HomeMy WebLinkAboutAttachment 4 - Environmental Impact Report EIR20-0002Sunbow Sectional Planning Area
Plan Amendment for the
Sunbow II, Phase 3 Project
Final Environmental Impact Report
EIR 20-0002
SCH No.
2020110148
July 2021
Sunbow Sectional Planning Area Plan Amendment
for the
Sunbow II, Phase 3 Project
Final Environmental Impact Report
Prepared for:
City of Chula Vista
276 Fourth Avenue
Chula Vista, California 91910
Contact: Oscar Romero
Prepared by:
605 Third Street
Encinitas, California 92024
Contact: Brian Grover, AICP
JULY 2021
Printed on 30% post-consumer recycled material.
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 TOC-i
Table of Contents
Section Page No.
PREFACE TO THE FINAL ENVIRONMENTAL IMPACT REPORT AND REESPONSE TO COMMENTS ....................... RTC-1
1 EXECUTIVE SUMMARY ............................................................................................................................... 1-1
1.1 Project Location and Setting .............................................................................................................. 1-1
1.2 Project Background ............................................................................................................................ 1-1
1.3 Project Description ............................................................................................................................. 1-2
1.3.1 Project Objectives ................................................................................................................. 1-4
1.3.2 Discretionary Actions ............................................................................................................ 1-4
1.4 Areas of Controversy .......................................................................................................................... 1-4
1.5 Issues to Be Resolved by the City Council ........................................................................................ 1-5
1.6 Project Alternatives ............................................................................................................................ 1-5
1.6.1 No Project/No Build Alternative ........................................................................................... 1-5
1.6.2 Existing Land Use Designations Alternative ........................................................................ 1-5
1.6.3 Reduced Development Alternative ...................................................................................... 1-6
1.7 Summary of Significant Environmental Impacts .............................................................................. 1-6
2 INTRODUCTION .......................................................................................................................................... 2-1
2.1 Project Purpose and Background ...................................................................................................... 2-1
2.2 Hierarchy of Sunbow Planning Documents ...................................................................................... 2-1
2.2.1 City of Chula Vista General Plan .......................................................................................... 2-1
2.2.2 Sunbow General Development Plan .................................................................................... 2-2
2.2.3 City of Chula Vista Multiple Species Conservation Program .............................................. 2-2
2.2.4 Sectional Planning Area Plans ............................................................................................. 2-2
2.3 Scope of the EIR ................................................................................................................................. 2-3
2.4 Environmental Procedures ................................................................................................................ 2-3
2.4.1 CEQA Compliance ................................................................................................................. 2-3
2.4.2 Notice of Preparation and Scoping ...................................................................................... 2-3
2.4.3 Overview of the EIR Process................................................................................................. 2-4
2.5 Intended Uses of the EIR ................................................................................................................... 2-4
2.6 Organization and Content of the EIR ................................................................................................. 2-5
2.7 Mitigation Monitoring and Reporting Program ................................................................................. 2-6
3 ENVIRONMENTAL SETTING ........................................................................................................................ 3-1
3.1 Existing Site Conditions ...................................................................................................................... 3-1
3.1.1 Surrounding Land Uses ........................................................................................................ 3-1
3.1.2 Existing Topography and Soils ............................................................................................. 3-1
3.1.3 Climate .................................................................................................................................. 3-2
3.1.4 Access .................................................................................................................................... 3-2
3.2 Existing Land Use Designations ........................................................................................................ 3-2
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3.2.1 Existing General Plan Designations ..................................................................................... 3-2
3.2.2 Existing Zoning ...................................................................................................................... 3-2
3.2.3 Existing Sunbow General Development Plan Designation ................................................. 3-2
3.2.4 Existing Sunbow Sectional Planning Area Plan Designation .............................................. 3-2
4 PROJECT DESCRIPTION ............................................................................................................................. 4-1
4.1 Location .............................................................................................................................................. 4-1
4.2 Background ......................................................................................................................................... 4-1
4.3 Project Objectives ............................................................................................................................... 4-2
4.4 Project Description ............................................................................................................................. 4-2
4.4.1 Land Uses .............................................................................................................................. 4-2
4.4.2 Access and Circulation Network .......................................................................................... 4-7
4.4.3 Public Service and Utilities ................................................................................................... 4-9
4.4.4 MSCP Boundary Line Adjustment and Minor Amendment............................................... 4-11
4.4.5 Tentative Map ..................................................................................................................... 4-11
4.4.6 Conceptual Grading ............................................................................................................ 4-11
4.4.7 Construction and Phasing .................................................................................................. 4-11
4.4.8 Project Design Features ..................................................................................................... 4-12
4.5 Discretionary Actions/Approvals ..................................................................................................... 4-13
5 ENVIRONMENTAL IMPACT ANALYSIS ......................................................................................................... 5-1
5.1 Aesthetics ........................................................................................................................................ 5.1-1
5.1.1 Existing Conditions............................................................................................................. 5.1-1
5.1.2 Thresholds of Significance ................................................................................................ 5.1-7
5.1.3 Impacts ............................................................................................................................... 5.1-7
5.1.4 Level of Significance Prior to Mitigation ......................................................................... 5.1-11
5.1.5 Mitigation Measures ........................................................................................................ 5.1-12
5.1.6 Level of Significance After Mitigation ............................................................................. 5.1-12
5.2 Air Quality ......................................................................................................................................... 5.2-1
5.2.1 Existing Conditions............................................................................................................. 5.2-1
5.2.2 Thresholds of Significance .............................................................................................. 5.2-19
5.2.3 Impacts ............................................................................................................................. 5.2-20
5.2.4 Level of Significance Prior to Mitigation ......................................................................... 5.2-35
5.2.5 Mitigation Measures ........................................................................................................ 5.2-35
5.2.6 Level of Significance After Mitigation ............................................................................. 5.2-35
5.3 Biological Resources ....................................................................................................................... 5.3-1
5.3.1 Existing Conditions............................................................................................................. 5.3-1
5.3.2 Thresholds of Significance .............................................................................................. 5.3-22
5.3.3 Impacts ............................................................................................................................. 5.3-23
5.3.4 Level of Significance Prior to Mitigation ......................................................................... 5.3-44
5.3.5 Mitigation Measures ........................................................................................................ 5.3-44
5.3.6 Level of Significance After Mitigation ............................................................................. 5.3-53
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5.4 Cultural and Tribal Cultural Resources .......................................................................................... 5.4-1
5.4.1 Existing Conditions............................................................................................................. 5.4-1
5.4.2 Thresholds of Significance .............................................................................................. 5.4-13
5.4.3 Impacts ............................................................................................................................. 5.4-13
5.4.4 Level of Significance Prior to Mitigation ......................................................................... 5.4-14
5.4.5 Mitigation Measures ........................................................................................................ 5.4-15
5.4.6 Level of Significance After Mitigation ............................................................................. 5.4-16
5.5 Energy .............................................................................................................................................. 5.5-1
5.5.1 Existing Conditions............................................................................................................. 5.5-1
5.5.2 Thresholds of Significance .............................................................................................. 5.5-12
5.5.3 Impacts ............................................................................................................................. 5.5-12
5.5.4 Level of Significance Prior to Mitigation ......................................................................... 5.5-18
5.5.5 Mitigation Measures ........................................................................................................ 5.5-18
5.5.6 Level of Significance After Mitigation ............................................................................. 5.5-18
5.6 Geology and Soils ............................................................................................................................ 5.6-1
5.6.1 Existing Conditions............................................................................................................. 5.6-1
5.6.2 Thresholds of Significance ................................................................................................ 5.6-7
5.6.3 Impacts ............................................................................................................................... 5.6-8
5.6.4 Level of Significance Prior to Mitigation ......................................................................... 5.6-11
5.6.5 Mitigation Measures ........................................................................................................ 5.6-11
5.6.6 Level of Significance After Mitigation ............................................................................. 5.6-12
5.7 Greenhouse Gas Emissions ............................................................................................................ 5.7-1
5.7.1 Existing Conditions............................................................................................................. 5.7-1
5.7.2 Thresholds of Significance .............................................................................................. 5.7-22
5.7.3 Impacts ............................................................................................................................. 5.7-24
5.7.4 Level of Significance Prior to Mitigation ......................................................................... 5.7-40
5.7.5 Mitigation Measures ........................................................................................................ 5.7-40
5.7.6 Level of Significance After Mitigation ............................................................................. 5.7-41
5.8 Hazards and Hazardous Materials ................................................................................................. 5.8-1
5.8.1 Existing Conditions............................................................................................................. 5.8-1
5.8.2 Thresholds of Significance .............................................................................................. 5.8-13
5.8.3 Impacts ............................................................................................................................. 5.8-14
5.8.4 Level of Significance Prior to Mitigation ......................................................................... 5.8-20
5.8.5 Mitigation Measures ........................................................................................................ 5.8-20
5.8.6 Level of Significance After Mitigation ............................................................................. 5.8-24
5.9 Hydrology and Water Quality ........................................................................................................... 5.9-1
5.9.1 Existing Conditions............................................................................................................. 5.9-1
5.9.2 Thresholds of Significance ................................................................................................ 5.9-7
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5.9.3 Impacts ............................................................................................................................... 5.9-7
5.9.4 Level of Significance Prior to Mitigation ......................................................................... 5.9-12
5.9.5 Mitigation Measures ........................................................................................................ 5.9-12
5.9.6 Level of Significance After Mitigation ............................................................................. 5.9-12
5.10 Land Use and Planning ................................................................................................................. 5.10-1
5.10.1 Existing Conditions........................................................................................................... 5.10-1
5.10.2 Thresholds of Significance .............................................................................................. 5.10-9
5.10.3 Impacts ............................................................................................................................. 5.10-9
5.10.4 Level of Significance Prior to Mitigation ...................................................................... 5.10-20
5.10.5 Mitigation Measures ..................................................................................................... 5.10-21
5.10.6 Level of Significance After Mitigation .......................................................................... 5.10-21
5.11 Noise .............................................................................................................................................. 5.11-1
5.11.1 Existing Conditions........................................................................................................... 5.11-1
5.11.2 Thresholds of Significance .............................................................................................. 5.11-5
5.11.3 Impacts ............................................................................................................................. 5.11-6
5.11.4 Level of Significance Prior to Mitigation ...................................................................... 5.11-13
5.11.5 Mitigation Measures ..................................................................................................... 5.11-13
5.11.6 Level of Significance After Mitigation .......................................................................... 5.11-13
5.12 Population and Housing ................................................................................................................ 5.12-1
5.12.1 Existing Conditions........................................................................................................... 5.12-1
5.12.2 Thresholds of Significance .............................................................................................. 5.12-6
5.12.3 Impacts ............................................................................................................................. 5.12-6
5.12.4 Level of Significance Prior to Mitigation ......................................................................... 5.12-8
5.12.5 Mitigation Measures ........................................................................................................ 5.12-8
5.12.6 Level of Significance After Mitigation ............................................................................. 5.12-8
5.13 Public Services .............................................................................................................................. 5.13-1
5.13.1 Existing Conditions........................................................................................................... 5.13-1
5.13.2 Thresholds of Significance ........................................................................................... 5.13-13
5.13.3 Impact Analysis ............................................................................................................. 5.13-14
5.13.4 Level of Significance Prior to Mitigation ...................................................................... 5.13-18
5.13.5 Mitigation Measures ..................................................................................................... 5.13-18
5.13.6 Level of Significance After Mitigation .......................................................................... 5.13-19
5.14 Recreation ...................................................................................................................................... 5.14-1
5.14.1 Existing Conditions........................................................................................................... 5.14-1
5.14.2 Thresholds of Significance .............................................................................................. 5.14-7
5.14.3 Impacts ............................................................................................................................. 5.14-7
5.14.4 Level of Significance Prior to Mitigation ......................................................................... 5.14-8
5.14.5 Mitigation Measures ........................................................................................................ 5.14-8
5.14.6 Level of Significance After Mitigation ............................................................................. 5.14-8
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5.15 Transportation ............................................................................................................................... 5.15-1
5.15.1 Existing Conditions........................................................................................................... 5.15-1
5.15.2 Thresholds of Significance .............................................................................................. 5.15-9
5.15.3 Impacts ............................................................................................................................. 5.15-9
5.15.4 Level of Significance Prior to Mitigation ...................................................................... 5.15-13
5.15.5 Mitigation Measures ..................................................................................................... 5.15-14
5.15.6 Level of Significance After Mitigation .......................................................................... 5.15-14
5.16 Utilities and Service Systems ........................................................................................................ 5.16-1
5.16.1 Existing Conditions........................................................................................................... 5.16-1
5.16.2 Thresholds of Significance ........................................................................................... 5.16-18
5.16.3 Impacts .......................................................................................................................... 5.16-18
5.16.4 Level of Significance Prior to Mitigation ...................................................................... 5.16-26
5.16.5 Mitigation Measures ..................................................................................................... 5.16-26
5.16.6 Level of Significance After Mitigation .......................................................................... 5.16-26
5.17 Wildfire ........................................................................................................................................... 5.17-1
5.17.1 Existing Conditions........................................................................................................... 5.17-1
5.17.2 Thresholds of Significance .............................................................................................. 5.17-9
5.17.3 Impacts ............................................................................................................................. 5.17-9
5.17.4 Level of Significance Prior to Mitigation ...................................................................... 5.17-14
5.17.5 Mitigation Measures ..................................................................................................... 5.17-14
5.17.6 Level of Significance After Mitigation .......................................................................... 5.17-14
6 CUMULATIVE IMPACTS ............................................................................................................................... 6-1
6.1 Introduction......................................................................................................................................... 6-1
6.2 Methodology ....................................................................................................................................... 6-1
6.3 Cumulative Projects ........................................................................................................................... 6-3
6.3.1 Land Development................................................................................................................ 6-3
6.3.2 Adopted Plans ....................................................................................................................... 6-4
6.4 Cumulative Impact Analysis ............................................................................................................... 6-4
6.4.1 Aesthetics .............................................................................................................................. 6-5
6.4.2 Air Quality .............................................................................................................................. 6-5
6.4.3 Biological Resources ............................................................................................................ 6-6
6.4.4 Cultural Resources and Tribal Cultural Resources ............................................................. 6-7
6.4.5 Energy .................................................................................................................................... 6-7
6.4.6 Geology and Soils ................................................................................................................. 6-8
6.4.7 Greenhouse Gas Emissions ................................................................................................. 6-8
6.4.8 Hazards and Hazardous Materials ...................................................................................... 6-9
6.4.9 Hydrology and Water Quality .............................................................................................. 6-10
6.4.10 Land Use and Planning....................................................................................................... 6-10
6.4.11 Noise .................................................................................................................................... 6-11
6.4.12 Population and Housing ..................................................................................................... 6-11
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6.4.13 Public Services .................................................................................................................... 6-12
6.4.14 Recreation ........................................................................................................................... 6-12
6.4.15 Transportation ..................................................................................................................... 6-12
6.4.16 Utilities and Service Systems ............................................................................................. 6-13
6.4.17 Wildfire ................................................................................................................................ 6-13
7 GROWTH INDUCEMENT ............................................................................................................................. 7-1
7.1 Growth Inducement Due to Population Growth ................................................................................ 7-1
7.2 Growth Inducement Due to Economic Growth ................................................................................. 7-2
7.3 Growth Inducement Due to Additional Housing ............................................................................... 7-2
7.4 Growth Inducement Due to Removal of Obstacles .......................................................................... 7-3
7.5 Taxation of Existing Public Facilities and Services ........................................................................... 7-4
8 SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES ....................................................................... 8-1
9 EFFECTS FOUND NOT TO BE SIGNIFICANT ................................................................................................ 9-1
9.1 Agriculture and Forestry Resources .................................................................................................. 9-1
9.2 Mineral Resources ............................................................................................................................. 9-2
10 ALTERNATIVES ......................................................................................................................................... 10-1
10.1 Introduction....................................................................................................................................... 10-1
10.2 Project Objectives ............................................................................................................................. 10-1
10.3 Alternatives Considered but Rejected ............................................................................................. 10-2
10.4 Alternatives under Consideration .................................................................................................... 10-2
10.5 Alternatives Impact Summary .......................................................................................................... 10-3
10.5.1 No Project/No Build Alternative ......................................................................................... 10-3
10.5.2 Existing Land Use Designations Alternative ...................................................................... 10-6
10.5.3 Reduced Development Alternative .................................................................................. 10-11
10.6 Environmentally Superior Alternative ............................................................................................ 10-16
11 REFERENCES ........................................................................................................................................... 11-1
12 LIST OF PREPARERS ................................................................................................................................ 12-1
Appendices
A NOP Comment Letters
B Sectional Planning Area Plan Amendment
C Air Quality and Greenhouse Gas Emissions Analysis (including Health Risk Assessment Report and
Nuisance Analysis)
D1 Biological Resources Technical Report
D2 Functional Equivalency Analysis for MSCP Boundary Line Adjustment
E Cultural and Paleontological Resources Inventory Report
F Energy Calculations
G Geotechnical Report
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H1 Phase 1 Evironmental Site Assessment
H2 Vapor Instrusion Memorandum
H3 Fire Protection Plan
I1 Stormwater Quality Management Plan
I2 Drainage Study
J Noise Impact Analysis
K Transportation Impact Analysis
L1 Water System Analysis
L2 Water Supply Assessment
L3 Water Conservation Plan
L4 Sewer System Analysis
M Mitigation, Monitoring, and Reporting Program
Figures
3-1 Existing General Plan Land Use ................................................................................................................... 3-3
3-2 Existing General Development Plan Land Use Designation ....................................................................... 3-5
3-3 Existing SPA Plan Land Use Plan ................................................................................................................. 3-7
4-1 Project Location .......................................................................................................................................... 4-15
4-2 Proposed General Plan Land Use .............................................................................................................. 4-17
4-3 Proposed General Development Plan Land Use Designation .................................................................. 4-19
4-4 Proposed SPA Land Use Plan..................................................................................................................... 4-21
4-5 Proposed Zoning ......................................................................................................................................... 4-23
4-6 Illustrative Concept Plan ............................................................................................................................ 4-25
4-7 Community Purpose Facility Conceptual Site Plan ................................................................................... 4-27
4-8 Proposed Poggi Creek Easement and MSCP Boundary ........................................................................... 4-29
4-9 Vehicular Circulation Plan .......................................................................................................................... 4-31
4-10 Bicycle and Pedestrian Circulation Plan .................................................................................................... 4-33
4-11 Streets ‘A’ and ‘B’ – Typical Street Sections ............................................................................................. 4-35
4-12 Private Residential Streets – Typical Street Sections .............................................................................. 4-37
4-13 Proposed Water and Recycled Water System ........................................................................................... 4-39
4-14 Proposed Sewer System............................................................................................................................. 4-41
4-15 Proposed Storm Drain System ................................................................................................................... 4-43
4-16 Tentative Map ............................................................................................................................................. 4-45
4-17 Conceptual Grading Plan............................................................................................................................ 4-47
5.3-1 Local Environmental Setting Map ........................................................................................................... 5.3-55
5.3-2 Biological Resources Map ....................................................................................................................... 5.3-57
5.3-3 Wetland Delineation Map ........................................................................................................................ 5.3-59
5.3-4 Biological Impacts Map ........................................................................................................................... 5.3-61
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5.3-5 MSCP Preserve BLA Map ........................................................................................................................ 5.3-63
5.11-1 Noise Measurement and Modeling Locations .................................................................................... 5.11-15
5.13-1 Facility Locations .................................................................................................................................. 5.13-21
5.16-1 Existing Water Facilities ....................................................................................................................... 5.16-27
6-1 Cumulative Projects .................................................................................................................................... 6-15
Tables
1-1 Sunbow II, Phase 3 Sectional Planning Area Plan Land Use Summary .................................................... 1-2
1-2 Summary of Significant Environmental Impacts and Mitigation ............................................................... 1-7
4-1 Sunbow II, Phase 3 Sectional Planning Area Plan Land Use Summary .................................................... 4-3
5.2-1 Ambient Air Quality Standards .................................................................................................................. 5.2-2
5.2-2 San Diego Air Basin Attainment Classification ...................................................................................... 5.2-17
5.2-3 Local Ambient Air Quality Data ............................................................................................................... 5.2-18
5.2-4 City of Chula Vista Air Quality Significance Thresholds ......................................................................... 5.2-19
5.2-5 Estimated Maximum Daily Construction Criteria Air Pollutant Emissions ............................................ 5.2-23
5.2-6 Estimated Maximum Daily Operational Criteria Air Pollutant Emissions ............................................. 5.2-23
5.2-7 Landfill Health Risk Assessment Results – Unmitigated ...................................................................... 5.2-28
5.2-8 Summary of Odor Analysis ...................................................................................................................... 5.2-34
5.2-9 Dust Analysis ............................................................................................................................................ 5.2-34
5.3-1 Habitats/Vegetation Communities within Project Site ............................................................................ 5.3-6
5.3-2 Summary of Jurisdictional Resources Present within the Project Site ................................................. 5.3-11
5.3-3 Sensitive Flora Located On Site Inside and Outside Preserve Boundaries .......................................... 5.3-14
5.3-4 Sensitive Fauna Located On Site Inside and Outside Preserve Boundaries........................................ 5.3-15
5.3-5 Schedule of Survey Dates, Times, Conditions, and Staff ...................................................................... 5.3-18
5.3-6 Proposed Impacts to Sensitive Plant Species........................................................................................ 5.3-23
5.3-7 Quantitative Summary of Vegetation Community Impacts from the Proposed Project ...................... 5.3-29
5.3-8 City of Chula Vista MSCP Preserve Boundary Line Adjustment Habitats and Acreages ..................... 5.3-35
5.3-9 Cumulative Impacts to Covered Habitat from Future Facilities ............................................................ 5.3-37
5.3-10 Narrow Endemic Policy – Estimated Otay Tarplant Impact Assessment ............................................. 5.3-39
5.3-11 Project Habitat Mitigation Ratios and Acreages .................................................................................... 5.3-51
5.4-1 Reports within the Proposed Project APE ................................................................................................ 5.4-8
5.4-2 Resource within Proposed Project Research Area (1-Mile Buffer) ......................................................... 5.4-9
5.5-1 Hours of Operation for Construction Equipment ................................................................................... 5.5-13
5.5-2 Construction Equipment Diesel Demand ............................................................................................... 5.5-13
5.5-3 Construction Worker Vehicle Gasoline Demand .................................................................................... 5.5-13
5.5-4 Construction Vendor Truck Diesel Demand ........................................................................................... 5.5-14
5.6-1 Principal Active Faults Near Project Site .................................................................................................. 5.6-6
5.7-1 2028 Interpolated Efficiency Metric ....................................................................................................... 5.7-24
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5.7-2 Estimated Annual Construction Greenhouse Gas Emissions ............................................................... 5.7-25
5.7-3 Estimated Annual Operational Greenhouse Gas Emissions ................................................................. 5.7-26
5.7-4 City of Chula Vista Climate Action Plan Consistency Analysis ............................................................... 5.7-27
5.7-5 San Diego Forward: The Regional Plan Consistency Analysis ............................................................... 5.7-30
5.7-6 Project Consistency with Scoping Plan Greenhouse Gas Emissions Reduction Strategies ............... 5.7-33
5.8-1 Database Search Report Findings ............................................................................................................ 5.8-9
5.11-1 City of Chula Vista Exterior Property-Line Noise Limits ......................................................................... 5.11-2
5.11-2 Measured Baseline Outdoor Ambient Noise Levels .............................................................................. 5.11-5
5.11-3 Typical Construction Equipment Maximum Noise Levels ..................................................................... 5.11-6
5.11-4 Estimated Distances between Construction Activities and the Nearest
Noise-Sensitive Receptors ...................................................................................................................... 5.11-7
5.11-5 Predicted Construction Noise Levels per Activity Phase ....................................................................... 5.11-8
5.11-6 Roadway Traffic Noise Modeling Results ............................................................................................... 5.11-9
5.11-7 On-Site Roadway Traffic Noise Modeling Results ............................................................................... 5.11-10
5.11-8 Predicted Net Sound Transmission Class of Sample Occupied Room Facade ................................ 5.11-11
5.12-1 San Diego Region vs. City of Chula Vista Population, Housing, and Employment Forecast .............. 5.12-2
5.12-2 Past Performance RHNA 5th Cycle (2013–2020) ................................................................................ 5.12-3
5.12-3 RHNA Allocation for the 6th Cycle (2021–2029) .................................................................................. 5.12-3
5.12-4 Chula Vista Projected Population in 2030 ............................................................................................. 5.12-4
5.13-1 Chula Vista Fire Department Staffing ..................................................................................................... 5.13-7
5.13-2 City of Chula Vista Fire Station Facilities ................................................................................................ 5.13-8
5.13-3 CVFD Emergency Response Analysis for the Proposed Project Site ................................................. 5.13-15
5.13-4 Fire Station Call Volumes ..................................................................................................................... 5.13-15
5.14-1 City of Chula Vista Parks and Recreation Resource Categories ........................................................... 5.14-3
5.14-2 Summary of Existing (January 2018) Citywide Public Parks and Major Recreation Facilities ........... 5.14-4
5.14-3 Parks and Recreational Facilities Located within 2 Miles of the Proposed Project Site .................... 5.14-5
5.15-1 Project VMT Analysis............................................................................................................................. 5.15-11
5.15-2 Project VMT Results with Implementation of Series Measures ......................................................... 5.15-12
5.16-1 Projected Normal Year Water Supplies (AFY)...................................................................................... 5.16-10
5.16-2 Average/Normal Water Year Supply and Demand Assessment (AFY) .............................................. 5.16-11
5.16-3 Single Dry Water Year Supply and Demand Assessment (AFY) ......................................................... 5.16-12
5.16-4 Multiple Dry Water Year Supply and Demand Assessment (AFY) ...................................................... 5.16-12
5.16-5 Otay Water District Projected Water Supply and Demand ................................................................. 5.16-14
5.16-6 Projected Recycled Water Demand ..................................................................................................... 5.16-15
5.16-7 Sewer Generation Factor ..................................................................................................................... 5.16-16
5.16-8 Water Duty Factors ............................................................................................................................... 5.16-19
5.16-9 Sunbow II, Phase 3 Projected Potable Water Demands .................................................................... 5.16-19
5.16-10 Sunbow II, Phase 3 Projected Recycled Water Demands .................................................................. 5.16-20
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5.16-11 Sunbow II, Phase 3 Sewer Flow Summary .......................................................................................... 5.16-21
5.16-12 Projected Balance of Water Demands and Supplies Normal Year
Conditions (Acre Feet) ......................................................................................................................... 5.16-23
5.16-13 Projected Balance of Water Demands and Supplies Single Dry and Multiple Dry Year
Conditions (Acre Feet) .......................................................................................................................... 5.16-24
5.17-1 Proposed Project Vegetation Communities and Land Cover Types ...................................................... 5.17-8
6-1 Geographic Scope of Cumulative Impact Analyses .................................................................................... 6-1
6-2 Cumulative Projects ...................................................................................................................................... 6-3
10-1 Alternatives Impact Summary .................................................................................................................. 10-16
Preface to the Final Environmental Impact
Report and Response to Comments
The City of Chula Vista, as the Lead Agency under the California Environmental Quality Act (CEQA), has prepared
this Final Environmental Impact Report (Final EIR) for the proposed Sunbow Sectional Planning Area (SPA) Plan
Amendment for the Sunbow II, Phase 3 Project (proposed project) located within the Sunbow Master Planned
Community of the City of Chula Vista. As described in Sections 15089 and 15132 of the CEQA Guidelines, the lead
agency must prepare a Final EIR before approving a project. Pursuant to CEQA Guidelines Section 15132, a Final
EIR shall consist of:
• The Draft EIR or a revision of the draft.
• Comments and recommendations received on the Draft EIR either verbatim or in summary.
• A list of persons, organizations, and public agencies commenting on the Draft EIR.
• The responses of the Lead Agency to significant environmental points raised in the review and consultation
process; and
• Any other information added by the Lead Agency.
Pursuant to these guidelines, this Final EIR (State Clearinghouse No. 2020110148) includes in the following order:
a list of persons, organizations, and agencies that provided comments on the Draft EIR; responses to comments
received on the Draft EIR; the Draft EIR.
1.1 Comments Received on Draft EIR and Responses
The Draft EIR was circulated for public review on March 15, 2021 through April 28, 2021, in accordance with the
45-day comment period required under Section 15105(a) of the CEQA Guidelines. A total of five (5) comment
letters were received on the Draft EIR from a gencies, organizations, and individuals as shown in the list below.
In response to the comments received during public review and to City staff input subsequent to distribution of
the Draft EIR, minor revisions, clarifications, and/or additions have been made to the document which do not
change the conclusions of the Final EIR regarding the project’s potential environmental impacts and required
mitigation. These minor revisions do not represent significant new information. No new significant environmental
impacts would occur from these modificat ions, and similarly, no substantial increase in the severity of
environmental impacts would occur.
Commenters on the Draft EIR are provided below:
• Comment Letter A: Sherry Barton
• Comment Letter B: San Diego Association of Governments, Tracy Ferchaw
• Comment Letter C: Bracken Ellis
• Comment Letter D: California Department of Fish and Wildlife, David A. Mayer
• Comment Letter E: San Diego County Archaeological Society, Inc., James W. Royle, Jr.
Copies of all letters received by the City of Chula Vista regarding the Draft EIR and the responses to comments follow.
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Comment Letter A
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Response to Comment Letter A
Sherry Barton
March 22, 2021
A-1 This comment pertains to the increase in traffic along Olympic Parkway as a result of the project.
Impacts related to traffic are addressed in Section 5.15, Transportation, of the Draft EIR. In June 2020,
the City of Chula Vista adopted its Transportation Study Guide to comply with Senate Bill 743, which
replaced Level of Service (LOS) with Vehicle Miles Traveled (VMT) as the metric for determining the
significance of a project’s transportation impacts under CEQA. Nonetheless, the Transportation Impact
Analysis (TIA) prepared for the project included a Local Mobility Analysis (LMA) to focus on automobile
delay/LOS. The LMA is a City requirement for transportation analysis that is not tied to CEQA;
therefore, implementation of measures to address LOS -related effects does not constitute CEQA
mitigation. The TIA determined that the project would result in effects associated with unacceptable LOS
under the General Plan LOS standards. While Olympic Parkway is built-out and the provision of additional
lanes is considered physically infeasible, it is recommended that payment of the City’s Transportation
Development Impact Fee (TDIF) should be applied towards other planned network enhancements included
in the Eastern TDIF program that would reduce traffic on Olympic Parkway and be implemented as a
condition of approval for the project outside of this EIR. In addition, it is recommended that the project
provide a fair share contribution toward the provision of Adaptive Traffic Signal Control (ATSC) modules to
each signalized intersection along the Olympic Parkway corridor between the I-805 Ramps and La Media
Road. These TDIF and other requirements associated with LOS deficiencies would be included as part of
the project’s conditions of approval, outside of this EIR.
A-2 The City acknowledges this comment and the concern of water seepage occurring where two existing
Otay Water District above ground water tanks are located. Both existing water tanks are located
southwest of the project site adjacent to the on-site open space preserve where no development is
proposed. This comment has no bearing on the analysis contained in the Draft EIR. The City has already
begun coordination with the commenter regarding this concern and will continue to do so in the future.
No further response is required.
A-3 This comment pertains to the displacement of wildlife off open land as a result of the project. Impacts
related to biological resources are addressed in Section 5.3, Biological Resources, of the Draft EIR.
Development would primarily occur in the southeastern portion of the project site. The north, west, and
southwestern boundaries of the site would remain open space preserve. The wildlife species known or
expected to occur on site consist of urban tolerant species such as coyote and raccoon that are
expected to continue to move throughout the site and along Poggi Creek after implementation of the
project. The City is in the early stages of developing a Wildlife Management Plan which will include
management for wildlife known to occur within the City, including the project site.
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Comment Letter B
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Response to Comment Letter B
San Diego Association of Governments (SANDAG)
Tracy Ferchaw
April 26, 2021
B-1 This comment pertains to the project site being located along the proposed SANDAG 2021 Regional
Plan Complete Corridor network and suggests implementation of additional strategies to support the
implementation of the 2021 Regional Plan, and further reduce the number of automobile trips
generated by residents and vehicle miles traveled. Transportation demand management strategies
(TDMs) are addressed in Section 5.15, Transportation, of the Draft EIR. The project incorporates the
California Air Pollution Control Officers’ Association (CAPCOA) land use and location TDM to reduce the
project’s VMT impact. Impacts related to VMT are less than significant and therefore mitigation
measures are not required. Additional trip reduction strategies are identified in project design feature
(PDF)-TRA-1 which would further reduce the number of automobile trips generated by residents of the
project and the distance that the residents drive. Please note that the transportation analysis does not
take credit for trip reduction strategies included in PDF-TRA-1; therefore, the less-than-significant
determination for transportation impacts does not rely on PDF-TRA-1. As such, additional mitigation
measures are not required to reduce transportation impacts to a level below significance. However, in
response to this comment PDF-TRA-1 of the Draft EIR has been revised to include implementation of a
multimodal wayfinding signage program. Note that the provision of transit information is already
included in PDF-TRA-1. The suggestion regarding implementation of a dockless micromobility program
would not likely be feasible within the project site given the proposed residential only land use.
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Comment Letter C
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Response to Comment Letter C
Bracken Ellis
April 28, 2021
C-1 The City acknowledges the commenter’s opinion regarding the proposed project. The City, as lead
agency, has prepared the Draft EIR in compliance with all criteria, standards, and procedures of the CEQA
Guidelines (14 CCR Section 15000 et seq.). This comment is introductory in nature and summarizes specific
comments to follow. Please refer to Responses to Comments C-2 though C-21 below.
C-2 This comment suggests that the Draft EIR’s analysis regarding potential odors from the landfill is
incorrect. A nuisance analysis was prepared for the project and is contained in Appendix C, and
summarized in Section 5.2, Air Quality, of the Draft EIR. It should be noted that the nuisance Report
analyzed the impact of the landfill on the residents of the project. The nuisance analysis was prepared
to evaluate the potential impacts of odors emitted from the Otay Landfill on future residents of the
project. The nuisance analysis for the project demonstrated that using the SDAPCD provided
meteorological data for the project site and landfill emission parameters, odors are not likely to be
detected by future residents at the project site. The significance threshold of 1.0 is based on greater
than 50% likelihood that odor would be detected. As the analysis resulted in less than 1.0, it is
concluded that a less than 50% likelihood that odor would be detected. Therefore, while odors may be
detected from time to time it was determined they would not present a nuisance. The complete
nuisance analysis is provided in Appendix D of Appendix C.
Section 5.2, Air Quality, of the Draft EIR, also noted that on April 26, 2020, the Otay Landfill submitted
an application (proposed Otay Landfill Compostable Materials Handling Facility, Permit #37-AA-0984)
for the addition of up to 200 tons per day of agricultural and food waste at the organics composting
operation within the existing footprint of the Otay Landfill, which represents a 2.5% increase in volume
allowed to be processed onsite. Based upon the applicant’s environmental analysis (CEQA Addendum
#2, dated September 12, 2019, PDS2019-MUP-76-046W2M3; ER76-18-026B; and CEQA document,
dated October 29, 2020 SCH#96091009-6) there is a decrease in TAC emissions, specifically
ammonia emissions, and no change in vehicular emissions; therefore, the proposed composting
operation would most likely reduce odor levels as compared to the existing operation. There would also
be a reduction of volatile organic compound and ammonia emissions by 80% or more, reducing odor
units by 56%-80%, and diverting methane-forming organics away from landfill disposal. In addition, the
composting operation would divert up to 100 tons per day of oxidation of organic matter away from
landfill disposal, resulting in lower ammonia emissions and odors generated onsite as compared to the
existing operation. As such, impacts from odor to future residents from landfill operations would be less than
significant.
C-3 This comment suggests that the Draft EIR does not provide adequate evidence to support the
conclusion that development of the site is financially infeasible. Per Section 15131 of the CEQA
Guidelines, economic or social information may be included in an EIR. However, the scope of an EIR is
not to determine financial feasibility of any given project. Provided as background supporting
information in Section 5.10, Land Use and Planning, the City conducted a market and financial analysis
for the site relative to its existing industrial use; this analysis determined that industrial development
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of the site is unlikely to be financially feasible with an appropriate citation to the referenced analysis.
All references cited within the Draft EIR are available upon request.
The City acknowledges the commenter’s opinion regarding potential industrial development within
Chula Vista. Please note that the example industrial project referenced by the commenter is a separate
project in a different location with different circumstances and has no bearing on the potential future
development of other parcels within the City, including the project site. As such, no revisions to the
Draft EIR are necessary.
C-4 This comment pertains to noise data being misrepresentative of normal conditions as noise readings
were taken in April 2020, when the County of San Diego was under a stay -at-home order. Impacts
related to noise are addressed in Section 5.11, Noise, and Appendix J, of the Draft EIR. Sample
measurements of the existing outdoor ambient sound environment conducted during COVID-19
response conditions may have quantified noise levels due to acoustic contribution from temporarily
atypical or reduced roadway traffic flows. However, the basis for the traffic noise impact assessment is
Federal Highway Administration (FHWA) Traffic Noise Model (“TNM”, version 2.5) modeling which uses
data from the Traffic Impact Analysis (TIA) prepared for the project (included as Appendix K to the Draft
EIR) and thereby provides average daily trips input for the existing, near-term, and plus-project
scenarios. Hence, the TNM-predicted existing (2019) scenario shown in Table 6 of the Noise Technical
Report (Appendix J to the Draft EIR) shows community noise equivalent levels (CNEL) values that would
be considered more representative of pre- and post-COVID 19 conditions (i.e., after traffic flows have
returned to “normal”) and were used for evaluating change to the outdoor ambient sound level due to
project-added traffic. The measured equivalent noise level (Leq) values shown in Table 2 of the Noise
Technical Report, at four different perpendicular distances from Olympic Parkway, are less than the
predicted existing (2019) case CNEL values but vary by comparable quantities with respect to
geographic position and thus helps confirm that Olympic Parkway is—as expected—the dominant
acoustical contributor to the existing outdoor ambient sound environment. Therefore, the noise data is
not misrepresentative and revisions to the Draft EIR are not required.
C-5 This comment states that the City has sufficient housing sites available under the current planning
documents and because the project site is zoned industrial, it is not being counted as housing in the
Draft Housing Element 2021-2029 update. Potential impacts associated with housing needs are
addressed in Section 5.12, Population and Housing, of the Draft EIR. Currently, the City is updating the
General Plan Housing Element to account for housing needs and establish clear goals and objectives
to inform future housing decisions for the 2021 to 2029 housing cycle. Because the 2021 to 2029
Housing Element has not been adopted and is subject to change, the Draft EIR relies on the current
2013 to 2020 Housing Element and most up to date Regional Housing Needs Assessment (RHNA)
allocations provided by SANDAG. Tables 5.12-2 and 5.12.3 of the Draft EIR show the past performance
RHNA from the 5th Cycle (2013–2020) and the current RHNA allocation for the 6th Cycle (2021–
2029), respectively. Of the City’s previous 5th Cycle RHNA allocation, the City has only met 8,590 out
of 12,861 units; only 648 very-low and low units have been developed out of the 5,648 allocated.
Although the project site may not be identified as potential housing within the Draft Housing Element
2021-2029 update, the City has the discretion to adjust allocated housing units or identified sites as
necessary to balance proposed plans for residential development, approved/constructed residential
development, and sites identified within the housing inventory that are not yet planned for
development. The City would then be able to account for the proposed units and estimated population
resulting from the proposed project when considering future residential development proposals.
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C-6 This comment suggests that the Draft EIR inadequately discloses potential population growth resulting
from the proposed project compared to the existing underlying land use designations. CEQA guidelines
require that the Draft EIR evaluate unplanned population growth in an area, either directly or indirectly.
Potential impacts associated with population growth are addressed in Section 5.12, Population and
Housing, of the Draft EIR. The proposed project was originally identified to b e developed as Industrial
Park in the Sunbow GDP and SPA Plan . As such, the change in land use from Industrial Park to
Medium-High and High Residential would be considered unplanned population growth in excess of
the original estimates in the Sunbow GDP and SPA Plan. As stated in the Section 5.12 of the Draft EIR,
the project would result in approximately 2,314.83 persons (rounded to 2,315). A project consistent with
the existing Industrial Park land use would result in approximately 957 employees, which is based on the
best available employment density calculation for the area provided by SANDAG. As indicated by the
commenter, and discussed in Section 5.12 of the Draft EIR, a conservative approached was taken that the
proposed project would result in greater and unplanned population inducement when compared to the
existing underlying designations which would also have resulted in an increase in population with the
interpolated persons per household ratio of 3.224. Therefore, the Draft EIR clearly indicated the estimated
potential population growth of both development scenarios, while also taking a conservative approach that
acknowledges that it is unlikely that all estimated 957 potential employees would move to the area.
For additional reasons discussed in Section 5.12 of the Draft EIR (accommodation of the City’s future
growth projections and housing needs, the project site location surrounded by existing development and
services, compliance with the City’s Growth Management Program), although the proposed project would
result in greater population inducement, the population inducement resulting from the proposed project
would not be considered substantial. Thus, the Draft EIR adequately addresses unplanned population
growth as a result of the project.
