation Impact Analysis provided the basis for the conclusions made within the
Draft IS/MND.
Noise impacts were analyzed in Section XIII, pages 81 through 98, of the Draft IS/MND. The
Draft IS/MND noise analysis was based on a Noise Impact Analysis prepared for the project
to evaluate off-site and on-site noise impacts associated with the proposed project, including
noise sources from the existing railroad and roadways. As a result of the analysis, mitigation
measures were included to reduce noise-related impacts to less than significant levels.
Implementation of Mitigation Measure (MM) NOI-1 would reduce traffic and railroad noise
impacts to the proposed project through project design, such as the construction of a sound
wall to create a barrier, as well as project review by an acoustic consultant. Implementation of
MM NOI-2 would reduce potential construction noise impacts. The Draft IS/MND found that
the noise impacts would be less than significant with the incorporation of the mitigation
measures.
2
From: Kenn Colclasure [mailto:kcolclas@sdccd.edu]
Sent: Monday, May 25, 2020 7:18 AM
To: Stan Donn; Steve Power; Oscar Romero
Subject: 676 Moss Street Project 2
Comments on the MND for: 1. Project Name: 676 Moss Street Project 2.
Project Location: 676 Moss Street, Chula Vista, California 3. Assessor’s Parcel
No.: 618-010-2601, 618-010-2602, 618-010-3100, and 618-010-3200 4. Project
Applicant: Shopoff Land Fund-Moss Street, LLC 2 Park Plaza, Suite 700, Irvine, California
92614 Contact: James O’Malley 949.417.1396 5. Date of Draft Document: April 27,
2020 6. Case No: IS18-0004 7.
Message:
Mayor and Council members,
This document is totally inadequate since it totally ignores the impact of the proposed project on the
current users of the property. It is a classic confirmation of exactly how unfriendly the city of Chula
Vista is to businesses. As well as how it ignores the economic consequences of proposed changes to
the General Plan and historic zoning. This is not vacant property. There are 6 important thriving
businesses most of whom have been here for over 20 years in some cases more than 30 years
providing high quality jobs and services to developers, the Navy, public agencies and individuals in
our community and nationally.
In addition, will this project resolve our shortage of police coverage, traffic congestion on I-5, and
worse, impending water shortage in our region? For sure, we will see more traffic with residents
driving north to jobs that don't exist in Chula Vista.
Can we do better and consider the people who live here rather than the builders and developers from
other places?
Warning:
External
Email
Kenn Colclasure
Chula Vista
COLCLASURE
Page 1 of 1
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2-11
Kenn Colclasure (COLCLASURE)
Response to COLCLASURE -1
The comment expresses general opposition to the project due to anticipated business and
economic impacts. The comment does not raise any CEQA issues or question the
environmental analysis, and therefore no response is necessary. This comment will be provided
to the City decision makers for their review and consideration in determining whether to
approve the project.
Response to COLCLASURE -2
This comment states that the project will result in impacts to police services, traffic and
transportation, and hydrology/water quality.
Police protection impacts were analyzed in the Section XV, pages 101 through 102, of the Draft
IS/MND. The Draft IS/MND found that impacts to police services would be less than
significant. The proposed project plans would be reviewed by the City and the Chula Vista
Police Department to ensure adequate safety and crime prevention measures are provided.
Transportation impacts were analyzed in Section XVII, pages 105 through 110, of the Draft
IS/MND. The Draft IS/MND found that the proposed project would not have adverse impacts
to existing transit, roadway, bicycle, or pedestrian facilities and would be consistent with the
City of Chula Vista Vision 2020 General Plan. The Draft IS/MND concluded that
transportation impacts would be less than significant. A Traffic Impact Analysis prepared for
the proposed project was used as the basis for the analysis and conclusion.
Hydrology and water quality impacts were analyzed in Section X, pages 66 through 72, of the
Draft IS/MND. San Diego County Water Authority’s 2015 Urban Water Management Plan
(2015 UWMP), which provides water to the Sweetwater Authority who in turn provides water
to the project site area. The Sweetwater Authority’s 2020 water supply is anticipated to come
from a combination of 75.2 percent imported water (supplied by the Metropolitan Water
District of Southern California) and 24.8 percent local water supply (approximately 4.1 percent
of which is groundwater). The 2015 UWMP anticipates having adequate water supplies
through the year 2040, with groundwater production remaining stable, groundwater recovery
supplies increasing yearly, and groundwater replenishment increasing yearly. The proposed
project would not substantially decrease groundwater supplies or interfere with groundwater
recharge such that it would contribute to regional water shortages in the future. The Draft
IS/MND found that impacts to hydrology and water quality would be therefore less than
significant.
The comment does not provide additional information that would require additional analysis
of potential environmental impacts. No additional analysis is required.
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)URP *UHJ0RRUH VHDSRZHUJUHJ#\DKRRFRP!