C-7 This comment suggests that public services provided in this area are intended to serve industrial
development and that the proposed mitigation measures for impacts to public services are inadequate.
Impacts related to public services are addressed in Section 5.13, Public Services, of the Draft EIR. As
discussed in the Draft EIR, impacts associated with public services as a result of the project would be
potentially significant and would require implementation of mitigation measures MM-PS-1 through MM-
PS-3, to reduce impacts to less than significant levels. Please note that mitigation measures MM-PS-
1 through MM-PS-3 require compliance with existing codes and regulations.
With respect to potential impacts to fire protection, police protection, libraries, and other public
services, mitigation measures MM-PS-1 require the payment of a Public Facilities Development Impact
Fee (PFDIF). The PFDIF is a program established by the City to address a project’s proportional impact
on capital facilities, such as structures and equipment associated with providing public services. It does
not address the impact associated with operations and maintenance for those facilities. It is the city’s
policy to use public funds such as property taxes, sales taxes, and fees generated by the project to
cover the incremental costs associated with providing public services like fire and police.
The project would be required to pay the PFDIF, which is used exclusively to fund facility improvements
and ensures that the project contributes its fair share of the cost of such facilities and equipment as
determined necessary to adequately accommodate new development in the City.
With respect to fire protection services, the proposed project is projected to slightly increase the nearest
station’s (Fire Station 3) current call volume, but not at significant levels, because the current call
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volume is considered slightly above average compared to other urban fire stations and the capacity
would not be considered impacted to the point of resulting in a busy or stressed condition. In the event
that new capital facilities or equipment are needed in the future, the project will contribute to the
project’s proportional impact on such capital facilities through the payment of the City’s PFDIF as well
as all future taxes and fees adopted by the city to cover fire protection services.
With respect to the increase demand for libraries, the proposed project would generate demand for
approximately 1,158 square feet of additional library facilities within the City. Although the proposed
project does not specifically include the development of a library, this demand would be satisfied
through payment of PFDIF as stated in CVMC Section 3.50.030 and 3.50.060, which would go toward
the City’s library system expansion program.
With respect to police, the project would be required to pay the PFDIF, which would be used exclusively
for future facility improvements necessary to ensure that the development contributes its fair share of
the cost of police facilities and equipment determined to be necessary to adequately accommodate
new development in the City.
Also, the City’s Growth Management Program, adopted quality of life threshold standards for eleven
public facility and service topics, including fire, police, library and emergency medical services.
Adherence to these citywide standards is intended to preserve and enhance both the environment and
residents’ quality of life as growth occurs. The GMOC was created to provide an independent, annual,
review of the effectiveness of the General Plan in regard to development and growth-oriented issues;
to make determinations in regard to the impact of development of the “quality of life” in Chula Vista,
using adopted threshold criteria as a basis; and to publish findings and make recommendations.
Should the GMOC determine that the growth management threshold standard is not being satisfied
because of the impacts of growth, the City Council is required to consider adopting measures to bring
the condition into conformance, prior to issuing further building permits. The combination of PFDIF fees
and compliance with existing city policies and mechanisms would ensure tha t the GMOC threshold
standard is achieved.
With respect to potential impacts to schools, mitigation measure MM-PS-2 requires payment of
appropriate fee charge, dedication, or other requirement levied by the school districts. Pursuant to
Government Code Section 65996, the payment of these fees by a developer serves to fully mitigate all
potential project impacts on school facilities to less than significant levels.
With respect to potential impacts to parks, mitigation measure MM-PS-3, requires the applicant to pay
the Park Benefit Fee, as outlined in the project’s Development Agreement, equal to the City’s Park
Acquisition and Development (PAD) Fee Update pursuant to the Park Lands Dedication OrdinanceChula
Vista Municipal Code Section 17.10 et seq. The Park Lands Dedication Ordinance, which requires the
dedication of three acres of parkland per 1,000 people or a combination of land dedication, in -lieu
fees, or park development improvements. With implementation of MM-PS-3, the project would satisfy
its park obligations.
In all instances, new or expanded facilities constructed through the use of these funds would be subject
to CEQA compliance and environmental review at a later time. Therefore, no revisions to the Draft EIR
are necessary.
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C-8 This comment related to the use of a proxy site located across Olympic Parkway from the project site
within the vehicle miles traveled (VMT) analysis. Potential impacts related to VMT are discussion is
Section 5.15, Transportation, of the Draft EIR. As discussed in the Draft EIR, the project site is currently
zoned for industrial uses and therefore it would not be appropriate to use that site to conduct the VMT
analysis because the proposed land use is different from the underlying designations. The proxy site is
located within a few hundred feet and is a single family residential site located immediately north of
the project site across Olympic Parkway. Typical trip lengths associated with residential uses are
approximately 8.0 miles, therefore the use of a proxy site just a few hundred feet away would still result
in an accurate VMT calculation. In addition, per the SANDAG Trip Generation Brief Guide, single-family
and multi-family residential units have the same trip lengths, therefore, the difference in unit type
between the proxy site and the project site does not alter the VMT analysis. The proxy site does not
have direct access, to Olympic Parkway which results in longer trip lengths (and therefore greater VMT)
as compared to the project site. Therefore, the VMT analysis is conservative. Lastly, the Office of
Planning and Research (OPR) and SANDAG do not differentiate VMT between multi -family and single-
family land uses, so the fact that the proxy site contains single-family uses is not relevant. Therefore,
the Draft EIR contains an accurate VMT analysis in compliance with CEQA and industry standards of
practice. In response to this comment, Section 5.15 of the Draft EIR has been revised to provide
clarification of the use of the proxy site.
C-9 This comment pertains to the use of measures published by the California Air Pollution Control Officers’
Association (CAPCOA) in the project VMT analysis. Potential impacts related to VMT are discussed in
Section 5.15, Transportation, of the Draft EIR. As discussed in Section 5.15 and shown in Table 5.15-
2 of the Draft EIR, the project VMT only needed to be reduced by 1.4% to avoid a potentially significant
impact. Because implementation of one CAPCOA measure would reduce the VMT by more than 1.4%,
the inclusion of several reduction measures was not warranted. While many of the CAPCOA measures
were considered applicable to the project, Land Use and Location series measure LUT-1 was selected
based on the intrinsic characteristics of the project (e.g. suburban infill, proximity to transit, schools,
employment, etc.).
The commenter is correct in that a range of effectiveness is described for the recommended measure.
However, the actual reduction percentage is calculated based on the density of the project. As shown
in Table 5.15-2, based on the project’s density of 16.3 units per acre, the VMT reduction would be 8%,
when compared to the proxy site. Please refer to Appendix G of the TIA (Appendix K to the Draft EIR)
for detailed calculations. No revisions to the Draft EIR are necessary.
C-10 This comment suggests that the Draft EIR does not provide a reasonable range of alternatives for the
project. Alternatives are addressed in Section 10, Alternatives, of the Draft EIR. As stated in Section
15126.6 of the CEQA guidelines, an EIR need not consider every conceivable alternative to a project.
The range of alternatives evaluated in an EIR is governed by the “rule of reason” that requires the EIR
set forth only those alternatives necessary to permit a reasoned choice. Alternatives addressed in the
Draft EIR include the No Project/No Build Alternative, the Existing Land Use Designations Alternative,
and the Reduced Development Alternative. In developing the alternatives addressed in this EIR, the
potential alternatives were evaluated in terms of their ability to meet the basic objectives of the project,
while reducing or avoiding the environmental impacts of the project identified in Section 5.0,
Environmental Analysis, of the EIR. No further analysis is required in the Draft EIR.
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C-11 This comment states that the Draft EIR fails to consider a commercial or mixed-use development for
the project site in the alternatives analysis. Per Section 15126.6 of the CEQA Guidelines, in developing
the alternatives to be addressed in this EIR, the potential alternatives were evaluated in terms of their
ability to meet the basic objectives of the project, while reducing or avoiding the environmental impacts
of the project identified in Section 5.0, Environmental Analysis, of the EIR. The commenter suggests
that other alternatives not considered within the Draft EIR may reduce traffic impacts. As discussed in
Section 5.15, Transportation, of the Draft EIR, transportation impacts, including VMT, would be less
than significant. As such, consideration of alternatives focuses on reduction of significant
environmental impacts.
The commentor has suggested that the Draft EIR be revised to consider a commercial or mixed-use
alternative. Because no description of this alternative has been proposed, a reasonable evaluation of
this particular alternative cannot be provided. An EIR need not consider an alternative whose effects
cannot be reasonably evaluated when there is insufficient detail regarding the alternative and whose
implementation is remote and speculative (CEQA Guidelines Sections 15126.6(f)(3), 15145)
As stated above, the proposed project identified a significant impact for greenhouse gas emissions
which informed the basis for the alternative analysis in the Draft EIR. Under the Reduced Development
Alternative, construction and operational GHG emissions would be reduced as compared to the
proposed project. But the Reduced Development Alternative’s service population (residents) would also
be reduced due to the reduction in number of residential units, resulting in similar impacts as the
proposed project in the context of the City’s GHG efficiency metric threshold. Therefore, impacts to
GHGs were determined to remain significant and unavoidable under this alternative.
Similarly, a commercial or mixed-use alternative would also result in a reduction in number of
residential units, resulting in similar impacts to GHG as described in the Reduced Development
Alternative, with impacts remaining significant and unavoidable. There may be some additional
employees added to the site, however commercial uses in a mixed-use site that would still require
avoidance of MSCP preserve areas, would not be of significant size to make any considerable difference
with respect to the City’s GHG efficiency metric threshold. While this alternative would place some
employment in proximity to residential uses reducing VMT, impacts to transportation would still be
similar to the Reduced Development Alternative and the proposed project.
A commercial or mixed-use development would require a General Plan, General Development Plan, SPA
and Zoning Ordinance amendment similar to the Reduced Developmen t Alternative. The alternative
proposed by the commentor would not achieve the goal of contributing to the growing housing needs
of the City and region to the same extent as the project. Because there is insufficient detail regarding
the commercial or mixed-use alternative, it impossible to determine if the land use plan can be
realistically developed within a foreseeable time frame and under projected economic conditions as
described in objective 8. Additionally, mixed-use is not likely feasible at this location given the required
density to support such uses. The proposed project would support the existing Sunbow community,
which provides a variety of including housing, child-care, a school, public parks, and neighborhood-serving
commercial and office uses, which serve the entire community.
Because there is no CEQA mandate to include additional alternatives that achieve the same end
relative to impact avoidance/reduction to a less than significant level, this alternative was not
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considered in the Draft EIR. Therefore, the Draft EIR adequately considers a reasonable range of
alternatives and no revisions are required.
C-12 This comment suggests that the extent shown on Figure 3-1, Existing General Plan Land Use, is
misleading and omits existing industrial uses. Figure 3-1 identifies existing General Plan land use
designations for Limited Industrial directly east of the project site and to the southwest. Please refer to
Figure 4-1, Project Location, which provides an aerial image at a greater extent and inclu des the
referenced existing industrial land uses to the south beyond the Otay Landfill. Other figures provided
throughout the Draft EIR and its appendices provide varying extents showing the greater vicinity
surrounding the project site. Therefore, the Draft EIR provides accurate information regarding existing
land uses and designations in the vicinity of the project site.
C-13 This comment indicates that Figures 3-2 and 3-3 of the Draft EIR are unreadable. The City
acknowledges that Figures 3-2 and 3-3 present challenges with respect to legibility; please note that
these images are the original land use exhibits contained in the Sunbow General Development Plan
(GDP) and Sunbow Sectional Planning Area (SPA) Plan, adopted in 1989 and 1990, respectively.
Updated maps have not been generated to improve legibility. However, Sections 3.2.3 and 3.2.4 of the
Draft EIR provide an accurate text description existing Sunbow GDP and SPA Plan designations.
Therefore, accurate information pertinent to the project is contained in the Draft EIR.
C-14 This comment states that the project is relying on carpooling and transit services to reduce
transportation demands. Please note that this comment is in reference to Section 4.4.8.4 of the Draft
EIR, which includes project design features (PDFs) related to transportation. PDF-TRA-1 includes a list
of trip reduction strategies to be employed by the project during operation. Note that the analysis
contained in Section 5.15, Transportation, and in the TIA (Appendix K) of the Draft EIR do not take
credit for any transit usage, bicycle usage, or carpooling. In other words, the conclusion of a less than
significant transportation impact is supported without accounting for any trip reductions that may occur
through implementation of PDF-TRA-1. Refer to Appendix K of the Draft EIR for detailed analysis.
C-15 This comment states that the EIR does not clearly identify nearby commercial and employment centers.
As described in Section 5.10, Land Use and Planning, the project would develop new, higher density
housing on a site in a central location within the City that is already near existing commercial and
employment centers. These commercial and employment centers include the commercial/industrial
uses along Main Street to the south, the Sharp Chula Vista Medical Center, and the Sunbow Village
Center commercial area that includes retail/commercial and medical office space. Additionally, the
project is located near the University Innovation District, which plans for approximately 10.1 million of
university and regional technologies uses, while the Eastern Urban Center SPA Plan provides for
development of approximately 3.8 million square feet of commercial/mixed use development.
The comment also states that the project is not consistent with the City’s Climate Action Plan (CAP)
policy related to Smart Growth & Transportation. Consistency with the City’s CAP is discussed in Section
5.7, Greenhouse Gas Emissions, of the Draft EIR. As discussed, the project would be consistent with
the Smart Growth & Transportation measure by developing multifamily residential units that would
provide higher density development and would expand the housing choices in the region near existing
commercial and employment cetners. In addition, the project would be located close to public transit,
Interstate 805 (I-805), and located approximately one mile from the East Palomar Transit Station. The
project would also support the Smart Growth & Transportation measure by providing ride share
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coordination services, coordinating with nearby schools to carpool to/from school, provide on -site
transit opportunities information, encourage bicycling by providing on-site bicycle infrastructure such
as bike racks.
This comment states that the Draft EIR includes misinformation regarding available MTS bus routes.
Available transit options to the project are discussed in Section 5.7, Greenhouse Gas Emissions, and
Section 5.15, Transportation, of the Draft EIR. Section 5.7 of the Draft EIR inadvertently referenced
outdated information regarding MTA bus route 703 that previously existed nearby the project site;
Route 703 was previously a limited service route that traveled along a similar route as Route 704 in
the vicinity of the project site. In response to this comment, Section 5.7 of the Draft EIR has been
revised to remove references to MTS bus route 703. As described in Section 5.15 of the Draft EIR,
there are no bus routes that travel directly along Olympic Parkway adjacent to the project site and that
five existing bus routes generally serve the project area. The Draft EIR otherwise makes no claim that
existing bus service travels along Olympic Parkway adjacent to the project site. Furthermore, as
described in Section 5.7, Greenhouse Gas Emissions, of the Draft EIR, the East Palomar Transit Station
is located approximately one mile from the project site, providing future residents of the project transit
opportunities. Therefore, multiple transit options exist in the vicinity of the project site.
Please refer to Responses to Comment C-10 and C-11 regarding alternatives.
C-16 This comment suggests that the project would not meet the Sunbow GDP’s principal objective.
Consistency with applicable land use documents is discussed in Section 5.10, Land Use and Planning.
The project includes concurrent processing of amendments to the Sunbow GDP and SPA Plan, changing
the land use designations from Industrial Park to Residential Multi-Family and Residential
Condominium. These amendments to the GDP and SPA Plan would allow the proposed land uses to be
developed on the project site consistent with the GDP as amended by the proposed project. The project
would not conflict with the principal objective of the Sunbow Planned Community “to create an efficient,
self-contained village.” Even without the industrial uses in the GDP, Sunbow would still contain a
compatible mix of uses that includes the Sunbow Village Center Commercial Area with
retail/commercial and medical office space uses and the Sharp Hospital in close proximity to the
project’s residential uses. The proposed project would provide a variety of housing types, recreational
facilities, and open space that would satisfy the GDP’s other objectives.
C-17 This comment suggests that Project Objective 1, which highlights development of a pedestrian-oriented
community, would not be adequately met by the project. Section 5.15, Transportation, of the Draft EIR
addresses pedestrian facilities. The project would propose a high-density residential use located in
close proximity to major streets such as Olympic Parkway, Brandywine Avenue, Heritage Road and the
I-805 freeway. Future residents of the project would have access to existing Class 2 bike lanes and
sidewalks and the Chula Vista Regional Trail adjacent to the project site along Olympic Parkway. Two
fully signalized intersections with pedestrian crossings are planned at Streets “A” and “B” at Olympic
Parkway are planned as part of the project. Located adjacent to the project site at the intersection of
Olympic Parkway and Brandywine Avenue are four signalized crosswalks with ramps on each corner.
Within the Sunbow community, a mix of uses that includes the Sunbow Village Center Commercial Area
with retail/commercial and medical office space uses are located in close proximity to the project
(approximately 0.6 miles to the north, or approximately 1.5 miles driving distance). The surrounding
area is served by transit provided by the San Diego MTS. While there are no bus routes that travel
directly along Olympic Parkway adjacent to the project site, transit connection for route 704 is provided
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at the transit stop on Brandywine Avenue located approximately 250-feet west of the project site. As
such, the future residents of the project would have access to transit, bicycle, and pedestrian facilities
and is located in close proximity to the Sunbow Village Center Commercial Area. Thus, the project would
be consistent with Project Objective 1.
C-18 This comment suggests that Objective 2, contribution to the growing housing needs of the City and
region, would not be adequately met by the project. Please refer to Responses to Comments C-5 and
C-6 regarding housing needs as they relate to the project.
C-19 This comment suggests that Project Objective 5, which encourages implementation of goals, objectives,
and policies of the General Plan, the MSCP Subarea Plan, the GDP, and the SPA Plan, would not be
adequately met by the project. Section 5.10, Land Use and Planning, of the Draft EIR addresses the
project’s consistency with applicable planning documents. A consistency analysis of the City’s General
Plan Land Use and Transportation Element, Housing Element, Economic Development Element, Public
Facilities and Services Element, Environmental Element, and Growth Management Element, showed
that the project would not result in conflicts with any element of the General Plan. Additionally, as discussed
in Section 5.3, Biological Resources, the project would not result in conflicts with the City’s MSCP
Subarea Plan through compliance with the MSCP Boundary Line Adjustment functional equivalency
criteria. Please refer to Response to Comment C-16 regarding the Sunbow GDP. SPA Plan objectives
for the Industrial Park District are not included in the Draft EIR as they would no longer apply if the
project proposed amendments are approved. The environmental analysis of the Draft EIR must assume
that the proposed amendments are approved because the proposed amendments are a component of
the project. The proposed amendments are not a separate action requested by the project applicant.
It should be noted that Appendix G of the CEQA Guidelines (used as the thresholds of significance
for environmental analysis within the EIR) require an EIR to consider whether a proposed project
conflicts with an applicable land use plan, policy, or regulation adopted for the purpose of avoiding
or mitigating an environmental impact. Under CEQA, a conflict or inconsistency with an
applicable plan is not, by itself, considered a significant environmental impact. Instead, the
inconsistency must result in a significant physical impact for there to be a significant impact under
CEQA. The final determination of consistency with the General Plan will be made by City Council.
C-20 This comment suggests that Project Objective 6, implementation of the City’s Growth Management
Ordinance (GMO), would not be adequately met by the project. The project includes a Supplemental
Public Facilities Financing Plan as required by the City’s GMO to ensure that development of the project
would not adversely impact the City’s quality of life standards by requiring public facilities and services
be provided concurrent with demand. Additionally, the project would pay PFDIFs which would ensure the
project would not significantly impact public services and facilities; please refer to Response to Comment C-
7. Furthermore, as discussed in Section 5.16, Utilities and Service Systems, there would be adequate
water supply and utility infrastructure to serve the project and impacts associated with public utilities
would be less than significant. The project would not conflict with the City’s GMO.
C-21 The City acknowledges the commenter’s suggestion of an alternative to the proposed project. Please
refer to Responses to Comment C-10 and C-11 regarding alternatives, as well as other responses to
specific comments contained in this comment letter.
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Comment Letter D
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Response to Comment Letter D
California Department of Fish and Wildlife (CDFW)
David A. Mayer
April 28, 2021
D-1 This comment is introductory in nature and provides an explanation of CDFW’s role in environmental
review, a summary of the proposed project, and existing biological setting, with specific comments to
follow. As this comment does not pertain to the adequacy of the Draft EIR, no further response is
provided.
D-2 This comment requests clarifications be made regarding the conservation easement areas. Potential
impacts to biological resources and proposed mitigation are discussed in Section 5.3, Biological
Resources, and in the Biological Impact Analysis Report and Functional Equivalency Analysis Report
(Appendix D) of the Draft EIR. The proposed project does not include habitat compensatory mitigation
within the onsite existing recorded and unrecorded conservation easements. In response to this
comment, the Draft EIR has been revised to include clarifications as requested:
• Figure 5.3-5 of the Draft EIR and Figure 6 of the Biological Impact Analysis Report have been
revised to delineate the 48.95 acres of proposed habitat mitigation area to demonstrate its
location outside of any existing conservation easements onsite.
• The project description within the Biological Impact Analysis Report has been revised as
follows: “None of the conservation easement areas are proposed as habitat compensatory
mitigation or proposed as a part of the Give area to the Preserve in the proposed BLA (See
Functional Equivalency Analysis for a MSCP BLA Report, Figure 6).”
D-3 This comment requests that additional mitigation measures for potential impacts to burrowing owl be
incorporated into the project. Note that this species was not present during the numerous biological
surveys conducted onsite and is not expected to occur onsite. The Draft EIR include the following
mitigation measures MM-BIO-2 and MM-BIO-7, which require a qualified biologist to monitor the
construction activities full time during habitat clearing and grubbing activities to avoid take of wildlife
species (including burrowing owl), as well as the requirement to conduct pre-construction surveys to
determine the presence of any actively nesting birds (including burrowing owl) onsite within the
proposed project impact areas, if construction activities cannot avoid the avian breeding season. While
these mitigation measures do not explicitly identify burrowing owl, they do not exclude the species from
surveys and monitoring. However, in response to this comment mitigation measure MM-BIO-7 and the
surrounding discussion in Section 5.3 of the Draft has been revised to include the commenter’s
recommended measures to reduce potential impacts to burrowing owl during construction.
D-4 This comment provides a link for which the information contained in the Draft EIR can be added to
biological resources databases, filing fee requirements, and concludes the comment letter.
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Comment Letter E
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Response to Comment Letter E
San Diego County Archaeological Society, Inc.
James W. Royle, Jr.
April 23, 2021
E-1 The City appreciates the San Diego County Archaeological Society committee’s review of the Draft EIR.
This comment pertains to the agreeance with the impact analysis and mitigation measure MM-CUL-1
included in the Draft EIR. No further response is required.
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1 Executive Summary
This environmental Impact Report (EIR) is an informational document intended for the use by the City of Chula Vista
(City), other public agencies, and members of the general public in evaluating the potential environmental effects
of the proposed Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II, Phase 3 Project
(proposed project).
California Environmental Quality Act (CEQA) Section 21002 requires that an EIR identify the significant effects of a
project on the environment and provide measures or alternatives that can mitigate or avoid these effects. This Draft
EIR evaluates the environmental effects associated with development of the project and discusses the manner in
which the project’s significant effects can be reduced or avoided through the implementation of mitigation measures
or feasible alternatives to the proposed project. In accordance with Section 15130 of the CEQA Guidelines, this EIR
also includes an examination of the effects of cumulative development.
This summary provides a brief synopsis of (1) the proposed project, (2) results of the environmental analysis
contained within this environmental document, (3) alternatives to the proposed project that were considered, and
(4) major areas of controversy and issues to be resolved by decision makers. This summary does not contain the
extensive background and analysis found throughout the individual chapters within the EIR. Therefore, the reader
should review the entire document to fully understand the proposed project and its environmental consequences.
1.1 Project Location and Setting
ACI Sunbow LLC (applicant) is proposing to develop an approximately 135.7-acre site (Assessor’s Parcel Numbers
644-171-12500, 644-011-0600, 644-020-1100) within the Sunbow Master Planned Community of the City of
Chula Vista (Figure 4-1, Project Location). The project site is located within the southern portion of the City of Chula
Vista (City), in southwestern San Diego County, California. The site is located south of Olympic Parkway, east of
Brandywine Avenue, and north and northwest of the Otay Landfill. Undeveloped land approved for industrial and
residential land uses within Otay Ranch Village Two is located to the east of the site. The project site is approximately
3.8 miles southeast of downtown Chula Vista, 9.9 miles southeast of downtown San Diego 2.3 miles west of State
Route 125 (SR-125) and approximately 0.5 miles east of Interstate 805 (I-805).
1.2 Project Background
The Sunbow General Development Plan (GDP), which originally included 604.8 acres in eastern Chula Vista, was
adopted on December 5 , 1989, with the primary objective to create an efficient, self -contained village with a
mix of residential, commercial, commu nity recreation, industrial park, and open space/trails land uses. The
GDP is implemented through the adoption of a subsequent, more detailed Sunbow Sectional Planning Area
(SPA) Plan, tentative tract maps, and potential annexation and development agreemen ts. The GDP is designed
to function as a policy bridge between the City of Chula Vista General Plan (General Plan) and the SPA Plan,
which provides more detailed plans for development of the Sunbow Master Planned Community (City of Chula
Vista 1989).
The portion of the Sunbow Master -Planned Community designated as Sunbow II, Phase 3 (project site),
includes the area slated to be developed as Industrial Park (formerly referred to as Planning Area 23 in the
GDP and SPA Plan), while the rest of the project si te was designated as Open Space in the GDP and the SPA
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Plan. The GDP designated the 54.7 acres as Industrial Park to include research/development and light
industrial uses, with approximately 700,000 square feet of leasable area generating approximately 2,800
employment opportunities. Based upon the City’s Multiple Species Conservation Program (MSCP) Preserve
Boundary data, the applicant’s civil engineer determined that there is an approximately 67.5 -acre development
area within the project site. This area (referred to herein as the proposed development area), would be
developed with residential uses and associated infrastructure. The remainder of the project site would be left as
MSCP Preserve and Open Space area.
1.3 Project Description
The proposed project is primarily a residential project with associated infrastructure and open space areas. The
proposed land uses are summarized in Table 1-1 and shown in Figure 4-2, Proposed General Plan Land Use; Figure
4.3, Proposed General Development Plan Land Use; and Figure 4-4, Proposed SPA Plan Land Use, all included in
Chapter 4, Project Description. Development would be centered within the southeastern portion of the site. The
approximately 67.5-acre development area would be composed of 44.2 acres of residential uses, a 0.9-acre
Community Purpose Facility (CPF), 5.9 acres of public streets, 4.3 acres of Poggi Creek conservation easements,
16.5 acres of manufactured slopes and basins, and a 0.3-acre wetland avoidance area. Approximately 63.6 acres
designated MSCP Preserve are also within the project site. Under the proposed project, the Industrial Park area
(Planning Area 23) would be modified to Medium-High and High Residential land uses (see Figures 4-2 and 4-3).
Table 1-1. Sunbow II, Phase 3 Sectional Planning Area Plan Land Use Summary
Land Use Planning Area Units Gross Acres Target Density
Residential
Multi-Family (Medium-High) Residential – 13–16 du/ac
MF R-1 131 8.5 15.4
MF R-2 73 4.6 15.8
MF R-3 108 8.1 13.3
MF R-4 118 8.2 14.4
MF R-5 104 7.0 14.7
Multi-Family Medium-High Residential Subtotal 534 36.5 14.7a
Multi-Family (High) Residential – 24.1 du/ac
MF R-6 184 7.6 24.1
Multi-Family High Residential Subtotal 184 7.6 24.1
Residential Total 718 44.2 16.3a
Other
Community Purpose Facility (CPF)
CPF CPF — 0.9 —
CPF Subtotal — 0.9 —
Other Total — 0.9 —
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Table 1-1. Sunbow II, Phase 3 Sectional Planning Area Plan Land Use Summary
Land Use Planning Area Units Gross Acres Target Density
Open Space
MPCP Open Space Preserve (OS)
OS OS-1 — 42.8 —
OS OS-2 — 10.0 —
OS OS-3 — 9.6 —
OS OS-9b — 1.1 —
MSCP Open Space Preserve Subtotal — 63.6 —
Poggi Creek Conservation Easement
OS OS-4 — 2.6 —
OS OS-5 — 0.7 —
OS OS-6a — 1.0 —
OS OS-6b — 0.1 —
Poggi Creek Conservation Easement Subtotal — 4.3 —
Manufactured Slopes/Basins
OS OS-7 — 3.2 —
OS OS-8 — 0.5 —
OS OS-9a — 0.5 —
OS OS-10 — 4.9 —
OS OS-11 — 1.3 —
OS OS-12 — 1.6 —
OS OS-13 — 4.6 —
Manufactured Slopes/Basins Subtotal — 16.5 —
Wetland Avoidance Area
OS OS-14 — 0.3 —
Wetland Avoidance Area Subtotal — 0.3 —
Open Space Total — 84.7 —
Circulation
Public Streetsb Circulation — 5.9 —
Circulation Subtotal — 5.9 —
Circulation Total — 5.9 —
All Land Use Types – Summary
All Land Use Types Total — 135.7 —
Notes: du/ac = dwelling units per acre; MSCP = Multiple Species Conservation Program.
Subtotals and totals may not sum precisely due to rounding.
a Target density represents the average densities proposed.
b The acreages for all proposed private streets are included as a part of the residential portion.
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1.3.1 Project Objectives
Following are the objectives of the proposed project:
1. Develop a pedestrian-oriented community on an underutilized site with a range of residential uses, open
space and MSCP Preserve areas, and recreational opportunities, which are compatible with the adjacent
established residential communities.
2. Contribute to the growing housing needs of the City and the region by providing for multi-family housing
units with a range of housing types to accommodate a spectrum of demographics.
3. Preserve portions of the project site as permanent open space and increase MSCP Preserve Areas.
4. Provide pedestrian and bicycle facilities, including a pedestrian connection to the Chula Vista Regional Trail
and connection to bike lanes within Olympic Parkway and nearby transit.
5. Implement the goals, objectives, and policies of the General Plan; the MSCP Subarea Plan; the GDP; and
the SPA Plan.
6. Implement the City’s Growth Management Ordinance to ensure that public and community facilities, such
as transportation, water, flood control, sewage disposal, schools, and parks, are provided in a timely
manner and financed by the parties creating the demand for, and benefiting from, the improvements.
7. Ensure new uses are compatible with the existing community by establishing setbacks, design regulations and
guidelines, best practices, and performance standards that enhance quality of life for neighboring properties.
8. Create a land use plan that can realistically be developed within a foreseeable time frame and under
economic conditions.
1.3.2 Discretionary Actions
A discretionary action is an action taken by an agency that calls for the exercise of judgment in deciding whether to
approve or how to carry out a project. The following discretionary actions are associated with the proposed project
and would be considered by the City:
• Certification of a Final EIR and adoption of a Mitigation Monitoring and Reporting Program pursuant to CEQA
• Approval of amendments to the General Plan
• Approval of amendments to the GDP
• Approval of amendments to the SPA Plan
• Approval of the Tentative Map for Sunbow II, Phase 3
• Chula Vista MSCP Subarea Plan Boundary Adjustment and Minor Amendment
• Rezone
• Approval of the Development Agreement between the applicant and the City
1.4 Areas of Controversy
Pursuant to Section 15082 of the CEQA Guidelines, the City circulated a Notice of Preparation (NOP) dated
November 9, 2020, to begin a 30-day public scoping period, to interested agencies, organizations, and parties. The
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NOP was also sent to the State Clearinghouse at the California Office of Planning and Research. The State
Clearinghouse assigned a state identification number (SCH No. 2020110148) to this EIR.
Comments received during the NOP public scoping period were considered during the preparation of this EIR. The
NOP and comments are included in Appendix A to this EIR.
1.5 Issues to Be Resolved by the City Council
The issues to be resolved by the decision-making body are whether to adopt the proposed project and how to
mitigate significant effects created by its implementation. The City will decide if benefits of the project outweigh any
significant unmitigable impacts associated with greenhouse gas emissions.
The City will also decide if the significant impacts associated with the environmental issues of biological resources,
cultural and tribal cultural resources, geology and soils, hazards and hazardous materials, public services,
recreation, and wildfire have been fully mitigated below a level of significance. Lastly, the City would determine
whether any alternative might meet the key objectives of the project while reducing its environmental impact.
1.6 Project Alternatives
Pursuant to the CEQA Guidelines, EIRs are required to “describe a range of reasonable alternatives to the project,
or to the location of the project, which would feasibly attain most of the basic objectives of the project but would
avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of
the alternatives” (14 California Code of Regulations (CCR) 15126.6(a)). This EIR “must consider a reasonable range
of potentially feasible alternatives that will foster informed decision making and public participation” (14 CCR
15126.6(a)). The alternatives discussion is required even if these alternatives “would impede to some degree the
attainment of the project objectives or would be more costly” (14 CCR 15126.6(b)).
1.6.1 No Project/No Build Alternative
CEQA Guidelines Section 15126.6 requires the inclusion of a No Project/No Build Alternative to be analyzed. Under
the No Project/No Build Alternative, no development would occur on the project site. Accordingly, the site
characteristics of this alternate would be equivalent to the existing conditions for each category analyzed in Chapter
5, Environmental Impact Analysis, of this EIR. Although no development would occur, surrounding land uses in the
region would continue to be built out.
1.6.2 Existing Land Use Designations Alternative
The Existing Land Use Designations Alternative would include the development consistent with the General Plan,
the GDP, and the SPA Plan. The General Plan designates the development area within the southeastern portion of
the site as Limited Industrial (see Figure 3-1, Existing General Plan Land Use). The GDP designated the 54.7 acres
as Research & Industrial Park to include research/development and light industrial uses (see Figure 3-3, Existing
General Development Plan Land Use Designation), with approximately 700,000 square feet of leasable area
generating approximately 2,800 employment opportunities; however, actual leasable area may be less than this
approximation when accounting for required infrastructure and amenities. Note, that the development areas under
the existing land use designations and the proposed project are different because the MSCP hardline was
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established after the approval of the Sunbow GDP and SPA Plan. The rest of the project site would be preserved as
Open Space and MSCP Preserve, similar to the proposed project. It is anticipated that access would be provided
via Olympic Parkway and internal circulation on th e project site would be similar to the proposed project. However,
features such as pedestrian and bicycle circulation, the Community Purpose Facility (CPF), and active and passive
recreational open space areas, proposed to be developed throughout the residential uses under the proposed
project, would not be developed under the Existing Land Use Designations Alternative.
1.6.3 Reduced Development Alternative
The Reduced Development Alternative would include the development of 360 residential units, within a similar area
as the proposed residential developments area under the project. This number of units, which is 358 fewer units
than the proposed project, was chosen in order to provide low to medium density residential. This alternative would
still include associated infrastructure, a reduced size Community Purpose Facility, and Open Space/MSCP Preserve
areas as proposed under the project. Due to the decreased number of units and the same development area, the
Reduced Development Alternative is assumed to be developed with low to medium density residential rather than
medium-high and high density residential as proposed under the project. As discussed in Section 5.3 , Biological
Resources, of the EIR, the proposed project would require a Boundary Line Adjustment (BLA) between the currently
proposed development boundaries and the mapped Multiple Species Conservation Program (MSCP) preserve on
site. Due to the reduced development of this alternative, this BLA would be avoided under this alternative.
1.7 Summary of Significant Environmental Impacts
Table 1-2 is a summary of the proposed project’s significant environmental impacts under CEQA , including
mitigation measures (MMs) incorporated. A Mitigation, Monitoring, and Reporting Program is included as
Appendix M to this EIR. For issue areas where impacts were determined to be less than significant or no impact,
including aesthetics, air quality, energy, hydrology and water quality, land use , noise, population and housing,
transportation, and utilities, refer to the respective discussions in Chapters 5 and 9 of this EIR.
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Table 1-2. Summary of Significant Environmental Impacts and Mitigation
Environmental Issue Result of Impact Analysis Mitigation Measures Impact Level After Mitigation
5.3 Biological Resources
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. Wildlife Service?
The project would result in direct and indirect impacts to
sensitive plant and wildlife species.
MM-BIO-1 The Applicant shall include an irrevocable offer of dedication (IOD) to the City of Chula
Vista on the first final map for 62.16 acres of onsite Preserve land within Preserve Management
Area 3, Subunits 3-1a, 3-1b, and 3-1c of the Chula Vista Central City Preserve lands. The MSCP
Preserve land shall be conserved, maintained, and managed by the City of Chula Vista or its
designee in perpetuity as directed in the Chula Vista Central City Preserve Area-Specific
Management Directives (ASMDs) for Preserve Management Area 3 (PMA 3) (RECON
Environmental, April 26, 2004) and funded by the Sunbow Preserve Community Facilities District
(No. 98-3). The City of Chula Vista Preserve Habitat Manager shall be responsible for the long-term
Preserve management activities identified in the Central City Preserve ASMD. Said IOD for the
62.16 acres Proposed MSCP Preserve shall include 48.95 acres to mitigate for significant habitat
impacts to 7.79 acres of native grassland, 8.55 acres of Diegan coastal sage scrub, and 55.61 of
non‐native grassland as well as the following sensitive species significant impacts:
• Coastal California Gnatcatcher- occupied Diegan coastal sage scrub to mitigate for significant
direct impacts to coastal California gnatcatcher occupied habitat;
• Otay Tarplant- 0.34 acre of Otay tarplant occupied habitat (i.e.,native grassland) to mitigate for
direct impacts to 0.34 acre of Otay tarplant occupied habitat that currently supports 836 Otay
tarplant individual plants;
• Orcutt’s Bird’s-beak- Orcutt’s bird’s-beak habitat (i.e., Diegan coastal sage scrub) to mitigate for
significant direct impacts to onsite Diegan coastal sage scrub that currently supports 91
Orcutt’s bird’s‐beak individual plants;
• Decumbent Goldenbush- Decumbent goldenbush habitat (i.e., Diegan coastal sage scrub and
native grassland), that includes at least 289 decumbent goldenbush individual plants) to
mitigate for significant direct impacts to onsite native grassland and Diegan coastal sage scrub
that currently supports 289 decumbent goldenbush individual plants; and
• San Diego Viguiera- San Diego viguiera habitat (i.e., Diegan coastal sage scrub) that includes at
least 2,979 San Diego viguiera individual plants) to mitigate for significant direct impacts to onsite
Diegan coastal sage scrub that currently supports 5,958 San Diego viguiera individual plants.
MM-BIO-2 Prior to initiation of construction related activities including clearing and grubbing or
prior to vegetation/ground disturbance or prior to site mobilization activities or issuance of a
grading permit, the Applicant shall submit documentation to the City demonstrating that the
Applicant has contracted with a qualified biologist(s) to monitor the project construction activities
and avoid any inadvertent impacts to sensitive biological and ensure complete avoidance of
jurisdictional resources. Each qualified biologist shall have demonstrated expertise with the
sensitive habitats, special status species of the project region. The qualified biologist(s) shall
monitor the installation of the construction temporary fencing and/or flagging, silt fencing, and
other best management practices (BMPs) along the construction limits prior to construction
activities. The qualified biologist shall be present full‐time during all initial vegetation clearing and
grubbing activities, and potentially on a less frequent basis during grading activities to ensure
construction remains within the approved project development area. The Applicant shall report
results of biological monitoring activities to the City on a regular basis through the preparation and
submission of summary monitoring reports.
MM-BIO-3 Prior to the issuance of any land development permits including for clearing and
grubbing or grading, the Applicant shall prepare a Restoration Plan prepared by a qualified biologist
to mitigate for impacts to sensitive plant species consisting of Otay tarplant, Orcutt’s bird’s-beak,
decumbent goldenbush, and San Diego County viguiera consistent with the conceptual Restoration
Plan (Merkel & Associates, Inc. 2021, Appendix D). The Applicant shall implement the 5-year
maintenance and monitoring activities consistent with the Habitat Restoration and Sensitive Plant
Specifies Mitigation Plan to the satisfaction of the Development Services Director (or their
Less than significant.
1 – Executive Summary
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 1-8
Table 1-2. Summary of Significant Environmental Impacts and Mitigation
Environmental Issue Result of Impact Analysis Mitigation Measures Impact Level After Mitigation
designee). The revegetation plan must be prepared by a qualified City approved biologist familiar
with the City’s MSCP Subarea Plan and must include, but not be limited to, an implementation
plan; appropriate seed mixtures and planting method; irrigation method; quantitative and
qualitative success criteria; maintenance, monitoring, and reporting program; estimated
completion time; and contingency measures. The Project Applicant shall be required to prepare
and implement the revegetation plan subject to the oversight and approval of the Development
Services Director (or their designee). NOTE: Since the revegetation is critical to approving the MSCP
Boundary Line Adjustment, the applicant will be required to enter into a Secured Agreement with
the City and will be required to provide a cash deposit.
MM-BIO-4 To avoid any direct impacts to nesting coastal California gnatc atcher, all vegetation
clearing, grubbing and grading activities within gnatcatcher occupied habitat (i.e., Diegan
coastal sage scrub) shall be conducted outside of the gnatcatcher breeding season (February
15 to August 15).