Sent: Thursday, May 14, 2020 9:39 PM
To: Mary Salas <MSalas@chulavistaca.gov>; John McCann <jmccann@chulavistaca.gov>; Jill Galvez
<jmgalvez@chulavistaca.gov>; Steve C. Padilla <spadilla@chulavistaca.gov>; Mike Diaz
<mdiaz@chulavistaca.gov>; Stan Donn <Sdonn@chulavistaca.gov>; Steve Power <SPower@chulavistaca.gov>;
Oscar Romero <oromero@chulavistaca.gov>; ecrockett@chulavista.ca.gov; Gary Halbert
<GHalbert@chulavistaca.gov>; John Downing <johnd@rapidprep.com>; Southwest Mobile Storage
<daniel.a@swmobilestorage.com>; Jim Garcia <jgarcia@hawthornecat.com>; John Herbert
<jherbert@kleenblast.com>; debbie@kleenblast.com; THERESA ACERRO <thacerro@yahoo.com>
Subject: Tennant objection and comments for 676 moss street large commercial to residential development
Warning: External Email
Dear City representatives: Attached are my May 27th deadline objections and comments to this super large
development as a current lot tennant who repairs the two yachts seen on page 170 in the large L shaped parcelshown
on photo.
If I have to move these two yachts and tear down this yard I built just to do these two yacht projects before these two
boats are done, I am ruined for life. Please pass my objections along to all parties who can help postpone or cancel
this development. Moving before I finish and liquidating all assets under this time deadline might be the death ofme.
I'm not in notice loop and just now hearing about getting kicked out this soon. see attached file.
.
Thank you, please have a wonderful day.
Greg Moore
Boat Yard San Diego
ph- (619) 218-1018
Address: 676 Moss St. Lot A
Chula Vista Ca. 91911
Services:
http://www.boatyardsandiego.com boat building, repower, repaint
http://www.sandiegoboatelectric.com<http://www.sandiegoboatelectric.com/> est 1983 Drawings, repairs to
propulsion controls and switchboards. Electronics and Electrical Engineering for Navy, Pleasure, Commercial,
Industrial.
MOORE
Page 1 of 3
1
Greg Moore
Boat Yard San Diego
676 Moss St Chula Vista Lot A, Ca 91911
619-218-1018, seapowergreg@yahoo.com
TO:
msalas@chulavistaca.gov, jmccann@chulavistaca.gov, jmgalvez@chulavistaca.gov, spadilla@c
hulavistaca.gov, mdiaz@chulavistaca.gov,
Stan Donn sdonn@chulavistaca.gov, Steve Power spower@chulavistaca.gov, Oscar
Romero oromero@chulavistaca.gov, Eric Crockett ecrockett@chulavista.ca.gov
Gary Halbert ghalbert@chulavistaca.gov
Tennant Objection to large industrial to residential development and Comments on the MND for:
1. Project Name: 676 Moss Street Project
2. Project Location: 676 Moss Street, Chula Vista, California
3. Assessor’s Parcel No.: 618-010-2601, 618-010-2602, 618-010-3100, and 618-010-3200
4. Project Applicant: Shopoff Land Fund-Moss Street, LLC 2 Park Plaza, Suite 700, Irvine,
California 92614 Contact: James O’Malley 949.417.1396 5. Date of Draft Document: April 27,
2020 6. Case No: IS18-0004 7. Date of Final Document: TBD
See page 170 and you will see two yachts inside an L shaped large parcel on said 676 Moss St.
development land. That is my business. I will be ruined and put completely out of business if I
must move before finishing these two yachts. I spent everything I had and a punishing amount
of effort to first find a zoned for boat repair and large yachts large lot you can get to waterfront
from. This parcel is extremely rare and it will be next to impossible to finish these two yachts
and move out by November.
I built a very capable yacht yard that took 1.5 years and cost 200 grand just so I can restore
these two boats. This is first notice I got about this development. Plus, Covid is stalling me big
time. I am extremely worried I might not be able to get both yachts finished and have time to
liquidate all the assets I built here. When I moved into 676 Moss Stree I was told I could restore
these yachts with no plans except to make this yacht a master piece on the only spot I could
find suitable and legal to do this on. Maybe if I was lucky it would become sustainable and last
until I die. I was already told once to move out of previous location I had on industrial land in
front of nassco shipyard and it almost bankrupted me to move. It took 7 months of lost
production and cost over one hundred grand to find this spot and just get here, not counting
setup and facilities we built from scratch on an empty piece of gravel. I cannot do it again. I was
incredibly careful to select and get a properly zoned and approved business license so I could
finish and with luck last as Boat Yard instead of dockworker.
When will these boats be done? Right about that time but we can’t be rushed. Now that we have
come to an almost complete stage of a five year project, moving yacht now, will damage it..