MM-BIO-5 Prior to initiating any construction related activities requiring a clearing and grubbing or
grading permit, the Applicant shall delineate coastal California gnatcatcher occupied habitat
located adjacent to the proposed project development area during the breeding season (February
15 to August 15) by orange biological fencing or comparable materials to ensure that no work shall
occur within these habitats. In addition, a minimum 300-foot buffer and on-site noise
reduction/attenuation techniques shall be incorporated, as appropriate to avoid impacts to
breeding gnatcatcher from elevated construction noise levels. The City Development Services
Director (or their designee) shall have the discretion to modify the buffer width depending on site-
specific conditions. Noise monitoring may be required to ensure that the elevated construction
noise levels are appropriately attenuated at the edge of occupied habitat to a level that is not
expected to adversely affect nesting bird behavior (i.e., not to exceed an hourly average of 60 A-
weighted decibels (dBA) or ambient at the edge of occupied habitat).
MM-BIO-6 Prior to initiating any construction related activities requiring a clearing and grubbing or
grading permit, the Applicant shall delineate least Bell’s vireo occupied habitat by orange biological
fencing or comparable to avoid direct impact to vireo within occupied habitat located adjacent to
the proposed project during the breeding season (March 15 to September 15). In addition, a
minimum 300-foot buffer and on-site noise reduction/attenuation techniques shall be
incorporated, as appropriate to avoid impacts to breeding vireo from elevated construction noise
levels. The City Development Services Director (or their designee) shall have the discretion to
modify the buffer width depending on site-specific conditions. Noise monitoring may be required to
ensure that the elevated construction noise levels are appropriately attenuated at the edge of
occupied habitat to a level that is not expected to adversely affect nesting bird behavior (i.e., not to
exceed an hourly average of 60 dBA or ambient at the edge of occupied habitat).
MM-BIO-7 To avoid any direct impacts to migratory birds and/or raptors protected under the
federal Migratory Bird Treaty Act and California Fish and Game Code Sections 3503 and 3513,
removal of habitat that supports active nests on the proposed area of disturbance should occur
outside of the breeding season for these species. The breeding season is defined as January 15–
August 31 for raptor species and February 15–August 15 for other non-raptor birds (excluding
listed species). If removal of habitat on the proposed area of disturbance must occur during the
breeding season, then prior to initiating any construction related activities requiring a clearing and
grubbing or grading permit, the Applicant shall retain a City-approved biologist to conduct a pre-
construction survey to determine the presence or absence of nesting birds (including burrowing
owl) on the proposed area of disturbance. The pre-construction survey must be conducted within
10 calendar days prior to the start of construction, and the results must be submitted to the City
for review and approval prior to initiating any construction activities. If nesting birds are detected, a
letter report or mitigation plan, as deemed appropriate by the City, shall be prepared and include
proposed measures to be implemented to ensure that disturbance of breeding activities are
1 – Executive Summary
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 1-9
Table 1-2. Summary of Significant Environmental Impacts and Mitigation
Environmental Issue Result of Impact Analysis Mitigation Measures Impact Level After Mitigation
avoided. The report or mitigation plan shall be submitted to the City for review and approval and
implemented to the satisfaction of the City. The City’s mitigation monitor shall verify and approve
that all measures identified in the report or mitigation plan are in place prior to and/or during
construction.
To reduce potential impacts to burrowing owl during construction, the City-approved biologist shall
perform pre-construction inspection of potential habitat, and, at minimum, twice weekly
inspections be performed while rough grading is ongoing. All pre-construction survey efforts shall
be conducted prior to any project activities that could result in habitat disturbance to soil,
vegetation or other sheltering habitat for burrowing owl. If any burrowing owls or sign of burrowing
owls are detected, the Wildlife Agencies (jointly, CDFW and USFWS) shall be contacted; efforts shall
be made to determine the breeding status of the species on site, and whether it is safe at that
point to exclude burrowing owls from occupied burrows. Active or passive relocation methods shall
only be employed with concurrence by CDFW and USFWS.
MM-BIO-8 Prior to approval of the first final map, the Applicant shall submit a Landscape Master
Plan for the entire project which shall demonstrate compliance with the proposed fence and wall
plan for the project. The proposed fence and wall plan shall include appropriate fencing and
barriers (e.g., vegetation) where applicable to shield human presence and deter human intrusion
into the Preserve.
MM-BIO-9 Concurrent with design review and prior to issuance of a building permit for any
development located adjacent to the Preserve, the Applicant shall prepare, a lighting plan and
photometric analysis for review and approval the Development Services Director (or their
designee). The lighting plan shall illustrate the location of the proposed lighting standards and type
of shielding measures. Low-pressure sodium lighting shall be used, if feasible, and shall be subject
to the approval of the Development Services Director (or their designee).
MM-BIO-10 Prior to approval of the first final map, the Applicant shall submit a Landscape Master
Plan for the entire project which shall demonstrate compliance with the proposed plant palette for
the project. The proposed plant palette shall prohibit invasive non‐native plant species on the
California Exotic Pest Plant Council List of Exotic Pest Plants of Greatest Ecological Concern in
California that could spread into the adjacent Preserve. No invasive non-native plant species shall
be introduced into areas immediately adjacent to the preserve. All slopes immediately adjacent to
the Preserve shall be planted with native species that reflect the adjacent native habitat. Further,
the proposed plant palette shall be consistent with the plant list contained in the “Wildland/Urban
Interface: Fuel Modification Standards,” and provided as Appendix L of the Subarea Plan, must be
reviewed and utilized to the maximum extent practicable when developing landscaping plans in
areas adjacent to the Preserve.
MM-BIO-11 To avoid habitat degradation to the adjacent Preserve lands, project irrigation shall be
contained to the project development and fuel modification zones and shall not drain or overspray
resulting in potential erosion/sedimentation, spread of invasive plant species, and/or non‐native
species such as Argentine ants.
MM-BIO-12 Prior to initiating any construction related activities requiring a clearing and grubbing or
grading permit, the Applicant shall demonstrate how the project would avoid or minimize applicable
inadvertent impacts during construction. To ensure the avoidance and minimization of impacts to
biological resources during construction the following construction BMPs shall be implemented:
a) Prior to ground disturbance, all permanent and temporary disturbance areas shall be clearly
delineated by orange construction fencing and the identification of environmentally sensitive
areas with flagging and/or fencing.
b) To minimize disturbance of areas outside the project site, all construction and operation
vehicle traffic shall be restricted to established roads, construction areas, and other
designated areas. These areas shall be included in pre‐construction surveys and, to the
1 – Executive Summary
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 1-10
Table 1-2. Summary of Significant Environmental Impacts and Mitigation
Environmental Issue Result of Impact Analysis Mitigation Measures Impact Level After Mitigation
extent possible, shall be established in locations disturbed by previous activities to prevent
further impacts.
c) Construction and operation vehicles shall observe appropriate safe speed limits and adhere
to safety practices.
d) Dust suppression shall occur during construction activities when necessary to meet air
quality standards and protect biological resources.
e) No vehicles or equipment shall be refueled or undergo maintenance within 100 feet of a
jurisdictional waters feature. Spill kits shall be maintained on the site in sufficient quantity to
accommodate at least three complete vehicle tank failures of 50 gallons each. Any vehicles
driven or operated within or adjacent to drainages or wetlands shall be checked and
maintained daily to prevent leaks of contaminated fluids.
f) All general trash, food‐related trash items (wrappers, cans, bottles, food scraps, cigarettes,
etc.), and other human‐generated debris scheduled to be removed shall be stored in animal‐
proof containers and removed from the site on a regular basis (weekly during construction,
and at least monthly during operations). No deliberate feeding of wildlife shall be allowed.
g) Use of chemicals, fuels, lubricants, or biocides shall comply with all local, state, and federal
regulations. All uses of such compounds shall observe label and other restrictions mandated by
the U.S. Environmental Protection Agency, California Department of Food and Agriculture, and
other state and federal legislation. Use of first‐and second‐ generation rodenticides shall not be
permitted except for the limited use of zinc phosphide, or a rodenticide approved by the City, and
only after other means of pest control (e.g. rodent traps) have proven to be ineffective.
MM-BIO-13 Prior to issuance of a grading permit, prior to vegetation clearing, grubbing, grading, or
any ground disturbing activities, the Applicant shall submit evidence to the City that the Applicant
has retained qualified biologists to prepare a Worker Environmental Awareness Program that shall
be presented to all construction personnel and employees before any ground‐disturbing activities
commence at the project site and shall be continued through the construction phase for all new
construction personnel. The program shall consist of a brief presentation going over the on-site
sensitive biological resources and compliance with project impact and open space boundaries, and
applicable environmental laws and requirements with all personnel involved in the project. This
presentation shall explain to construction personnel how best to avoid impacts sensitive resources
during construction. The program shall include a description of all special status species potentially
on the project site and their habitat needs; an explanation of the status of the species and their
protection under the state and federal regulations; specific mitigation measures applicable to listed
and other special status species; permit conditions, and the penalties for violation of applicable
laws. The program shall also explain to construction personnel how to avoid impacts to
jurisdictional waters, including wetlands. The program shall include a map and description of
jurisdictional waters on the site to be avoided and measures to implement to ensure the protection
and avoidance of jurisdictional waters.
Have a substantial adverse effect on any riparian
habitat or other sensitive natural community
identified in local or regional plans, policies,
regulations, or by the California Department of Fish
and Game or U.S. Fish and Wildlife Service?
The project would result in direct and indirect impacts to
sensitive natural communities.
MM-BIO-1, MM-BIO-2, and MM-BIO-8 through MM-BIO-13 Less than significant.
Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation
Plan, or other approved local, regional, or State
habitat conservation plan?
The project would require an MSCP Boundary Line
Adjustment and Minor Amendment that would result in
impacts to sensitive biological resources.
MM-BIO-1 through MM-BIO-13
MM-BIO-14 Prior to initiating any construction related activities requiring a clearing and grubbing or
grading permit, the Applicant shall prepare a revegetation plan for the temporary impact areas
within the 25-foot grading buffer in the Minor Amendment Area that utilizes a native erosion control
hydroseed mix acceptable to the City and the Wildlife Agencies (U.S. Fish and Wildlife Service and
California Department of Fish and Wildlife) to ensure soil stability and prevent subsequent erosion.
Less than significant.
1 – Executive Summary
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 1-11
Table 1-2. Summary of Significant Environmental Impacts and Mitigation
Environmental Issue Result of Impact Analysis Mitigation Measures Impact Level After Mitigation
The revegetation plan must be prepared by a qualified City approved biologist familiar with the
City’s MSCP Subarea Plan and must include, but not be limited to, an implementation plan;
appropriate seed mixtures and planting method; irrigation method; quantitative and qualitative
success criteria; maintenance, monitoring, and reporting program; estimated completion time; and
contingency measures. The Project Applicant shall be required to prepare and implement the
revegetation plan subject to the oversight
MM-BIO-15 Prior to initiating any construction related activities requiring a clearing and grubbing or
grading permit, the Applicant shall receive approval by the City and Wildlife Agencies for the MSCP
BLA. The Applicant shall be required to implement conditions associated with the BLA subject to
the oversight and approval of the Development Services Director (or their designee).
MM-BIO-16 Prior to initiating any construction related activities requiring a clearing and grubbing or
grading permit, the Applicant shall receive approval by the City and Wildlife Agencies for the MSCP
Minor Amendment. The Applicant shall be required to implement conditions associated with the
Minor Amendment subject to the oversight and approval of the Development Services Director (or
their designee).
5.4 Cultural and Tribal Cultural Resources
Cause a substantial adverse change in the
significance of an archaeological resource as
defined in CEQA Guidelines Section 15064.5?
The project has the potential to encounter previously
unidentified subsurface cultural deposits.
MM-CUL-1
A. Prior to beginning construction activities, the project archaeologist and Native American
representative shall attend any pertinent preconstruction meetings with the construction
manager and/or grading contractor in order to provide recommendations and answer questions
relating to the archaeological monitoring program. The project archaeologist shall be familiar with
the cultural inventory conducted for the current project and shall be prepared to introduce any
pertinent information concerning expectations and probabilities of discovery during ground-
disturbing activities.
B. Both an archaeological monitor familiar with local resources and a Native American monitor
shall be present full time during the initial disturbance of soil with potential to contain cultural
deposits. All areas of initial project-related subsurface disturbance shall be assumed to have the
potential to contain cultural deposits. Monitoring of initial ground disturbance shall not exceed a
depth of 5 feet (1.5 meters) unless cultural resources are identified or if, through direct
inspection of subsurface exposures by the project Archaeologist, an area is observed to have the
potential to support the presence of archaeological deposits at greater depths. Cultural resources
monitoring may be reduced from initial full-time monitoring to periodic spot checks, or
discontinued if appropriate, once the project archaeologist determines that there is little or no
risk of encountering cultural material.
C. Daily archaeological and Native American monitoring logs shall be prepared. Logs shall include
monitor names and affiliations, a description of general activities observed, cultural discoveries,
as well as comments or concerns as applicable.
D. In the event of an archaeological discovery, and when requested by the archaeological monitor
or Native American monitor, the resident contractor will divert, redirect, or temporarily halt
ground disturbing activities in the area of discovery or impacts to allow for preliminary inspection
of potentially significant archaeological resources or impacts. The significance of the discovered
resources or impacts shall be determined by the archaeologist, in consultation with the City of
Chula Vista (City). For significant cultural resources, a Research Design and Data Recovery
Program shall be prepared and carried out to mitigate impacts before grading activities in the
area of discovery shall be allowed to resume.
E. The project archaeologist shall be responsible for ensuring that all cultural materials collected
will be cleaned, catalogued, and curated permanently with an appropriate institution; that a letter
of acceptance from the curation institution has been submitted to the City; that all artifacts are
Less than significant.
1 – Executive Summary
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 1-12
Table 1-2. Summary of Significant Environmental Impacts and Mitigation
Environmental Issue Result of Impact Analysis Mitigation Measures Impact Level After Mitigation
analyzed to identify function and chronology as they relate to the history of the area; that faunal
material will be identified as to species; and that specialty studies are completed, as appropriate.
The project archaeologist shall make a good-faith effort to ensure that all archaeological material
collected through previous work is appropriately curated with any material recovered through
construction monitoring.
F. If human remains are discovered, work shall halt in that area and procedures set forth in the
California Public Resources Code (Section 5097.98) and State Health and Safety Code (Section
7050.5) shall be followed by the archaeological monitor after notification to the County Coroner
by the project Archaeologist. If Native American remains are present, the County Coroner shall
contact the Native American Heritage Commission to designate a Most Likely Descendant, who
shall arrange for the dignified disposition and treatment of the remains.
G. Within 3 months following the completion of monitoring, two copies of a monitoring results
report (even if negative) and/or evaluation report, if applicable, that describes the results,
analysis, and conclusions of the archaeological monitoring program (with appropriate graphics)
shall be submitted to City.
H. For significant archaeological resources encountered during monitoring, the Research Design
and Data Recovery Program shall be included as part of the final evaluation monitoring report.
Two copies of the final monitoring report for significant archaeological resources, if required,
shall be submitted to the City. This final monitoring report should also incorporate a summary of
the evaluation results and analyses previously conducted within the project area.
I. The archaeologist shall be responsible for recording (on the appropriate CA DPR 523 Series
forms) any significant or potentially significant resources encountered during the archaeological
monitoring program in accordance with Section 106 and the City’s Cultural Resources
Guidelines, and submittal of such forms to the South Coastal Information Center at San Diego
State University with the final monitoring results report.
Disturb any human remains, including those
interred outside of formal cemeteries?
The project has the potential to inadvertently encounter
human remains.
MM-CUL-1 Less than significant.
Cause a substantial adverse change in the
significance of a tribal cultural resource, defined in
Public Resources Code section 21074 as either a
site, feature, place, cultural landscape that is
geographically defined in terms of the size and
scope of the landscape, sacred place, or object with
cultural value to a California Native American tribe,
and that is:
A. 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)?
B. A resource determined by the lead agency, in its
discretion and supported by substantial
evidence, to be significant pursuant to criteria
set forth in subdivision (c) of Public Resources
Code Section 5024.1. In applying the criteria set
forth in subdivision (c) of Public Resources Code
Section 5024.1, the lead agency shall consider
the significance of the resource to a California
Native American tribe?
The project has the potential to inadvertently encounter
tribal cultural resources.
MM-CUL-1 Less than significant.
1 – Executive Summary
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 1-13
Table 1-2. Summary of Significant Environmental Impacts and Mitigation
Environmental Issue Result of Impact Analysis Mitigation Measures Impact Level After Mitigation
5.6 Geology and Soils
Directly or indirectly destroy a unique
paleontological resource or site or unique geologic
feature?
The project has the potential to inadvertently encounter
paleontological resources.
MM-GEO-1: Paleontological Monitoring Program. Prior to the issuance of grading permits, the
applicant shall provide written confirmation to the City that a qualified paleontologist has been
retained to carry out an appropriate mitigation program. (A qualified paleontologist is defined as an
individual with an MS or PhD in paleontology or geology who is familiar with paleontological
procedures and techniques.) A pre-grading meeting shall be held that shall include the
paleontologist and the grading and excavation contractors.
A paleontological monitor shall be on site at all times during the original cutting of previously
undisturbed sediments of highly sensitive geologic formations (i.e., Otay Formation and San Diego
Formation) to inspect cuts for contained fossils. (A paleontological monitor is defined as an
individual who has experience in the collection and salvage of fossil materials.) The paleontological
monitor shall work under the direction of a qualified paleontologist. The monitor shall be on site on
at least a half-time basis during the original cutting of previously undisturbed sediments of
moderately sensitive geologic formations (e.g., unnamed river terrace deposits and the Mission
Valley Formation) to inspect cuts for contained fossils. However, neither of these rock units have
been mapped within the project area of potential effect (APE) and are therefore not anticipated to
be impacted during construction.
The monitor shall be on site on at least a quarter-time basis during the original cutting of previously
undisturbed sediments of low sensitivity geologic formations (e.g., Lindavista Formation and
Santiago Peak Volcanics [metasedimentary portion only]) to inspect cuts for contained fossils.
However, these deposits have not been mapped within the project APE and are therefore not
anticipated to be impacted during construction. The monitor shall periodically (every several weeks)
inspect original cuts in deposits with an unknown resource sensitivity (i.e., Quaternary alluvium).
In the event that fossils are discovered in unknown, low, or moderately sensitive formations, the
Applicant shall increase the per-day field monitoring time. Conversely, if fossils are not discovered,
the monitoring, at the discretion of the City’s Deputy City Manager/Development Services Director
or its designee, shall be reduced. A paleontological monitor is not needed during grading of rocks
with no resource sensitivity (i.e., Santiago Peak Volcanics, metavolcanic portion).
When fossils are discovered, the paleontologist (or paleontological monitor) shall recover them. In
most cases, this fossil salvage can be completed in a short period of time. However, some fossil
specimens (such as a complete whale skeleton) may require an extended salvage time. In these
instances, the paleontologist (or paleontological monitor) shall be allowed to temporarily direct,
divert, or halt grading to allow recovery of fossil remains in a timely manner. Because of the
potential for the recovery of small fossil remains such as isolated mammal teeth, it may be
necessary in certain instances and at the discretion of the paleontological monitor to set up a
screen-washing operation on the site.
Prepared fossils along with copies of all pertinent field notes, photos, and maps shall be deposited
in a scientific institution with paleontological collections such as the San Diego Natural History
Museum. A final summary report shall be completed. This report shall include discussions of the
methods used, stratigraphy exposed, fossils collected, and significance of recovered fossils.
Less than significant.
5.7 Greenhouse Gas Emissions
Generate greenhouse gas emissions, either directly
or indirectly, that may have a significant impact on
the environment?
This project has the potential to result in significant
greenhouse gas emissions during construction and
operational activities.
MM GHG-1: Greenhouse Gas Emissions Reduction Measures. The following GHG emissions
reduction measures shall be implemented:
• Off-road construction equipment with engines rated at 75 horsepower or greater shall meet at a
minimum Tier 3 standard.
• Install purple pipes to provide reclaimed water for outdoor water use.
• Install low-flow water fixtures such as low-flow toilets, faucets, showers, etc.
Significant and unavoidable.
1 – Executive Summary
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 1-14
Table 1-2. Summary of Significant Environmental Impacts and Mitigation
Environmental Issue Result of Impact Analysis Mitigation Measures Impact Level After Mitigation
• Two parking spaces shall be pre-wired for electric vehicle (EV) capable and designated as
preferential parking spaces shall be provided for carpool, shared, electric, and hydrogen vehicles.
• 718 parking garages shall be pre-wired to be EV capable.
• Energy-efficient lighting shall be used for all street, parking, and area lighting associated with
the proposed project, including all on-site and off-site lighting.
• Energy-efficient design practices, such as high-performance glazing, Energy Star compliant
systems and appliances, radiant heat roof barriers, insulation on all pipes, programmable
thermostats, and sealed ducts, shall be implemented.
• Native species and drought-tolerant species shall be used for a minimum of 50% of the
ornamental plant palette in non-turf areas to minimize water demand.
• Recycling of construction debris and waste shall be ensured through administration by an on-
site recycling coordinator and presence of recycling/separation areas. Exceed the City of Chula
Vista’s Construction and Demolition Debris Waste Management Plan’s 65% diversion of
construction and demolition waste.
• Install cool roofs that meet the U.S. Green Building Council standards with a greater solar
reflectivity to help conserve energy.
• Install 1,462-kilowatt solar photovoltaic system meeting the minimum 2019 Title 24 standards.
• Install bicycle racks.
• The project shall plant 600 trees and 40 acres of shrubs.
Conflict with an applicable plan, policy or regulation
adopted for the purpose of reducing the emissions
of greenhouse gases?
This project has the potential to result in significant
greenhouse gas emissions causing the project to
conflict with an applicable plan, policy or regulation
adopted for the purpose of reducing the emissions of
greenhouse gases.
MM-GHG-1 Significant and unavoidable.
5.8 Hazards and Hazardous Materials
Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury, or death
involving wildland fires?
There is the potential for the project to exacerbate
impacts involving wildland fires.
MM-WF-1: Site Access
Site access, including fire lane, driveway, and entrance road widths, primary and secondary access,
gates, turnarounds, dead end lengths, signage, aerial fire apparatus access, surface, and other
requirements will comply with the requirements of the 2019 California Fire Code and the Chula
Vista Fire Department (CVFD) Standards. Fire access will be reviewed and approved by CVFD prior
to construction (see the FPP, Appendix H3, for additional details).
The developer will provide information illustrating the new roads, in a format acceptable to the City,
for updating of City maps.
Ignition Resistant Construction
All new structures within the Proposed Project will be constructed to at least the California Fire
Code standard. Each of the proposed buildings will comply with the enhanced ignition-resistant
construction standards of the 2019 CBC (Chapter 7A) and Chapter 5 of the Urban-Wildland
Interface code, except where buildings require enhanced ignition resistance as part of an
alternative material and method proposal. These requirements address roofs, eaves, exterior walls,
vents, appendages, windows, and doors and result in hardened structures that have been proven
to perform at high levels (resist ignition) during the typically short duration of exposure to burning
vegetation from wildfires (see the FPP, Appendix H3, for additional details).
Fire Protection Systems
• Water supply requirements specified in the California Fire Code (see FPP, Appendix H3, for
additional details) including for hydrants and interior sprinklers will be provided for the
proposed project.
Less than significant.
1 – Executive Summary
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 1-15
Table 1-2. Summary of Significant Environmental Impacts and Mitigation
Environmental Issue Result of Impact Analysis Mitigation Measures Impact Level After Mitigation
• Hydrants shall be located along fire access roadways and cul-de-sacs as determined by the
CVFD Fire Marshal to meet operational needs. Hydrants will be consistent with CVFD Design
Standards and provided every 500 feet (on-center).
• All structures within the Proposed Project will include interior sprinklers, per code requirements
(see FPP, Appendix H3, for additional details). Sprinklers will be specific to each occupancy type
and based on the most recent National Fire Protection Association (NFPA) 13, 13R, or 13D,
requirements.
• All residential units shall have a fire alarm system be installed in accordance with NFPA 72, Fire
Protection Signaling System and CVFD requirements. The fire alarm system will be supervised
by a third-party alarm company. The system will be tested annually, or as needed, with test
results provided to CVFD.
Additionally, all residences will be equipped with residential smoke detectors and carbon monoxide
detectors and comply with current CBC, CFC, and California Residential Code standards.
All residential dwelling units shall have electric-powered, hard-wired smoke detectors with battery
backup per CVFD.
Defensible Space and Vegetation Management
Fuel Modification Zones (FMZs) would be located on the perimeter of all structures and along both
ingress/egress roadways to and from Olympic Parkway. All brush management zones and related
fuel modification activities shall occur outside of the Preserve. FMZs shall be a minimum of 100
feet in width. A 100-foot-wide FMZ will be installed for lots abutting designated Preserve Lands to
the north and west of the Project Site. To ensure long-term identification and maintenance, each
respective FMZ shall be identified by a permanent marker system meeting the approval of CVFD.
Other Vegetation Management
• New roads will be subject to fuel modification zones with Zone 1 and/or Zone 2 standards
described above. The combustible vegetation will be modified within 30 feet from each side of
Streets A and B. Roadway-adjacent fuel modification does not preclude the planting of street
trees in these fuel modification zones, as long as they are not found on the Prohibited Plant List
(Appendix D of the FPP) and are included in the Approved Plant Palette (Appendix C of the FPP).
• Pre-Construction Requirements:
• Perimeter fuel modification areas must be implemented and approved by the CVFD prior to
combustible materials being brought on site.
• Existing flammable vegetation shall be reduced by 50% on vacant lots upon commencement of
construction.
• Dead fuel, ladder fuel (fuel which can spread fire from ground to trees), and downed fuel shall
be removed, and trees/shrubs shall be properly limbed, pruned, and spaced per this plan.
• Undesirable Plants. Certain plants are considered to be undesirable in the landscape due to
characteristics that make them highly flammable. These characteristics can be physical
(structure promotes ignition or combustion) or chemical (volatile chemicals increase
flammability or combustion characteristics). The plants included in the Prohibited Plant List
(Appendix D of Appendix H3, FPP) are unacceptable from a fire safety standpoint and will not be
planted on the site or allowed to establish opportunistically within fuel modification zones or
landscaped areas. No fuel modification zones are proposed within the MSCP areas, thus no
vegetation within the MSCP will be removed.
Tree Notes for Publicly Owned Areas.
The project shall maintain all trees in publicly owned areas, per the project's FPP. These
requirements include, but are not limited to (see Appendix H3 for additional details):
• All standard form (single trunk) trees to include a single strong central leader with no branches
extending at an angle narrower than 30 degrees from the main trunk. If the tree does not
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Table 1-2. Summary of Significant Environmental Impacts and Mitigation
Environmental Issue Result of Impact Analysis Mitigation Measures Impact Level After Mitigation
display a single strong central leader, a tree may be approved if the Developer’s arborist or
landscape architect of record can demonstrate that a single strong central leader can be
achieved through structural pruning.
• No grafted species that sucker from the base stock will be allowed as a street tree.
Vacant Parcels and Lots
The project shall comply with requirements of the project's FPP related to vacant parcels and lots.
These requirements include, but are not limited to:
• Vegetation management would not be required on vacant lots until construction begins.
However, perimeter FMZs must be implemented prior to commencement of construction
utilizing combustible materials.
• Vacant lots adjacent to active construction areas/lots would be required to implement
vegetation management if they are within 50 feet of the active construction area. Perimeter
areas of the vacant lot would be maintained as a vegetation management zone extending 50
feet from roadways and adjacent construction areas.
• Prior to issuance of a permit for any construction, grading, digging, installation of fences, etc.,
on a vacant lot, the 50 feet at the perimeter of the lot is to be maintained as a vegetation
management zone.
• FMZ on slope L&I does not have to be completed prior to construction starting, but all
flammable vegetation and plants found on the Prohibited Plant List, needs to grubbed and
graded or mowed prior to any construction.
Fuel Modification Area Vegetation Maintenance
All fuel modification area vegetation management shall be completed annually by May 1 of each
year and more often as needed for fire safety, as determined by the CVFD.
Annual Fuel Modification Area Vegetation Maintenance
The property owner would obtain an FMZ inspection and report from a qualified CVFD-approved 3rd
party inspector in May of each year certifying that vegetation management activities throughout the
Project Site have been performed pursuant to this FPP. A copy of the annual inspection report
would be provided to the proposed project homeowner association (HOA) and a copy made
available to CVFD, if requested.
Reduced Fuel Modification Zone Discussion
Due to site constraints, it is not feasible to achieve a 100-foot FMZ width on the south side of the
proposed development. This FPP incorporates additional fire protection measures as described in
this mitigation measure that shall be implemented to compensate for potential fire related threats.
These measures are were customized for this site based on the analysis results and focus on
providing functional equivalency for reduced defensible space.
Landscape and Building Hardening.
1. Provide exterior glazing in windows (and sliding glass doors, garage doors, or decorative or
leaded glass doors) facing the open space areas to be dual pane with both panes tempered
glass, exceeding the fire-building code requirement.
2. Ensure no eave overhangs and combustible construction in portion of yards facing natural open
space areas.
3. Install 1-hour rated walls (Type X - 5/8-inch thickness of gypsum) behind non -combustible
covering (stucco, fiber cement siding) for a façade facing the open space areas to the east
and south.
4. Conduct a formal landscaping plan review for structures with a façade facing open space area.
Landscape plans shall be reviewed and approved by the Chula Vista Fire Department.
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Table 1-2. Summary of Significant Environmental Impacts and Mitigation
Environmental Issue Result of Impact Analysis Mitigation Measures Impact Level After Mitigation
5. Annually hire a third-party inspector to evaluate whether designated fuel modification zone areas
meet the requirements of the project Fire Protection Plan.
6. Provide a non-combustible fire-rated 6-foot-tall masonry block or view wall at the property line on
the south and east sides of the proposed project to provide a physical, non-combustible barrier
that would deflect heat and flame and would capture ground-blowing embers before they
reached the proposed project’s developed areas.
The proposed project’s slopes to the south provide an opportunity to place a non-combustible, 6
foot-tall, heat-deflecting wall (or view wall with lower 1 to 2 feet block wall and upper 4 to 5 feet
dual-pane, one pane tempered glazing) to provide additional deflection for these lots to
compensate for the reduced fuel modification zones. The wall shall meet any of the following
specifications:
• Be constructed of multi-pane glazing with a minimum of one tempered pane meeting the
requirements of Section 2406 Safety Glazing, or
• Have a fire-resistance rating of not less than 20 minutes when tested according to NFPA 257, or
• Be tested to meet the performance requirements of SFM Standard 12-7A-2.
Homeowner’s Wildfire Education Program
Per the FPP, the proposed project’s residents shall be provided a proactive educational component
disclosing the potential wildfire risk and this report’s requirements as part of their purchase
documents. Property owners shall be required to sign notice of receiving this information during
escrow. This educational information must include maintaining the landscape and structural
components according to the appropriate standards and embracing a “Ready, Set, Go” stance on
evacuation.
5.13 Public Services
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 fire protection and emergency services?
The project would result in an incremental increase in
demand for fire and emergency services.
MM-PS-1: Prior to the issuance of each building permit for any residential dwelling units, the
applicant shall pay a Public Facilities Development Impact Fee (PFDIF) in accordance with the fees
in effect at the time of building permit issuance and phasing approved in the Supplemental Public
Facilities Finance Plan, unless stated otherwise in a separate development agreement.
Less than significant.
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 police protection services?
The project would result in an incremental increase in
demand for police services.
MM-PS-1 Less than significant.
Result in substantial adverse physical impact
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 library services?
The project would result in an incremental increase in
demand for library services.
MM-PS-1 Less than significant.
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Table 1-2. Summary of Significant Environmental Impacts and Mitigation
Environmental Issue Result of Impact Analysis Mitigation Measures Impact Level After Mitigation
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 school services?
The project would result in an incremental increase in
demand for schools.
MM-PS-2: Prior to the issuance of a building permit, the applicant shall provide evidence or
certification by the Chula Vista Elementary School District (CVESD) and the Sweetwater Union High
School District (SUHSD) that any fee charge, dedication or other requirement levied by the school
district(s) has been complied with or that the district(s) has determined the fee, charge, dedication
or other requirements do not apply to the construction or that the applicant has entered into a
school mitigation agreement. School facility mitigation fees shall be in accordance with the fees in
effect at the time of building permit issuance.
Less than significant.
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 parks?
The project would result in an incremental increase in
demand for parks.
MM-PS-3: No earlier than issuance of certificate of occupancyPrior to the issuance of each building
permit for any residential dwelling units, the applicant shall pay the Park Benefit Fee as outlined in
the project’s Development Agreement, equal to the City’s Park Acquisition and Development (PAD)
Fee Update pursuant to Chula Vista Municipal Code Section 17.10. The final Park Benefit Fee
amount shall be determined based on the number and type of residential units constructed and
the PAD fee rates in effect as of the effective date of paymentthe project’s Development
Agreement. To create this Park Benefit Fee, the City will waive the parkland dedication and
development requirements set in Chapter 17.10 of the Chula Vista Municipal Code, including the
Parkland Acquisition and Public Facilities Development fees, and Quimby Act fees. The Park Benefit
Fee shall satisfy the project’s park obligations and may be utilized by the City to acquire or develop
parkland, as the City determines appropriate and in the best interest of the City.
Less than significant.
5.14 Recreation
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?
The project would result in an incremental increase in
demand for parks.
MM-PS-3 Less than significant.
5.17 Wildfire
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?
There is the potential for the project to exacerbate
impacts involving wildland fires.
MM-WF-1 Less than significant.
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2 Introduction
This chapter of the environmental impact report (EIR) describes the purpose, scope, and legislative authority of the
EIR, the intent of the California Environmental Quality Act (CEQA) and other pertinent environmental rules and
regulations, and the environmental review process. The section also includes the structure, required contents, and
relationship of the EIR to other potential responsible or trustee agencies.
2.1 Project Purpose and Background
This EIR addresses the environmental effects associated with the proposed Sunbow Sectional Planning Area (SPA)
Plan Amendment for the Proposed Sunbow II, Phase 3 Project (project or proposed project). Implementation of the
project requires a Chula Vista General Plan Amendment, Sunbow General Development Plan Amendment, Sunbow
Sectional Planning Area Plan Amendment, a rezone, and a Tentative Map.
This EIR was prepared in accordance with CEQA (Public Resources Code, Section 21000 et seq.), the CEQA
Guidelines (14 CCR 15000 et seq.), and the City of Chula Vista (City) environmental review procedures. The City is
the lead agency for the EIR and processing of the project.
This EIR provides decision makers, public agencies, and the public with detailed information about the potential for
significant adverse environmental impacts to occur as a result of the proposed project. Similarly, responsible
agencies will use this EIR to fulfill their legal authority associated with permits issued for the project. The analysis
and findings in this document reflect the independent judgment of the City.
2.2 Hierarchy of Sunbow Planning Documents
2.2.1 City of Chula Vista General Plan
California law requires that each county and city adopt a General Plan “for the physical development of the
County or City, and of any land outside its boundaries which…bears relation to its planning” (California
Government Code, Section 65300). Each General Plan must be internally consistent and all discretionary land
use plans and projects must also be consistent with the General Plan.
The City of Chula Vista City Council adopted an updated General Plan on December 13, 2005 (Resolution N os.
2005-424, 2005-425, 2005-426). The General Plan outlines goals, objectives, and policies for land use in the City
in response to the community’s vision for the City. This General Plan also guides day -to-day decision making to
ensure that there is a continuing progress toward the attainment of the General Plan goals.
The General Plan Update includes Area Plans for specific parts of the City, including the East Planning Area, where
the project is located (City of Chula Vista 2005). The East Planning Area encompasses approximately 23,807 acres
in the City’s incorporated area. In the East Planning Area, developments are suburban in nature and characterized
by single-use residential areas, curvilinear streets, cul-de-sacs, and commercial malls; however, future development
would be designed to support regional transit service, provide neighborhood and regional commercial areas, and
offer a variety of housing opportunities. The vision for future development would require new infrastructure inclusi ve
of improvements to roads, utilities, and community parks. The East Planning Area is divided into six subareas: East
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Main Street Subarea, unincorporated Sweetwater Subarea, Otay Ranch Subarea, Master Planned Communities
Subarea, unincorporated East Otay Ranch Subarea, and other miscellaneous subareas (City of Chula Vista 2005).
The project is located within the Master Planned Communities Subarea, which is further broken down into six
subareas: Sunbow, Rancho del Rey, Eastlake, Rolling Hills Ranch, San Miguel Ranch, and Otay Ranch.
2.2.2 Sunbow General Development Plan
The Sunbow General Development Plan (GDP), which originally included 604.8 acres in eastern Chula Vista, was
adopted on December 5 , 1989, with the primary objective to create an efficient, self -contained village with a
mix of residential, commercial, community recreation, industrial park, and open space/trails land uses. The
principal objective of the GDP was to develop an efficient , self-contained village (City of Chula Vista 1989).
The GDP is implemented through the adoption of a more detailed SPA Plan, tentative tract maps, and potential
annexation and development agreements. The GDP is designed to function as a policy bridge between the City
of Chula Vis ta General Plan (General Plan) and the SPA Plan, which provides more detailed plans for
development of the Sunbow Master Planned Community (City of Chula Vista 19 89).
2.2.3 City of Chula Vista Multiple Species Conservation Program
The project site is part of the City’s Multiple Species Conservation Program (MSCP), which was adopted in 2003. The
municipalities of southern San Diego County collaborated in producing the MSCP Subregional Plan. The MSCP
Subregional Plan is implemented through individual Subarea Plans adopted by each jurisdiction and would allow
“take” authorization for covered species through specific conditions of coverage pursuant to Section 4(d) of the
Federal Endangered Species Act. The Chula Vista MSCP Subarea Plan provides for conservation of upland habitats
and species through Preserve design, regulation of impacts and uses, and management of the Preserve (City of
Chula Vista 2003). The MSCP identifies coastal sage scrub, coastal California gnatcatcher, coastal cactus wren, snake
cholla, and barrel cactus as preserve species within and adjacent to the project site.
The MSCP outlines covered projects, which include projects involving land use development within the City for which
hardline preserve boundaries have been established pursuant to the approved MSCP Subarea Plan, and where
conservation measures consistent with the MSCP Subregional Plan and Chula Vista Subarea Plan have been or will
be specified as biding conditions of approval in such projects’ plans and approval. The proposed project was not
identified as a covered project in the MSCP. However, the MSCP established a hardline preserve boundary within the
project site, adjacent to the Sunbow II Phase 3 area.
2.2.4 Sectional Planning Area Plans
The SPA Plan was approved by the City Council on February 20, 1990. According to the City, GDPs are
implemented through the adoption of SPA Plans, which are more detailed in its zoning, design regulations, and
development parameters. The purpose of the SPA Plan is to ensure high-quality development, create an
economically viable plan, provide a plan for long -range development, facilitate provisions for community facilities,
preserve open space, and establish a planning and development framework. Regulations within the SPA Plan
supersede other regulations where there is potential conflict between the GDP and the General Plan.
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2.3 Scope of the EIR
Pursuant to Section 15161 of the CEQA Guidelines, this document was prepared as a “project EIR” and is “focused
primarily on the changes in the environment that would result from the development” (i.e., the buildout of the
proposed project). Where environmental impacts have been determined to be potentially significant, this EIR
presents mitigation measures directed at reducing those adverse environmental effects. The development of
mitigation measures provides the lead agency with ways to substantially lessen or avoid the significant effects of
the project on the environment, to the degree feasible. Alternatives to the proposed project are presented to
evaluate whether there are alternative development scenarios that can further minimize or avoid significant
impacts associated with the project.
2.4 Environmental Procedures
2.4.1 CEQA Compliance
The California Public Resources Code (Section 21000 et seq.) requires the preparation and certification of an EIR for any
project that a lead agency determines may have a significant effect on the environment. This EIR has been prepared in
compliance with all criteria, standards, and procedures of the CEQA Guidelines (14 CCR Section 15000 et seq.).
2.4.2 Notice of Preparation and Scoping
CEQA establishes mechanisms whereby the public and decision makers can be informed about the nature of a
proposed project and the extent and types of impacts that the project and its alternatives would have on the
environment, should the project or alternatives be implemented. Pursuant to Section 15082 of the CEQA
Guidelines, the City circulated a Notice of Preparation (NOP) dated November 9, 2020, to begin a 30-day public
scoping period, to interested agencies, organizations, and parties. The NOP was also sent to the State
Clearinghouse at the California Governor’s Office of Planning and Research. The State Clearinghouse assigned a
state identification number (SCH No. 2020110148) to this EIR.
The NOP is intended to encourage interagency communication regarding the proposed action so that agencies,
organizations, and individuals are afforded an opportunity to respond with specific comments and/or questions
regarding the scope and content of the EIR. A pre-recorded public scoping presentation was published on the City’s
website to gather additional public input. The pre-recorded presentation was made available during the entire public
scoping period.
Comments received during the NOP public scoping period were considered during the preparation of this EIR. The NOP
and comments are included in Appendix A to this EIR.
Based on the scope of the proposed project as described in the NOP, the following issues were determined to be
potentially significant and are addressed in Chapter 5, Environmental Impact Analysis, of this EIR:
• Aesthetics
• Air Quality
• Biological Resources
• Cultural and Tribal Cultural Resources
• Energy
• Geology and Soils
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• Greenhouse Gas Emissions
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Land Use and Planning
• Noise
• Population and Housing
• Public Services
• Recreation
• Transportation
• Utilities and Service Systems
• Wildfire
2.4.3 Overview of the EIR Process
This EIR will be made available to members of the public, public agencies, and interested parties for a 45-day public
comment period in accordance with Section 15105 of the CEQA Guidelines. Public comment of the EIR is intended
to focus “on the sufficiency of the document in identifying and analyzing the possible impact s on the environment
and ways in which the significant effects of the project might be avoided or mitigated” (14 CCR 15204). The Notice
of Completion of the EIR will be filed with the State Clearinghouse as required by Section 15085 of the CEQA
Guidelines. In addition, the Notice of Availability of the EIR will be distributed pursuant to Section 15087 of the
CEQA Guidelines. Interested parties may provide comments on the EIR in written form. This EIR and all related
technical appendices are available for review upon request during the 45-day public comment period by the
following means:
• The EIR is available to review electronically at http://www.chulavistaca.gov/departments/
development-services/planning/public-notices/environmental-notices.
• For additional options to review, please contact Oscar Romero, Associate Planner, by email at
oromero@chulavistaca.gov or phone at 619.691.5098.
Once the 45-day public comment period has concluded, the City will review all public comments on the EIR, provide
written responses to comments, and authorize revisions to the EIR text, if necessary. The final Mitigation Monitoring
and Reporting Program (MMRP) will be incorporated into the Final EIR. Mitigation measures contained in the EIR
consider future monitoring requirements and are written in sufficient detail to address impacts of the proposed
project, referencing the appropriate implementing permits and plans. If one or more significant environmental
impacts are determined, written findings for each of those significant effects, accompanied by an overriding
justification and rationale for each finding in the form of a statement of overriding considerations will also be
included in the Final EIR, if necessary. The Final EIR includes all comment letters received, final written response
to comments, a Final EIR preface, if applicable, edits made to the EIR as a result of public review/comment, and
findings of fact and statement of overriding considerations, if necessary.
2.5 Intended Uses of the EIR
According to Section 21002.1(a) of the Public Resources Code (CEQA), “[t]he purpose of an environmental impact
report is to identify the significant effects of a project, to identify alternatives to the project, and to indicate the
manner in which those significant effects can be mitigated or avoided.” This EIR provides relevant information
concerning the potential environmental effects associated with construction and operation of the proposed project
and identifies and evaluates potentially significant effects that may result from im plementation of the proposed
project. It is intended for use by decision makers and the public.
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As the designated lead agency, the City has assumed responsibility for preparing this EIR. When deciding whether
to approve the proposed project, the City will use the information provided in this EIR to consider potential impacts
to the physical environment associated with the proposed project. The City will consider all written comments
received on the EIR during the 45-day public comment period in making its decision to certify the EIR as complete
and in compliance with CEQA and in making its determination whether to approve or deny the project. In the final
review of the document, environmental considerations, and economic and social factors will be weighed to
determine the most appropriate course of action.
After certification of the Final EIR, agencies with permitting authority over all or portions of the project will use the
Final EIR as the basis for their evaluation of environmental effects related to the project and approval or denial of
other applicable permits or authorizations.
2.6 Organization and Content of the EIR
This EIR is organized to provide a tiered project-level analysis of the potentially significant environmental impacts,
mitigation measures, and alternatives for the proposed project. To describe the direct, indirect, and cumulative
impacts, mitigation measures, and alternatives for the proposed project, this EIR is organized as follows:
• Chapter 1, Executive Summary, outlines the conclusions of the environmental analysis and a summary of
the project as compared to the alternatives analyzed in the EIR. This section also includes a table
summarizing all environmental impacts identified in this EIR along with the associated project design
features and mitigation measures proposed to reduce or avoid each impact.
• Chapter 2, Introduction, serves as a foreword to this EIR, introducing the project background, applicable
environmental review procedures, and the organization of the EIR.
• Chapter 3, Environmental Setting, describes the project location and physical environmental setting.
• Chapter 4, Project Description, provides a thorough description of the proposed project and required
discretionary approvals, along with project design features used as part of the City’s standard practice to
minimize project impacts.
• Chapter 5, Environmental Impact Analysis, provides an analysis of the potentially significant environmental
impacts identified, and proposed mitigation measures to reduce or avoid any potentially significant impacts.
• Chapter 6, Cumulative Impacts, provides an analysis of the cumulative effects of the proposed project.
• Chapter 7, Growth Inducement, discusses the project’s potential growth-inducing impact.
• Chapter 8, Significant Irreversible Environmental Changes, addresses impacts that have been identified as
significant and irreversible.
• Chapter 9, Effects Found Not to Be Significant, address impacts that were determined to not be significant
during the scoping process.
• Chapter 10, Alternatives, analyzes a range of reasonable alternatives to the proposed project that would
lessen or avoid significant environmental effects of the proposed project.
• Chapter 11, References, provides a compiled list of references cited in each section of the EIR.
• Chapter 12, List of Preparers, provides a list of persons who contributed to the preparation of this EIR.
• Appendices include various technical studies and correspondence prepared for the project, as listed in the
table of contents.
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2.7 Mitigation Monitoring and Reporting Program
The City will prepare an MMRP prior to project approval. The MMRP will include all mitigation measures outlined in
the EIR, the responsible entity for implementation, implementation timing (prior to construction, during
construction, post-construction), and any follow-up reporting requirements (such as submittal of materials to
regulatory agencies). The City, as the designated lead agency, is responsible for enforcing and verifying that each
mitigation measure is implemented as required. The MMRP is included as Appendix M to this EIR.
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3 Environmental Setting
This chapter of the environmental impact report (EIR) provides a description of the existing site conditions,
surrounding land uses, and land use planning context relevant to the proposed Sunbow Sectional Planning Area
(SPA) Plan Amendment for the Sunbow II, Phase 3 Project (project or proposed project). Additionally, this chapter
includes a description and map of related projects and growth factor assumptions for the project area.
3.1 Existing Site Conditions
The Sunbow Master Planned Community lies within the East Planning Area of the City of Chula Vista (City), as
identified in the General Plan (City of Chula Vista 2005). The approximately 135.7-acre project site is located south
of Olympic Parkway and east of Brandywine Avenue. The Otay Landfill is located to the south and southeast of the
site and undeveloped land approved for industrial and residential land uses is located to the east within Otay Ranch
Village Two. The existing Olympic Parkway, a six-lane prime arterial roadway, forms the northern boundary of the
project site. The project site is approximately 3.8 miles southeast of downtown Chula Vista , 9.9 miles southeast of
downtown San Diego approximately 2.3 miles west of State Route 125, and approximately 0.7 miles east of
Interstate 805 (I-805). The project site consists of vacant and undeveloped land.
3.1.1 Surrounding Land Uses
The project site is bordered by the Otay Landfill to the south and southeast of the site, and undeveloped land
approved for industrial and residential land uses is located to the east. Residential Medium High land uses are
located to the west of the project site, across Brandywine Avenue (City of Chula Vista 2005). The existing Olympic
Parkway forms the northern boundary of the project site and an open space area is located to the north of the
project site, across Olympic Parkway, and residential development is located approximately 400 feet to the north.
Olympic Parkway is designated a scenic roadway in the General Plan.
3.1.2 Existing Topography and Soils
Soils on the site consist of previously placed compacted fill, topsoil, alluvium, colluvium, San Diego formation,
Otay formation, and Sweetwater formation. The compacted fill is associated with previous grading operations for
Olympic Parkway and is present along the northern project boundary. The topsoil encountered consists of
unconsolidated, clayey sands to sandy clays with a high expansion potential. Alluvium is present within the three
main drainages within the northern portion of the site and along Olympic Parkway. Colluvium deposits are present
along the hillsides above the alluvial drainages within the northern portion of the site. The San Diego Formation
overlies the Otay Formation and consists of dense, fine to medium -grained sandstone with relatively low cohesion
and moderate to high permeability. Otay Formation is the predominant geologic unit on the site. It consist s of
dense, silty to clayey, sandstone and hard, siltstone and claystone bed with continuous to discontinuous
interbeds of weak, highly -plastic bentonitic claystone. The Sweetwater Formation, commonly referred to as the
gritstone layer of the Otay Formation, underlies the Otay Formation and is characterized as dense to very dense,
gravelly, and fine to coarse sandstone that is locally cemented.
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3.1.3 Climate
The San Diego Air Basin experiences warm summers, mild winters, infrequent rainfalls, light winds, and moderate
humidity. This usually mild climatological pattern is interrupted infrequently by periods of extremely hot weather,
winter storms, or Santa Ana winds. The weather of the San Diego region, as in most of Southern California, is
influenced by the Pacific Ocean and its semi-permanent high-pressure systems that result in dry, warm summers
and mild, occasionally wet winters. The average temperature ranges (in degrees Fahrenheit) from the mid -40s to
the high 90s. Most of the region’s precipitation falls during November through April, with infrequent (approximately
10%) precipitation during the summer. The average seasonal precipitation in the City of Chula Vista is approximately
9.7 inches; the amount increases with elevation as moist air is lifted over the mountains to the east (WRCC 2017).
3.1.4 Access
Primary regional access to the project site is from I-805 via Olympic Parkway. There is currently no public roadway
access to or within the site. The project site is currently accessible from Olympic Parkway through two existing
unpaved culverts crossing Poggi Canyon Creek in the northern portion of the site.
3.2 Existing Land Use Designations
3.2.1 Existing General Plan Designations
As shown on Figure 3-1, the project site’s land use is designated largely as Open Space Preserve with small sections
designated as Open Space, as well as Research & Limited Industrial within the southeastern portion of the site.
Land uses designated as Open Space Preserve are area s within the Chula Vista Multiple Species Conservation
Program Subarea Plan for the permanent conservation of biological resources (City of Chula Vista 2005). The Open
Space land use designation is intended for lands to be protected from urban development, including floodplains,
canyon, mountain, and agricultural uses (City of Chula Vista 2005).
3.2.2 Existing Zoning
The City of Chula Vista Zoning Map designates the zoning of the project site as a Planned Community (P-C) Zone.
Per Title 19 of the City of Chula Vista Municipal Code, the City’s Zoning Code, P-C Zones shall be divided into
sectional planning areas. Thus, the project site is designated as SPA under the P-C Zone (City of Chula Vista 2020).
Specific land use districts are established by the SPA Plan (described below).
3.2.3 Existing Sunbow General Development Plan Designation
The General Development Plan designates the project site as Industrial Park and Open Space, as shown on Figure
3-2 (City of Chula Vista 19 89).
3.2.4 Existing Sunbow Sectional Planning Area Plan Designation
Zoning (land use district) for the project site is established in the Sunbow SPA Plan. The SPA Plan designates the
project site as Industrial Park and Open Space , as shown on Figure 3 -3 (City of Chula Vista 1990).
Existing General Plan Land Use
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4 Project Description
This chapter of the environmental impact report (EIR) provides a description of the proposed Sunbow Sectional
Planning Area (SPA) Plan Amendment for the Sunbow II, Phase 3 Project (project or proposed project). As required
by Section 15124 of the California Environmental Quality Act (CEQA) Guidelines, this chapter includes the precise
location of the project site, a statement of the project objectives, a general description of project chara cteristics
that accounts for public service facilities, and a summary of the discretionary actions that would be required.
4.1 Location
ACI Sunbow LLC (applicant), is proposing to develop an approximately 135.7-acre site (Assessor’s Parcel Numbers
644-171-12500, 644-011-0600, 644-020-1100) within the Sunbow Master Planned Community of the City of
Chula Vista (Figure 4-1, Project Location). The project site is located within the southern portion of the City of Chula
Vista (City), in southwestern San Diego County, California. The site is located south of Olympic Parkway, east of
Brandywine Avenue, and north and northwest of the Otay Landfill. Undeveloped land approved for industrial and
residential land uses is located to the east of the site within Otay Ranch Village 2. The project site is approximately
3.8 miles southeast of downtown Chula Vista 9.9 miles southeast of downtown San Diego approximately 2.3 miles
west of State Route (SR) 125, and approximately 0.5 miles east of Interstate (I) 805.
4.2 Background
The Sunbow General Development Plan (GDP), which originally included 604.8 acres in eastern Chula Vista, was
adopted on December 5, 1989 (City of Chula Vista 1989), with the primary objective to create an efficient,
self-contained village with a mix of residential, commercial, community recreation, industrial park, and open
space/trails land uses. The GDP is implemented through the adoption of a more detailed SPA Plan, tentative
tract maps, and potential annexation and development agreements. The GDP is designed to function as a
policy bridge between the City of Chula Vista General Plan (General Plan ; City of Chula Vista 2005) and the
SPA Plan, which provides more detailed plans for development of the Sunbow Master Planned Community (City
of Chula Vista 1990.
The portion of the Sunbow Master Planned Community designated as Sunbow II, Phase 3 (project site),
includes the area slated to be developed as Industrial Park (formerly referred to as Planning Area 23 in the
GDP and the SPA Plan ), while the rest of the project site was designated as Open Space in the GDP and the
SPA Plan. The GDP designated the 54 .7 acres as Industrial Park to include research/development and light
industrial uses, with approximately 700,000 square feet of leasable area generating approximately 2,800
employment opportunities. Based on the City’s Multiple Species Conservation Program (MSCP) Preserve
Boundary data, the applicant’s civil engineer determined that there is an approximately 6 7.5-acre development
area within the project site. The development area (referred to herein as the prop osed development area)
would consistent of residential uses , a community purpose facility, manufactures slopes, basins, and
associated infrastructure. The remainder of the project site would be designated MSCP Preserve, Poggi Creek
Conservation Easement areas, a 0.3-acre wetland resources area, with 63.6 acres preserved as permanent Open
Space as part of the City MSCP Subarea Plan Preserve.
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4.3 Project Objectives
Following are the objectives of the proposed project:
1. Develop a pedestrian-oriented community on an underutilized site with a range of residential uses, open
space and MSCP Preserve areas, and recreational opportunities, which are compatible with the adjacent
established residential communities.
2. Contribute to the growing housing needs of the City and the region by providing for multi-family housing
units with a range of housing types to accommodate a spectrum of demographics.
3. Preserve portions of the project site as permanent open space and increase the MSCP Preserve Areas.
4. Provide pedestrian and bicycle facilities, including a pedestrian connection to the Chula Vista Regional Trail
and connection to bike lanes within Olympic Parkway and nearby transit.
5. Implement the goals, objectives, and policies of the General Plan; the MSCP Subarea Plan; the GDP; and
the SPA Plan.
6. Implement the City’s Growth Management Ordinance to ensure that public and community facilities, such
as transportation, water, flood control, sewage disposal, schools, and parks, are provided in a timely
manner and financed by the parties creating the demand for, and benefiting from, the improvements.
7. Ensure that new uses are compatible with the existing community by establishing setbacks, design
regulations and guidelines, best practices, and performance standards that enhance quality of life for
neighboring properties.
8. Create a land use plan that can realistically be developed within a foreseeable time frame and under
projected economic conditions.
4.4 Project Description
The following section describes the components of the proposed project. Amendments to the General Plan, GDP, SPA
Plan, and a rezoning of the project site would be required to implement the proposed project as described below.
4.4.1 Land Uses
The 135.7-acre project site will consist of an approximately 67.5-acre development area composed of 44.2 acres of
residential uses, a 0.9-acre Community Purpose Facility (CPF), 5.9 acres of public streets, and 16.5 acres of
manufactured slopes and drainage basins. The project will also preserve 4.3 acres of Poggi Creek conservation
easement areas and a 0.3-acre wetland avoidance area. Approximately 63.6 acres will be designated MSCP Preserve.
The proposed land uses are summarized in Table 4-1 and shown in Figure 4-2, Proposed General Plan Land Use;
Figure 4.3, Proposed General Development Plan Land Use; Figure 4-4, Proposed SPA Plan Land Use; and Figure 4-5,
Proposed Zoning. Development would be centered within the southeastern portion of the site. Under the proposed
project, the Industrial Park area (Planning Area 23) would be modified to Medium -High and High Residential
land uses (see Figures 4 -2 and 4-3).
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Table 4-1. Sunbow II, Phase 3 Sectional Planning Area Plan Land Use Summary
Land Use Planning Area Units Gross Acres Target Density
Residential
Multi-Family (Medium-High) Residential – 13–16 du/ac
MF R-1 131 8.5 15.4
MF R-2 73 4.6 15.8
MF R-3 108 8.1 13.3
MF R-4 118 8.2 14.4
MF R-5 104 7.0 14.7
Multi-Family Medium-High Residential Subtotal 534 36.5 14.7a
Multi-Family (High) Residential – 24.1 du/ac
MF R-6 184 7.6 24.1
Multi-Family High Residential Subtotal 184 7.6 24.1
Residential Total 718 44.2 16.3a
Other
Community Purpose Facility (CPF)
CPF CPF — 0.9 —
CPF Subtotal — 0.9 —
Other Total — 0.9 —
Open Space
MSCP Open Space Preserve (OS)
OS OS-1 — 42.8 —
OS OS-2 — 10.0 —
OS OS-3 — 9.6 —
OS OS-9b — 1.1 —
MSCP Open Space Preserve Subtotal — 63.6 —
Poggi Creek Conservation Easement
OS OS-4 — 2.6 —
OS OS-5 — 0.7 —
OS OS-6a — 1.0 —
OS OS-6b — 0.1 —
Poggi Creek Conservation Easement Subtotal — 4.3 —
Manufactured Slopes/Basin
OS OS-7 — 3.2 —
OS OS-8 — 0.5 —
OS OS-9a — 0.5 —
OS OS-10 — 4.9 —
OS OS-11 — 1.3 —
OS OS-12 — 1.6 —
OS OS-13 — 4.6 —
Manufactured Slopes/Basin Subtotal — 16.5 —
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Table 4-1. Sunbow II, Phase 3 Sectional Planning Area Plan Land Use Summary
Land Use Planning Area Units Gross Acres Target Density
Wetland Avoidance Area
OS OS-14 — 0.3 —
Wetland Avoidance Area Subtotal — 0.3 —
Open Space Total — 84.7 —
Circulation
Public Streetsb Circulation — 5.9 —
Circulation Subtotal — 5.9 —
Circulation Total — 5.9 —
All Land Use Types – Summary
All Land Use Types Total — 135.7 —
Notes: du/ac = dwelling units per acre; MSCP = Multiple Species Conservation Program.
Subtotals and totals may not sum precisely due to rounding.
a Target density represents the average densities proposed.
b The acreages for all proposed private streets are included as a part of the residential portion.
4.4.1.1 Residential
As shown in Table 4-1, the proposed project would introduce 534 multi-family medium-high-density residential
dwelling units on 36.5 acres, and 184 multi-family high-density residential dwelling units on 7.6 acres, for a total
of 718 units on approximately 44.2 acres of the project site. The medium-high-density development would range
from 13 to 16 dwelling units per acre, and the high-density development would be 24.1 dwelling units per acre.
Proposed residential uses would feature four unique multi-family attached residential product types with 15 unique
floorplans, ranging in square footage from approximately 1,100 to 2,050, in two- and three-story homes. The
proposed residences would feature a contemporary architectural style and unique combinations of e levations and
colors, focusing on creating a varied street scene. Proposed garages would be accessed from private driveways,
while front doors and balconies would face streets, private yards, and communal open space areas.
The project applicant would be required to enter into a Balanced Community Affordable Housing Agreement, in
accordance with the inclusionary housing policy to increase the diversity of housing prices and rents throughout the
community. Per the City’s Balanced Community Affordable Housing Agreement, the project’s affordable housing
obligation is 72 affordable housing units, including 36 low-income and 36 moderate-income affordable units.
Various passive and active recreational open space areas would be distributed throughout the residential areas to
provide recreational opportunities within walking distance of proposed residences (see Figure 4-6, Illustrative Concept
Plan). Active recreation areas may include children’s play areas, bocce ball courts, a fenced dog run, and open turf areas,
while passive recreational uses may include shaded picnic areas and movable seating areas.
Landscaping
Proposed landscaping is shown in Figure 4-6. All landscaping will be provided in accordance with the Sunbow II
Phase 3 Landscape Master Plan, prepared for the project, and the Chula Vista Landscape Manual, which requires
the use of recycled water for irrigated open space slopes and common landscaped areas, wherever feasible.
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Drought-tolerant plants would also be provided per the Chula Vista Landscape Manual. Further, all landscaping
shall comply with the Landscape Water Conservation Ordinance (CVMC Section 20.12), the Fire Protection Plan and
the Chula Vista MSCP Subarea Plan.
Park Requirements
According to Chula Vista Municipal Code (CVMC), Section 17.10, Parklands and Public Facilities, and the City of Chula
Vista Park Acquisition and Development (PAD) Fee Update, the project would generate a parkland obligation of 5.6
acres. The Community Benefit Agreement, between the City and the applicant, includes a provision for payment of a
Park Benefit Fee, equal to the PAD fee that would have been due pursuant to CVMC Section 17.10, of approximately
$11.03 million based on 2019 PAD fees, which may be revised by the City from time to time. The final Park Benefit
Fee amount will be determined based on the number and type of residential units constructed and the PAD fee rates
in effect as of the effective date of paymentthe project’s Development Agreement. To create this Park Benefit Fee, the
City will waive the parkland dedication and development requirements set in Chapter 17.10 of the CVMC, including
the Parkland Acquisition and Public Facilities Development fees, and Quimby Act fees. The Park Benefit Fee shall
satisfy the project’s park obligations and may be used by the City to acquire or develop parkland, as the City determines
appropriate and in the best interest of the City.
4.4.1.2 Community Purpose Facility
CVMC Section 19.48.040 P-C Planned Community Zone requires 1.39 acres of Community Purpose (CPF) land per
1,000 persons be provided. For the purposes of determining CPF obligation, the project would generate
approximately 2,334 persons resulting in an obligation to provide approximately 3.2 acres of CPF land.
Approximately 0.9 acres within the project site would be designated community purpose facility (CPF). The CPF area
would be centrally located in the project site, toward the southeast (see Figure 4-4). The CPF would be used as a
community recreation area and would accommodate a swimming pool, spa, and associated pool uses; a clubhouse;
a shaded BBQ area; a children’s play area; a multi-use hard court area; and a level turf area (see Figure 4-7,
Community Purpose Facility Conceptual Site Plan). As shown in Figure 4-4, the CPF would be located directly to the
south of proposed Street ‘A,’ (Street A) and would be bounded by R-4 to the east, south, and west The community
recreation area is designed consistent with the provisions of CVMC)Section 19.48.025 as a qualified CPF private
recreation use. The project applicant would enter into an agreement with the City to ensure compliance with the
remaining 2.3-acre CPF obligation as part of the Development Agreement.
4.4.1.3 Open Space
The Sunbow Master Planned Community was created to achieve the residential goals and objectives of the GDP.
As shown in Figure 4-3, the western portion and northern boundary of the project site was anticipated to be
developed as open space in the GDP. Approximately 84.8 acres of the project site would be designated as open
space and open space preserve. Within the development area, approximately 16.5 of open space acres would be
comprised of manufactured slopes, basins and fuel modification zones. Open Space areas preserved outside the
development area would be comprised of a 0.3-acre wetland resource area, 4.3 acres of Poggi Creek Conservation
Easement areas and approximately 63.6 acres designated MSCP Preserve open space. Preserved open space
would be managed by the City with funding from Community Facilities District (CFD) 98-3. The project’s
homeowner’s association would manage the manufactured slopes, basins, and wetland avoidance areas.
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MSCP Open Space Preserve
Approximately 63.6 acres of Open Space (Parcels OS-1, OS-2, OS-3, and OS-9b) would be preserved as MSCP open
space under the City’s MSCP Subarea Plan. The MSCP open space area would be dedicated to the City of Chula
Vista. Land use and design of these areas is regulated by the MSCP Subarea Plan, as discussed in the SPA Plan
Amendment (see Appendix B).
The project also includes a Chula Vista MSCP Boundary Adjustment (BLA) that would correct an inadvertent error in
the MSCP that placed a 100% Preserve overlay on the project site even though the project was not identified as a
Covered Project. The BLA would implement minor adjustments to the development limits and the adjacent open
space and MSCP open space preserve areas (see Section 4.4.4, MSCP Boundary Line Adjustment and Minor
Amendment, and Section 5.3, Biological Resources, for additional details). The applicant is also requesting an
MSCP Minor Amendment to allow off-site temporary project impacts that would encroach 25 feet onto City’s
property and within this Minor Amendment Area (see Figure 5.3-1, Local Environmental Setting Map, and Figure
5.3-4, Biological Impacts Map). This off-site area would result in the installation of permanent buttressing; however,
the impacts from grading would be temporary as this area would be return to its original condition. These areas are
intended to remain unimproved and/or restored and their use strictly limited consistent with the Chula Vista MSCP
Subarea Plan. Vegetation would consist of native plants that already occur on site. Only under limited circumstances
may certain facilities, as determined by the City to be compatible with the goals and objectives of the City’s MSCP
Subarea Plan, be permitted within the preserve. Any proposed facilities within the MSCP Open Space Preserve area
shall be subject to the prior review and approval of the Director of Development Services. The proposed project
would limit grading for proposed Street ‘A’ and Street ‘B’ (Street A and Street B) to the north of the project site, as
they intersect the MSCP Preserve area. Development of Streets A and B would occur consistent with previously
approved alignments and existing Poggi Creek crossing improvements.
The proposed MSCP Preserve includes a portion of a water quality basin (OS-9b) as a Future Facility within the
existing MSCP Preserve. The relocation of this basin to minimize impacts to the MSCP Preserve was considered
during project design; however, due to site specific topography for drainage and the confined development footprint
the basin was instead modified to reduce potential impacts to the MSCP Preserve to the extent practicable. This
encroachment into the MSCP Preserve would quality as a Future Facility (a conditional compatible use) and is
analyzed for Functional Equivalency Criteria. Refer to Section 5.3, Biological Resources.
Poggi Creek Conservation Easement Areas
Approximately 3.9 acres of open space , located in the northern portion of the project site, within Parcels OS-
4, OS-5, OS-6a, and OS-6b, would consist of the Poggi Creek Conservation Easement Areas. There are currently
19.2 acres of recorded and unrecorded conservation easements associated with Poggi Cree k within the project
site. This includes the 9.7 -acre recorded conservation easement, a 5.6 -acre proposed unrecorded
conservation easement, and the 3.9 -acre proposed unrecorded Poggi Creek Conservation Easement. Of the
recorded and unrecorded easements of Poggi Creek, 12.4 acres are within the proposed Chula Vista MSCP
Boundary , as shown on Figure 4 -8, Proposed Poggi Creek Conservation Easement and MSCP Boundary . The
Poggi Creek Conservation Easement areas would remain undeveloped and allow for protection o f the existing
Poggi Creek. Note that the existing Poggi Creek Crossing (culverts) were analyzed as part of previous projects
in this area and mitigation for impacts is fully complete.
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Manufactured Slopes/Basins/Wetland Resources
Approximately 16.8 acres of open space within the proposed project site, located on Parcels OS-7, 8, 9a, 10 and
13, and would consist of manufactured slopes, basins, fuel modification zones and associated buffer areas. A 0.3
acre wetland resource is preserved on-site and is designated OS-14 in the Sunbow SPA Amendment. Two proposed
detention/water quality control basins would be constructed within the northeast and northwest portion of the
development area, within Parcels OS-9a and OS-11, to treat on-site stormwater runoff. Large landscaped slopes
would be provided along the perimeter of the development area within Parcels OS-7, OS-10, and OS-12 and would
incorporate a diverse plant palette and planting program . Fuel modification areas would also be provided in these
areas and would be landscaped consistent with the Fire Protection Plan prepared for the project.
4.4.2 Access and Circulation Network
4.4.2.1 Site Access
Regional access to the project site is from I-805, which runs north–south and is located approximately 0.5 miles
west of the project site. Additional north–south access is provided from SR-125, located approximately 2.3 miles
east of the project site, and I-5, located approximately 3.8 miles west of the project site. SR-125 and I-5 both provide
north–south circulation. SR-54 and SR-905 provide regional east–west circulation and are located approximately
4.3 miles north and 2.8 miles south, respectively, of the project site.
East–west access is provided by the existing Olympic Parkway, located adjacent to the project site to the north,
connecting to I-805 to the west and SR-125 to the east. Olympic Parkway is designated as a scenic roadway within
the General Plan. Direct access to the project site would be provided by two proposed public streets, Street A and
Street B. Street A would extend south from Olympic Parkway, through the project site, and then curve to the east
and connect with Street B. Street B would also extend south from the eastern portion of Olympic Parkway, adjacent
to the project site (see Figure 4-2, Project Site Plan, and Figure 4-9, Vehicular Circulation Plan). Both Street A and
Street B would be signalized at the Olympic Parkway intersections, with pedestrian crossings. The impact areas of
both Street A and Street B within Poggi Creek are within areas previously addressed and mitigated for impacts to
Poggi Creek described above.
4.4.2.2 Internal Circulation
The proposed project’s circulation system provides a system of roadway corridors to support both vehicular and
non-vehicular modes of transportation to serve the site and the community. This system includes the development
of internal systems to serve the SPA area, including planned roads, pedestrian improvements, and transit from
adjacent villages.
The proposed project establishes the on-site public and private street cross sections for the project. Street pattern
organizes traffic into a hierarchy of travel ways, arranged according to anticipated volumes and modes of travel .
The western portion of the project site would be primarily developed as open space and no internal vehicular
circulation is proposed. The street pattern in the development area of the site is a suburban street pattern, provides
a transition to the natural open space areas to the west, and reflects the topography of this portion of the site.
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As shown in Table 4-1, approximately 5.9 acres of the project site would be used for public streets, which includes
proposed public Streets A and Street B, discussed in Section 4.4.2.1, Site Access, and shown in Figure 4-9.
Pedestrian and bicycle circulation proposed is shown in Figure 4-10, Bicycle and Pedestrian Circulation Plan.
Streets ‘A’ and ‘B’
Streets A and B would be classified as Modified Class III Collector Streets, planned as two unique street sections to
serve the project. The Modified Class III Collector, with a 55-foot-wide right-of-way, 13-foot-wide travel lanes, two 7.5-
foot-wide landscape parkways, and a 6-foot-wide sidewalk and parking on one side of each street, would be
implemented on the portion of Street A from Olympic Parkway to the entrance of neighborhoods R-1/R-3 and along
Street B between Olympic Parkway and the intersection at Street A. This narrowed street section is designed to provide
an enhanced pedestrian experience, while minimizing grading adjacent to MSCP Preserve areas. The wider 61-foot-
wide right-of-way is implemented on Street A within the development area and includes two 11-foot-wide travel lanes,
a 5-foot-wide sidewalk, and 7.5-foot-wide landscaped parkways on both sides of the street. Parking is permitted on
both sides of this segment of Street A. Class 3 Bike Lane would also be provided along Streets A and B.
One roundabout would be constructed at the intersection of Streets A and B. The roundabout would be designed to
identify the main entrance into the community as well as provide traffic calming. The center of the proposed
roundabout may include low landscaping and enhanced paving. The design of Street A and B sections, shown on
Figure 4-11 , as well as the design of the proposed roundabout, will be implemented on the site plan, may be refined
during final engineering, and shall be subject to City approval.
Private Streets
In addition to the proposed public Streets A and B, various private streets and drives are proposed throughout the
proposed development area. Two types of private streets are proposed throughout the project site. Private
neighborhood collector streets are planned within the proposed residential areas and would be comprised of two
12-foot-wide travel lanes, 5-foot-wide sidewalks, and 5.5-foot-wide landscaped parkways on both sides. No parking
would be allowed within the private neighborhood collector streets. Private residential streets with parking would
also be planned throughout the project site and would be designed to include two 12-foot-wide travel lanes, 8-foot-
wide parallel or 18-foot-wide perpendicular parking lanes, a contiguous sidewalk on one side, and a 5-foot-wide
landscaped parkway on the opposite side. The design of both of these street sections, shown on Figure 4-12, Private
Residential Streets –Typical Street Sections, will be implemented on the site plan, may be refined during final
engineering and shall be subject to City approval. Pedestrian connections from the end of proposed private drives
to walkways within individual neighborhoods would be provided, where feasible.
Pedestrian and Bicycle Circulation
As shown in Figure 4-10, the residential street pattern would be designed to provide access into the neighborhoods
and promote walkability. The proposed project would provide a pedestrian connection to the existing Chula Vista
Regional Trail, located to the north of the project site, across Olympic Parkway. Pedestrian access to the Regional
Trail would be provided at the two signalized intersections of Streets A and B and Olympic Parkway. A Class 3 Bike
Lane would be provided along Streets A and B and would connect with the existing Class 2 Bike Lane along Olympic
Parkway as well as the San Diego Metropolitan Transit System bus stop located at the corner of Olympic Parkway
and Brandywine Avenue. Bicyclists using the proposed on-site Class 3 Bike Lanes would share the roadway with
vehicles along Streets A and B. Internal pedestrian circulation would be provided via a network of sidewalks and
paseos connecting neighborhoods and public streets.
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4.4.3 Public Service and Utilities
4.4.3.1 Water Service
Water service for the proposed project would be provided by the Otay Water District (OWD). A water system would be
installed in accordance with OWD standards and would be maintained and operated by OWD. One existing OWD potable
waterline and one existing OWD recycled water line are located within Olympic Parkway. The proposed project would
receive water by expanding the existing 624 Pressure Zone, located within the Central Area System of OWD, through
creating two domestic service connections and two fire service connections transmission lines within Olympic Parkway
public streets, directly to the north of Streets A and B. In addition, an on-site loop would be constructed for domestic and
fire protection systems and would include a proposed public 12-inch OWD potable waterline, an 8-inch-diameter private
domestic waterline, an 8-inch-diameter private fire protection waterline, and an 86-inch-diameter public OWD recycled
water line, to be constructed within Streets A and B, and an 8-inch-diameter private domestic waterline and an 8-inch-
diameter private fire protection waterline, to be constructed outside of the public streets. Recycled water would be used
to irrigate all common landscaped areas, the on-site open space areas, and the CPF site. The proposed water and
recycled water systems are shown in Figure 4-13.
4.4.3.2 Sewer Service
Sewer service for the proposed project would be provided by and connected to the existing City of Chula Vista Poggi
Canyon Interceptor. The proposed project sewer would result in construction of an 8-inch-diameter public gravity sewer
line along the proposed Street A, that would convey flow to the existing Poggi Canyon Interceptor, located within
Olympic Parkway, to the north of the project site. Private sewer lines would be connected to this new public sewer line
and extended to the proposed building sewer laterals. All utilities would be underground, and easements would be
provided as necessary. The City operates and maintains its own sanitary sewer collection system that connects to the
City of San Diego’s Metropolitan Sewer System. The proposed sewer plan is shown in Figure 4-14.
4.4.3.3 Drainage and Stormwater Facilities
The approximately 135.7-acre site generally consists of natural grades and hills covered by native vegetation and
shrubs, and the drainage of the site generally flows from south to nor th, toward Poggi Canyon Creek. The Poggi
Canyon Creek, located within the northern portion of the project site, flows from the northeast to southwest and
accepts stormwater runoff from the surrounding area, as well as downstream runoff from the project sit e. Site
elevations within the site range from approximately 231 feet above mean sea level at the open space area of
the project site to approximately 440 feet above mean sea level, toward the southeastern portion of the site,
where it abuts the Otay Landfill.
The proposed storm drain system and layout, shown in Figure 4 -15, would be designed to address peak flows and
to integrate water quality features needed to comply with the City’s Standard Urban Stormwater Mitigation Plan
requirements for water quality. The proposed storm drain system would be designed to prevent the co-mingling of
treated flows with untreated runoff. Drainage easements shall be provided as required by the City Development
Services Department.
Under the proposed project, two proposed detention/water quality control basins would be constructed within the
northeast and northwest portion of the development area to treat stormwater runoff. In addition, various storm
drains, curb inlets, and cleanouts would be constructed within proposed private roads and parking areas to collect
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and convey stormwater runoff associated with the proposed project. All stormwater facilities would be designed
using low impact development techniques and best management practices (BMPs).
Specific methods of handling stormwater are subject to detailed approval by the development services department
at the time of submission of improvement and grading plans. Design shall be accomplished on the basis of
requirements of the City of Chula Vista Subdivision Manual.
4.4.3.4 Dry Utilities
Dry utilities would be extended underground throughout the project site, primarily within streets and other public easements.
Telephone, cable television, and internet service would be provided by companies such as Cox Communications, Time
Warner, and AT&T. Gas and electric services would be provided by San Diego Gas & Electric Company.
4.4.3.5 Schools
The Chula Vista Elementary School District serves the project site. More specifically, Valle Lindo Elementary School
(grades K–6) serves the project site and surrounding area (Chula Vista Elementary School District 2020). Valle
Lindo Elementary School is the closest elementary school to the project site, located approximately 0.3 miles west
of the project site.
The Sweetwater Union High School District serves the project site. The majority of the project site is within the
attendance boundary of Rancho Del Rey Middle School, while the southwestern portion of the project site is served
by Castle Park Middle School. Similarly, the majority of the project site is served by Otay Ranch High School, while
the southwestern portion of the site is served by Castle Park High School (Sweetwater Union High School District
2020). All middle schools (grades 7–12) and high schools (grades 9–12) are located approximately 1 mile from the
project site. Additionally, Southwestern College is located 1 mile north of the project site.
4.4.3.6 Police and Fire Services
The Chula Vista Police Department currently provides police services within the City. Development of the project
site would increase demand for police services. To meet Growth Management Ordinance service thresholds,
additional personnel and facilities may be required at buildout of the project. The proposed project would contribute
and estimated $1.5 million in Development Impact Fees dedicated to police services.
The Chula Vista Fire Department would provide fire service for the project. Fire Station Number 3 is the closest fire
station to the project site, located approximately 910 feet to the northwest of the site, at 1410 Brandywine Avenue.
Additional fire equipment, staff, and facilities required to serve the increased population as a result of the proposed
project is identified in Section 5.13, Public Services, and the Supplemental Public Facilities Financing Plan prepared
for the proposed project. The proposed project would contribute an estimated $840,000 in Development Impact
Fees dedicated to Fire Suppression.
American Medical Response (AMR) currently provides emergency medical services on a contract basis within the
City. There are five AMR South County paramedic units: two are located in Chula Vista, two are in National City, and
one is in Imperial Beach. However, the Chula Vista Fire Department is planning to take over ambulatory services for
the City once AMR’s current contract expires in September 2021.
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4.4.4 MSCP Boundary Line Adjustment and Minor Amendment
The proposed project includes an MSCP Boundary Line Adjustment to adjust the existing MSCP Preserve Boundary in
areas on site that overlap with the proposed project’s development area. As a part of the proposed MSCP Boundary Line
Adjustment, the proposed project is required to set aside a potentially suitable area currently located outside of the MSCP
Preserve to incorporate into the MSCP Preserve at a 1:1 acreage ratio. The proposed MSCP Boundary Line Adjustment
would be required to result in equal or higher biological value as compared to the existing MSCP Preserve. The
determination of biological value of the proposed MSCP Preserve Boundary Line Adjustment shall be made by the City,
as the local jurisdiction, in concurrence with the U.S. Fish and Wildlife Service and the California Department of Fish and
Wildlife. The proposed MSCP Boundary Adjustment would meet the MSCP Boundary Line Adjustment functional
equivalency criteria and would result in a 0.09-acre increase to the MSCP Preserve Area. Section 5.3 of this EIR provides
a detailed description of the conditions of the “give” and “take” areas separately. Where it is appropriate to discuss the
give and take areas together, the area is referred to as the Boundary Line Adjustment Area. An MSCP Minor Amendment
is also proposed to address off-site grading adjacent to the southwestern boundary of the development area.
4.4.5 Tentative Map
The Tentative Map, shown in Figure 4-16, would address subdivision of the project site, street standards, and
infrastructure. The Tentative Map would also address provisions for underground encroachment (e.g., all
underground utilities lines) into the right-of-way, off-site streets (traffic signals at Olympic Parkway), and grading
required to implement the subdivision. This includes the proposed sewer line within the Street A and Street B right-
of-way, which would convey flow to the existing Poggi Canyon Interceptor, located within Olympic Parkway to the north
of the project site, as shown in Figures 4-14 and 4-16.
4.4.6 Conceptual Grading
Conceptual grading and cut-and-fill plans are shown in Figure 4-17. Grading for the proposed project would consist
of cuts and fills that are planned to have maximum heights of approximately 100 feet, with a maximum slope
inclination of 2:1 (horizontal to vertical). The proposed raw grading quantity for the project is app roximately
1,200,000 cubic yards of balanced cut and fill material.