MOORE
Page 2 of 3
2
3
Talent and very limited space on a boat with all new surfaces prevent loading it up with talent
that doesn’t exist and pushing project faster if we want to hit our extremely yacht quality target
mark needed to be competitive, sell and pray to at least break even. We may only need a few
extra months, weeks, impossible to say and depending on this COVID 19 and the Boats needs
which new ones pop up every day. It’s a prototype, one of a king project.
I do not have a lease, I’m a verbal agreement sublease with Rapid prep. When they were
blindsided by sale of property, they mentioned something to me but I have not received one
notice from the city of the developer as required.
Please I beg of the city, if you have to kick out, disrupt or in my case crush 5 major businesses
on a working industrial lot off industrial blvd and a lot that’s as rare as lakefront front property
along highway 5 with 5, not 3 major businesses here and a bunch of good jobs and services as
rare and as unique as the lot itself.
I’m a marine business on a lot zoned for marine repair, near the water in an industrial area with
extremely high noise from trains and huge traffic back ups due to trolly out in front of this
development. Trolleys, freight trains, cars lined up half the block with stereos blazing, extremely
high theft area and crime due to freeway and trolly less than a pitching wedge away.
I’m all for a guy who wants to make money. I build yachts, wealthy men have fed my dreams my
entire life and I can assume this seller, investor and developer are wealthy. I don’t want to
impede their dreams to make big money or the city’s future dreams. But I beg you to consider
how valuable the jobs and working land is and how much a big lot near the waterfront is needed
for boaters everywhere not just Chula Vista (you have a huge marina nearby). 50,000 visitors a
month see our website and study our services in Chula Vista after spending 22 years on Shelter
Island we bring yachtsmen and jobs to your city now. I am in my 42nd year working on yachts or
navy in SD. Just a Navy Electronics tech who somehow worked his way up to building an entire
yacht and having a boat yard. This yard and tools are all I have.
everyone should think carefully about cramming all those units on this already
crammed and jammed street off Industrial BLVD, the buffer zone between freeway and rail track
noises. Any more cars trying to turn in here between 3pm to 6pm are in for a rude awakening.
Please consider the economic impact of us being forced out early. Please consider how rare
Kleen blast and rapid preop and boat yard san Diego and Hawthorne are? The hawthorns have
big yachts, I’m sure they will be fine but the other 4 businesses here are extremely suited for
just this property. You would be surprised about how clean and quiet boat restoration is. It’s a
very cool and specialized talent for everyone who loves the sea. I’d stay here forever and give
business to next generation if I could.
If I have to move before boat is done, I would be forced to sue the city if I was forced to waste 7
months and another 100 grand I didn’t count on. Finding a route, location, boat mover big
enough to move 2, 70 ft long 55,000 and 75,000 pound yachts down the street and under
bridges and trolly lines. Its hard to get a spot reserved and cost a fortune. The timing of all this is
so close to our completion. If you cant spare my head and must crush this dream industrial spot,
at least give me extra time. Are supply and talent line are completely disrupted and hurting us
further.
MOORE
Page 3 of 3
4
5
6
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2-17
Greg Moore (MOORE)
Response to MOORE-1
The commenter states that the proposed project would harm his business and require him to
relocate the business. The comment does not raise any CEQA issues or question the
environmental analysis, and therefore no response is necessary. This comment will be provided
to the City decision makers for their review and consideration in determining whether to
approve the project.
Response to MOORE-2
The comment states that the commenter chose the location for his business, a yacht and boat
repair center, because of appropriate zoning and proximity to the waterfront. The comment
further states that the current operations of the business cannot be completed before November.
The Draft IS/MND provided an analysis of land use and planning consistency. The analysis
found that the proposed residential land uses are an appropriate use for the site.
The proposed land uses would provide high-density residential units to meet the current and
future housing demands in the City; create a more balanced set of land uses by adding high-
density housing in an area with excellent access to existing and planned civic and public
facilities; and provide an effective mix of land uses in the Southwest Planning Area.
Furthermore, the site would be located within walking distance to public transit, public
services, and amenities, including schools, parks, bus stops, and other public facilities.
Furthermore, the proposed project is not located within the Chula Vista Bayfront Master Plan
area and would not conflict with or impede the City’s ability to implement the plan. According
to the Draft IS/MND Section XI, Land Use and Planning, page 73, , the Bayfront Project would
create 6,000 permanent jobs and designated spaces for entertainment, retail, and open space.
The high-density residential uses at 676 Moss Street would help support and complement the
Bayfront Project.
This comment will be provided to the City decision makers for their review and consideration
in determining whether to approve the project. No additional analysis is required.
Response to MOORE-3
The comment states that a combination of events, including the proposed project, COVID-19,
and previous difficulty finding a location for the business, pose a hardship on the business.
Furthermore, the commenter provides details about the difficulty of securing the current
location for the business and the importance of keeping this location. The commenter also
states that moving the location of the business will damage his long-term project that is nearing
completion.