4.4.7 Construction and Phasing
Construction of the proposed project would commence in May 2021 and would last approximately 7 years, ending
in May 2028. Grading of the project site would commence in June 2021 and last approximately 8 months. Building
construction would occur over 6 years and 5 months and would begin in December 2021. Paving would take
approximately 6 months, and architectural coatings would take approximately 6 years and 5 months. The analysis
contained herein is based on the following assumptions (duration of phases is approximate):
• Site Preparation: one month (May 2021 to June 2021)
• Grading: 8 months (June 2021 – February 2022)
• Building construction: 6 years and 5 months (December 2021 to May 2028)
• Paving: 6 months (March 2022 to September 2022)
• Architectural coatings: 6 years and 5 months (December 2021 to May 2028)
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Grading of the project site would require 1,200,000 cubic yards of balanced cut and fill and is expected to occur
over 8 months. The proposed project would involve development of 718 multi-family residential units1 but would be
developed in phases. The phased occupancy of the proposed residential development would begin in 2023 and the
residential development would be fully occupied by 2028.
4.4.8 Project Design Features
4.4.8.1 Air Quality
The following project design features (PDFs) would be implemented as part of the proposed project:
PDF-AQ-1 Fugitive Dust Control. The applicant or its designee shall implement the following measures to
minimize fugitive dust (PM10 and PM2.5):
a. A non-toxic dust control agent shall be used on the grading areas or watering shall be applied
at least three times daily.
b. Grading areas shall be stabilized as quickly as possible.
c. Chemical stabilizer shall be applied, a gravel pad shall be installed, or the last 100 feet of
internal travel path within the construction site shall be paved prior to public road entry and for
all haul roads.
d. Visible track-out into traveled public streets shall be removed with the use of sweepers, water
trucks, or similar method at the end of the workday.
e. All soil disturbance and travel on unpaved surfaces shall be suspended if winds exceed 25 mph.
f. On-site stockpiles of excavated material shall be covered.
g. A 15 mph speed limit on unpaved surfaces shall be enforced.
PDF-AQ-2 Architectural Coating. The applicant or its designee shall use low or no-volatile organic compound
(VOC) architectural coatings.
4.4.8.2 Biological Resources
PDF-BIO-1 Habitat Restoration. The project also proposes habitat restoration efforts (soil salvage, seed
transplant) within appropriate on-site areas proposed, to be added to the City 100% Preserve. To
this end, considerable clay soil exists within the current project development areas and could be
used to develop suitable habitat to support Otay tarplant within an enhanced portion of the on-site
Preserve. This effort would further benefit the Otay tarplant population and native grassland
conservation on site and could also support the goals of the City’s Subarea Plan and the
Conservation Recommendations of the 1995 Biological Opinion (BO).
1 Note that the Air Quality and Greenhouse Gas Emissions Technical Report (Appendix C) assumed 720 proposed residential units
for a conservative analysis.
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4.4.8.3 Noise
PDF-NOI-1 Exterior-to-Interior Noise Analysis. An exterior-to-interior noise analysis shall be conducted by the
project applicant for the proposed dwelling units facing the adjoining roadways (e.g., Olympic
Parkway) prior to issuance of building permits. Installation of mechanical ventilation systems or air
conditioning systems and sound-rated windows shall be required if the predicted interior
background noise due to traffic noise intrusion through the building envelope assemblies exceeds
the state and City 45 dBA CNEL interior standard. The acoustical analysis shall substantiate that
the resulting interior background noise levels, with appropriate implementation of interior comfort
systems and sound insulation, will be less than this noise standard.
4.4.8.4 Transportation
PDF-TRA-1 Trip Reduction Strategies. The strategies outlined below would reduce the number of automobile
trips generated by residents of the project and the distance that the residents drive.
•Provide ride share coordination services thru through the project’s homeowner’s association
to match residents interested in carpooling,
•Coordinate with nearby schools and/or the project’s homeowner’s association to match
residents interested in carpooling to/from schools.
•Provide on-site transit opportunities information.
•Encourage bicycling by providing on-site bicycle infrastructure such as bike racks.
•Implement a multimodal wayfinding signage program
PDF-TRA-2 Adaptive Traffic Signal Control. The project will also contribute its fair share contribution toward the
provision of Adaptive Traffic Signal Control (ATSC) modules to each signalized intersection along
the Olympic Parkway corridor between the I-805 Ramps and La Media Road.
4.5 Discretionary Actions/Approvals
A discretionary action is an action taken by an agency that calls for the exercise of judgment in deciding whether to
approve or how to carry out a project. The following discretionary actions are associated with the proposed project
and would be considered by the City:
•Certification of a Final EIR and adoption of a Mitigation Monitoring and Reporting Program pursuant to CEQA
•Approval of amendments to the General Plan
•Approval of amendments to the GDP
•Approval of amendments to the SPA Plan
•Approval of the Tentative Map for Sunbow II, Phase 3
•Chula Vista MSCP Subarea Plan Boundary Adjustment and Minor Amendment
•Rezone
•Approval of the Development Agreement between the applicant and the City2
2 A Development Agreement between the Applicant and the City of Chula Vista is proposed in conjunction with the proposed project. The
Development Agreement would address the provisions included in the Community Benefit Agreement approved by the Chula Vista City
Council (Resolution No. 2020-003, January 7, 2020). The Development Agreement would also address the project’s Community Purpose
Facility and affordable housing obligations, along with other terms and conditions acceptable to the City of Chula Vista.
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02,0001,000 Feet
Project Boundary
FIGURE 4-1
Project Site
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Exhibit 7a: Modified Public Class III Collector – 55’ ROW (Public)
55-foot Right-of-Way (Public)
61-foot Right-of-Way (Public)
Streets ‘A’ and ‘B’ – Typical Street Sections
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Exhibit 8: Private Neighborhood Collector
Private Residential Streets with parking are planned in the residential neighborhoods and include
two 12-foot travel lanes, 8-foot parallel or 18-foot perpendicular parking lane and a contiguous
sidewalk on one side and a 5-foot landscaped parkway on the opposite side. Refer to Exhibit 9:
Private Residential Street w/Parking.
Private Neighborhood Collector
Private Residential Street w/Parking
Private Residential Streets – Typical Street Sections
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Proposed Water and Recycled Water System
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5 Environmental Impact Analysis
5.1 Aesthetics
This section of the environmental impact report (EIR) describes relevant regulations, policies, and guidelines governing
views and aesthetic considerations relevant to the proposed Sunbow Sectional Planning Area (SPA) Plan Amendment
for the Sunbow II, Phase 3 Project (project or proposed project). As applicable, provisions of view ordinances, design
guidelines, and general plan and scenic highway plans are summarized. Views of the site from representative public
vantage points such as from scenic roads and regional trails are analyzed. On-site and nearby off-site scenic resources
are also identified. The impact analysis determines whether the proposed project would significantly impact a scenic
vista or visual feature or preclude the ability of the public to view a significant visual feature. In addition, the analysis
addresses the introduction of new sources of lighting into the proposed project site.
5.1.1 Existing Conditions
5.1.1.1 Regulatory Framework
State
California Scenic Highway Program
The California Scenic Highway Program was created in 1963 with the intent “to protect and enhance the
natural scenic beauty of California highways and adjacent corridors, through special conse rvation treatment.”
The state laws that govern the Scenic Highway Program are Sections 260 through 263 of the Streets and
Highways Code. A highway may be designated scenic based on the natural landscape visible by travelers, the
scenic quality of the lands cape, and the extent to which development intrudes upon the views of the highway.
The Scenic Highway Program includes both officially designated scenic highways and highways that are eligible
for designation. It is the responsibility of local jurisdictions to apply for scenic highway approval, which requires
the adoption of a Corridor P rotection Program (Caltrans 2020 ). In addition, once a scenic highway is
designated, the local jurisdiction is responsible for regulating development within the scenic highwa y corridor.
There is no designated or eligible state Scenic Highway within the project site.
Local
County of San Diego Light Pollution Code
The County of San Diego (County) Code of Regulatory Ordinances Section 59.101 through 59.115 (Light Pollution
Code) was adopted for the purposes of minimizing light pollution for the public enjoyment of the dark sky
environment and to protect astronomical research at the Palomar and Mount Laguna observatories. The Light
Pollution Code contains restrictions regarding the type of outdoor light fixtures that may operate on private property
and designates all lands into one of two zones (Zone A or Zone B). Zone A has more stringent lighting regulations
than Zone B and includes all areas within a 15-mile radius of the Palomar or Mount Laguna observatory. Zone B
includes all other lands located outside of the 15-mile radius. The proposed project is located within Zone B (County
of San Diego 2009).
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City of Chula Vista Design Manual
The City of Chula Vista’s Design Manual (City of Chula Vista 2011) provides a set of guidelines in conjunction with
development standards to assist the City of Chula Vista (City) in achieving a high quality of aesthetic and functional
design. The City’s Design Manual includes guidelines for multi-family residential developments, which would apply
to the proposed project. These guidelines focus on site planning, architecture, and landscaping. With regard to
aesthetics, guidelines for building bulk, scale, materials, colors, and lighting are provided. Consistent with the City’s
Design Manual, the proposed Sunbow II, Phase 3 SPA Amendment for the proposed project also includes
development regulations and design guidelines. Specifically, the Sunbow II Phase 3 SPA Amendment includes
guidelines for architecture, site planning and building plotting, pedestrian connectivity, and landscaping.
City of Chula Vista General Plan
The City of Chula Vista General Plan contains objectives and policies to preserve and enhance aesthetic resources.
Specifically, the Land Use and Transportation Element includes policies that strive to continue to protect the open
space network and design policies for features such as view, entryways, gateways, streetscapes, buildings, parks ,
and plazas. The General Plan identifies valued scenic vistas and open space throughout the City as discussed under
the Scenic Resources and Scenic Vistas subheading in this section (City of Chula Vista 2005). Olympic Parkway is
designated a scenic roadway in the General Plan.
Land Use and Transportation Element
The General Plan includes the following objectives and policies relevant to the proposed project with regard to aesthetics:
• Objective LUT 7. Appropriate transitions should be provided between land uses.
• Policy LUT 7.4. Require landscape and/or open space buffers to maintain a naturalized or softer edge for
proposed private development directly adjacent to natural and public open space areas.
• Objective LUT 13. Preserve scenic resources in Chula Vista, maintain the City's open space network, and
promote beautification of the City.
• Policy LUT 13.1. Identify and protect important public viewpoints and viewsheds throughout the Planning
Area, including features within and outside the planning area, such as: mountain; native habitat areas; San
Diego Bay; and historic resources.
• Policy LUT 13.4 Any discretionary projects proposed adjacent to scenic routes, with the exception of
individual single-family dwellings, shall be subject to design review to ensure that the design of the
development proposal will enhance the scenic quality of the route. Review should include site design,
architectural design, height, landscaping, signage, and utilities. Development adjacent to designated scenic
routes should be designed to:
o Create substantial open areas adjacent to scenic routes through clustering development;
o Create a pleasing streetscape through landscaping and varied building setbacks; and
o Coordinate signage, graphics and/or signage requirements, and standards.
Scenic Resources and Scenic Vistas
The General Plan identifies significant scenic resources and open space that help to define various area’s visual
and community character within the City. Scenic vistas and open space identified in the General Plan include the
Otay River and Sweetwater River Valleys; Upper and Lower Otay Lakes; Sweetwater Reservoir; San Miguel/Mother
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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. The Greenbelt includes Multiple Species Conservation Program (MSCP) Preserve lands, general
open space, and existing and future trails, and connects several of the City’s existing and future public parks.
Additional natural open space areas within the City are identified in General Plan Figure 5-5, Open Space Network.
The closest identified scenic vista and open space area to the project site is the Otay River Valley located
approximately 1 mile south of the project site. The project site is also identified as part of the City’s open space
network but is not part of the City’s Greenbelt (City of Chula Vista 2005).
Gateways
The General Plan identifies entryways and gateways that offer opportunities to improve the City’s appearance and
establish a community image through special design treatments such as signage, landscape, and architectural
design enhancements. The City designates both Primary and Secondary Gateways. Primary Gateways are from
freeways and should appear visually inviting, provide adequate direction to places of interest, and have high quality
design features. Primary Gateways near the project site include Olympic Parkway from Interstate (I) 805 to
Brandywine Avenue. There are no Secondary Gateways on or near the project site (City of Chula Vista 2005).
City-Designated Scenic Roadways
The City has designated several Scenic Roadways for their views of natural features and roadway characteristics,
including enhanced landscaping, adjoining natural slopes, or special design features (City of Chula Vista 2005).
Existing City-designated Scenic Roadways in the project area include Olympic Parkway adjacent to the northern
boundary of the project site.
Sunbow General Development Plan
The Sunbow General Development Plan (GDP), which originally included 604.8 acres in eastern Chula Vista, was
adopted on December 5, 1989, with the primary objective to create an efficient, self-contained village with a mix of
residential, commercial, community recreation, industrial park, and open space/trails land uses. The purpose of
the GDP was to develop an efficient self-contained village that would set the framework for a socially, economically,
and environmentally sound urban community. The GDP also contains landscape and design guidelines for the
various land uses (City of Chula Vista 1989).
The GDP is implemented through the adoption of a subsequent, more detailed Sunbow Sectional Planning Area
(SPA) Plan, tentative tract maps, and potential annexation and development agreements. The GDP is designed to
function as a policy bridge between the City of Chula Vista General Plan (General Plan) and the SPA Plan, which
provides more detailed plans for development of the Sunbow Master Planned Community . Specifically, the GDP
includes general standards for building height and bulk, architectural design review, landscaping, and development
conformance with locally designated scenic routes. More specific provisions for each planning area are identified
in the SPA Plan (City of Chula Vista 1990).
Sunbow Sectional Planning Area Plan
The SPA Plan was approved by the City Council on February 20, 1990. According to the City, GDPs are implemented
through the adoption of SPA Plans, which are more detailed in its zoning, design regulations, and development
parameters. The purpose of the SPA Plan is to assure high quality development, create an economically viable plan,
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provide a plan for long-range development, facilitate provisions for community facilities, preserve open space, and
establish a planning and development framework. Regulations within the SPA Plan supersede other regulations where
there is potential conflict between the GDP and the General Plan. The SPA Plan also contains more specific landscaping,
design, lighting, and aesthetics standards for the various land uses established in the GDP (City of Chula Vista 1990).
City of Chula Vista Municipal Code
Title 19 of the City of Chula Vista Municipal Code (CVMC) is the City’s Zoning Code, which is intended to implement the
General Plan. The Eastern Planning Area, which includes the project site, is designated as, a Planned Community (P-C)
Zone (City of Chula Vista 2020). As defined in Chapter 19.48 of the CVMC, the purposes of the P-C zone are as follows:
• Provide for the orderly preplanning and long-term development of large tracts of land. These tracts may
contain a variety of land uses, but are under unified ownership or development control, so that the entire
tract will provide an environment of stable and desirable character.
• Give the developer reasonable assurance that sectional development plans in accordance with the
approved general development plan will be acceptable to the City. Sectional development plans may
include subdivision plans and/or planned unit development plans as provided in this title.
• Enable the City to adopt measures for the development of the surrounding area compatible with the
planned community zone.
According to Section 19.48.020 of the Zoning Code, P-C zoning may be established on lands that are suitable and
of sufficient size for planning and development in a manner consistent with the purpose of the zone. P-C zoning
does not include any area of less than 50 acres of contiguous land. Section 19.48.025 establishes a requirement
for Community-Purpose Facility (CPF) sites to be provided within the P-C zone at the rate of 1.39 acres per 1,000
persons. Section 19.48.090 establishes requirements for sectional planning areas.
The City also regulates signage through the CVMC, Chapter 19.60, Signs. Among other things, the purpose of the
Sign Ordinance is “to balance the public interests in community aesthetics against the signage needs of
establishments and persons who wish to express information or a message by displaying a sign” (CVMC, Chapter
19.60). In addition, the Sign Ordinance is intended to improve the visua l environment for residents and visitors of
the City and protect prominent viewsheds. There are specific standards for “sensitive” zones, such as agricultural,
residential estates, and other residential zones (CVMC, Chapter 19.60).
Light and glare are regulated by Chapter 17.28 and Section 19.66.100 of the CVMC, respectively. Chapter 17.28,
Unnecessary Lights, is intended to prevent lighting from creating a nuisance by regulating the use of lighting in and
around residential areas. Although lighting can be used to improve the aesthetics of a residential property, this
chapter ensures that such lighting is properly controlled and doesn’t create a nuisance. The ordinance recognizes
that lighting is widely used in commercial or industrial zones for the purpose of advertising and security and that
such lighting is essential to the conduct of many commercial or industrial enterprises. The ordinance requires light
shielding on commercial and industrial lighting near residences; prohibits residential lighting that spills over to
adjacent properties during nighttime hours; and requires multi -family residential, commercial, and industrial
developments to submit lighting plans to the City. Lighting from any use that is unshielded or so directed as to focus
the beams directly upon adjacent residential property is prohibited at all times.
Section 19.66.100, Glare, prohibits direct or sky-reflected glare from floodlights and high-temperature processes
that produce glare that is visible at the points of measurement as specified in Section 19.66.060, Locations where
determinations are to be made. In any district except the Industrial zone, the point of measurement is at the lot line
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of the establishment or use. Within the Industrial zone it is 500 feet from the establishment or use or at any point
within an adjacent zone other than an Industrial zone.
5.1.1.2 Visual Resources Components
The characterization of existing visual resources and available scenic vistas on the project site and the surrounding
areas form the basis of this aesthetics and views analysis. Aesthetics refers to visual qualities within a given field
of view and may include such considerations as size, shape, color, texture, and general composition, as well as the
relationships between these elements.
Aesthetic features often consist of unique or prominent natural or man-made attributes or several small features that,
when viewed together, create a whole that is visually interesting or appealing. Views refer to visual access to aesthetic
features. Viewsheds, or the extent of a given view, are typically defined by landscape elements and building locations.
Existing views may be partially obstructed or entirely blocked by modification of the environment. Conversely,
modifications to the natural or man-made landscape of an area may create or enhance view opportunities.
Light impacts are typically associated with the use of artificial light during the evening and nighttime hours. Artificial
light may be generated from point sources and from indirect sources of reflected light. Uses such as residences,
hospitals, and hotels are considered light sensitive since they are typically occupied by persons who have
expectations for privacy during evening hours and who are subject to disturbance by bright light sources. Wildli fe
habitat areas may also be considered light sensitive if the introduction of light sources would compromise the
quality and function of a habitat area.
Glare is primarily a daytime occurrence caused by the reflection of sunlight or artificial light by highly polished surfaces
such as window glass or reflective materials and, to a lesser degree, from broad expanses of light-colored surfaces.
Daytime glare generation is common in urban areas and is typically associated with mid- to high-rise buildings with
exterior façades largely or entirely composed of highly reflective glass or mirror-like material from which the sun can
reflect at a low angle in the periods following sunrise and prior to sunset. Glare can also be produced during evening and
nighttime hours by the reflection of artificial light sources such as automobile headlights. Glare generation is typically
related to either moving vehicles or sun angles, although glare resulting from reflected sunlight can occur regularly at
certain times of the year. Glare-sensitive uses generally include residences and transportation corridors.
5.1.1.3 Existing Aesthetic Character
On-Site Conditions
Currently, the project site consists of vacant and undeveloped land with various dirt roads traversing the site. Land uses
within the project site are designated in both the General Plan and the GDP. Within the General Plan, the project site is
designated as Limited Industrial and Open Space (City of Chula Vista 2005). Within the GDP, the project site is designated
as Industrial Park and Open Space (City of Chula Vista 1989). The entire project site is composed of approximately 135.7
acres. The GDP designates the approximately 54.7 acres within the southeastern portion of the project site as Industrial
Park area, which was slated in the SPA to include research/development and light industrial uses, with approximately
700,000 square feet of leasable area generating approximately 2,800 employment opportunities (City of Chula Vista
1990). The aesthetic character of the project site is currently defined by the undeveloped, rolling landscape and natively
vegetated hillsides adjacent to Olympic Parkway. The rising topography of the project site prevents expansive southward
views of the site from Olympic Parkway. Thus, the aesthetic character of the project site is primarily defined by the natural
hillsides immediately adjacent to Olympic Parkway.
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Surrounding Land Uses
The project site is surrounded by existing development, including residential land uses, to the north, west, and
southwest. Open space hillsides are present approximately 300–500 feet north of the project site, between Olympic
Parkway and the existing residential land uses. South of the project site is the Otay Landfill and directly east of the
project site is vacant and undeveloped land which is approved for industrial and residential development as part of
Otay Ranch Village Two. The existing undeveloped state of the land to the east within Otay Ranch Village Two is
similar in aesthetic character to the existing project site and open space north of Olympic Parkway.
The greater Eastern Planning Area is topographically similar to the project site, with small hillsides and canyons.
However, much of the Eastern Planning Area has already been developed or is proposed for development as part
of the Sunbow GDP and Otay Ranch GDP. Most undeveloped land similar in aesthetic character to the existing
project site is concentrated in the southern and eastern portions of the Otay Ranch area as part of the City’s
Greenbelt. The project site is not located within or adjacent to the City’s Greenbelt System (City of Chula Vista 2003).
Light and Glare
Two astronomical observatories are located within 50 miles of the project site: Mount Laguna Observatory, loca ted
approximately 38 miles northeast of the project site, and Palomar Mountain Observatory, located approximately 52
miles north of the project site. Both of these observatories use large telescopes and conduct astronomical and
related research. These observatories are located in the unincorporated County of San Diego. Light pollution within
a 15-mile radius of these observatories is strictly controlled through implementation of the County of San Diego’s
Light Pollution Code (Title 5, Division 9), which includes less restrictive measures for areas outside the 15-mile
radius. The project site is outside the jurisdiction of the County; however, the project site is located within Zone B
of the County’s Light Pollution Code, which includes all other lands locate d outside the 15-mile radius (County of
San Diego 2009). In addition, the City’s Unnecessary Lights Ordinance outlines restrictions and limitations on the
use of lighting in or near the residential zones to prevent lighting from creating a nuisance to resi dents. These
lighting restrictions also benefit the observatories (CVMC, Chapter 17.28, Unnecessary Lights).
Currently, the project site is undeveloped and not lit at night. Additionally, the project site does not contain expanses
of material that would result in glare. The City, including the Sunbow area, is urbanized and currently generates
substantial night lighting. The buildings in the surrounding area include windows and other glass or metal expanses
that can result in localized glare. Surrounding residential land uses contain lighting typical of an urban setting,
including but not limited to street lighting and security lighting.
Viewers
Viewer exposure varies depending on several factors including the angle of view (i.e., normal, inferior, or superior
viewing angles); view distance (foreground, middle ground, and background); relationship to sun angle (backlighting
versus front or side lighting); the extent of visibility (i.e., whether views are panoramic or limited by vegetation,
topography, or other land uses); and viewer screening conditions (e.g., whether the project facilities will be skylined
on ridgelines, backscreened by topography and/or vegetation, or screened by structures or vegetation in the
foreground). Viewer exposure also considers the duration of view based on viewer activity (e.g., travel route,
residential, recreation) and often relates to speed of travel (pedestrian, vehicular, or stationary).
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The project site is located south of Olympic Parkway and north of the Otay Landfill. The project site abruptly slopes
southward from Olympic Parkway toward the Otay Landfill, providing limited view opportunities for motorists passing
the project site along Olympic Parkway. Due to the hilly nature of the project site and steep slopes within the
northern portion of the site, views along Olympic Parkway mostly consist of foreground views of the hills immediately
adjacent to Olympic Parkway. The rising topography of the project site also prevents expansive southward views
into the site from Olympic Parkway. The project site is not immediately visible from any public vantage points to
the south, east, or west. East of the City are existing mountainous open space areas which contain public trails that
provide board views of the City. These higher elevation areas (such as the Otay Ranch Mountain Wilderness) are
located approximately 6 miles east of the project site. Therefore, views of the project site would be limited, and not
immediately discernable, due to the distance and highly urbanized character of the surrounding area.
5.1.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to Aesthetics is based on the recommendations
provided in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). A significant impact would occur if the
project would:
A. Have a substantial adverse effect on a scenic vista.
B. Substantially damage scenic resources, including, but not limited to, tress, rock outcroppings, and historic
buildings within a state scenic highway.
C. In non-urbanized areas, substantially degrade the existing visual character or quality of the site and its
surroundings? (Public views are those that are experienced from publicly accessible vantage points). If the project
is in an urbanized area, a significant impact would occur if the project conflicts 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.
5.1.3 Impacts
A. Have a substantial adverse effect on a scenic vista.
As discussed in Section 5.1.1.1, Regulatory Framework, the General Plan identifies the following scenic vistas: Otay
River and Sweetwater River Valleys; Upper and Lower Otay Lakes; Sweetwater Reservoir; San Miguel/Mother Miguel
Mountains; and the San Diego Bay. The closest identified scenic vista to the project site is the Otay River Val ley,
located approximately 1 mile to the south. Additionally, the General Plan identifies the City’s open space network,
which includes both the previously mentioned scenic vistas and more general open space areas considered to be
scenic resources, including the project site. The proposed project would also include 63.6 acres of MSCP Preserve,
which, as part of the City’s open space network, is considered a scenic resource.
Olympic Parkway, which is adjacent to the northern boundary of the project site, currently provides scenic views of
the project site’s existing and proposed open space areas for motorists, bicyclists, and pedestrians. However, view
opportunities of the proposed project’s development area are limited due to the steep slopes within the northern
portion of the site. The project site abruptly slopes from north to south from Olympic Parkway towards the Otay
Landfill. As such, views of the project site experienced by viewers traveling east and west along Olympic Parkway,
located within the northern boundary of the project site, mostly consist of foreground views of the hills immediately
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adjacent to Olympic Parkway, due to the site topography . Under the proposed project, MSCP Preserve lands would
exist between the development area and Olympic Parkway, and in the western portion of the project site, which
would provide a visual buffer for viewers traveling along Olympic Parkway (see Figure 4-4, Proposed SPA Land Use
Plan). Therefore, fleeting glimpses of the proposed project’s development area may be afforded along limited
portions of Olympic Parkway. However, viewers would be oriented in an east –west direction and with the
proposed open space buffer of approximately 500 feet, the proposed project would not have a substantial effect
on views of the City’s open space network.
Viewers traveling along Olympic Parkway would also be afforded views of the access points of proposed Streets ‘A’
and ‘B’ (Streets A and B). However, the proposed project would incorporate landscaping along proposed Streets A
and B as shown in Figure 4-6, Illustrative Concept Plan, to soften views of these driveways for viewers passing by
the project site along Olympic Parkway. Landscaping would exist along both sides of proposed Streets A and B as
well as beyond the MSCP Preserve lands abutting the closest proposed residences. All landscaping will be provided
in accordance with the Sunbow II Phase 3 Landscape Master Plan, prepared for the project, and the City’s
Landscape Manual. Therefore, the access points of proposed Streets A and B would not have a substantial effect
on views of the City’s open space network.
As described above, the closest identified scenic vista to the project site is the Otay River Valley, located 1 mile
south. Due to the existing development between the Otay River Valley and the project site, as well as the distance
from the project site and intervening topography, implementation of the proposed project would not result in
adverse effects on this scenic vista. The open space areas, located approximately 6 miles east of the project site,
also contains General Plan identified scenic vistas including the Lower and Upper Otay Lakes. Additionally, the Otay
Mountain Wilderness contains many trails at higher elevations than the majority of the City, which provide scenic
views for recreationists. Views of the project site from this distance are obscured and not immediately discernable
due to distance and the highly urbanized character of the City.
Development of the proposed project would be substantially similar to the existing surrounding development and
greater Eastern Planning Area within the City. Further, the proposed project would blend with the existing
surroundings, when viewed at a distance. As discussed, the proposed project would not result in adverse effects
on identified scenic vistas including the Otay River Valley or Otay Mountain Wilderness. Additionally, due to proposed
landscaping, the MSCP Preserve open space areas between Olympic Parkway and the development area, and
existing topography of the site and its surroundings, the proposed project would also not result in a substantial
adverse effect on views of the on-site open space, which is identified as a scenic resource as part of the City’s open
space network, but not a scenic vista. Therefore, impacts related to substantial adverse effects on a scenic vista
would be less than significant.
B. Substantially damage scenic resources, including, but not limited to, tress, rock outcroppings, and historic
buildings within a state scenic highway.
According to the Caltrans Scenic Highway Mapping System for San Diego County (Caltrans 2020), there are no officially
designated scenic highways that pass by the project site. The following are the closest designated scenic highways:
• A 2-mile portion of the SR-125 from SR-94 to SR-8 near La Mesa, located approximately 10 miles north of
the project site.
• SR-75, Silver Strand Highway, between Imperial Beach and Coronado, located approximately 6.5 miles west
of the project site.
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The following is the closest eligible scenic highway:
• I-5 from the international border at Tijuana to SR-75, located approximately 4 miles southwest of the project site.
The project site is not located within the vicinity of an officially designated or eligible state scenic highway. Therefore,
implementation of the proposed project would not substantially damage scenic resources within a state scenic
highway. No impact would occur.
For informational purposes, a discussion of locally designated scenic roadways and gateways within the City is
included below.
As outlined in Section 5.1.1.1, the City has designated several Scenic Roadways for their views of natural features
and roadway characteristics, including enhanced landscaping, adjoining natural slopes, or special design features
(City of Chula Vista 2005). Existing City-designated Scenic Roadways in the project area include Olympic Parkway,
located adjacent the northern boundary of the project site. As discussed under Threshold A, views of the proposed
project’s development area from Olympic Parkway would be limited due to the site topography and the proposed
MSCP Preserve which would act as a visual buffer between Olympic Parkway and the closest proposed residential
units. The proposed project would comply with City regulations regarding development along a scenic roadway. The
General Plan identifies primary and secondary gateways which are meant to be visually inviting entryways into the
City. Olympic Parkway from Interstate 805 (I-805) to Brandywine Avenue is a primary gateway identified in the
General Plan. This gateway ends approximately 300 feet west of the project site. Therefore, the special design
treatments used for development along gateways do not apply to the proposed project.
C. In non-urbanized areas, substantially degrade the existing visual character or quality of the site and its surroundings.
(Public views are those that are experienced from publicly accessible vantage points). If the project is in an urbanized
area, would the project conflict with applicable zoning and other regulations governing scenic quality).
CEQA Section 21071 defines an “urbanized area” as “(a) an incorporated city that meets either of the following
criteria: (1) has a population of at least 100,000 persons, or (2) has a population of less than 100,000 persons if
the population of that City and not more than two contiguous incorporated cities combined equals at least 100,000
persons.” As of July 1, 2019, the US Census Bureau estimated the population of the City to be 274,492 persons,
which is well over the 100,000 persons threshold (US Census Bureau 2019). Thus, the City would be considered
an urbanized area per CEQA and the first portion of Aesthetics Threshold C related to changes in the visual
character or quality of public views of the site and its surroundings would not apply to the propos ed project
aesthetics analysis. As such, this analysis focuses on the second portion of CEQA Guidelines Aesthetics Threshold
C, regarding whether the project would conflict with applicable zoning and other regulations governing scenic
quality, for projects in urbanized areas.
Zoning, GDP, and SPA Plan
The project site is designated as a SPA, which is a designation under the Planned Community (P-C) Zone (CVMC,
Chapter 19.60), with specific land use districts designated by the SPA Plan. As discussed in Chapter 4, Project
Description, the proposed project would amend the General Plan to allow for the change in land use from Research
& Limited Industrial to Residential Medium-High and Residential High. Additionally, amendments to the GDP and
SPA Plan as well as a Rezone would be considered by the City in the approval process to allow for project
implementation. The project site would remain designated as a SPA under the existing P-C zoning. However, the
specific zoning districts identified within the GDP and SPA Plan for the Sunbow II, Phase 3 area would be amended
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to allow for the proposed residential, community purpose facility, and open space project components. If approved,
the proposed project would not conflict with the applicable zoning, the GDP, or the SPA Plan, as the GDP and SPA
Plan amendments and Rezone would be approved concurrently with the proposed project.
General Plan
As discussed in Section 5.1.1.1, the General Plan aims to preserve scenic resources and maintain the City’s open
space network. The following policies of the General Plan govern scenic quality throughout the City and would apply
to the proposed project:
• Policy LUT 7.4. Require landscape and/or open space buffers to maintain a naturalized or softer edge for
proposed private development directly adjacent to natural and public open space areas.
• Policy LUT 13.1. Identify and protect important public viewpoints and viewsheds throu ghout the Planning
Area, including features within and outside the planning area, such as: mountain; native habitat areas; San
Diego Bay; and historic resources.
• Policy LUT 13.4. Any discretionary projects proposed adjacent to scenic routes, with the exception of
individual single-family dwellings, shall be subject to design review to ensure that the design of the
development proposal will enhance the scenic quality of the route. Review should include site design,
architectural design, height, landscaping, signage, and utilities. Development adjacent to designated scenic
routes should be designed to:
o Create substantial open areas adjacent to scenic routes through clustering development;
o Create a pleasing streetscape through landscaping and varied building setbacks; and
o Coordinate signage, graphics and/or signage requirements, and standards.
While the project site does not contain any identified important public viewpoints, there is currently native habitat
that provides scenic views for viewers traveling along Olympic Parkway. Further, this native habitat is identified in
the General Plan as part of the City’s open space network, which is a scenic resource. Implementation of the
proposed project would preserve 63.6 acres of the project site as MSCP Preserve, 3.9 acres as Poggi Creek
Conservation Easement, and 18.8 acres as Manufactured Slopes/Basin.
As discussed under Threshold A and consistent with General Plan Policy LUT 13.1, implementation of the proposed
project would not result in substantial adverse effects on a scenic vista, including the existing and proposed open space
lands within the project site which are identified as a scenic resource within the General Plan. Additionally, in compliance
with General Plan Policy LUT 7.4, the proposed project would include landscape and open space buffers between the
proposed project’s development area and MCSP Preserve lands, as shown in Figure 4-2. Finally, due to the steep slopes
in the northern portion of the project site and the proposed open space setback of approximately 500 feet between
Olympic Parkway and the closest proposed residences, views of the proposed project’s development area would be
limited. However, the proposed project would still undergo design review in compliance with General Plan Policy LUT 13.4
because the project site is adjacent to Olympic Parkway, which is a locally designated scenic roadway. Therefore, the
proposed project would not conflict with General Plan policies related to scenic quality.
City Design Manual
The SPA Plan amendment for the proposed project includes residential design guidelines for site planning, architectural
design, height, landscaping, in compliance with the City’s Design Manual, and approved Design Guidelines and P-C
District Regulations for the Sunbow community. The proposed project would be required to comply with these residential
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design guidelines, which are intended to assist the City in achieving a high quality of aesthetic and functional design. For
example, the landscape would transition to a naturalized palette at the project perimeter to blend with the existing native
character of the existing slopes and MSCP Preserve area located along the northern edge of the site and to the west.
Additionally, building heights would be limited to a maximum of 35 feet and the plotting of residential buildings would
focus on creating a cohesive community with green spaces and strong pedestrian connectivity. Finally, the proposed
project would undergo design review in compliance with General Plan Policy LUT 13.4, as previously described. Therefore,
the proposed project would not conflict with the City’s Design Manual.
Conclusion
In summary, the proposed project would not conflict with General Plan policies governing scenic quality or the City’s
Design Manual. Additionally, if approved, the proposed project would not conflict with the applicable zoning as the GDP
and SPA Plan amendments and Rezone would be approved concurrently with the proposed project to allow for the changes
in land use and zoning. Therefore, impacts would be less than significant.
D. Create a new source of substantial light or glare, which would adversely affect day or nighttime views in the area.
The project site is currently undeveloped and there are no existing sources of on-site lighting. Additionally, the
project site does not contain expanses of material that would result in glare. Therefore, development of the
proposed project would introduce new sources of lighting and glare on the project site. Lighting within the project
site would be typical of a residential land use, including street lighting along proposed Streets A and B, as well as
exterior lighting on residences. New sources of glare within the project site would include windows on residences.
As discussed in Section 5.1.1.1, light and glare are regulated by Chapter 17.28 and Section 19.66.100 of the
CVMC, respectively. The proposed project would comply with Chapter 17.28, Unnecessary Lights, of the CVMC,
which prohibits residential lighting that spills over to adjacent properties during nighttime hours and requires multi-
family residential, commercial, and industrial developments to submit lighting plans to the City. The County of San
Diego Light Pollution Code also regulates lighting within the County and the proposed project would be required to
comply with all Zone B lighting standards. Additionally, the proposed project would comply with Section 19.66.100,
Glare, which prohibits direct or sky-reflected glare from floodlights and high-temperature processes that produce
glare that is visible at the points of measurement as specified in the CVMC.
The City, including the GDP area, is urbanized and currently generates substantial night lighting. The buildings in
the surrounding area include windows and other glass o r metal expanses that can result in localized glare.
Surrounding residential land uses contain lighting typical of an urban setting, including but not limited to, street
lighting and security lighting. While the proposed project would result in new sources of light and glare, these would
be similar to the surrounding land uses. Furthermore, with compliance with the CVMC and County Light Pollution
Ordinance, these new sources of light and glare would not result in adverse day or nighttime views in the area.
Impacts would be less than significant.
5.1.4 Level of Significance Prior to Mitigation
Impacts related to aesthetics would be less than significant.
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5.1.5 Mitigation Measures
No mitigation measures would be required.
5.1.6 Level of Significance After Mitigation
No mitigation measures would be required. Impacts related to aesthetics would be less than significant.
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5.2 Air Quality
This section of the environmental impact report (EIR) addresses potential impacts to air quality resulting from the
Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II, Phase 3 Project (project or proposed
project). The discussion in this section is based on the Air Quality and Greenhouse Gas Emissions Technical Report
prepared for the project by Dudek. The complete report is contained in Appendix C of this EIR. The complete Health
Risk Assessment (HRA) Report and Nuisance Analysis are included as Appendices B and D of the Air Quality and
Greenhouse Gas Emissions Technical Report
5.2.1 Existing Conditions
5.2.1.1 Regulatory Framework
Federal
Criteria Air Pollutants
The federal Clean Air Act (CAA), passed in 1970 and last amended in 1990, forms the basis for the national air
pollution control effort. The U.S. Environmental Protection Agency (EPA) is responsible for implementing most
aspects of the CAA, including the setting of the National Ambient Air Quality Standards (NAAQS) for major air
pollutants, hazardous air pollutant (HAP) standards, approval of state attainment plans, motor vehicle emission
standards, stationary source emission standards and permits, acid rain control measures, stratospheric ozone
(O3) protection, and enforcement provisions.
Under the CAA, NAAQS are established for the following criteria pollutants: O3, carbon monoxide (CO), nitrogen
dioxide (NO2), sulfur dioxide (SO2), particulate matter with an aerodynamic diameter less than or equal to 10
microns (coarse particulate matter, or PM10), particulate matter with an aerodynamic diameter less than or equal
to 2.5 microns (fine particulate matter, or PM2.5), and lead. The NAAQS describe acceptable air quality conditions
designed to protect the health and welfare of the citizens of the nation. The CAA requires EPA to reassess the NAAQS
at least every 5 years to determine whether adopted standards are adequate to protect public health based on
current scientific evidence. States with areas that exceed the NAAQS must prepare a State Implementation Plan
(SIP) that demonstrates how those areas will attain the standards within mandated time frames.
Hazardous Air Pollutants
The 1977, federal CAA amendments required EPA to identify national emission standards for hazardous air
pollutants (HAPs) to protect public health and welfare. HAPs include certain volatile organic chemicals, pesticides,
herbicides, and radionuclides that present a tangible hazard, based on scientific studies of exposure to humans
and other mammals. Under the 1990 CAA amendments, which expanded the control program for HAPs, 189
substances and chemical families were identified as HAPs.
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State
Criteria Air Pollutants
The federal CAA delegates the regulation of air pollution control and the enforcement of the NAAQS to the states.
In California, the task of air quality management and regulation has been legislatively granted to the California Air
Resources Board (CARB), with subsidiary responsibilities assigned to air quality management districts and air
pollution control districts at the regional and county levels. CARB, which became part of the California
Environmental Protection Agency in 1991, is responsible for ensuring implementation of the California CAA of
1988, responding to the CAA and regulating emissions from motor vehicles and consumer products.
CARB has established California Ambient Air Quality Standards (CAAQS), which are generally more restrictive than
the NAAQS. The CAAQS describe adverse conditions; that is, pollution levels must be below these standards before
a basin can attain the standard. Air quality is considered “in attainment” if pollutant levels are continuously below
the CAAQS and violate the standards no more than once each year. The CAAQS for O3, CO, SO2 (1-hour and 24-
hour), NO2, PM10, PM2.5, and visibility-reducing particles are values that are not to be exceeded. All others are not
to be equaled or exceeded. The NAAQS and CAAQS are presented in Table 5.2-1.
Table 5.2-1. Ambient Air Quality Standards
Pollutant Averaging Time
California Standardsa National Standardsb
Concentrationc Primaryc,d Secondaryc,e
O3 1 hour 0.09 ppm
(180 g/m3)
— Same as Primary
Standardf
8 hours 0.070 ppm
(137 g/m3)
0.070 ppm
(137 g/m3)f
NO2g 1 hour 0.18 ppm
(339 g/m3)
0.100 ppm
(188 g/m3)
Same as Primary
Standard
Annual arithmetic
mean
0.030 ppm
(57 g/m3)
0.053 ppm
(100 g/m3)
CO 1 hour 20 ppm (23 mg/m3) 35 ppm (40 mg/m3) None
8 hours 9.0 ppm (10 mg/m3) 9 ppm (10 mg/m3)
SO2h 1 hour 0.25 ppm
(655 g/m3)
0.075 ppm
(196 g/m3)
—
3 hours — — 0.5 ppm
(1,300 g/m3)
24 hours 0.04 ppm
(105 g/m3)
0.14 ppm
(for certain areas)g
—
Annual — 0.030 ppm
(for certain areas)g
—
PM10i 24 hours 50 g/m3 150 g/m3 Same as Primary
Standard Annual arithmetic
mean
20 g/m3 —
PM2.5i 24 hours — 35 g/m3 Same as Primary
Standard
Annual arithmetic
mean
12 g/m3 12.0 g/m3 15.0 g/m3
Leadj,k 30-day average 1.5 g/m3 — —
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Table 5.2-1. Ambient Air Quality Standards
Pollutant Averaging Time
California Standardsa National Standardsb
Concentrationc Primaryc,d Secondaryc,e
Calendar quarter — 1.5 g/m3 (for certain
areas)k
Same as Primary
Standard
Rolling 3-month
average
— 0.15 g/m3
Hydrogen
sulfide
1 hour 0.03 ppm (42 µg/m3) — —
Vinyl
chloridej
24 hours 0.01 ppm (26 µg/m3) — —
Sulfates 24 hours 25 µg/m3 — —
Visibility
reducing
particles
8 hour (10:00 a.m.
to
6:00 p.m. PST)
Insufficient amount
to produce an
extinction
coefficient of 0.23
per kilometer due
to the number of
particles when the
relative humidity is
less than 70%
— —
Source: Appendix C.
Notes: O3 = ozone; ppm = parts per million by volume; µg/m3 = micrograms per cubic meter; — = no data available; NO2 = nitrogen
dioxide; CO = carbon monoxide; mg/m3 = milligrams per cubic meter; SO2 = sulfur dioxide; PM10 = particulate matter with an
aerodynamic diameter less than or equal to 10 microns; PM2.5 = particulate matter with an aerodynamic diameter less than or equal
to 2.5 microns; PST = Pacific Standard Time.
a California standards for O3, CO, SO2 (1-hour and 24-hour), NO2, suspended particulate matter (PM10, PM2.5), and visibility-reducing
particles are values that are not to be exceeded. All others are not to be equaled or exceeded. CAAQS are listed in the Table of
Standards in Section 70200 of Title 17 of the California Code of Regulations.
b National standards (other than O3, NO2, SO2, particulate matter, and those based on annual averages or annual arithmetic mean)
are not to be exceeded more than once per year. The O3 standard is attained when the fourth-highest 8-hour concentration
measured at each site in a year, averaged over 3 years, is equal to or less than the standard. For PM10, the 24-hour standard is
attained when the expected number of days per calendar year with a 24-hour average concentration above 150 µg/m3 is equal
to or less than 1. For PM2.5, the 24-hour standard is attained when 98% of the daily concentrations, averaged over 3 years, are
equal to or less than the standard.
c Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based on a reference
temperature of 25°C (77°F) and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a
reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles
of pollutant per mole of gas.
d National Primary Standards: The levels of air quality necessary, with an adequate margin of safety, to protect the public hea lth.
e National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known o r anticipated
adverse effects of a pollutant.
f On October 1, 2015, the national 8-hour O3 primary and secondary standards were lowered from 0.075 to 0.070 ppm.
g To attain the national 1-hour standard, the 3-year average of the annual 98th percentile of the 1-hour daily maximum
concentrations at each site must not exceed 100 parts per billion (ppb). Note that the national 1-hour standard is in units of ppb.
California standards are in units of ppm. To directly compare the national 1 -hour standard to the California standards, the units
can be converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 ppm.
h On June 2, 2010, a new 1-hour SO2 standard was established, and the existing 24-hour and annual primary standards were revoked.
To attain the national 1-hour standard, the 3-year average of the annual 99th percentile of the 1-hour daily maximum concentrations
at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until 1 year after an
area is designated for the 2010 standard, except that in areas designated nonattainment of the 1971 standards, the 1971 standards
remain in effect until implementation plans to attain or maintain the 2010 standards are approved.
i On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 μg/m3 to 12.0 μg/m3. The existing
national 24-hour PM2.5 standards (primary and secondary) were retained at 35 μg/m3, as was the annual secondary standard
of15 μg/m3. The existing 24-hour PM10 standards (primary and secondary) of 150 μg/m3 were also retained. The form of the
annual primary and secondary standards is the annual mean averaged over 3 years.
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j The California Air Resources Board has identified lead and vinyl chloride as toxic air contaminants with no threshold level of
exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below
the ambient concentrations specified for these pollutants.
k The national standard for lead was revised on October 15, 2008, to a rolling 3 -month average. The 1978 lead standard (1.5
μg/m3 as a quarterly average) remains in effect until 1 year after an area is designate d for the 2008 standard, except that in
areas designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain
or maintain the 2008 standard are approved.
Toxic Air Contaminants
A toxic air contaminant (TAC) is defined by California law as an air pollutant that may cause or contribute to an
increase in mortality or an increase in serious illness, or which may pose a present or potential hazard to human
health. Federal laws use the HAPs to refer to the same types of compounds that are referred to as TACs under
state law. California regulates TACs primarily through the Tanner Air Toxics Act (AB 1807) and the Air Toxics Hot
Spots Information and Assessment Act of 1987 (AB 2588).
AB 1807 sets forth a formal procedure for CARB to designate substances as TACs. This includes research, public
participation, and scientific peer review before CARB can designate a substance as a TAC. Pursuant to AB 2588,
existing facilities that emit air pollutants above specified levels were required to (1) prepare a TAC emission
inventory plan and report, (2) prepare a risk assessment if TAC emissions were significant, (3) notify the public
of significant risk levels, and (4) if health impacts were above specified levels, prepare and implement risk
reduction measures.
The following regulatory measures pertain to the reduction of diesel particulate matter (DPM) and criteria pollutant
emissions from off-road equipment and diesel-fueled vehicles:
Idling of Commercial Heavy-Duty Trucks (13 CCR 2485)
In July 2004, CARB adopted an Airborne Toxic Control Measure (ATCM) to control emissions from idling trucks. The ATCM
prohibits idling for more than 5 minutes for all commercial trucks with a gross vehicle weight rating over 10,000 pounds.
The ATCM contains an exception that allows trucks to idle while queuing or involved in operational activities.
In-Use Off-Road Diesel-Fueled Fleets (13 CCR 2449 et seq.)
In July 2007, CARB adopted an ATCM for in-use off-road diesel vehicles. This regulation requires that specific fleet
average requirements be met for NOx emissions and for particulate matter emissions. Where average requirements
cannot be met, Best Available Control Technology requirements apply. The regulation also includes several
recordkeeping and reporting requirements.
In response to AB 8 2X, the regulations were revised in July 2009 (effective December 3, 2009) to allow a partial
postponement of the compliance schedule in 2011 and 2012 for existing fleets. On December 17, 2010, CARB
adopted additional revisions to further delay the deadlines, reflecting reductions in diesel emissions due to the poor
economy and overestimates of diesel emissions in California. The revisions delayed the first compliance date until
no earlier than January 1, 2014, for large fleets, with final compliance by January 1, 2023. The compliance dates
for medium fleets were delayed until an initial date of January 1, 2017, and a final compliance date of January 1,
2023. The compliance dates for small fleets were delayed until an initial date of January 1, 2019, and a final
compliance date of January 1, 2028. Correspondingly, the fleet average targets were made more stringent in future
compliance years. The revisions also accelerated the phaseout of equipment with older equipment added to existing
large and medium fleets over time, requiring the addition of Tier 2 or higher engines starting on March 1, 2011,
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with some exceptions: Tier 2 or higher engines on January 1, 2013, without exception; and Tier 3 or higher engines
on January 1, 2018 (January 1, 2023, for small fleets).
On October 28, 2011 (effective December 14, 2011), the Executive Officer approved amendments to the
regulation. The amendments included revisions to the applicability section and additions and revisions to the
definitions. The initial date for requiring the addition of Tier 2 or higher engines for large and medium fleets, with
some exceptions, was revised to January 1, 2012. New provisions also allo w for the removal of emission control
devices for safety or visibility purposes. The regulation also was amended to combine the particulate matter and
NOx fleet average targets under one, instead of two, sections. The amended fleet average targets are based on the
fleet’s NOx average, and the previous section regarding particulate matter performance requirements was deleted
completely. The Best Available Control Technology requirements, if a fleet cannot comply with the fleet average
requirements, were restructured and clarified. Other amendments to the regulations included minor administrative
changes to the regulatory text.
In-Use On-Road Diesel-Fueled Vehicles (13 CCR 2025)
On December 12, 2008, CARB adopted an ATCM to reduce NOx and particulate matter emissions from most in-use
on-road diesel trucks and buses with a gross vehicle weight rating greater than 14,000 pounds. The original ATCM
regulation required fleets of on-road trucks to limit their NOx and particulate matter emissions through a
combination of exhaust retrofit equipment and new vehicles. The regulation limited particulate matter emissions
for most fleets by 2011, and limited NOx emissions for most fleets by 2013. The regulation did not require any
vehicle to be replaced before 2012 and never required that all vehicles in a fleet be replaced.
In December 2009, the CARB Governing Board directed staff to evaluate amendments that would provide additional
flexibility for fleets adversely affected by the poor California economy. On December 17, 2010, CARB revised this
ATCM to delay its implementation along with limited relaxation of its requirements. Starting on January 1, 2015,
lighter trucks with a gross vehicle weight rating of 14,001 to 26,000 pounds with 20-year-old or older engines need
to be replaced with newer trucks (2010 model year emissions equivalent, as defined in the regulation). Trucks with
a gross vehicle weight rating greater than 26,000 pounds with 1995 model year or older engines needed to be
replaced as of January 1, 2015. Trucks with 1996–2006 model year engines must install a Level 3 (85% control)
diesel particulate filter starting on January 1, 2012, to January 1, 2014, depending on the model year, and then
must be replaced after 8 years. Trucks with 2007–2009 model year engines have no requirements until 2023,
at which time they must be replaced with 2010 model year emissions equivalent engines, as defined in the
regulation. Trucks with 2010 model year engines would meet the final compliance requirements. The ATCM
provides a phase- in option under which a fleet operator would equip a percentage of trucks in the fleet with diesel
particulate filters, starting at 30% as of January 1, 2012, with 100% by January 1, 2016. Under each option,
delayed compliance is granted to fleet operators who have complied or will comply with requirements before the
required deadlines.
On September 19, 2011 (effective December 14, 2011), the Executive Officer a pproved amendments to the
regulations, including revisions to the compliance schedule for vehicles with a gross vehicle weight rating of 26,000
pounds or less to clarify that all vehicles must be equipped with 2010 model year emissions equivalent engines by
2023. The amendments included revised and additional credits for fleets that have downsized; implemented early
particulate matter retrofits; incorporated hybrid vehicles, alternative-fueled vehicles, and vehicles with heavy-duty
pilot ignition engines; and implemented early addition of newer vehicles. The amendments included provisions for
additional flexibility, such as for low-usage construction trucks, and revisions to previous exemptions, delays, and
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extensions. Other amendments to the regulations included minor administrative changes to the regulatory text,
including recordkeeping and reporting requirements related to other revisions.
California Health and Safety Code Section 41700
Section 41700 of the California Health and Safety Code states that a person shall not discharge from any source
whatsoever quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance
to any considerable number of persons or to the public, or that endanger the comfort, repose, health, or safety of
any of those persons or the public, or that cause, or have a natural tendency to cause, injury or damage to business
or property. This section also applies to sources of objectionable odors.
Building Energy Efficiency Standards (Title 24, Part 6; Title 24, Part 11)
As required by the 2019 Standards of Part 6 and Part 11 of the Title 24 of the California Code of Regulations, multi-
family residential units are required to install high-efficiency return air filters on all heating, ventilation, and air
conditioning (HVAC) systems. The air filtration system shall reduce at least 90% of particulate matter emissions,
such as can be achieved with a Minimum Efficiency Reporting Value 13 (MERV 13) air filtration system installed on
return vents in residential units.
Local
San Diego Air Pollution Control District
While CARB is responsible for the regulation of mobile emission sources within the state, local air quality
management districts and air pollution control districts are responsible for enforcing standards and regulating
stationary sources. The project site is located within the San Diego Air Basin (SDAB) and is subject to the guidelines
and regulations of the San Diego Air Pollution Control District (SDAPCD).
In the County, O3 and particulate matter are the pollutants of main concern, since exceedances of the CAAQS for
those pollutants are experienced here in most years. For this reason, the SDAB has been designated as a
nonattainment area for the state PM10, PM2.5, and O3 standards. The SDAB is also a federal O3 attainment
(maintenance) area for the 1997 8-hour O3 standard, an O3 nonattainment area for the 2008 8-hour O3 standard,
and a CO maintenance area (western and central part of the SDAB only, including the project site).
Federal Attainment Plans
In December 2016, SDAPCD adopted an update to the Eight-Hour Ozone Attainment Plan for San Diego County
(2008 O3 NAAQS). The Final 2008 Eight-Hour Ozone Attainment Plan for San Diego County (2016 8-Hour O3
Attainment Plan; SDAPCD 2016a) indicates that local controls and state programs would allow the region to reach
attainment of the federal 8-hour O3 standard (1997 O3 NAAQS) by 2018. In this plan, SDAPCD relies on the Regional
Air Quality Strategy (RAQS) to demonstrate how the region will comply with the federal O3 standard. The RAQS details
how the region will manage and reduce O3 precursors (NOx and VOCs) by identifying measures and regulations
intended to reduce these pollutants. The control measures identified in the RAQS generally focus on stationary
sources; however, the emissions inventories and projections in the RAQS address all potential sources, including
those under the authority of CARB and EPA. Incentive programs for reduction of emissions from heavy -duty diesel
vehicles, off-road equipment, and school buses are also established in the RAQS.
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Currently, the County is designated as moderate nonattainment for the 2008 NAAQS and maintenance for the 1997
NAAQS. As documented in the 2016 8-Hour O3 Attainment Plan, the County has a likely chance of obtaining
attainment due to the transition to low-emission cars, stricter new source review rules, and continuing the
requirement of general conformity for military growth and the San Diego International Airport. The County will also
continue emission control measures, including ongoing implementation of existing regulations in O3 precursor
reduction to stationary and area-wide sources, subsequent inspections of facilities and sources, and the adoption
of laws requiring Best Available Retrofit Control Technology for control of emissions (SDAPCD 2016a).
State Attainment Plans
SDAPCD and the San Diego Association of Governments (SANDAG) are responsible for developing and
implementing the clean air plans for attainment and maintenance of the ambient air quality standards in the
SDAB. The RAQS for the SDAB was initially adopted in 1991 and is updated on a triennial basis, most recently in
2016 (SDAPCD 2016b). The RAQS outlines SDAPCD’s plans and control measures designed to attain the CAAQS
for O3. The RAQS relies on information from CARB and SANDAG, including mobile and area source emissions, as
well as information regarding projected growth in the County and the cities in the County, to forecast future
emissions and then determine from that the strategies necessary for the reduction of emissions through
regulatory controls. CARB mobile source emission projections and SANDAG growth projections are based on
population, vehicle trends, and land use plans developed by the County and the cities in the County as part of the
development of their general plans (SANDAG 2017a, 2017b).
In December 2016, SDAPCD adopted the revised RAQS for the County. Since 2007, the San Diego region reduced
daily VOC emissions and NOx emissions by 3.9% and 7.0%, respectively; SDAPCD expects to continue reductions
through 2035 (SDAPCD 2016b). These reductions were achieved through implementation of six VOC control
measures and three NOx control measures adopted in SDAPCD’s 2009 RAQS (SDAPCD 2009a); in addition, the
SDAPCD is considering additional measures, including three VOC measures and four control measures to reduce
0.3 daily tons of VOC and 1.2 daily tons of NOx, provided they are found to be feasible regionwide. In addition,
SDAPCD has implemented nine incentive-based programs, has worked with SANDAG to implement regional
transportation control measures, and has reaffirmed the state emission offset repeal.
In regard to particulate matter emissions reduction efforts, in December 2005, SDAPCD prepared a report titled
“Measures to Reduce Particulate Matter in San Diego County” to address implementation of Senate Bill (SB) 656
in San Diego County (SB 656 required additional controls to reduce ambient concentrations of PM10 and PM2.5)
(SDAPCD 2005). In the report, SDAPCD evaluated implementation of source-control measures that would reduce
particulate matter emissions associated with residential wood combustion; various construction activities including
earthmoving, demolition, and grading; bulk material storage and handling; carryout and trackout removal and
cleanup methods; inactive disturbed land; disturbed open areas; unpaved parking lots/staging areas; unpaved
roads; and windblown dust (SDAPCD 2005).
SDAPCD Rules and Regulations
As stated previously, SDAPCD is responsible for planning, implementing, and enforcing federal and state ambient
standards in the SDAB. The rules and regulations provided in the following paragraphs apply to all sources in the
jurisdiction of SDAPCD and would apply to the project.
SDAPCD Regulation II: Permits; Rule 20.2: New Source Review Non-Major Stationary Sources. Requires new or
modified stationary source units (that are not major stationary sources) with the potential to emit 10 pounds per
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day or more of VOC, NOx, SOx, or PM10 to be equipped with Best Available Control Technology. For those units with
a potential to emit above Air Quality Impact Assessments Trigger Levels, the units must demonstrate that such
emissions would not violate or interfere with the attainment of any national air quality standard (SDAPCD 2016b).
SDAPCD Regulation IV: Prohibitions; Rule 50: Visible Emissions. Prohibits discharge into the atmosphere from any single
source of emissions whatsoever any air contaminant for a period or periods aggregating more than 3 minutes in any
period of 60 consecutive minutes, which is darker in shade than that designated as Number 1 on the Ringelmann Chart,
as published by the U.S. Bureau of Mines, or of such opacity as to obscure an observer’s view to a degree greater than
does smoke of a shade designated as Number 1 on the Ringelmann Chart (SDAPCD 1997).
SDAPCD Regulation IV: Prohibitions; Rule 51: Nuisance. Prohibits the discharge, from any source, of such quantities
of air contaminants or other materials that cause or have a tendency to cause injury, detriment, nuisance,
annoyance to people and/or the public, or damage to any business or property (SDAPCD 1969).
SDAPCD Regulation IV: Prohibitions; Rule 55: Fugitive Dust Control. Regulates fugitive dust emissions from any
commercial construction or demolition activity capable of generating fugitive dust emissions, including active operations,
open storage piles, and inactive disturbed areas, as well as track-out and carry-out onto paved roads beyond a project
area (SDAPCD 2009b).
SDAPCD Regulation IV: Prohibitions; Rule 67.0.1: Architectural Coatings. Requires manufacturers, distributors, and end
users of architectural and industrial maintenance coatings to reduce VOC emissions from the use of these coatings,
primarily by placing limits on the VOC content of various coating categories (SDAPCD 2015). Construction and operation
of the project would include application of architectural coatings (e.g., paint and other finishes), which are subject to
SDAPCD Rule 67.0.1.
SDAPCD Regulation XII: Toxic Air Contaminants; Rule 1200: Toxic Air Contaminants – New Source Review.
Requires new or modified stationary source units with the potential to emit TACs above rule threshold levels to
demonstrate that they will not increase the maximum incremental cancer risk above 1 in 1 million at every receptor
location, or demonstrate that toxics Best Available Control Technology will be employed if maximum incremental
cancer risk is equal to or less than 10 in 1 million, or demonstrate compliance with SDAPCD’s protocol for those
sources with an increase in maximum incremental cancer risk at any receptor location of greater than 10 in 1
million but less than 100 in 1 million (SDAPCD 2017a).
SDAPCD Regulation XII: Toxic Air Contaminants; Rule 1210: Toxic Air Contaminant Public Health Risks – Public
Notification and Risk Reduction. Requires each stationary source required to prepare a public risk assessment to
provide written public notice of risks at or above the following levels: maximum incremental cancer risks equal to
or greater than 10 in 1 million, cancer burden equal to or greater than 1.0, total acute non-cancer health hazard
index equal to or greater than 1.0, or total chronic non-cancer health hazard index equal to or greater than 1.0
(SDAPCD 2017b).
San Diego Association of Governments
SANDAG is the regional planning agency for the County and serves as a forum for regional issues r elating to
transportation, the economy, community development, and the environment. SANDAG serves as the federally
designated metropolitan planning organization for the County. With respect to air quality planning and other regional
issues, SANDAG has prepared San Diego Forward: The Regional Plan (Regional Plan) for the San Diego region
(SANDAG 2015). The Regional Plan combines the big-picture vision for how the region will grow over the next 35
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years with an implementation program to help make that vision a reality. The Regional Plan, including its
Sustainable Communities Strategy (SCS), is built on an integrated set of public policies, strategies, and investments
to maintain, manage, and improve the transportation system so that it meets the diverse needs of the San Diego
region through 2050. The 2019 Federal Regional Transportation Plan builds on the 2015 Regional Plan and
provides updated project costs and revenues and a new regional growth forecast (SANDAG 2020a). Preparation of
the 2021 Regional Plan is currently underway. In fall 2020, key policies and programs to be considered as part of
the vision will be presented to SANDAG policymakers. The draft 2021 Regional Plan and its draft Environmental
Impact Report are expected to be released for public and policymaker review in spring 2021 (SANDAG 2020b).
In regard to air quality, the Regional Plan sets the policy context in which SANDAG participates in and responds to
SDAPCD’s air quality plans and builds off SDAPCD’s air quality plan processes that a re designed to meet health-
based criteria pollutant standards in several ways (SANDAG 2015). First, it complements air quality plans by
providing guidance and incentives for public agencies to consider best practices that support the technology-based
control measures in air quality plans. Second, the Regional Plan emphasizes the need for better coordination of
land use and transportation planning, which heavily influences the emissions inventory from the transportation
sectors of the economy. This also minimizes land use conflicts, such as residential development near freeways,
industrial areas, or other sources of air pollution.
On September 23, 2016, SANDAG’s Board of Directors adopted the final 2016 Regional Transportation Improvement
Program. The 2016 Regional Transportation Improvement Program is a multi-billion-dollar, multi-year program of
proposed projects for major transportation projects in the San Diego region. Transportation projects funded with
federal, state, and TransNet (the San Diego transportation sales tax program) must be included in an approved
regional transportation improvement program. The programming of locally funded projects also may be programmed
at the discretion of the agency. The 2016 Regional Transportation Improvement Program covers five fiscal years and
incrementally implements the Regional Plan (SANDAG 2016).
City of Chula Vista
Chula Vista General Plan
In Chapter 3.1.6, Promoting Clean Air, of the Environmental Element of the Chula Vista General Plan, the City
outlines in the background of air quality in the region and the following objectives and policies related to air quality
(City of Chula Vista 2005):
E6: Improve local air quality and reduce greenhouse gas emissions by minimizing the release of air
pollutants and toxic air contaminants and limiting the exposure of people to such pollutants.
E6A: Explore opportunities for improving indoor air quality.
E6B: Prioritize greening efforts to keep air, water, and land clean.
The following policies related to air quality are found in Section 3.1.6 of the Environmental Element in the Chula
Vista General Plan:
E6.1: Encourage compact development featuring a mix of uses that locate residential areas
within reasonable walking distance to jobs, services, and transit.
E6.2: Promote and facilitate transit system improvements in order to increase transit use and
reduce dependency on the automobile.
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E6.3: Facilitate the use of alternative fuel and low- and zero-emission vehicles and equipment
in the community.
E6.4: Do not site new or re-powered fossil-fueled baseload or peaking-type Electric Generating
Facilities and other major toxic emitters within 1,000 feet of sensitive receptors, or site
sensitive receptors within 1,000 feet of such facilities.
E6.5: Ensure Electrical Generating Facilities incorporate cleaner fuel sources and least polluting
technologies in order to help transition the City to a less fossil fuel dependent future, while
meeting Chula Vista’s energy demand.
E6.6: Explore incentives to promote voluntary air pollutant reductions, including incentives for
developers who go above and beyond applicable requirements and for facilities and
operations that are not otherwise regulated.
E6.7: 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.
E6.9: Discourage the use of landscaping equipment powered by two -stroke gasoline engines
within the City and promote less-polluting alternatives to their use.
E6.10: The siting of new sensitive receivers within 500 feet of highways resulting from development
or redevelopment projects shall require the preparation of a health risk assessment as part of
the CEQA review of the project. Attendant health risks identified in the HRA shall be feasibly
mitigated to the maximum extent practicable, in accordance with CEQA, in order to help ensure
that applicable federal and state standards are not exceeded.
E6.11: Develop strategies to minimize CO hot spots that address all modes of transportation.
E6.12: Promote clean fuel sources that help reduce the exposure of sensitive uses to pollutants.
E6.13: 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.
E6.14: Transition the City fleet to 100% “clean” vehicles by integrating hybrid and alternative fuel
vehicles as current municipal fleet vehicles are replaced
E6.15: Site industries and other stationary emitters in a way that minimizes the potential impacts
of poor air quality on homes, schools, hospitals, and other land uses where people
congregate, and disadvantaged populations.
E6.16: Encourage the use of bicycles through support of bike share opportunities, community bike
programs, and the provision of bicycle parking opportunities such as bike racks and bike lockers.
E6.A.1: Continue to limit exposure to secondhand smoke by encouraging the creation of smoke free
spaces and facilities in public spaces, and at all workplaces and multi-unit housing.
Sunbow Sectional Planning Area Plan
The SPA Plan provides general performance standards, intended to describe the overall minimum design standards
for the Industrial Park area, where the proposed project would be located. The following general performance
standard (City of Chula Vista 1990) pertains to air quality:
K. Air Pollution: There shall be no emission on any site, for more than one minute in any hour, of
air contaminants which, at the emission point or within a reasonable distance of the emission
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point, which is as dark or darker in shade as that designated as No. 1 on the Ringelman Chart
as published in the United States Bureau of Mines Information Circular 7718.
5.2.1.2 Climate and Topography
The project site is located within the SDAB, which is one of 15 air basins that geographically divide California. The SDAB
lies in the southwest portion of California, comprises the entire San Diego region, covers approximately 4,260 square
miles, and is an area of high air pollution potential. The SDAB experiences warm summers, mild winters, infrequent
rainfalls, light winds, and moderate humidity. This usually mild climatological pattern is interrupted infrequently by
periods of extremely hot weather, winter storms, or Santa Ana winds.
The SDAB experiences frequent temperature inversions. Subsidence inversions occur during the warmer months
as descending air associated with the Pacific High Pressure Zone meets cool marine air. The boundary between the
two layers of air creates a temperature inversion that traps pollutants. Another type of inversion, a radiation
inversion, develops on winter nights when air near the ground cools by heat radiation and air aloft remains warm.
The shallow inversion layer formed between these two air masses can trap pollutants. As the pollutants become more
concentrated in the atmosphere, photochemical reactions occur that produce O3, commonly known as smog.
Light daytime winds, predominantly from the west, further aggravate the condition by driving air pollutants inland,
toward the mountains. During the fall and winter, air quality problems are created due to CO and oxides of nitrogen
(NOx) emissions. CO concentrations are generally higher in the morning and late evening. In the morning, CO levels
are elevated due to cold temperatures and the large number of motor vehicles traveling. Higher CO levels during
the late evenings are a result of stagnant atmospheric conditions trapping CO in the area. Since CO is produced
almost entirely from automobiles, the highest CO concentrations in the basin are associated with heavy traffic. NO2
levels are also generally higher during fall and winter days when O3 concentrations are lower.
Under certain conditions, atmospheric oscillation results in the offshore transport of air from the Los Angeles region
to San Diego County (County). This often produces high O3 concentrations, as measured at air pollutant monitoring
stations within the County. The transport of air pollutants from the Los Angeles region to San Diego County has also
occurred within the stable layer of the elevated subsidence inversion, where high levels of O3 are transported.
The local climate in the southern part of the County is characterized as semi-arid with consistently mild, warmer
temperatures throughout the year. The average summertime high temperature in the region is approximately 81°F,
with highs approaching 80°F in August on average, and record highs approaching 104°F in August. The average
wintertime low temperature is approximately 43.8°F, although record lows have approached 32°F in January.
Average precipitation in the local area is approximately 9.7 inches per year, with the bulk of precipitation falling
between December and March (WRCC 2017).
5.2.1.3 Sensitive Receptors
Some land uses are considered more sensitive to changes in air quality than others, depending on the population
groups and the activities involved. People most likely to be affected by air pollution include children, elderly people,
athletes, and people with cardiovascular and chronic respiratory diseases. Facilities and structures where these air
pollution-sensitive people live or spend considerable amounts of time are known as “sensitive receptors.” Land
uses where air-pollution-sensitive individuals are most likely to spend time include schools and schoolyards, parks
and playgrounds, daycare centers, nursing homes, hospitals, and residential communities (sensitive sites or
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sensitive land uses) (CARB 2005). SDAPCD identifies sensitive receptors as those who are especially susceptible to
adverse health effects from exposure to TACs, such as children, elderly people, and ill people. Sensitive receptors
include schools (grades Kindergarten through 12), daycare centers, nursing homes, retirement homes, health clinics,
and hospitals within 2 kilometers (1.2 miles) of the facility (SDAPCD 2019a). The closest sensitive receptors to the
proposed project are existing residences located 1,040 feet north of the project site. The project would also introduce
new on-site sensitive receptors to the area. The new sensitive receptors would be located approximately 100 feet
from the existing Otay Landfill. However, a 50-foot existing slope is currently present between the proposed homes
and the existing Otay Landfill.
5.2.1.4 Pollutants and Effects
Criteria air pollutants are defined as pollutants for which the federal and state governments have established
ambient air quality standards, or criteria, for outdoor concentrations to protect public health. The federal and state
standards have been set, with an adequate margin of safety, at levels above which concentrations could be harmful
to human health and welfare. These standards are designed to protect the most sensitive persons from illness or
discomfort. Pollutants of concern include O3, NO2, CO, SO2, PM10, PM2.5, and lead. These pollutants, as well as toxic
air contaminants (TACs), are discussed in the following paragraphs. In California, sulfates, vinyl chloride, hydrogen
sulfide, and visibility-reducing particles are also regulated as criteria air pollutants.
Criteria Air Pollutants
Ozone. O3 is a strong-smelling, pale blue, reactive, toxic chemical gas consisting of three oxygen atoms. It is a
secondary pollutant formed in the atmosphere by a photochemical process involving the sun’s energy and O3
precursors. These precursors are mainly NOx and volatile organic compounds (VOCs). The maximum effects of
precursor emissions on O3 concentrations usually occur several hours after they are emitted and many miles from
the source. Meteorology and terrain play major roles in O3 formation, and ideal conditions occur during summer
and early autumn on days with low wind speeds or stagnant air, warm temperatures, and cloudless skies. O3 exists
in the upper atmosphere O3 layer (stratospheric ozone) and at the Earth’s surface in the troposphere (ozone)1. The
O3 that the U.S. Environmental Protection Agency (EPA) and the California Air Resources Board (CARB) regulate as
a criteria air pollutant is produced close to the ground level, where people live, exercise, and breathe. Ground-level
O3 is a harmful air pollutant that causes numerous adverse health effects and is thus considered “bad” O3.
Stratospheric, or “good” O3, occurs naturally in the upper atmosphere, where it reduces the amount of ultraviolet
light (i.e., solar radiation) entering the Earth’s atmosphere. Without the protection of the beneficial stratospheric O3
layer, plant and animal life would be seriously harmed.
O3 in the troposphere causes numerous adverse health effects; short-term exposures (lasting for a few hours) to O3 at levels
typically observed in Southern California can result in breathing pattern changes, reduction of breathing capacity, increased
susceptibility to infections, inflammation of the lung tissue, and some immunological changes (EPA 2013). These health
problems are particularly acute in sensitive receptors such as sick people, elderly people, and young children.
Nitrogen Dioxide. NO2 is a brownish, highly reactive gas that is present in all urban atmospheres. The major
mechanism for the formation of NO2 in the atmosphere is the oxidation of the primary air pollutant nitric oxide (NO),
which is a colorless, odorless gas. NOx plays a major role, together with VOCs, in the atmospheric reactions that
produce O3. NOx is formed from fuel combustion under high temperature or pressure. In addition, NOx is an
1 The troposphere is the layer of the Earth’s atmosphere nearest to the surface of the Earth. The troposphere extends outward
about 5 miles at the poles and about 10 miles at the equator.
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important precursor to acid rain and may affect both terrestrial and aquatic ecosystems. The two major emissions
sources are transportation and stationary fuel combustion sources, such as electric utility and industrial boilers.
NO2 can irritate the lungs, cause bronchitis and pneumonia, and lower resistance to respiratory infections (EPA 2016).
Carbon Monoxide. CO is a colorless, odorless gas formed by the incomplete combustion of hydrocarbon or fossil fuels.
CO is emitted almost exclusively from motor vehicles, power plants, refineries, industrial boilers, ships, aircraft, and trains.
In urban areas, such as the project location, automobile exhaust accounts for the majority of CO emissions. CO is a
nonreactive air pollutant that dissipates relatively quickly; therefore, ambient CO concentrations generally follow the
spatial and temporal distributions of vehicular traffic. CO concentrations are influenced by local meteorological
conditions—primarily wind speed, topography, and atmospheric stability. CO from motor vehicle exhaust can become
locally concentrated when surface-based temperature inversions are combined with calm atmospheric conditions, which
is a typical situation at dusk in urban areas from November to February. The highest levels of CO typically occur during
the colder months of the year, when inversion conditions are more frequent.
In terms of adverse health effects, CO competes with oxygen, often replacing it in the blood, reducing the blood’s
ability to transport oxygen to vital organs. The results of excess CO exposure can include dizziness, fatigue, and
impairment of central nervous system functions.
Sulfur Dioxide. SO2 is a colorless, pungent gas formed primarily from incomplete combustion of sulfur-containing
fossil fuels. The main sources of SO2 are coal and oil used in power plants and industries; as such, the highest
levels of SO2 are generally found near large industrial complexes. In recent years, SO2 concentrations have been
reduced by the increasingly stringent controls placed on stationary source emissions of SO2 and limits on the sulfur
content of fuels.
SO2 is an irritant gas that attacks the throat and lungs and can cause acute respiratory symptoms and diminished
ventilator function in children. When combined with particulate matter, SO2 can injure lung tissue, as well as reduce
visibility and the level of sunlight. SO2 can also yellow plant leaves and erode iron and steel.
Particulate Matter. Particulate matter pollution consists of very small liquid and solid particles floating in the air,
which can include smoke, soot, dust, salts, acids, and metals. Particulate matter can form when gases emitted from
industries and motor vehicles undergo chemical reactions in the atmosphere. PM2.5 and PM10 represent fractions
of particulate matter. PM10 consists of particulate matter that is 10 microns or less in diameter and is about 1/7
the thickness of a human hair. Major sources of PM10 include crushing or grinding operations; dust stirred up by
vehicles traveling on roads; wood-burning stoves and fireplaces; dust from construction, landfills, and agriculture;
wildfires and brush/waste burning; industrial sources; windblown dust from open lands; and atmospheric chemical
and photochemical reactions. PM2.5 consists of particulate matter that is 2.5 microns or less in diameter and is
roughly 1/28 the thickness of a human hair. PM2.5 results from fuel combustion (e.g., from motor vehicles and
power generation and industrial facilities), residential fireplaces, and woodstoves. In addition, PM2.5 can be formed
in the atmosphere from gases such as sulfur oxides (SOx), NOx, and VOCs.
PM2.5 and PM10 pose a greater health risk than larger-size particles. When inhaled, these tiny particles can
penetrate the human respiratory system’s natural defenses and damage the respiratory tract. PM2.5 and PM10 can
increase the number and severity of asthma attacks, cause or aggravate bronchitis and other lung diseases, and
reduce the body’s ability to fight infections. Very small particles of substances such as lead, sulfates, and nitrates
can cause lung damage directly or be absorbed into the bloodstream, causing damage elsewhere in the body.
Additionally, these substances can transport absorbed gases such as chlorides or ammonium into the lungs, also
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causing injury. Whereas PM10 tends to collect in the upper portion of the respiratory system, PM2.5 is so tiny that it
can penetrate deeper into the lungs and damage lung tissue. Suspended particulates also damage and discolor
surfaces on which they settle and produce haze and reduce regional visibility.
People with influenza, people with chronic respiratory and cardiovascular diseases, and elderly people may suffer
worsening illness and premature death as a result of breathing particulate matter. People with bronchitis can expect
aggravated symptoms from breathing in particulate matter. Children may experience a decline in lung function due
to breathing in PM10 and PM2.5 (EPA 2009).
Lead. Lead in the atmosphere occurs as particulate matter. Sources of lead include leaded gasoline; the
manufacturing of batteries, paints, ink, ceramics, and ammunition; and secondary lead smelters. Prior to 1978, mobile
emissions were the primary source of atmospheric lead. Between 1978 and 1987, the phaseout of leaded gasoline
reduced the overall inventory of airborne lead by nearly 95%. With the phaseout of leaded gasoline, secondary lead
smelters, battery recycling, and manufacturing facilities are becoming lead-emissions sources of greater concern.
Prolonged exposure to atmospheric lead poses a serious threat to human health. Health effects associated with exposure
to lead include gastrointestinal disturbances, anemia, kidney disease, and in severe cases, neuromuscular and neurological
dysfunction. Of particular concern are low-level lead exposures during infancy and childhood. Such exposures are
associated with decrements in neurobehavioral performance, including intelligence quotient performance, psychomotor
performance, reaction time, and growth. Children are highly susceptible to the effects of lead.
Volatile Organic Compounds. Hydrocarbons are organic gases that are formed from hydrogen and carbon and
sometimes other elements. Hydrocarbons that contribute to formation of O3 are referred to and regulated as VOCs
(also referred to as reactive organic gases). Combustion engine exhaust, oil refineries, and fossil-fuel power plants
are major sources of hydrocarbons. Other sources of hydrocarbons include evaporation from petroleum fuels,
solvents, dry-cleaning solutions, and paint.
The primary health effects of VOCs result from the formation of O3 and its related health effects. High levels of VOCs
in the atmosphere can interfere with oxygen intake by reducing the amount of available oxygen through
displacement. Carcinogenic forms of hydrocarbons, such as benzene, are considered TACs. There are no separate
health standards for VOCs as a group.
Sulfates. Sulfates are the fully oxidized forms of sulfur, which typically occur in combination with metals or hydrogen
ions. Sulfates are produced from reactions of SO2 in the atmosphere. Sulfates can result in respiratory impairment
and reduced visibility.
Vinyl Chloride. Vinyl chloride is a colorless gas with a mild, sweet odor, which has been detected near landfills, sewage
plants, and hazardous waste sites, due to the microbial breakdown of chlorinated solvents. Short-term exposure to
high levels of vinyl chloride in the air can cause nervous system effects such as dizziness, drowsiness, and headaches.
Long-term exposure through inhalation can cause liver damage, including liver cancer.
Hydrogen Sulfide. Hydrogen sulfide is a colorless and flammable gas that has a characteristic odor of rotten eggs.
Sources of hydrogen sulfide include geothermal power plants, petroleum refineries, sewers, and sewage treatment
plants. Exposure to hydrogen sulfide can result in nuisance odors, as well as headaches and breathing difficulties
at higher concentrations.
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Visibility-Reducing Particles. Visibility-reducing particles are any particles in the air that obstruct the range of
visibility. Effects of reduced visibility can include obscuring the viewshed of natural scenery, reducing airport safety,
and discouraging tourism. Sources of visibility-reducing particles are the same as for PM2.5.
Non-Criteria Air Pollutants
Toxic Air Contaminants. A substance is considered toxic if it has the potential to cause adverse health effects in
humans, including increasing the risk of cancer upon exposure, or acute and/or chronic non-cancer health effects.
A toxic substance released into the air is considered a TAC. TACs are identified by federal and state agencies based
on a review of available scientific evidence. In the State of California, TACs are identified through a two-step process
that was established in 1983 under the Toxic Air Contaminant Identification and Control Act. This two-step process
of risk identification and risk management and reduction was designed to protect residents from the health effects
of toxic substances in the air. In addition, the California Air Toxics “Hot Spots” Information and Assessment Act,
Assembly Bill (AB) 2588, was enacted by the legislature in 1987 to address public concern over the release of TACs
into the atmosphere. The law requires facilities emitting toxic substances to provide local air pollution control districts
with information that will allow an assessment of the air toxics problem, identification of air toxics emissions sources,
location of resulting hotspots, notification of the public exposed to significant risk, and development of effective
strategies to reduce potential risks to the public over 5 years.
Examples include certain aromatic and chlorinated hydrocarbons, certain meta ls, and asbestos. TACs are
generated by a number of sources, including stationary sources, such as dry cleaners, gas stations, combustion
sources, and laboratories; mobile sources, such as automobiles; and area sources, such as landfills. Adverse health
effects associated with exposure to TACs may include carcinogenic (i.e., cancer-causing) and non-carcinogenic
effects. Non-carcinogenic effects typically affect one or more target organ systems and may be experienced on
either short-term (acute) or long-term (chronic) exposure to a given TAC.