Although the comment does not raise any CEQA issues or question the environmental analysis
contained within the Draft IS/MND, it will be provided to the City decision makers for their
review and consideration in determining whether to approve the project.
2-18
Response to MOORE-4
The comment pertains to the importance of finishing the commenter’s business’s current
project in its current location. Although the comment does not raise any CEQA issues or
question the environmental analysis contained within the Draft IS/MND, it will be provided to
the City decision makers for their review and consideration in determining whether to approve
the project.
Response to MOORE-5
The commenter states that he is a tenant of the building and does not have a lease, but only a
verbal agreement of a sublease with Rapid Prep. The commenter was not notified by the
developer of the sale of the property. Although the comment does not raise any CEQA issues
or questions about the environmental analysis of the Draft IS/MND, it will be provided to the
City decision makers for their review and consideration in determining whether to approve the
project.
Response to MOORE-6
The comment pertains to the negative effect of the proposed project on the businesses currently
operating at the site. Although the comment does not raise any CEQA issues or questions about
the environmental analysis of the Draft IS/MND, it will be provided to the City decision makers
for their review and consideration in determining whether to approve the project.
Response to MOORE-7
The comment states that the area is zoned for marine repair and is near the water in an industrial
area with noise, traffic, and crime due to proximity to the railway and freeways.
Regarding noise and traffic-related impacts, please see Response to ACERRO-6.
Regarding zoning and land uses, please see Response to ACCERRO-3.
Response to MOORE-8
The comment pertains to the value of the site for boating purposes. The comment further states
that the site is not appropriate for residential units due to the industrial character of the site and
traffic.
Regarding zoning and land uses, please see Response to ACCERRO-3.
Regarding noise and traffic-related impacts, please see Response to ACERRO-6.
Response to MOORE-9
The comment pertains to the economic impact of the project. The Draft IS/MND determined
that the project would be consistent with Policy LUT-1.6 of the Chula Vista Vision 2020
General Plan, which seeks to attract and maintain land uses that generate revenue for the City
of Chula Vista. According to the analysis, the proposed project would significantly increase
revenues from existing levels, thereby having a positive overall economic impact for the City
of Chula Vista. The site currently generates roughly $48,100 in gross revenue, while the
proposed project would generate roughly $302,300 in gross revenue, a six-fold increase.
2-19
The comment concerning the economic impacts to the existing businesses on the site will be
provided to the City decision makers for their review and consideration in determining whether
to approve the project.
Response to MOORE-10
The comment states that the proposed project would displace his business at an inopportune
time and requests extra time to avoid disruption to business operations. Although the comment
does not raise any CEQA issues or questions about the environmental analysis of the Draft
IS/MND, it will be provided to the City decision makers for their review and consideration.
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1
From:RobertStack<rstack@emindom.com>
Sent:Tuesday,May26,202011:05AM
To:StanDonn<Sdonn@chulavistaca.gov>
Subject:Commentfor676MossStreetProject
DearMr.Donn,
Pleaseseeattachedcommentsforthe676MossStreetProject.Thanks.
Bestregards,
Rob
Warning:
External
Email
Law Offices Of Robert A. Stack
4445 Eastgate Mall, Suite 200
San Diego, CA 92121
Bus:(858) 812-8479
Fax:(858) 812-2001
Stacklawfirm.com
rstack@emindom.com
67$&.
3DJHRI
67$&.
3DJHRI
67$&.
3DJHRI
THIS PAGE INTENTIONALLY LEFT BLANK
2-25
Robert Stack (STACK)
Response to STACK -1
The comment consists of introductory remarks and expresses general opposition to the project
due to business impacts. The comment requests preparation of an Environmental Impact
Report. This comment will be provided to the City decision makers for their review and
consideration in determining whether to approve the project.
The comment continues to state that the Draft IS/MND’s analysis of land use zoning and the
Land Use and Planning Consistency with the Chula Vista Vision 2020 General Plan is
inadequate. The Draft IS/MND Section XI, Land Use and Planning, Impact Question (b)
provides a thorough evaluation of the proposed project’s land use and planning consistency
with the City of Chula Vista Vision 2020 General Plan.. This analysis determined that the
project would have a less than significant impact and would not conflict with any land use
plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental
effect. Table 21, Land Use and Planning Consistency with the City Chula Vista Vision 2020
General Plan, in the Draft IS/MND provides a complete and detailed consistency analysis of
the project with General Plan objectives and policies. The Draft IS/MND has been prepared in
accordance with CEQA Guidelines Section 15070 and meets the standards for adequacy
established by CEQA. .
Response to STACK -2
The comment expresses general opposition to the proposed zone change and General Plan
Amendment. The comment claims that residential land uses are not compatible with the
industrial character of the project site.
For information regarding zoning and land uses, please see Response to ACCERRO-3.