Diesel Particulate Matter. DPM is part of a complex mixture that makes up diesel exhaust. Diesel exhaust is
composed of two phases, gas and particle, both of which contribute to health risks. More than 90% of DPM is less
than 1 micrometer in diameter (about 1/70th the diameter of a human hair) and, thus, is a subset of PM2.5 (CARB
2016a). DPM is typically composed of carbon particles (“soot,” also called black carbon) and numerous organic
compounds, including more than 40 known cancer-causing organic substances.
Examples of these chemicals include polycyclic aromatic hydrocarbons, benzene, formaldehyde, acetaldehyde,
acrolein, and 1,3-butadiene (CARB 2016a). The CARB classified “particulate emissions from diesel-fueled
engines” (i.e., DPM; 17 CCR 93000) as a TAC in August 1998. DPM is emitted from a broad range of diesel
engines, including on-road diesel engines (trucks, buses, and cars) and off-road diesel engines (locomotives,
marine vessels, and heavy-duty construction equipment, among others). Approximately 70% of all airborne cancer
risk in California is associated with DPM (CARB 2000). To reduce the cancer risk associated with DPM, CARB
adopted a diesel risk reduction plan in 2000 (CARB 2000). Because it is part of PM2.5, DPM also contributes to
the same non-cancer health effects as PM2.5 exposure. These effects include premature death; hospitalizations
and emergency department visits for exacerbated chronic heart and lung disease, including asthma; increased
respiratory symptoms; and decreased lung function in children. Several studies suggest that exposure to DPM
may also facilitate development of new allergies (CARB 2016b). Those most vulnerable to non-cancer health
effects are children, whose lungs are still developing, and elderly people, who often have chronic health problems.
Odorous Compounds. Odors are generally regarded as an annoyance rather than a health hazard. Manifestations
of a person’s reaction to odors can range from psychological (e.g., irritation, anger, or anxiety) to physiological (e.g.,
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circulatory and respiratory effects, nausea, vomiting, and headache). The ability to detect odors varies considerably
among the population and overall is subjective. People may have different reactions to the same odor. An odor that
is offensive to one person may be perfectly acceptable to another (e.g., a coffee roaster). An unfamiliar odor is more
easily detected and is more likely to cause complaints than a familiar one. In a phenomenon known as odor fatigue,
a person can become desensitized to almost any odor, and recognition may only occur with an alteration in the
intensity. The occurrence and severity of odor impacts depend on the nature, frequency, and intensity of the source;
wind speed and direction; and the sensitivity of receptors.
Valley Fever. Coccidioidomycosis, more commonly known as “valley fever,” is an infection caused by inhalation of
the spores of the Coccidioides immitis fungus, which grows in the soils of the southwestern United States. When
fungal spores are present, any activity that disturbs the soil, such as digging, grading, or other earthmoving
operations, can cause the spores to become airborne and thereby increase the risk of exposure. The ecologic
factors that appear to be most conducive to survival and replication of the spores are high summer temperatures,
mild winters, sparse rainfall, and alkaline sandy soils.
Valley fever is not considered highly endemic to San Diego. Per the County Health and Human Services Agency,
the 10-year average (2009–2018) for coccidioidomycosis cases in the County of San Diego is 5.5 cases per
100,000 people per year. The project site is wholly contained within the 91911 zip code. For the 91911 zip code,
there were 113 cases of coccidioidomycosis between 2009 and 2018, which is equivalent to a rate of 13.5 cases
per 100,000 people (Nelson 2019). Statewide incidences in 2018 were 18.8 per 100,000 people (CDPH 2019).
Even if Coccidioides immitis is present at a site, earthmoving activities may not result in increased incidence of
valley fever. Propagation of Coccidioides immitis is dependent on climatic conditions, with the potential for growth
and surface exposure highest following early seasonal rains and long dry spells. Coccidioides immitis spores can
be released when filaments are disturbed by earthmoving activities, although receptors must be exposed to and
inhale the spores to be at increased risk of developing valley fever. Moreover, exposure to Coccidioides immitis
does not guarantee that an individual will become ill—approximately 60% of people exposed to the fungal spores
are asymptomatic and show no signs of an infection (USGS 2000).
5.2.1.5 Local Air Quality
San Diego Air Basin Attainment Designation
Pursuant to the 1990 federal CAA amendments, EPA classifies air basins (or portions thereof) as “attainment” or
“nonattainment” for each criteria air pollutant, based on whether the NAAQS have been achieved. Generally, if the
recorded concentrations of a pollutant are lower than the standard, the area is classified as “attainment” for that
pollutant. If an area exceeds the standard, the area is classified as “nonattainment” for that pollutant. If there is not
enough data available to determine whether the standard is exceeded in an area, the area is designated as
“unclassified” or “unclassifiable.” The designation of “unclassifiable/attainment” means that the area meets the
standard or is expected to be meet the standard despite a lack of monitoring data. Areas that achieve the standards
after a nonattainment designation are re-designated as maintenance areas and must have approved maintenance
plans to ensure continued attainment of the standards. The California CAA, like its federal counterpart, called for the
designation of areas as “attainment” or “nonattainment,” but based on the CAAQS rather than the NAAQS. Table 5.2-2
depicts the current attainment status of the project site with respect to the NAAQS and CAAQS. The attainment
classifications for the criteria pollutants are outlined in Table 5..2--2.
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Table 5.2-2. San Diego Air Basin Attainment Classification
Pollutant
Designation/Classification
National Standards State Standards
Ozone (O3) – 1 hour Attainmenta Nonattainment
O3 (8-hour – 1997)
O3 (8-hour – 2008)
Attainment (maintenance)
Nonattainment (moderate)
Nonattainment
Nitrogen Dioxide (NO2) Unclassifiable/attainment Attainment
Carbon Monoxide (CO) Attainment (maintenance) Attainment
Sulfur Dioxide (SO2)a Attainmentb Attainment
Coarse Particulate Matter (PM10) Unclassifiable/attainment Nonattainment
Fine Particulate Matter (PM2.5) Unclassifiable/attainment Nonattainment
Lead (Pb) Unclassifiable/attainment Attainment
Hydrogen Sulfide No national standard Attainment
Sulfates No national standard Unclassified
Visibility-Reducing Particles No national standard Unclassified
Vinyl Chloride No national standard No designation
Source: Appendix C.
Notes: Attainment = meets the standards; attainment/maintenance = achieve the standards after a nonattainment designation;
nonattainment = does not meet the standards; unclassified or unclassifiable = insufficient data to classify; unclassifiable/a ttainment
= meets the standard or is expected to be meet the standard despite a lack of monitoring data.
If nonattainment for federal standards, a clarifying classification will be provided indicating the severity of the nonattain ment status.
a The federal 1-hour standard of 0.12 parts per million was in effect from 1979 through June 15, 2005. The revoked standard is
referenced here, because it was employed for such a long period and because this benchmark is addressed in State
Implementation Plans.
b EPA retaining current federal standard for SO2 (84 FR 9866–9907).
In summary, the SDAB is designated as an attainment area for the 1997 8-hour O3 NAAQS and as a nonattainment
area for the 2008 8-hour O3 NAAQS. The SDAB is designated as a nonattainment area for O3, PM10, and PM2.5
CAAQS. The portion of the SDAB where the project site is located is designated as attainment or
unclassifiable/unclassified for all other criteria pollutants under the NAAQS and CAAQS.
Local Ambient Air Quality
CARB, air districts, and other agencies monitor ambient air quality at approximately 250 air quality monitoring
stations across the state. Local ambient air quality is monitored by SDAPCD. SDAPCD operates a network of ambient
air monitoring stations throughout the County, which measure ambient concentrations of pollutants and determine
whether the ambient air quality meets the CAAQS and the NAAQS. The nearest SDAPCD-operated monitoring station
is the Chula Vista monitoring station, which is located approximately 2.5 miles nor thwest of the project site. This
monitoring station was used to show the background ambient air quality for O3, PM10, PM2.5, and NO2. The closest
monitoring site that measures CO and SO2 is the First Street monitoring station in El Cajon, which is about 6.8 miles
northeast of the project site. The most recent background ambient air quality data and numbers of days exceeding
the ambient air quality standards from 2016 to 2018 are presented in Table 5.2-3.
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Table 5.2-3. Local Ambient Air Quality Data
Averaging Time Unit
Agency/
Method
Ambient
Air Quality
Standard
Measured Concentration
by Year Exceedances by Year
2016 2017 2018 2016 2017 2018
Ozone (O3) – Chula Vista
Maximum
1-hour
concentration
ppm State 0.09 0.088 0.073 0.085 0 0 0
Maximum
8-hour
concentration
ppm State 0.070 0.066 0.068 0.074 0 0 1
Federal 0.070 0.066 0.068 0.074 0 0 1
Nitrogen Dioxide (NO2) – Chula Vista
Maximum
1-hour
concentration
ppm State 0.18 0.049 0.054 0.057 0 0 0
Federal 0.100 0.049 0.054 0.057 0 0 0
Annual
concentration
ppm State 0.030 0.010 0.009 0.009 — — —
Federal 0.053 0.010 0.009 0.009 — — —
Carbon Monoxide (CO) – El Cajon
Maximum
1-hour
concentration
ppm State 20 — 1.6 1.5 — 0 0
Federal 35 — 1.6 1.5 — 0 0
Maximum
8-hour
concentration
ppm State 9.0 — 1.3 1.4 — 0 0
Federal 9 — 1.3 1.4 — 0 0
Sulfur Dioxide (SO2) – El Cajon
Maximum
1-hour
concentration
ppm Federal 0.075 0.0012 0.0006 0.0010 0 0 0
Maximum
24-hour
concentration
ppm Federal 0.14 0.0004 0.0002 0.0004 0 0 0
Annual
Concentration
ppm Federal 0.030 0.0001 0.0008 0.0001 0 0 0
Coarse Particulate Matter (PM10)a – Chula Vista
Maximum
24-hour
concentration
g/m3 State 50 39.0 45.0 48.0 0.0 (0) 0.0 (0) 0.0 (0)
Federal 150 38.0 46.0 48.0 0.0 (0) 0.0 (0) 0.0 (0)
Annual
Concentration
g/m3 State 20 23.4 19.8 21.8 0.0 (0) 0.0 (0) 0.0 (0)
Fine Particulate Matter (PM2.5)a – Chula Vista
Maximum
24-hour
concentration
g/m3 Federal 35 33.5 23.9 42.7 0 0 1
Annual
concentration
g/m3 State 12 8.4 8.7 9.3 0 0 0
Federal 12 8.4 8.7 9.3 0 0 0
Sources: Appendix C.
Notes: ppm = parts per million; — = no data available; μg/m3 = micrograms per cubic meter.
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Data taken from CARB’s iADAM (http://www.arb.ca.gov/adam) and EPA’s AirData (http://www.epa.gov/airdata/) represent the highest
concentrations experienced over a given year.
Daily exceedances for particulate matter are estimated days because PM10 and PM2.5 are not monitored daily. All other criteria
pollutants did not exceed federal or state standards during the years shown. There is no federal standard for 1 -hour O3, annual PM10,
or 24-hour SO2, nor is there a state 24-hour standard for PM2.5.
Chula Vista monitoring station is at 80 East J Street, Chula Vista, California.
El Cajon monitoring station is at Lexington Elementary School, at 533 First Street, El Cajon, California.
a Measurements of PM10 and PM2.5 are usually collected every 6 days and every 1 to 3 days, respectively. Number of days exceeding the
standards is a mathematical estimate of the number of days concentrations would have been greater than the level of the standard had
each day been monitored. The numbers in parentheses are the measured number of samples that exceeded the standard.
5.2.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to air quality is based on the recommendations
provided in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). A significant impact w ould occur if the
project would:
A. Conflict with or obstruct implementation of the applicable air quality plan.
B. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region
is 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.
Criteria Pollutants
Appendix G of the CEQA Guidelines indicates that, where available, the significance criteria established by the
applicable air quality management district or air pollution control district may be relied on to determine whether
a project would have a significant impact on air quality.
The City evaluates project emissions based on the quantitative emission thresholds established by the South Coast Air
Quality Management District (SCAQMD). SCAQMD sets forth quantitative emission significance thresholds below which
a project would not have a significant impact on ambient air quality. It should be noted that the use of these significance
thresholds is conservative, as SCAQMD’s significance thresholds were originally based on the South Coast Air Basin’s
extreme O3 nonattainment status for the 1-hour NAAQS, whereas the SDAB was designated as an attainment area for
the 1-hour NAAQS. Project-related air quality impacts estimated in this environmental analysis would be considered
significant if any of the applicable significance thresholds presented in Table 5.2-4 are exceeded.
Table 5.2-4. City of Chula Vista Air Quality Significance Thresholds
Pollutant Construction Operation
Criteria Pollutants Mass Daily Thresholds
VOC 75 lb/day 55 lb/day
NOx 100 lb/day 55 lb/day
CO 550 lb/day 550 lb/day
SOx 150 lb/day 150 lb/day
PM10 150 lb/day 150 lb/day
PM2.5 55 lb/day 55 lb/day
Leada 3 lb/day 3 lb/day
Source: Appendix C.
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Notes: VOC = volatile organic compound; lb/day = pounds per day; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur
oxides; PM10 = coarse particulate matter; PM2.5 = fine particulate matter.
GHG emissions thresholds for industrial projects, as added in the March 2015 revision to the SCAQMD Air Quality Significance
Thresholds, were not included in this table, as they will be addressed within the GHG emissions analysis and not the air qual ity study.
a The phaseout of leaded gasoline started in 1976. Since gasoline no longer contains lead, the project is not anticipated to result
in impacts related to lead; therefore, it is not discussed in this analysis.
The thresholds listed in Table 5.2-4 represent screening-level thresholds that can be used to evaluate whether
project-related emissions could cause a significant impact on air quality. Emissions below the screening-level
thresholds would not cause a significant impact. For nonattainment pollutants, if emissions exceed the thresholds
shown in Table 5.2-4, the project could have the potential to result in a cumulatively considerable net increase in
these pollutants and thus could have a significant impact on the ambient air quality.
With respect to odors, SDAPCD Rule 51 (Public Nuisance) prohibits emission of any material that causes nuisance
to a considerable number of persons or endangers the comfort, health, or safety of any person. A project that
proposes a use that would produce objectionable odors would be deemed to have a significant odor impact if it
would affect a considerable number of off-site receptors.
5.2.3 Impacts
A. Conflict with or obstruct implementation of the applicable air quality plan.
As mentioned in Section 5.2.1.1, Regulatory Framework—Local, SDAPCD and SANDAG are responsible for developing
and implementing the clean air plans for attainment and maintenance of the ambient air quality standards in the
basin— specifically, the SIP and the RAQS.2 The federal O3 maintenance plan, which is part of the SIP, was adopted in
2012. The most recent O3 attainment plan was adopted in 2016. The SIP includes a demonstration that current
strategies and tactics will maintain acceptable air quality in the SDAB based on the NAAQS. The RAQS was initially
adopted in 1991 and is updated on a triennial basis (most recently in 2016). The RAQS outlines SDAPCD’s plans and
control measures designed to attain the state air quality standards for O3. The SIP and RAQS rely on information from
CARB and SANDAG, including mobile and area source emissions, as well as information regarding projected growth in
the County as a whole and the cities in the County, to project future emissions and determine the strategies necessary
for the reduction of emissions through regulatory controls. CARB mobile source emission projections and SANDAG
growth projections are based on population, vehicle trends, and land use plans developed by the County and the cities
in the County as part of the development of their general plans.
If a project proposes development that is greater than that anticipated in the local plan and SANDAG’s growth
projections, the project might be in conflict with the SIP and the RAQS and may contribute to a potentially significant
cumulative impact on air quality. The General Plan Land Use Element designates the project site as Limited
Industrial (LI), which is intended for light manufacturing, warehousing, certain public utilities, auto repair, auto
salvage yards, and flexible-use projects that combine these uses with associated office space (City of Chula Vista
2005). Furthermore, the project proposes to redesignate the site from Industrial Park in the Sunbow General
Development Plan (City of Chula Vista 1989) and Sunbow Sectional Planning Area (SPA) Plan (City of Chula Vista
1990) to 718 multi-family residential units3 phased over approximately 7 years. The criteria air pollutant emissions
associated with operation of an Industrial Park land use would be greater than those for multi -family residential
2 For the purpose of this discussion, the relevant federal air quality plan is the 2016 8-Hour O3 Attainment Plan (SDAPCD 2016a).
The RAQS is the applicable plan for purposes of state air quality planning. Both plans reflect growth projections in the SDAB .
3 Note that the Air Quality and Greenhouse Gas Emissions Technical Report (Appendix C) assumed 720 proposed residential units
for a conservative analysis.
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units, particularly since Industrial Park land use generates more truck trips than residential land use. Thus, the
proposed Project would not result in emissions that are not accounted for in the RAQs.
The proposed project would involve development of 718 multi-family residential units but would be developed in
phases: 330 multi-family residential units would be operational in 2024, 165 units would be operational in 2025,
127 units would be operational in 2026, 75 units would be operational in 2027, and 23 units would be operational
in 2028. Based on SANDAG’s Series 13 forecast, the interpolated persons per household ratio in 2028 is 3.224.
Thus, the project would result in 2,315 persons. SANDAG Series 13 estimates the population in the City would grow
from 287,173 in 2020 to 326,625 in 2035. Furthermore, SANDAG Series 13 estimates that housing would increase
from 89,176 units in 2020 to 101,188 units in 2035. Thus, the addition of 330 multi-family residential units in
2024, 165 units in 2025, 127 units in 2026, 75 units in 2027, and 23 units in 2028 would provide balanced and
diverse housing to the City and would provide housing to accommodate the City’s future growth projections.
Therefore, the proposed project would not stimulate population growth or a population concentration or housing
above what is assumed in local and regional land use plans, or projections made by regional planning authorities.
Thus, impacts would be considered less than significant.
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.
Air pollution is largely a cumulative impact. The nonattainment status of regional pollutants is a result of past and
present development, and the SDAPCD develops and implements plans for future attainment of ambient air
quality standards. Based on these considerations, project-level thresholds of significance for criteria pollutants
are relevant in the determination of whether a project’s individual emissions would have a cumulatively significant
impact on air quality.
The SDAB is a nonattainment area for O3 under the NAAQS and CAAQS. The poor air quality in the SDAB is the result
of cumulative emissions from motor vehicles, off-road equipment, commercial and industrial facilities, and other
emission sources. Projects that emit these pollutants or their precursors (i.e., VOCs and NOx for O3) potentially
contribute to poor air quality. In analyzing cumulative impacts from a project, the analysis must specifically evaluate
the project’s contribution to the cumulative increase in pollutants for which the SDAB is designated as
nonattainment for the CAAQS and NAAQS. However, a project would only be considered to have a significant
cumulative impact if the project’s contribution accounts for a significant proportion of the cumulative total
emissions (i.e., it represents a “cumulatively considerable contribution” to the cumulative air quality impact).
Additionally, for the SDAB, the RAQS serves as the long-term regional air quality planning document for the purpose
of assessing cumulative operational emissions in the SDAB to ensure that the SDAB continues to make progress
toward NAAQS and CAAQS attainment status. As such, cumulative projects located in the San Diego region would
have the potential to result in a cumulative impact to air quality if, in combination, they would conflict with or
obstruct implementation of the RAQS. Similarly, individual projects that are inconsistent with the regional planning
documents on which the RAQS is based would have the potential to result in cumulative operational impacts if they
represent development and population increases beyond regional projections.
The SDAB has been designated as a federal nonattainment area for O3 and a state nonattainment area for O3,
PM10, and PM2.5. The nonattainment status is the result of cumulative emissions from all sources of these air
pollutants and their precursors within the SDAB. As discussed previously, the project would not exceed significance
thresholds during construction or operation. As such, the project would result in less-than-significant impacts to air
quality relative to emissions.
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Construction Emissions
Emissions from the construction phase of the project were estimated using the California Emissions Estimator Model
(CalEEMod) Version 2016.3.2 (CAPCOA 2017). For the purposes of modeling, it was assumed that construction of the
project would commence in May 2021 and would last approximately 7 years, ending in May 2028. The analysis
contained herein is based on the assumptions outlined in Section 4.4.7, Construction and Phasing (duration of phases
is approximate), as well as well as other assumptions made for the purposes of modeling, is included in Appendix C.
For this analysis, it was assumed that heavy construction equipment would operate 5 days a week during project
construction. Construction-worker and vendor estimates by construction phase were generated by CalEEMod. As
specified by the applicant, the project would require 1.2 million cubic yards of balanced cut and fill. Additional project-
specific assumptions regarding vehicle trips and construction schedules and phasing—including information
regarding subphases and equipment used during each subphase—are included in Appendix C. In addition, the
following project design features (PDFs) (see Section 4.4.8, Project Design Features, for the full text of the PDFs)
would be implemented as part of the proposed project:
• PDF-AQ-1 (Fugitive Dust Control)
• PDF-AQ-2 (Architectural Coating)
Implementation of the project would generate air pollutant emissions from entrained dust, off-road equipment,
vehicle emissions, and asphalt pavement application. Entrained dust results from the exposure of earth surfaces
to wind from the direct disturbance and movement of soil, resulting in PM10 and PM2.5 emissions. The project is
subject to SDAPCD Rule 55, Fugitive Dust Control (SDAPCD 2009b). This rule requires that the project take steps
to restrict visible emissions of fugitive dust beyond the property line. Compliance with Rule 55 would limit fugitive
dust (PM10 and PM2.5) generated during grading and construction activities. To account for dust control measures
in the calculations, it was assumed that the active sites would be watered at least three times daily, resulting in an
approximately 61% reduction of particulate matter (SCAQMD 2007).
The application of architectural coatings, such as exterior/interior paint and other finishes, would also produce VOC
emissions; however, the contractor is required to utilize architectural coatings in compliance with the requirements
of SDAPCD Rule 67.0.1, Architectural Coatings. This rule requires manufacturers, distributors, and end users of
architectural and industrial maintenance coatings to reduce VOC emissions from the use of these coatings,
primarily by placing limits on the VOC content of various coating categories 50 grams per liter (g/L) for interior
coating, 100 g/L for exterior architectural coating, and exterior architectural coatings and 250 g/L for parking
coating (SDAPCD 2015). Implementation of PDF-AQ-2, outlined in Section 4.4.8, would ensure that the project
would use no-VOC paints; therefore, 5 grams per liter VOC content was assumed for interior and exterior
architectural coating, which would be lower than the VOC content requirements of SDAPCD Rule 67.0.1.
Exhaust from internal combustion engines used by construction equipment and worker vehicles would result in
emissions of VOCs, NOx, CO, SOx, PM10, and PM2.5. The application of asphalt pavement and architectural coatings
would also produce VOC emissions.
Table 5.2-5 shows the estimated maximum daily construction emissions associated with construction of the
project without mitigation. Complete details of the emissions calculations are provided in Appendix C.
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Table 5.2-5. Estimated Maximum Daily Construction Criteria Air Pollutant Emissions
Year
VOC NOx CO SOx PM10 PM2.5
Pounds per Day
2021 11.72 90.76 84.02 0.24 16.53 9.77
2022 10.68 79.77 79.63 0.24 16.01 6.77
2023 6.48 34.76 47.64 0.16 11.17 3.57
2024 6.17 33.31 45.80 0.16 11.07 3.48
2025 5.88 31.86 44.11 0.16 10.97 3.39
2026 5.73 31.50 42.77 0.15 10.97 3.39
2027 5.59 31.16 41.58 0.15 10.97 3.38
2028 5.43 30.87 40.57 0.15 10.96 3.38
Maximum daily emissions 11.72 90.76 84.02 0.24 16.53 9.77
Chula Vista threshold 75 100 550 150 150 55
Threshold exceeded? No No No No No No
Source: Appendix C.
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse
particulate matter; PM2.5 = fine particulate matter.
See Appendix C for complete results.
The values shown are the maximum summer or winter daily emissions results from CalEEMod. Although not considered mitigation,
these emissions reflect CalEEMod “mitigated” output, which accounts for the required compliance with SDAPCD Rule 55 (Fugitive Dust
Control) and use of no-VOC architectural coatings.
As shown in Table 5.2-5, daily construction emissions would not exceed the City’s significance thresholds.
Therefore, impacts during construction would be less than significant.
Operational Emissions
Operation of the project would generate VOC, NOx, CO, SOx, PM10, and PM2.5 emissions from mobile sources, including
vehicle trips; area sources, including the use of consumer products and landscape maintenance equipment; and energy
sources. Pollutant emissions associated with long-term operations were quantified using CalEEMod. Project-generated
mobile source emissions were estimated in CalEEMod based on project-specific trip rates and trip distances. CalEEMod
default values were used to estimate emissions from the project site and energy sources.
Table 5.2-6 presents the maximum daily area, energy, and mobile source emissions associated with operation
(Year 2028) of the project. The values shown are the maximum summer or winter daily emissions results from
CalEEMod. Details of the emission calculations are provided in Appendix C.
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Table 5.2-6. Estimated Maximum Daily Operational Criteria Air Pollutant Emissions
Year
VOC NOx CO SOx PM10 PM2.5
Pounds per Day
Area 18.81 0.68 59.39 <0.01 0.33 0.33
Energy 0.29 2.48 1.06 0.02 0.20 0.20
Mobile 5.93 22.66 57.76 0.22 22.37 6.08
Total 25.03 25.83 118.20 0.24 22.90 6.61
Chula Vista
threshold
55 55 550 150 150 55
Threshold
exceeded?
No No No No No No
Source: Appendix C.
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse
particulate matter; PM2.5 = fine particulate matter.
See Appendix C for complete results.
Columns may not total precisely due to rounding.
The values shown are the maximum summer or winter daily emissions results from CalEEMod. These emissions reflect CalEEMod
“mitigated” output, which accounts for compliance with Rule 67.0.1 (Architectural Coatings).
As shown in Table 5.2-6, the combined daily area, energy, and mobile source emissions would not exceed the City’s
operational thresholds for VOC, NOx, CO, SOx, PM10, and PM2.5. Regarding long-term cumulative operational
emissions in relation to consistency with local air quality plans, the SIP and RAQS serve as the primary air quali ty
planning documents for the state and SDAB, respectively. The SIP and RAQS rely on SANDAG growth projections
based on population, vehicle trends, and land use plans developed by the cities and the County as part of the
development of their general plans. Therefore, projects that propose development that is consistent with the growth
anticipated by local plans would be consistent with the SIP and RAQS and would not be considered to result in
cumulatively considerable impacts from operational emissions. As stated previously, the project would site is
designated as Industrial Park in the Sunbow General Development Plan (City of Chula Vista 1989) and Sunbow SPA
Plan (City of Chula Vista 1990). However, the criteria air pollutant emissions associated with operation of an Industrial
Park land use would be greater than those for multi-family residential units, particularly since Industrial Park land
use generates more truck trips than residential land use. Furthermore, the 718 multi-family residential uses would
provide balanced and diverse housing to the City and would provide housing to accommodate the City’s future
growth projections. As a result, the project would not result in a cumulatively considerable contribution to regional
O3 concentrations or other criteria pollutant emissions. Impacts associated with project -generated operational
criteria air pollutant emissions would be less than significant.
C. Expose sensitive receptors to substantial pollutant concentrations.
Air quality varies as a direct function of the amount of pollutants emitted into the atmosphere, the size and
topography of the air basin, and the prevailing meteorological conditions. Air quality problems arise when the rate
of pollutant emissions exceeds the rate of dispersion. Reduced visibility, eye irritation, and adverse health impacts
on those persons termed sensitive receptors are the most serious hazards of existing air quality conditions in the
area. Some land uses are considered more sensitive to changes in air quality than others, depending on the
population groups and the activities involved. People most likely to be affected by air pollution, as identified by
CARB, include children, elderly people, athletes, and people with cardiovascular and chronic respiratory diseases.
As such, sensitive receptors include residences, schools, playgrounds, childcare centers, athletic facilities, long -
term healthcare facilities, rehabilitation centers, convalescent centers, and retirement homes. The closest sensitive
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receptors to the project site are existing residences adjacent to the western and northern property boundaries.
The project would also introduce new on-site sensitive receptors to the area.
Health Impacts of Toxic Air Contaminants
Incremental cancer risk is the net increased likelihood that a person continuously exposed to concentrations of TACs
resulting from a project over a 9-, 30-, and 70-year exposure period would contract cancer based on the use of standard
OEHHA risk-assessment methodology (OEHHA 2015). In addition, some TACs have non-carcinogenic effects. TACs that
would potentially be emitted during construction activities would be DPM emitted from heavy- duty construction
equipment and heavy-duty trucks. Heavy-duty construction equipment and diesel trucks are subject to CARB ATCMs to
reduce DPM emissions. According to the OEHHA, HRAs should be based on a 30-year exposure duration based on
typical residency period; however, such assessments should be limited to the period/duration of activities associated
with the project (OEHHA 2015). Thus, the duration of proposed construction activities (approximately 7 years) would
only constitute a small percentage of the total long-term exposure period and would not result in exposure of proximate
sensitive receptors to substantial TACs. Furthermore, the closest sensitive receptors to the proposed project site are
existing residences located 1,040 feet north of the project site. The heavy-duty construction equipment is subject to a
CARB ATCM for in-use diesel construction equipment to reduce diesel particulate emissions, and diesel trucks are
subject to a CARB ATCM that limits idling of equipment and trucks during loading and unloading to 5 minutes and
requires that electric auxiliary power units be used whenever possible. Also, construction equipment are subject to
CARB In-Use Off-Road Diesel Regulation that requires specific fleet average requirements be met for particulate matter
emissions, and apply Best Available Control Technology requirements. The future sensitive receptors of the project
would be exposed to the proposed construction activities from each phase of the project. The duration of construction
for each phase of the project would be approximately 7 years and would therefore constitute only a small percentage
of the total long-term exposure period and would not result in exposure of future sensitive receptors of the project.
As required by Policy E 6.10 in the General Plan Environmental Elemen t (City of Chula Vista 2005), the siting of
new sensitive receivers within 500 feet of highways resulting from development or redevelopment projects shall
require the preparation of an HRA as part of the CEQA review of the project. The project residences would be located
approximately 4,600 feet from Interstate 805 (I-805); therefore, the project is not subject to this requirement.
Impacts to sensitive receptors attributed to TACs would be less than significant.
Landfill Health Risk
For informational purposes only, an HRA was performed to estimate the Maximum Individual Cancer Risk, the
Chronic Hazard Index, and the Acute Hazard Index for the residential receptors as a result of emissions impacts
from the Otay Landfill operation on future sensitive receptors of the project.
The Landfill operation TAC emission sources include a diesel grinder generator, landfill gas (LFG) flares, LFG
fugitive emissions, off -road equipment, haul truck travel and idling emissions, and fugitive dust from land fill
operations. This HRA was prepared using information from the Air Toxics Health Risk Assessment for Otay Ranch
Village 3 North (CalRecycle 2020) and the AB 2588 Health Risk Assessment for Otay Landfill (SCS 2016).
Additional Landfill information was ob tained per the public records request to SDAPCD, including the Landfill
permit applications, engineering evaluations, emissions calculations, and past and current permits (Gould
2020a). The Landfill’s LFG-derived TAC emissions were estimated using SDAPCD’s default emission factors, the
U.S. Environmental Protection Agency (EPA) AP-42 emission factors, CARB’s EMFAC2017 emission factors, and
the EPA Landfill Gas Emissions Model (LandGEM), which projected future LFG generation.
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Emission sources associated with operation of the Landfill, including haul vehicles, equipment, and the grinder
generator, are not expected to operate after the landfill reaches capacity, which is expected to occur on February
28, 2030 (CalRecycle 2020). LFG -derived sources, however, are expected to continue operating over the full
exposure duration.
For risk assessment purposes, coarse particulate matter (PM10; particulate matter with an aerodynamic diameter
equal to or less than 10 microns) in diesel exhaust is considered DPM, which is assumed to be originating mainly
from diesel haul trucks traveling on site, truck idling, off-road equipment and the diesel-fueled grinder generator.
Haul truck travel and idling emission rates were obtained from EMFAC2017. The LFG-derived fugitive and flare
TAC emissions were identified from EPA’s AP-42 (EPA 1995). The speciated suspended dust TAC emissions from
haul truck travel on paved and unpaved roads on site were from the soil samples collected for the site (SCS
2013a, 2016). The grinder generator TAC emissions were calculated using the Landfill’s Title V permit (Title V
Permit to Operate Number 971227). The off-road diesel equipment is subject to the Regulation for In-Use Off-
Road Diesel-Fueled Fleets, and the equipment tier standards were updated from the 2013 SCS analysis (SCS
2013a) and assumed to be in compliance with the Medium Fleet Average Best Available Control Technology
(BACT) Requirements (CARB 2018).
As required by the 2019 Title 24 Building Code and the 2019 California Green Building Standards Code
(CALGreen) standards, the project would install MERV 13-rated air filtration on all HVAC systems able to achieve a
90% reduction in particulate matter.4 EPA conducted the National Human Activity Pattern Survey (NHAPS) to study
where people spend their time. The results of the NHAPS showed that on average, people spend 87% of their time
in enclosed buildings and 6% of their time in enclosed vehicles (Kleipeis et al. 2001). This assessment of risk
includes accounting for time spent indoors (87% of the time) as identified in the NHAPS and time spent away from
home as recommended by OEHHA (OEHHA 2015). Accounting for the actual time spent indoors and exposure
related to the residents of the project provides a more realistic exposure scenario from TAC emissions from the
Otay Landfill operation. Detailed HRA methodology, emissions data, and results are provided in Appendix C.
A dispersion modeling analysis of the Landfill operations on the Project site was conducted for this HRA. The air
dispersion modeling methodology was based on the generally accepted modeling practices of SDAPCD (SDAPCD
2019a) and OEHHA (OEHHA 2015). The dispersion modeling was performed using AERMOD, which is the model that
EPA approved for atmospheric dispersion of emissions (EPA 2015). AERMOD is a steady-state Gaussian plume
model that incorporates air dispersion based on planetary boundary layer turbulence structure and scaling
concepts, including treatment of surface and elevated sources, building downwash, and simple and complex
terrain. Principal parameters of AERMOD for the Landfill modeling included the following:
• Dispersion Model: The air dispersion model used was AERMOD Version 19191, with the Lakes
Environmental Software implementation/user interface, AERMOD View Version 9.8.3 (Lakes Environmental
2019). A unit emission rate of 1.0 grams per second (g/s) was applied to each source (i.e., truck idling,
grinder generator, flares). Unit emission rate of 1 g/s was divided by the area of the area source to calculate
the emission rate in units of grams per second per square meter. Furthermore, a unit emission rate was
normalized over the line of adjacent volume sources (i.e., truck travel and equipment operation) for the
AERMOD run to obtain the “Χ/Q” values. Χ/Q is a dispersion factor that is the average effluent concentration
normalized by source strength, and is used as a way to simplify the representation of emissions from many
sources. The maximum concentrations were determined for the 1-hour and period averaging periods.
4 EPA reported that the MERV 13 filters remove 90% of particles ranging from 1 to 10 microns (EPA 2019a).
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• Meteorological Data: AERMOD-specific meteorological data for the Chula Vista air monitoring station (CVA)
used for the dispersion modeling was provided by SDAPCD as the most recent, available, and
representative meteorological data available for the site (Gould 2020b). A 3-year meteorological data set
from 2010 through 2012 was provided by SDAPCD in a preprocessed format suitable for use in AERMOD.
• Urban and Rural Options: Based on the land use procedure, at least 50% of the land use within the
3-kilometer (1.9-mile) radius from the Landfill site is I1 (Heavy Industrial), I2 (Light-Moderate Industrial), C1
(Commercial), R1 (Common Residential), and R2 (Compact Residential). Therefore, the Urban dispersion
option was selected.
• Terrain Characteristics: Digital elevation data were imported into AERMOD and elevations were assigned
to receptors and emission sources, as necessary. Digital elevation data were obtained through the AERMOD
View in the U.S. Geological Survey’s National Elevation Dataset format with a resolution of 1/3 degree
(approximately 10 meters [33 feet]), consistent with the SDAPCD guidance (SDAPCD 2019a). The elevation
of the site is 350 feet (107 meters) above sea level.
• Sensitive Receptors: A 25-meter (82-foot) Cartesian receptor grid was applied across the proposed Project
site to establish the impact area and evaluate locations of maximum health risk impact.
• Source Release Scenario: Consistent with the 2013 and 2016 SCS Engineers analysis (SCS 2013a, 2016)
and the SDAPCD Engineering Evaluation Letter (SDAPCD 2017), the following sources were modeled:
o Flares 1 and 2 were modeled as point sources with 50-foot and 30-foot release height, respectively;
13-foot and 6-foot inside stack diameter, respectively; 1,601°F exit gas temperature; and 2.899-meter
per second (m/s) (or 9.511 feet per second [f/s]) exit gas velocity.
o On-site truck travel was modeled as a line of adjacent volume sources with a plume height and width
of 3 meters (9.8 feet) and release height of 1.5 meters (4.9 feet).
o Unpaved and paved dust from truck travel was modeled as a line of adjacent volume sources with a
plume height of 5.58 meters (18.31 feet), plume width of 8.51 meters (27.92 feet), and release height
of 2.55 meters (8.37 feet).
o Truck idling emissions were modeled as point sources with a release height of 4 meters (13.1 feet); inside
stack diameter of 0.33 feet; 442°F exit gas temperature; and 49.0 m/s (160.8 f/s) exit gas velocity.
o The grinder generator was modeled as a point source with a release height from the ground at 0 meters; inside
stack diameter of 0.33 feet; 1,100°F exit gas temperature; and 0.001 m/s (0.003 f/s) exit gas velocity.
o Off-road equipment was modeled as a line of adjacent volume sources with a plume height and width
of 2.33 meters (7.64 feet) and release height of 5 meters (16 feet).
o Landfill gas fugitive emissions were modeled as an area polygon source with a release height of
0 meters and initial vertical dimension of 0 meters.
o The grinder generator was modeled as a building (50 feet in length, 12 feet in width, and 13.5 feet in
height) to account for the grinder generator point source being affected by building downwash.
As shown in Table 5.2-7, the landfill operation would result in a Residential Maximum Individual Cancer Risk of
7.70 in 1 million, which would be less than the significance threshold of 10 in 1 million. Landfill operation would
result in a Residential Chronic Hazard Index and Acute Hazard Index of 0.244 and 0.080, respectively, which are
below the 1.0 significance threshold. These impact levels would be less than the SDAPCD significance threshold.
Furthermore, following closure of the Otay Landfill in 2030, the cancer risk impact from LFG fugitive and flare
emissions would be reduced to 6.61 in 1 million. In addition, chronic health risk and acute health risk would be
further reduced.
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Table 5.2-7. Landfill Health Risk Assessment Results – Unmitigated
Impact Parameter Units
Project
Impact
CEQA
Threshold Level of Significance
Maximum Individual Cancer Risk –
Residential
Per million 7.70 10 Less than significant
Chronic Hazard Index – Residential Index value 0.244 1.0 Less than significant
Acute Hazard Index -- Residential Index value 0.080 1.0 Less than significant
Source: SDAPCD 2019a.
Notes: CEQA = California Environmental Quality Act.
See Appendix C.
On April 26, 2020, the Otay Landfill submitted an application (proposed Otay Landfill Compostable Materials
Handling Facility, Permit #37-AA-0984) for the addition of up to 200 tons per day of agricultural and food waste
at the organics composting operation within the existing footprint of the Otay Landfill, which represents a 2.5 %
increase in volume allowed to be processed onsite. Based upon the applicant’s environmental analysis (CEQA
Addendum #2, dated September 12, 2019, PDS2019-MUP-76-046W2M3; ER76-18-026B; and CEQA document,
dated October 29, 2020 SCH#96091009-6) there is a decrease in TAC emissions, specifically ammonia
emissions, and no change in vehicular emissions; therefore, the proposed composting operation would most likely
reduce health risk impacts as compared to the existing operation. Furthermore, the composting technology would
implement a Covered Aeriated Static Pile composting system with a GORETM Cover. The composting technology
would reduce volatile organic compound and ammonia emissions by 80% or more and divert methane -forming
organics away from landfill disposal. In addition, the composting operation would divert up to 100 tons per day of
oxidation of organic matter away from landfill disposal, resulting in lower TAC emissions and odors generated
onsite as compared to the existing operation.
Health Impacts of Carbon Monoxide
Mobile-source impacts occur on two basic scales of motion. Regionally, project -related travel will add to regional
trip generation and increase the vehicle miles traveled within the local airshed and the SDAB. Locally, project traffic
will be added to the City’s roadway system. If such traffic occurs during periods of poor atmospheric ventilation,
consists of a large number of vehicles cold-started and operating at pollution-inefficient speeds, and operates on
roadways already crowded with non- project traffic, there is a potential for the formation of microscale CO hotspots
in the area immediately around points of congested traffic. Because of continued improvement in mobile emissions
at a rate faster than the rate of vehicle growth and/or congestion, the potential for CO hotspots in the SDAB is
steadily decreasing.
Projects contributing to adverse traffic impacts may result in the formation of CO hotspots. As the City does not have
CO hotspot guidelines, the County of San Diego’s Guidelines (County of San Diego 2007) CO hotspot screening
guidance was followed to determine whether the project would require a site-specific hotspot analysis. The County
recommends that a quantitative analysis of CO hotspots be performed for intersections that are operating at or
below an LOS of E and that have peak-hour trips exceeding 3,000 trips. The methodology of the CO hotspot analysis is
presented in Appendix C.