Response to STACK -3
The comment states that the proposed project would be out of character for the area and would
block views. Furthermore, the comment states that the open space that is proposed is not open
space, but a buffer space.
The Draft IS/MND found that the proposed project would have no impact to scenic vistas or
scenic resources as designated in the City of Chula Vista 2020 General Plan, or to any other
scenic resource including trees, rock outcroppings, historic buildings or a State Scenic
Highway. The Draft IS/MND also found that because the project is consistent with applicable
zoning and with the City of Chula Vistas Design Guidelines, the proposed project would have
a less than significant impact to scenic quality.
Regarding the comment related to open space, the Draft IS/MND states that approximately one
third of the site (2.5 acres) would be developed as open space. The proposed open space
includes approximately 19,636 square feet of rooftop decks for recreation, and approximately
36,864 square feet of common open space that would include a community recreational area
with barbeque counter, tot lot, and overhead structures with Americans with Disabilities Act
(ADA) compliant seating for social gatherings and special events. As shown in Exhibit 6:
2-26
Conceptual Open Space Plan of the Draft IS/MND, the total open space consists of a
combination of common areas, private grounds, decks, and rooftop decks. Landscaped areas
(45,381 square feet), which may serve as setbacks and buffers for the site, were not included
in the total open space area calculations. The open spaces that are proposed would provide
meaningful opportunities for recreation and social gatherings. No further analysis is required.
Response to STACK -4
The comment states that the proposed project would have adverse impacts on the CDI Marine
property and the Sweetwater Union High School District Maintenance Facility. The comment
does not raise any questions about the environmental analysis of the Draft IS/MND. This
comment will be provided to the City decision makers for their review and consideration in
determining whether to approve the project.
Response to STACK -5
The comment states the importance of commercial uses and infrastructure to the City of Chula
Vista. The proposed project would not include a reduction of commercial uses; however, the
proposed project would result in a reduction of industrial uses. The Draft IS/MND found that
consistent with General Plan Policy GM 2.1, the proposed reduction in industrially designated
lands would be very small (less than 0.4 percent) and would therefore not have a significant
effect on the Citywide mix and balance of land uses. The Draft IS/MND’s land use and
planning consistency analysis found that the proposed project would not cause significant
adverse impacts to the neighboring industrial sites or the adjacent apartment complex and would
not affect the viability of adjacent industrial lands. No further analysis is required.
Response to STACK -6
The comment states that there is no rational basis for the proposed project. The comment
further states that the project is out of character for the area, would damage residential and
commercial uses, and is inappropriately placed due to the industrial uses of the site and
proximity to the railroad and roadways.
The Draft IS/MND analyzed several benefits of the proposed project and performed a
consistency analysis to determine the proposed project’s land use and planning consistency
with the City of Chula Vista Vision 2020 General Plan. According to this analysis, the proposed
project would be consistent with and help provide additional, high-density residential units to
meet the current and future housing demands in the City. Additionally, the analysis found that
the proposed project would help enhance the character of the neighborhood by creating more
compatible land uses and improving the frontage of Moss Street. Furthermore, the proposed
project would be located within walking distance to transit, public services, and amenities,
including schools, parks, public transit, and other public facilities. The project would create
new residential uses at densities compatible with the adjacent uses, strengthening the balance of
land uses in the immediate surroundings. The analysis also determined that the proposed project
would not add an incompatible or potentially disruptive land use. The proposed project would
be located across the street from a single-family neighborhood and would work to increase the
integrity of the residential neighborhood by removing less compatible industrial uses and
2-27
aligning residential uses on Moss Street. A complete and detailed consistency analysis is
provided in Table 21 of the Draft Initial Study. No additional analysis is required.
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3-1
SECTION 3: ERRATA
The following are revisions to the Draft IS/MND for the 676 Moss Street Project.
These revisions are minor modifications and clarifications to the document, and do not
change the significance of any of the environmental issue conclusions within the Draft
IS/MND. The revisions are listed by page number. All additions to the text are underlined
(underlined) and all deletions from the text are stricken (stricken).
Mitigated Negative Declaration, Section B. Project Description
Page 2, Parking
The following text has been revised to reflect the revised number of parking spaces during
construction. The Draft IS/MND stated the anticipated number of parking spaces would be
348. The correct number of parking spaces is 346.
The proposed rezoning to R-3 requires two parking spaces per dwelling unit, for a
total of 282 parking spaces. The proposed project would provide 282 garage spaces
with an additional 64 66 non-garage spaces. Therefore, the proposed project would
provide 2.47 parking spaces per home equaling 346 348 parking spaces; 64 66 more
parking spaces than required by the R-3 zoning (Exhibit 5).
Initial Study, Section XV. Public Services, (b) Police Protection
Page 101, Paragraph 5
The following correction has been made with regard to the police department discussion.
(b) Less than significant impact. The City of Chula Vista Police Department (CVPD)
currently provides police protection to the project site and would continue to do so in
the future. The proposed project would develop 141 new dwelling units on the project
site, which would add an estimated 475 persons to the City’s population, which is less
than 0.2 percent of the total current population of the City. CVPD Headquarters is
located 2.35 miles from the project site at 315 Fourth Avenue. Using an average travel
speed of 25 mph, it would take a police vehicle fire engine less 6 minutes to reach the
project site from CVPD Headquarters.
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676 MOSS STREET PROJECT
INITIAL STUDY/MITIGATED NEGATIVE
DECLARATION
MITIGATION MONITORING
AND
REPORTING PROGRAM
Lead Agency:
City of Chula Vista
276 Fourth Avenue
Chula Vista, CA 91910
April 2020
676 Moss Street Project
April 2020 MMRP-3
MITIGATION MONITORING AND REPORTING PROGRAM
PREFACE
Section 21081.6 of the California Environmental Quality Act (CEQA) and CEQA Guidelines
Section 15097 require a Lead Agency to adopt a mitigation monitoring or reporting program
whenever it adopts a mitigated negative declaration in conjunction with a project approval.
The purpose of the mitigation monitoring or reporting program is to ensure compliance with
the mitigation measures during project implementation.
The Initial Study and Mitigated Negative Declaration (IS/MND) prepared for the 676 Moss
Street Project in Chula Vista, CA concluded that the implementation of the project could
result in potentially significant effects on the environment and mitigation measures were
incorporated into the proposed project or are required as a condition of project approval that
reduce these potential impacts to less than significant level. The purpose of this Mitigation
Monitoring and Reporting Program (MMRP) is to document how and when the mitigation
measures adopted by the lead agency are implemented, and to document that potential
environmental impacts are reduced to less than significant levels as identified in the MND.
This document does not discuss those subjects that the MND analysis demonstrates would
result in less than significant impacts and for which no mitigation was proposed or necessary.
MITIGATION MONITORING AND REPORTING PROGRAM
676 Moss Street Project
April 2020 MMRP-5
Table 1
Mitigation Monitoring and Reporting Program
Mitigation Measures
Time Frame of Mitigation Monitoring
Reporting
Agency
Time Frame for
Verification Frequency
to
Date of
Completion
Date of
Verification Planning Pre-Const.
During
Const. Post Const. Monitor Report
Air Quality
MM AIR-1: Prior to the issuance of any demolition or grading permit, the Project Applicant shall demonstrate to the satisfaction of the City
Building Department that all off-road construction equipment that will be used on the project site in excess of 50 horsepower will be
equipped with engines meeting the United States Environmental Protection Agency (EPA) Tier IV Final off-road engine emission
standards. This mitigation measure shall be included on the grading plan.
X X City of Chula
Vista Building
Department
Biological Resources
MM BIO-1: Construction activities that occur during the nesting season (generally March 1 to August 31) could disturb nesting sites for birds
protected by the Migratory Bird Treaty Act (MBTA) and Fish and Game Code. No action is necessary if no active nests are found or if
construction occurs during the non-breeding season (generally September 1 through February 14).
Implementation of the following avoidance and minimization measures would reduce impacts to nesting birds to a less than significant
level.
To prevent impacts to MBTA-protected birds, nesting raptors, and their nests, removal of trees will be limited to only those
necessary to construct the proposed project.
If any tree removal is necessary, then it will occur outside the nesting season, between September 1 and February 14. If trees
cannot be removed outside the nesting season, pre-construction surveys will be conducted 3 days prior to tree removal to verify
the absence of active nests.
If an active nest is located during pre-construction surveys, the United States Fish and Wildlife Service (USFWS) and/or the
California Department of Fish and Wildlife (CDFW) (as appropriate) shall be notified regarding the status of the nest.
Construction activities shall be restricted as necessary to avoid disturbance of the nest until it is abandoned or the agencies deem
disturbance potential to be minimal. Restrictions may include the establishment of exclusion zones (no ingress of personnel or
equipment at a minimum radius of 100 feet around an active raptor nest and a 50-foot radius around an active migratory bird
nest) or alteration of the construction schedule.
A Qualified Biologist will delineate the buffer using Environmentally Sensitive Area (ESA) fencing, pin flags, and or yellow
caution tape. The buffer zone will be maintained around the active nest site(s) until the young have fledged and are foraging
independently.
X X City of Chula
Vista
Development
Services
Department
Cultural and Tribal Cultural Resources
MM CUL-1 Prior to the issuance of any demolition or grading permit, the Project Applicant shall demonstrate to the satisfaction of the City
Development Services Department that a program related to potential archaeological resources uncovered during construction activities
on-site has been established, the program shall include that:
1. The Project Applicant shall retain a qualified professional Archaeologist approved by the City to be present and monitor all
ground-disturbing activities;
2. The Archaeologist shall halt work in the immediate area in the event that archaeological resources are identified until the
Archaeologist has evaluated the find and determined if the find is a “unique cultural resource” as defined in Section 21083.2 (g)
of the CEQA statutes;
3. The Project Applicant shall inform the City Development Services Department of the find;
4. If this determination is positive, the scientifically consequential information shall be fully recovered by the Archaeologist;
5. The Project Applicant shall stop work in the immediate location of the find until information recovery has been completed and a
report has been filed with the City; the South Coastal Information Center (SCIC) at San Diego State University; and, appropriate
Native American representatives;
6. The Project Applicant may continue outside the area of the find; and,
7. The City Development Services Department shall ensure compliance.
X X City of Chula
Vista
Development
Services
Department
MITIGATION MONITORING AND REPORTING PROGRAM
676 Moss Street Project
April 2020 MMRP-6
Mitigation Measures
Time Frame of Mitigation Monitoring
Reporting
Agency
Time Frame for
Verification Frequency
to
Date of
Completion
Date of
Verification Planning Pre-Const.
During
Const. Post Const. Monitor Report
MM CUL-2: Prior to the issuance of any demolition or grading permit, the Project Applicant shall demonstrate to the satisfaction of the City
Development Services Department that a program related to any human remains that might be encountered during ground-disturbing
activities on-site has been established, the program shall include:
1. The Project Applicant shall halt work in the immediate area of the find;
2. The Project Applicant shall contact the San Diego County Coroner, City Development Services Department, and Sherriff’s Department;
3. The Project Applicant shall be responsible for ensuring that the Native American Heritage Commission (NAHC) and the appropriate
Native American representatives are contacted and that the NAHC contacts the most appropriate most likely descendant (MLD) as
maybe directed by either the San Diego County Coroner, City Development Services Department, or Sherriff’s Department;
4. The City Development Services Department shall direct the treatment of the remains pursuant to Coroner and MLD recommendations.
X X City of Chula
Vista
Development
Services
Department
Geology and Soils
MM GEO-1: All recommendations included in the Preliminary Geotechnical Report, included as Appendix D of this Draft IS/MND, shall be
implemented during construction activities.
X X City of Chula
Vista
Development
Services
Department
MM GEO-2: The City of Chula Vista assesses and mitigates the potential impacts of private development and public facilities and infrastructure to
paleontological resources pursuant to the provisions of CEQA. Pursuant to Section 15065 of the CEQA Guidelines, a lead agency must
find that a project may have a significant effect on the environment where the project has the potential to eliminate important examples
of the major periods of California prehistory, which includes the destruction of significant paleontological resources.
With the implementation of Mitigation Measure (MM) GEO-2, impacts to any previously undiscovered paleontological resources
would be less than significant.
Because excavations may extend into undisturbed high sensitivity geological units, and may be greater than 10 feet below the ground
surface in certain areas of the project, a Paleontological Monitor will be required.
Prior to the issuance of any demolition or grading permit, the Project Applicant shall demonstrate to the satisfaction of the City
Development Services Department that a program related to paleontological resources potentially uncovered during ground-disturbing
activities on-site has been established, the program shall include:
1. The Project Applicant shall halt work in the immediate area of the find;
2. The Project Applicant shall notify the City Development Services Department;
3. The Project Applicant shall retain a qualified professional Paleontologist approved by the City:
The Paleontologist shall assess the discovered material(s).
The Paleontologist shall prepare a survey, study or report evaluating the find.
The Paleontologist’s survey, study, or report shall contain a recommendation(s), if necessary, for the preservation,
conservation, or relocation of the find.
The Report shall be reviewed and approved by the City Development Services Department.
The Project Applicant shall comply with the recommendations of the report as approved by the City.
Project development activities in the immediate area of the find will resume when copies of the report are submitted in a
manner acceptable to the City Development Services Department.
A find(s) recovered should be deposited in a manner approved by the City Development Services Department.
Prior to the issuance of any building permit, the Project Applicant shall submit a letter to the City Development Services Department
indicating what, if any, paleontological reports have been prepared for the project site, or a statement indicating that no material was
X X City of Chula
Vista
Development
Services
Department
MITIGATION MONITORING AND REPORTING PROGRAM
676 Moss Street Project
April 2020 MMRP-7
Mitigation Measures
Time Frame of Mitigation Monitoring
Reporting
Agency
Time Frame for
Verification Frequency
to
Date of
Completion
Date of
Verification Planning Pre-Const.
During
Const. Post Const. Monitor Report
discovered.
Greenhouse Gas Emissions
MM GHG-1 Prior to the occupancy of the proposed project, the Project Applicant shall provide for the purchase of voluntary carbon credits in a
manner approved by the City Development Services Department pursuant to the following performance standards and requirements: the
carbon offsets shall achieve real, permanent, quantifiable, verifiable, and enforceable reductions as set forth in Cal. Health & Saf. Code
Section 38562(d)(1); and ii. one carbon offset credit shall mean the past reduction or sequestration of one metric ton of carbon dioxide
equivalent that is “not otherwise required” (CEQA Guidelines Section 15126.4(c)(3)). The purchase shall be from a verified greenhouse
gas (GHG) emissions credit broker in an amount sufficient to offset operational GHG emissions of approximately 0 metric ton (MT)
carbon dioxide equivalent (CO2e) per year until 2030 and 450 MT CO2e per year beginning in 2030 (or a total amount estimated over
the lifetime of the proposed project, which is estimated to be 9,450 MT CO2e). The purchase shall be verified as occurring prior to
approval of occupancy permits. Copies of emission estimates and offset purchase contract(s) shall be provided to the City Development
Services Department for review and approval.
X City of Chula
Vista
Development
Services
Department
Hazards and Hazardous Materials
MM HAZ-1: Prior to the issuance of any demolition or grading permit, the Project Applicant shall demonstrate to the satisfaction of the City
Development Services Department that the five groundwater monitoring wells on the project site will remain in place should additional
groundwater testing be necessary. The Project Applicant will abandon the wells when they are longer needed in a manner approved by
the City Development Services Department and San Diego County Department of Environmental Health Monitoring Well Program.
X City of Chula
Vista
Development
Services
Department
MM HAZ-2a: Prior to the issuance of any grading permit and subsequent to the demolition of on-site structures, the Project Applicant shall conduct
soil testing on the soils the structures were on. If volatile organic compounds (VOCs) are present, soil containing elevated
concentrations of VOCs shall be excavated and removed from the project site. The excavation and removal of soil to be outlined in the
Soil Management Plan (SMP) approved by the San Diego County Department of Environmental Health.
X San Diego
County
Department of
Environmental
Health
MM HAZ-2b: Prior to issuance of any demolition permit, the Project Applicant shall obtain a permit from the San Diego County Hazardous Materials
Division. The permits shall provide that hydrocarbons or “other products” that might be encountered during building demolition,
grading, or construction activities, are disposed of in a manner approved by the City Development Services Department.
X X San Diego
County
Hazardous
Materials
Division
MM HAZ 3: Prior to the issuance of any site development permits (demolition, grading, building, construction), the Project Applicant shall enter into
the County of San Diego Department of Environmental Health Voluntary Assistance Program (VAP). Written Confirmation of VAP
participation and compliance shall be received from San Diego County Department of Environmental Health prior to any site
development activities.
X County of San
Diego
Department of
Environmental
Health VAP
Noise
MM NOI-1 To meet the interior noise level standard of 45 A-weighted decibel (dBA) Community Noise Equivalent Level (CNEL), each of the
proposed multi-family residential units shall be supplied with an alternative form of ventilation, such as air conditioning or
noise-attenuated passive ventilation systems, that would allow an occupant the option of controlling noise by keeping the windows
shut (as the interior noise standard would not be met with open windows).
X X City of Chula
Vista
Development
Services
Department
MM NOI-2 To reduce potential construction noise impacts, the Project Applicant shall demonstrate to the satisfaction of the City Development
Services Department that:
The Construction Contractor shall ensure that all equipment driven by internal combustion engines shall be equipped with
X X City of Chula
Vista
Development
Services
MITIGATION MONITORING AND REPORTING PROGRAM
676 Moss Street Project
April 2020 MMRP-8
Mitigation Measures
Time Frame of Mitigation Monitoring
Reporting
Agency
Time Frame for
Verification Frequency
to
Date of
Completion
Date of
Verification Planning Pre-Const.
During
Const. Post Const. Monitor Report
mufflers that are in good condition and appropriate for the equipment.
The Construction Contractor shall ensure that unnecessary idling of internal combustion engines (i.e., idling in excess of 5
minutes) is prohibited.
The Construction Contractor shall utilize “quiet” models of air compressors and other stationary noise sources where such market
available technology exists.
The Construction Contractor shall ensure that stationary noise-generating equipment shall be located as far as practicable from
sensitive receptors and placed so that emitted noise is directed away from the nearest residential land uses at all times during
project grading and construction.
The Construction Contractor shall designate a Noise Disturbance Coordinator who would be responsible for responding to any local
complaints about construction noise. The Noise Disturbance Coordinator would determine the cause of the noise complaints (starting
too early, bad muffler, etc.) and establishment reasonable actions necessary to correct the problem. The Construction Contractor shall
visibly post a telephone number for the Noise Disturbance Coordinator at the construction site.
The Construction Contractor shall limit noise producing construction activities to the hours between 7:00 a.m. and 10:00 p.m.,
Monday through Friday, and between 8:00 a.m. and 10:00 p.m. on Saturday and Sunday.
Prior to the issuance of each certificate of occupancy, the Construction Contractor shall demonstrate, to the satisfaction of the City
Development Services Department, compliance with Mitigation Measure (MM) NOI-2.
Department