The Traffic Impact Analysis prepared for the project (see Section 5.15, Transportation, of this EIR) analyzed Existing
and Existing Plus Cumulative Projects Plus Project Near Term (2024) for nine existing intersections near the
project site. The results of the LOS assessment show that under Existing Plus Project conditions, two of the nine
study intersections are forecast to operate at unacceptable LOS (LOS E or worse) during the peak hours, with a
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volume more than 3,000 trips. As shown in Appendix C of Appendix C, CO Hotspot Analysis, the two key study
intersections according to the criteria above are (1) Olympic Parkway and I-805 Southbound Ramps (LOS F in PM
peak hours) and (2) Olympic Parkway and I-805 Northbound Ramps (LOS F in AM peak hours). The remaining key
intersections are projected to operate at acceptable LOS conditions in the Existing Plus Project scenario.
Based on the CO hotspot screening evaluation (Appendix C of Appendix C), both failing intersections have 10 links
and are signal- controlled intersections. The potential impact of the project on local CO levels was assessed at these
intersections with the Caltrans CL4 interface based on the California LINE Source Dispersion Model (CALINE4),
which allows microscale CO concentrations to be estimated along each roadway corridor or near intersections
(Caltrans 1998a).
The emissions factor represents the weighted average emissions rate of the local County vehicle fleet expressed
in grams per mile per vehicle. Consistent with the traffic scenario, emissions factors for 2024, which is more
conservative than the operational year 2028, were used. Emissions factors were predicted by EMFAC2017 based
on a 5-mile-per-hour average speed for all of the intersections for approach and departure segments. The hourly
traffic volume anticipated to travel on each link, in units of vehicles per hour, was based on information provided
by the traffic consultant (see Section 5.15) and modeling assumptions are outlined in Appendix C of Appendix C.
Four receptor locations were modeled at each intersection to determine CO ambient concentrations. A receptor was
assumed on the sidewalk at each corner of the modeled intersections, to represent the future possibility of
extended outdoor exposure. CO concentrations were modeled at these locations to assess the maximum potential
CO exposure that could occur in 2024. A receptor height of 5.9 feet (1.8 meters) was used in accordance with
Caltrans recommendations for all receptor locations (Caltrans 1998b).
The highest 1-hour measurement in the last 3 years was used as the projected future 1-hour CO background concentration
for the analysis. A CO concentration of 1.6 parts per million by volume (ppm) was recorded in 2017 for the El Cajon
monitoring station in San Diego and was assumed in CALINE4 for 2024 (EPA 2019b). To estimate an 8-hour average CO
concentration, a persistence factor of 0.70 was applied to the output values of predicted concentrations in ppm at each
of the receptor locations. Model input and output data are available in Appendix C of Appendix C.
The maximum CO concentration predicted for the 1-hour averaging period at the studied intersections would be 1.7
ppm, which is below the 1-hour CO CAAQS of 20 ppm (CARB 2014). The maximum predicted 8-hour CO
concentration of 1.37 ppm at the studied intersections would be below the 8-hour CO CAAQS of 9.0 ppm (CARB
2016b). Neither the 1-hour nor the 8-hour CAAQS would be equaled or exceeded at any of the intersections studied.
Accordingly, the project would not cause or contribute to violations of the CAAQS and would not result in exposure
of sensitive receptors to localized high concentrations of CO. CO tends to be a localized impact associated with
congested intersections. Therefore, the project’s CO emissions would not contribute to significant health effects
associated with this pollutant. As such, project operation would result in a less-than-significant impact to air quality
with regard to potential CO hotspots.
Health Impacts of Other Criteria Air Pollutants
Construction and operation of the project would not result in emissions that exceed the City’s emission thresholds
for any criteria air pollutants.
Some VOCs are associated with motor vehicles and construction equipment, while others are associated with
architectural coatings, the emissions of which would not result in the exceedances of SDAPCD’s thresholds.
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Generally, the VOCs in architectural coatings are of relatively low toxicity. Additionally, SDAPCD Rule 67.0.1 restricts
the VOC content of coatings for both construction and operational applications. Furthermore, with implementation
of PDF-AQ-2, outlined in Section 4.4.8, the project would use no-VOC paints.
In addition, VOCs and NOx are precursors to O3, for which the SDAB is designated as nonattainment with respect to
the NAAQS and CAAQS (the SDAB is designated by EPA as an attainment area for the 1 -hour O3 NAAQS and the
1997 8-hour NAAQS). The health effects associated with O3, as discussed in Section 5.2.1.4, Pollutants and Effects,
are generally associated with reduced lung function. The contribution of VOCs and NOx to regional ambient O3
concentrations is the result of complex photochemistry. The increases in O3 concentrations in the SDAB due to O3
precursor emissions tend to be found downwind from the source location to allow time for the photochemical
reactions to occur. However, the potential for exacerbating excessive O3 concentrations would also depend on the
time of year that the VOC emissions would occur, because exceedances of the O3 NAAQS and CAAQS tend to occur
between April and October when solar radiation is highest.
The holistic effect of a single project’s emissions of O3 precursors is speculative due to the lack of quantitative
methods to assess this impact. Nonetheless, the VOC and NOx emissions associated with project construction and
operations could minimally contribute to regional O3 concentrations and the associated health impacts. Due to the
minimal contribution during construction and operation, as well as the existing good air quality in coastal San Diego
areas, health impacts of other criteria air pollutants would be considered less than significant.
Regarding NO2, according to the construction emissions analysis, construction of the proposed project would not
contribute to exceedances of the NAAQS and CAAQS for NO2. As described in Section 5.2.1.4, NO2 and NOx health
impacts are associated with respiratory irritation, which may be experienced by nearby receptors during the periods
of heaviest use of off-road construction equipment. However, these construction activities would be relatively short
term. Additionally, off-road construction equipment would operate at various portions of the site and would not be
concentrated in one portion of the site at any one time. Construction of the proposed project would not require any
stationary emission sources that would create substantial localized NOx impacts.
The VOC and NOx emissions, as described previously, would minimally contribute to regional O3 concentrations and its
associated health effects. In addition to O3, NOx emissions would not contribute to potential exceedances of the NAAQS
and CAAQS for NO2. As shown in Table 5.2-3, the existing NO2 concentrations in the area are well below the NAAQS and
CAAQS standards. Thus, it is not expected that the project’s operational NOx emissions would result in exceedances of
the NO2 standards or contribute to the associated health effects. CO tends to be a localized impact associated with
congested intersections. The associated CO hotspots were discussed previously as a less-than- significant impact. Thus,
the proposed project’s CO emissions would not contribute to significant health effects associated with this pollutant.
PM10 and PM2.5 emissions from the proposed project would not contribute to potential exceedances of the NAAQS and
CAAQS for particulate matter, would not obstruct the SDAB from coming into attainment for these pollutants, and would
not contribute to significant health effects associated with particulates.
Based on the preceding considerations, health impacts associated with criteria air pollutants would be considered
less than significant.
Valley Fever Exposure
As discussed in Section 5.2.1.4, valley fever is not highly endemic to San Diego, and within the County, the
incidence rate in the project area is below the County average and the statewide average. Construction of the
project would incorporate PDF-AQ-1 (see Section 4.4.8) and comply with SDAPCD Rule 55, which limits the amount
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of fugitive dust generated during construction. Strategies the project would implement to comply with SDAPCD
Rule 55 and control dust include watering three times per day, using magnesium chloride for dust suppression on
unpaved roads, and limiting speed on unpaved roads to 15 mph.
Based on the low incidence rate of coccidioidomycosis in the County and the project’s implementation of dust
control strategies, it is not anticipated that earthmoving activities during project construction would result in
exposure of nearby sensitive receptors to valley fever. Therefore, the project would have a less-than-significant
impact with respect to valley fever exposure for sensitive receptors.
D. Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.
The State of California Health and Safety Code, Division 26, Part 4, Chapter 3, Section 41700 and SDAPCD Rule
51, commonly referred to as public nuisance law, prohibits emissions from any source whatsoever in suc h
quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance to the public
health or damage to property. Projects required to obtain permits from SDAPCD are evaluated by SDAPCD staff
for potential odor nuisance, and conditions may be applied (or control equipment required) where necessary to
prevent occurrence of public nuisance.
Section 19.66.090, Odors, of the Chula Vista Municipal Code (CVMC) requires that no emission shall be permitted
of odorous gases or other odorous matter in such quantities as to be readily detectable at the points of
measurement specified in CVMC Section 19.66.060(A). Any process that may involve the creation or emission of
any odors shall be provided with an adequate secondary safeguard system of control, so that control will be
maintained if the primary safeguard system should fail (City of Chula Vista 1969). SDAPCD Rule 51 (Public
Nuisance) also prohibits emission of any material that causes nuisance to a considerable number of persons or
endangers the comfort, health, or safety of any person. A project that proposes a use that would produce
objectionable odors would be deemed to have a significant odor impact if it would affect a considerable number
of off-site receptors. Odor issues are very subjective by the nature of odors themselves and due to the fact that
their measurements are difficult to quantify. As a result, this guideline is qualitative and will focus on the existing
and potential surrounding uses and the location of sensitive receptors.
Odors are generally regarded as an annoyance rather than a health hazard. Manifestations of a person’s reaction
to odors can range from psychological (e.g., irritation, anger, or anxiety) to physiological (e.g., circulatory and
respiratory effects, nausea, vomiting, and headache) (US Army Corps of Engineers 2006). The ability to detect odors
varies considerably among the population and overall is subjective. People may have different reactions to the
same odor. An odor that is offensive to one person may be perfectly acceptable to another (e.g., a coffee roaster).
An unfamiliar odor is more easily detected and is more likely to cause complaints than a familiar one. In a
phenomenon known as odor fatigue, a person can become desensitized to almost any odor, and recognition may
only occur with an alteration in the intensity. The occurrence and severity of odor impacts depend on the nature,
frequency, and intensity of the source; wind speed and direction; and the sensitivity of receptors.
Characterization of odor emissions and quantitative determination of off-site impacts is a complex problem due to
the often variable nature of emissions, changing source conditions and characteristics, and the subjective nature
of perceived impacts (US Army Corps of Engineers 2006). Odors can exist at one concentration and not be offensive,
but offensive odors are usually noticed even at minute concentrations. It is these odor events that heighten the
public’s awareness of an odor and hence the sensitivity, resulting in complaints.
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Most odorous chemicals generated by biogenic processes are ammonia based or contain sulfur. Historically, odor
panels have been used to determine the “strength” of an odor by a dilution to sensory threshold method (i.e. h ow
many parts of odor per unit of air could be detected). This gives some information about the severity of an odor, but
does not identify the individual chemical species responsible for the odor.
Construction
Odors would be potentially generated from vehicles and equipment exhaust emissions during construction of the
project. Potential odors produced during construction would be attributable to concentrations of unburned
hydrocarbons from tailpipes of construction equipment, architectural coatings, and asphalt pavement application.
Such odors would disperse rapidly from the project site and generally would occur at magnitudes that would not
affect substantial numbers of people. Therefore, impacts associated with odors during construction would be less
than significant.
Operation
Land uses and industrial operations associated with odor complaints include agricultural uses, wastewater
treatment plants, food-processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass
molding facilities (SCAQMD 1993). The project does not include any of the land uses typically associated with odor
complaints. Therefore, project operations would result in an odor impact that would be less than significant.
Odors Associated with Existing Landfill
A nuisance analysis was prepared for the project to evaluate the potential impacts of odors and fugitive dust emitted from
the Otay Landfill on future residents of the project.
LFG-derived odorous chemicals emitted from the Landfill were identified using EPA’s Compilation of Air Pollutant
Emission Factors (AP-42) (EPA 1995) and include TACs identified in the Village 3 North HRA and Nuisance Study
conducted by SCS Engineers (SCS) in October 2013 (SCS 2013a, 2013b). Every TAC listed for landfills in AP-42 was
included in the assessment. Landfill surface emissions were calculated using the estimated LFG generation rate
and the concentration of each chemical in the LFG. No recent LFG analysis was available to provide site -specific
TAC concentrations. The first choice for the concentration for each TAC was the Waste Industry Air Coalition (WIAC)
Comparison of Recent Landfill Gas Analyses with Historic AP-42 Defaults. If the chemical was not included in the
WIAC comparison, the AP-42 default concentration was used. All generated LFG not destroyed in the flare and
engines were assumed to be emitted through the landfill surface and were included in this odor analysis. This odor
analysis does not include DPM, metals found in soils at the Landfill, and crystalline silica, which are not odorous
chemicals and/or do not produce odors characteristic of landfills.
The potential odor for each LFG-derived chemical was determined by comparing the concentration of the chemical
emitted from the Landfill to the published odor threshold. The odor threshold concentration represents the odor
concentration that is detected by 50% of population. Nuisance levels typically occur at concentrations that are
several multiples higher than the ODT (Kern County 2017). Thus, using the ODT as a threshold for nuisance should
be overly conservative and is the approach taken in evaluating the model results. Individuals may be more o r less
sensitive to specific chemicals than the odor threshold. The odor threshold was typically obtained from Safety Data
Sheets. Details of the odor thresholds and LFG concentrations can be found in the complete nuisance analysis is
provided in Appendix D of Appendix C.
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Dust emissions were estimated from both combustion sources and fugitive sources at the Landfill. The combustion
sources include vehicles and heavy-duty equipment. Fugitive sources include vehicle travel on paved and unpaved
roads. Emission calculations were based on activity data from the 2013 HRA and nuisance analysis prepared by
SCS (SCS 2013a, 2013b), permitting information for the Landfill (SDAPCD 2019b), and updated emission factors
from the SDAPCD, CARB, and EPA. Detailed emission calculations and summary of dust sources are found in
Appendix D of Appendix C.
A dispersion modeling analysis was conducted for odorous TACs and dust emissions from the Landfill. Two separate
model runs were conducted, one for each analysis (odor and dust). The dispersion modeling was performed using
AERMOD, which is the model that EPA approved and SDAPCD recommends for atmospheric dispersion of
emissions. AERMOD is a steady-state Gaussian plume model that incorporates air dispersion based on planeta ry
boundary layer turbulence structure and scaling concepts, including treatment of surface and elevated sources,
building downwash, and simple and complex terrain. Principal parameters of AERMOD for the project operations
included the following:
• Dispersion Model: The air dispersion model used was AERMOD, Version 19191, with the Lakes
Environmental Software implementation/user interface, AERMOD View, Version 9.8.3. The emission rate
for the odor analysis was determined in accordance with the D/T for each odor source. Similarly, the
emission rate for the dust analysis utilized source-specific fugitive dust emission rates. The maximum
concentrations were determined for the 1-hour, 8-hour, and period-averaging periods. Detailed source
parameters for modeling emissions with AERMOD can be found within Appendix B. Source parameters were
based on information contained within the SCS analysis (SCS 2013a), the 2016 AB2588 HRA for the
Landfill (SCS 2016), and current permits for the Landfill (SDAPCD 2019b).
• Meteorological Data: AERMOD-specific meteorological data for CVA was used for the dispersion modeling
which was provided by SDAPCD as the most recent, available, and representative meteorological data
available for the site. A 3-year meteorological data set from 2010 through 2012 was provided by the
SDAPCD in a preprocessed format suitable for use in AERMOD.
• Urban and Rural Options: Typically, urban areas have more surface roughness and structures and low-
albedo surfaces that absorb more sunlight, and thus, more heat, relative to rural areas. Based on the land
use procedure, at least 50% of the land use within the 3-kilometer radius from the Landfill site is I1 (Heavy
Industrial), I2 (Light-Moderate Industrial), C1 (Commercial), R1 (Common Residential), and R2 (Compact
Residential). The urban dispersion option was selected based on the application of the land use procedure.
• Terrain Characteristics: Digital elevation model files were imported into AERMOD so that complex terrain
features were evaluated as appropriate. The National Elevation Dataset (NED) dataset with resolution of
1/3 arc-second was used.
• Sensitive Receptors: A uniform Cartesian grid 25-meter spacing was created to cover the entire Project site.
The grid was then converted into discrete Cartesian receptors.
• Source Release Scenario: Based on the Landfill operation schedule of 8 hours per day, 6 days per week,
the variable emission factor of 4.5 was applied to off-road equipment and the grinder generator. Based on
the haul truck schedule of 11 hours per day, 6 days per week, the variable emission factor of 3.27 was
applied to haul trucks exhaust, dust from roads, and idling.
• Buildings: The grinder was also modeled as a building to account for downwash from that source. No other
buildings were included.
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The results of the odor analysis are shown in Table 5.2-8. The maximally exposed receptor would be the
southeastern corner of the project site. The normalized results in Table 5.2-8 represent the concentration at the
maximally exposed receptor compared to the mixture ODT. Odor indices greater than one (1.0) indicate a greater
than 50% likelihood that odor would be detected and indices less than one (1.0) indicates less than 50% likelihood
that odor would be detected. Values that are lower than 1.0 are less than the ODT, and values greater than 1.0
exceed the ODT and are thus more likely to be detected as odor.
Table 5.2-8. Summary of Odor Analysis
Receptor Type UTME (m) UTMN (m) Odor Index
MEIR 498962.5 3607637.5 0.068
Notes: m = meters; MEIR = maximally exposed individual resident; UTME = Universal Transverse Mercator East; UTMN = Universal
Transverse Mercator North.
See Appendix D of Appendix C.
As shown in Table 4, the odor index for the Project site at the maximally exposed resident was less than 1.0.
Therefore, odors are not likely to be detected by future residents at the Project site.
The results of the dust analysis are presented in Table 5.2 -9. The threshold is based on the time-waited value for
the PEL for PMOC established by the Cal-OSHA. As such, emissions over the 8-hour averaging time are appropriate
to compare to the PEL. However, for information purposes the 1-hour averaging time results are also shown.
Table 5.2-9. Dust Analysis
Averaging Period Concentration (ppm) Threshold (ppm)
8-hour 0.05 10
1-hour 0.18 NA
Notes: ppm = parts per million; NA = not applicable.
See Appendix D of Appendix C.
As shown in Table 5.2-9, the results of the dust analysis would not exceed the 8-hour threshold established by the
Cal-OSHA. Therefore, the Landfill is not expected to cause a nuisance at the project site residential receptors based
on the dust emitted during operations.
As discussed above, on April 26, 2020, the Otay Landfill submitted an application (proposed Otay Landfill
Compostable Materials Handling Facility, Permit #37-AA-0984) for the addition of up to 200 tons per day of
agricultural and food waste at the organics composting operation within the existing footprint of the Otay Landfill,
which represents a 2.5% increase in volume allowed to be processed onsite. Based upon the applicant’s
environmental analysis (CEQA Addendum #2, dated September 12, 2019, PDS2019 -MUP-76-046W2M3; ER76-
18-026B; and CEQA document, dated October 29, 2020 SCH#96091009-6) there is a decrease in TAC emissions,
specifically ammonia emissions, and no change in vehicular emissions; therefore, the proposed composting
operation would most likely reduce odor levels as compared to the existing operation. Furthermore, the composting
technology would implement a Covered Aeriated Static Pile composting system with a GORETM Cover. The
composting technology would reduce volatile organic compound and ammonia emissions by 80% or more, reduce
odor units by 56%-80%, and divert methane-forming organics away from landfill disposal. In addition, the
composting operation would divert up to 100 tons per day of oxidation of organic matter away from landfill disposal,
resulting in lower ammonia emissions and odors generated onsite as compared to the existing opera tion.
Furthermore, the Otay Landfill would implement an Odor Impact Minimization Plan that identifies the sources of
odor and management techniques to minimize odors.
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It should be noted that the Landfill is anticipated to cease operations in 2030 according to its current permit. At
that time, emissions of equipment, trucks, and working face fugitive emissions would cease. As such, emissions of
odorous compounds and dust emissions would be significantly be reduced upon closure of the landfill. As such,
impacts from odor and dust to future residents from landfill operations would be less than significant.
5.2.4 Level of Significance Prior to Mitigation
The proposed project would have a less-than-significant impact on air quality.
5.2.5 Mitigation Measures
No mitigation measures would be required.
5.2.6 Level of Significance After Mitigation
No mitigation measures would be required. Impacts to air quality would be less than significant.
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5.3 Biological Resources
This section of the environmental impact report (EIR) describes the existing biological resources within the proposed
Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II, Phase 3 Project (project or proposed
project) site, analyzes the potential environmental effects of the proposed project, and recommends mitigation
measures to reduce or avoid significant effects. Findings are based on the Biological Impact Analysis Report for the
Sunbow II Phase 3 Plan Amendment, City of Chula Vista, California (Biological Impact Analysis Report), prepared by
Merkel & Associates, and the Functional Equivalency Analysis for a Multiple Species Conservation Program (MSCP)
Boundary Line Adjustment and Facilities Siting Criteria Report for the proposed project, prepared by Merkel &
Associates (Functional Equivalency Analysis Report). Both of the reports are included in Appendix D of this EIR.
5.3.1 Existing Conditions
5.3.1.1 Regulatory Framework
Federal
Federal Endangered Species Act
The federal Endangered Species Act of 1973 (ESA), as amended (16 USC 1531 et seq.), provides for listing of
endangered and threatened species of plants and animals and designation of critical habitat for listed animal
species. The ESA also prohibits all persons subject to U.S. jurisdiction from “taking” endangered species, which
includes any harm or harassment. Section 7 of the ESA requires that federal agencies, prior to project approval,
consult the U.S. Fish and Wildlife Service (USFWS) and/or the National Marine Fisheries Service (NMFS) to ensure
adequate protection of listed species that may be affected by the project.
Migratory Bird Treaty Act
The Migratory Bird Treaty Act (MBTA) (16 USC 703 et seq.) is a federal statute that implements treaties with several
countries on the conservation and protection of migratory birds. The list of bird species covered by the MBTA is
extensive and is detailed in 50 CFR 10.13. The regulatory definition of “migratory bird” is broad and includes any
mutation or hybrid of a listed species, including any part, egg, or nest of such a bird (50 CFR 10.12). Migratory birds
are not necessarily federally listed endangered or threatened birds under the ESA. The MBTA, which is enforced by
USFWS, makes it unlawful “by any means or in any manner, to pursue, hunt, take, capture, [or] kill” any migrato ry
bird or attempt such actions, except as permitted by regulation. The applicable regulations prohibit the take,
possession, import, export, transport, sale, purchase, barter, or offering of these activities, except under a valid
permit or as permitted in the implementing regulations (50 CFR 21.11). It is important to note that “take” as defined
under the federal MBTA is not synonymous with “take” as defined under the federal ESA. The MBTA definition of
“take” lacks a “harm and harassment” clause comparable to “take” under the ESA, thus, the MBTA authority does
not extend to activities beyond the nests, eggs, feathers, or specific bird parts. Clean Water Act
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The federal Water Pollution Control Act Amendments of 1972 (Clean Water Act; 33 USC 1251 et seq.), as amended
by the Water Quality Act of 1987 (PL 1000-4), is the major federal legislation governing water quality. The purpose
of the Clean Water Act is to “restore and maintain the chemical, physical, and biological integrity of the nation’s
waters.” Discharges into waters of the United States are regulated under Section 404. Waters of the United States
include (1) all navigable waters (including all waters subject to the ebb and flow of tides); (2) all interstate waters
and wetlands; (3) all other waters, such as intrastate lakes, rivers, streams (including intermittent streams),
mudflats, sand flats, wetlands, sloughs, or natural ponds; (4) all impoundments of waters mentioned above; (5) all
tributaries to waters mentioned above; (6) the territorial seas; and (7) all wetlands adjacent to waters mentioned
above. In California, the State Water Resources Control Board (SWRCB) and the nine Regional Water Quality Control
Boards (RWQCBs) are responsible for implementing the Clean Water Act. Important applicable sections of the Clean
Water Act are discussed below:
• Section 303 requires states to develop water quality standards for inland surface and ocean waters
and submit to the EPA for approval. Under Section 303(d), the state is required to list waters that do
not meet water quality standards and to develop action plans, called total maximum daily loads, to
improve water quality.
• Section 304 provides for water quality standards, criteria, and guidelines.
• Section 401 requires an applicant for any federal permit that proposes an activity that may result in a
discharge to waters of the United States to obtain certification from the state that the discharge would
comply with other provisions of the Clean Water Act. Certification is provided by the respective RWQCB.
• Section 402 establishes the National Pollutant Discharge Elimination System (NPDES), a permitting system
for the discharge of any pollutant (except for dredge or fill material) into waters of the United States. The
NPDES program is administered by the RWQCB. Conformance with Section 402 is typically addressed in
conjunction with water quality certification under Section 401.
• Section 404 provides for issuance of dredge/fill permits by the U.S. Army Corps of Engineers (ACOE).
Permits typically include conditions to minimize impacts on water quality. Common conditions include (1)
ACOE review and approval of sediment quality analysis before dredging, (2) a detailed pre- and post-
construction monitoring plan that includes disposal site monitoring, and (3) required compensation for loss
of waters of the United States.
U.S. Army Corps of Engineers
The ACOE has primary federal responsibility for administering regulations that concern waters and wetlands in the
project site. In this regard, ACOE acts under two statutory authorities, the Rivers and Harbors Act (33 USC, Sections
9 and 10), which governs specified activities in navigable waters, and the Clean Water Act (Section 404), which
governs specified activities in waters of the United States, including wetlands and special aquatic sites. Wetlands
and non-wetland waters, e.g., rivers, streams, and natural ponds, are a subset of waters of the United States and
receive protection under Section 404 of the Clean Water Act. The ACOE has primary federal responsibility for
administering regulations that concern waters and wetlands in the project area under statutory authority of the
Clean Water Act (Section 404). In addition, the regulations and policies of various federal agencies mandate that
the filling of wetlands be avoided to the extent feasible. The ACOE requires obtaining a permit if a project proposes
placing structures within navigable waters and/or alteration of waters of the United States.
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State
California Endangered Species Act
Similar to the federal ESA, the California ESA of 1970 provides protection to species considered threatened or
endangered by the State of California (California Fish and Game Code, Section 2050 et seq.). The California ESA
recognizes the importance of threatened and endangered fish, wildlife, and plant species and their habitats, and
prohibits the taking of any endangered, threatened, or rare plant and/or animal specie s unless specifically
permitted for education or management purposes.
California Fish and Game Code
The California Fish and Game Code regulates the handling and management of the state’s fish and wildlife.
Most of the code is administered or enforced by th e California Department of Fish and Wildlife (CDFW). One
section of the code generally applies to public infrastructure projects such as the proposed project . as noted
in the following paragraph.
Section 1602 regulates activities that would divert or obstruct the natural flow or substantially change the bed,
channel, or bank of any river, stream, or lake that supports fish or wildlife. CDFW has jurisdiction over riparian
habitats associated with watercourses. Jurisdictional waters are delineated by the outer edge of riparian vegetation
or at the top of the bank of streams or lakes, whichever is wider. CDFW jurisdiction does not include tidal areas or
isolated resources.
Sections 3503, 3503.5, and 3513 of the California Fish and Game Code prohibit the “take, possession, or
destruction of bird nests or eggs.” Section 3503 states: “It is unlawful to take, possess, or needlessly destroy the
nest or eggs of any bird, except as otherwise provided by this code or any regulation made pursuant thereto.”
Section 3513 states: “It is unlawful to take or possess any migratory nongame bird as designated in the MBTA or
any part of such migratory nongame bird except as provided by rules and regulations adopted by the Secretary of
the Interior under provisions of the Migratory Bird Treaty Act.”
Porter-Cologne Water Quality Act
The Porter-Cologne Water Quality Act of 1969, updated in 2012 (California Water Code, Section 13000 et seq.),
provides for statewide coordination of water quality regulations. The act established the Cali fornia SWRCB as the
statewide authority, and nine separate RWQCBs were developed to oversee water quality on a day -to-day basis.
Local
City of Chula Vista Multiple Species Conservation Program Subarea Plan
The MSCP Subarea Plan is implemented through individual Subarea Plans adopted by each jurisdiction receiving
Take authorization for Covered Species. The Chula Vista MSCP Subarea Plan was approved by the City of Chula
Vista (City) in May 2003 and received take authorization in January 2005. The Subarea Plan provides for
conservation of upland habitats and species through Preserve design, regulation of impacts and uses, and
management of the Preserve. The MSCP Subregional Plan, dated August 1998, under the Natural Community
Conservation Planning Act of 1991, was prepared for 12 local San Diego jurisdictions including the City of Chula
Vista, and is to be implemented through MSCP Subarea Plans. Subarea Plans approved under the Natural
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Community Conservation Planning Act would allow “take” of various sensitive species through specific conditions
of coverage pursuant to Section 4(d) of the federal Endangered Species Act. The City has an adopted MSCP Subarea
Plan (City of Chula Vista 2003) and the Habitat Loss and Incidental Take (HLIT) Ordinance (City of Chula Vista 2005,
updated 2019) regulates the implementation of the Subarea Plan.
The western half of the proposed project site and much of the northern edges along Poggi Creek are designated
within the Chula Vista MSCP Subarea Plan as 100% Conservation Area- Habitat Preserve (referred to as “Preserve”),
while the eastern half of the site is designated Development Area outside of Covered Projects (Figure 5.3-1, Local
Environmental Setting Map).
The terms and conditions from the 1995 Biological Opinion (BO) for the project, as well as conservation
recommendations as outlined below, would be applied to the proposed project where applicable (i.e., Diegan
coastal sage scrub). However, the MSCP Subarea Plan and HLIT requirements would be applied to the remainder
of the project elements.
A BO is a USFWS document that states the opinion of the USFWS as to whether the federal action is likely to jeopardize
the continued existence of listed species or result in the destruction or adverse modification of critical habitat.
The proposed project is part of the larger Sunbow Development (710 acres), which consists of the 108‐acre Sunbow
I residential development approved in a 1987 EIR (ERC Environmental and Energy Services Co.) and the 602 ‐acre
Sunbow II development consisting of Phases 1 and 2 (residential, commercial, open space) and a portion of Phase
3 (business park, open space) that was approved in a 1989 EIR/1990 Addendum to EIR (ERC Environmental and
Energy Services Co). The full Sunbow II development project was issued local, state, and federal approvals and
development was completed within Phase 1 and 2 sites (located north of Olympic Parkway), but only access
crossing improvements, permitted wetland impacts, and 7 acres of wetland mitigation within Poggi Canyon were
completed on the Phase 3 site located south of Olympic Parkway. The 1995 BO for the Sunbow II phases included
terms and conditions relevant to habitat in the proposed project, as follows:
• #2: No clearing of sage scrub habitat shall occur during the gnatcatcher nesting season (15 February through 31
July) unless it is first demonstrated to be un-occupied by California gnatcatchers or other nesting avian species.
• #5: To mitigate for direct impacts to gnatcatchers and coastal sage scrub, a combination of on-site and off-
site measures shall be employed in accordance with Table 1 of the 1995 BO. The on-site restoration
mitigation shall be conducted concurrent or preceding the phase for which mitigation is required. Off -site
mitigation must be acquired and under long-term management prior to initiation of impacts for the project
phase for which mitigation is required.
• #9: Off-site mitigation shall be conducted at the O’Neill Canyon mitigation area in southern San Diego County. An
alternative site may be proposed and utilized at the discretion of the USFWS in consultation with the Department
of Fish and Game. Any alternative site proposed shall have a demonstrable value to the California gnatcatcher and
long-term strategic planning value for multi-species and habitat protection in San Diego.
The BO further included one Conservation Recommendation relevant to the proposed project.
• #1: The open space habitats proposed for Sunbow site are considered to be important for numerous
species which are candidates or future candidates for federal listing. Many of these species currently carry
state listing status and are a focus of multi-species planning efforts intended to reduce the need for future
listings. Among the most important resources within the open space are coastal cactus wrens and Otay
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tarplant. Potential exists for the compatible enhancement of these resources along with the restoration of
San Diego thornmint to some of the open space clay lenses. The USFWS would look favorably on such multi-
species enhancement efforts should the ACOE or the applicant incorporate consideration of these species
into the on-site restoration and maintenance program.
Narrow Endemic Species Protection
The following specific provisions are applicable to the project site.
Development Areas outside of Covered Projects. Development projects within Development Areas outside of
Covered Projects and regulated by the HLIT will avoid impacts to covered Narrow Endemic Species to the maximum
extent practicable. Where impacts are demonstrated to be unavoidable, impacts within these Development Areas
will be limited to 20% of the total Narrow Endemic Species population within the project site. Findings of
equivalency, as defined in Section 5.2.3.6 of the Subarea Plan, will be made by the City for such Take Authorization
of the covered Narrow Endemic Species.
If, after comprehensive consideration of avoidance and minimization measures, impacts exceed 20% of the covered
Narrow Endemic Species population within the project site, the City must make a determination of biologically
superior preservation consistent with the MSCP. The City will forward its written determination of biologically
superior preservation to the USFWS and CDFW (the Wildlife Agencies) for review. Within 30 days of receipt of mailed
notice of findings from the City, the Wildlife Agencies may submit to the City a written finding of non-concurrence
on the facts of the City’s findings. If such finding of non-concurrence is made within 30 days, the City will confer
with the Wildlife Agencies to resolve Narrow Endemic Species issues associated with the proposed development. If
the Wildlife Agencies do not respond within 30 days after receipt of mailed notice, the City shall deem the written
findings accepted (City of Chula Vista 2003).
100% Conservation Areas outside of Covered Projects. Projects within 100% Conservation Areas outside of Covered
Projects and regulated by the HLIT Ordinance will be limited to uses described in Sections 6.1, 6.2 and 6.3 of th e
Subarea Plan. In 100% Conservation Areas, planned and future facilities must avoid impacts to covered Narrow
Endemic Species to the maximum extent practicable. Where impacts are demonstrated to be unavoidable, impacts
within the 100% Conservation Areas will be limited to 5% of the total Narrow Endemic Species population within
the Project Area. Findings of equivalency will be made by the City for take of the covered Narrow Endemic Species,
pursuant to Section 5.2.3.6 of the Subarea Plan. The City will forward its written findings of equivalency to the
Wildlife Agencies. The Wildlife Agencies may submit to the City, within 30 days of receipt of mailed notice of findings
from the City, a written finding of non-concurrence on the facts of the City’s findings. If such finding of non-
concurrence is made within 30 days, the City will confer with the Wildlife Agencies to develop agreement upon an
appropriate location for the planned or future facility in question. If the Wildlife Agencies do not respond within 30
days after receipt of mailed notice, the City shall deem the written findings accepted.
If impacts exceed 5% of the covered Narrow Endemic Species population within the project site after comprehensive
consideration of avoidance and minimization measures, the City must make a determination of biologically superior
preservation, consistent with Section 5.2.3.7 of the Subarea Plan. The City will forward its written determination of
biologically superior preservation to the Wildlife Agencies for review. The Wildlife Agencies may submit to the City,
within 30 days of receipt of mailed notice of findings from the City, a written finding of non-concurrence on the facts
of the City’s findings. If such finding of non-concurrence is made within 30 days, the City will confer with the Wildlife
Agencies to develop agreement upon an appropriate location for the facility in question. If the Wildlife Agencies do
not respond within 30 days after receipt of mailed notice, the City shall deem the written findings accepted (City of
Chula Vista 2003).
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Wetlands Protection
As part of the CEQA review, development projects that contain wetlands would be required to demonstrate that
impacts to wetlands have been avoided to the greatest extent practicable and, where impacts are nonetheless
proposed, that such impacts have been minimized. For unavoidable impacts to wetlands within the Development
Area, the mitigation ratio would be in accordance with the wetlands mitigation ratios identified in the Subarea Plan.
The wetlands mitigation ratios provide a standard for each habitat type but may be adjusted depending on the
functions and values of both the impacted wetlands, as well as the wetlands mitigation proposed by the project.
The City may also consider the wetland habitat type(s) bein g impacted and used for mitigation in establishing
whether these standards have been met (City of Chula Vista 2003).
5.3.1.2 Existing Biological Resources
The proposed project encompasses approximately 135.7 acres (project area), which includes a 67.5‐acre
development area composed of 44.2 acres of residential, a 0.9‐acre Community Purpose Facility site, 5.9 acres of
public streets, and 16.5 acres of manufactured slopes/basins/wetland resources and associated buffer area.
Approximately 4.3 acres of proposed Poggi Canyon Conservation Easement area, a 0.3-acre wetland avoidance
area, and 63.6 acres of adjacent proposed MSCP Preserve area are also within the project site. The proposed MSCP
Preserve area within the project site can be seen in Figure 5.3-1.
Vegetation Communities
Several vegetation types were identified within the proposed project study area during the biological field surveys
(Figure 5.3-2, Biological Resources Map; Table 5.3-1). The project study area includes the proposed project site
and a 50-foot off-site mapping buffer (Figure 5.3-2). These identified vegetation types consist of upland habitats
including Diegan coastal sage scrub, native grassland, non‐native grassland, and non‐native vegetation as well as
wetland habitats including southern willow scrub, mule fat scrub and coastal and valley freshwater marsh. Acreages
of these vegetation types are summarized in Table 5.3-1, and each is discussed in more detail following the table.
A list of floral species observed or detected on site is included in the BTR (Appendix D).
Table 5.3-1. Habitats/Vegetation Communities within Project Site
Vegetation Type
MSCP Tier
Habitat Type
Holland/
Oberbauer Code
Total Area
(Acres)
Inside
Preserve
(Acres)
Outside
Preserve
(Acres)
Southern willow scrub
(including seep)
Wetland 63320 2.06 1.14 0.92
(0.01 seep)
Mule fat scrub Wetland 63310 0.03 0.03 0.00
Coastal and valley
freshwater marsh
Wetland 63300 7.66 6.31 1.35
Native grassland I 42100 24.09 19.38 4.71
Diegan coastal sage scrub II 32500 37.08 24.46 12.62
Non-native grassland III 42200 64.19 10.31 53.88
Non-native vegetation IV 11000 0.53 0.44 0.09
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Table 5.3-1. Habitats/Vegetation Communities within Project Site
Vegetation Type
MSCP Tier
Habitat Type
Holland/
Oberbauer Code
Total Area
(Acres)
Inside
Preserve
(Acres)
Outside
Preserve
(Acres)
Urban/developed N/A N/A 0.06 0.00 0.06
Total 135.70 62.07 73.63
Source: Appendix D.
Notes: MSCP = Multiple Species Conservation Program; N/A = not applicable.
Habitat/Vegetation Community Types
Diegan Coastal Sage Scrub
Diegan coastal sage scrub vegetation is primarily found in the western half of the project site. It is also found in the
eastern half of the project site to a lesser extent where it is predominantly associated with the planted slopes of
Poggi Creek channel that serve as a buffer to the wetland habitats created with the Sunbow II, Phase I development.
The 108-acre Sunbow I residential development was approved in a 1987 EIR. However, only access crossing
improvements, permitted wetland impacts, and 7 acres of wetland mitigation within Poggi Canyon were completed
on the project site as part of the Sunbow I residential development. In the western half of the project site, Diegan
coastal sage scrub is characterized by large stands of lemonadeberry (Rhus integrifolia) as well as areas that
support a mix of lower‐growing shrubs such as coastal sagebrush (Artemisia californica), flat‐top buckwheat
(Eriogonum fasciculatum var. fasciculatum), California encelia (Encelia californica), and bladderpod (Peritoma
arborea). A patch of habitat occurring near the western portion of the proposed development area is characterized
by San Diego viguiera (Bahiopsis laciniata) mixed with purple needlegrass (Stipa pulchra). The San Diego viguiera
is a sensitive species. One San Diego Needlegrass (Stipa diegoensis), a sensitive species, was also found on this
slope. Restoration areas along the slopes of Poggi Creek channel include a diverse mix of planted sage scrub shrubs
and cacti including coastal sagebrush, flat‐top buckwheat, white sage (Salvia apiana), coast cholla (Cylindropuntia
prolifera), and coast prickly pear (Opuntia littoralis). Giant wild rye (Leymus condensatus) is common in some areas.
Several sensitive species including San Diego bursage (Ambrosia chenopodiifolia), Palmer’s sagewort (Artemisia
palmeri), coast barrel cactus (Ferocactus viridescens), and Orcutt’s bird’s‐beak (Dicranostegia orcuttiana) were
also planted and are present on these slopes.
Native Grassland
Native grassland is found throughout most of the western half of the project site in mostly open areas adjacent to
Diegan coastal sage scrub vegetation. It is also found in patches along the bottom of the north‐facing slope in the
eastern half of the project site where it gives way to non‐native grassland to the south in more disturbed soils
conditions. Native grassland is also found to the east on the adjacent Otay Ranch Village Two property near the
northeast corner of the project site. It should be noted that current mapping of this area exhibits a decline of
approximately 0.31 acres of native grassland from Dudek’s 2006 mapping effort (Dudek 2006). This decline may
be a result of the several drought years experienced in the local area during the past fifteen years. Clay soils
accommodate fields of purple needlegrass as well as numerous geophytes including common goldenstar
(Bloomeria crocea), blue dicks (Dichelostemma capitatum ssp. capitatum), and sharp‐toothed sanicle (Sanicula
arguta). The taller rayless gumplant (Grindelia camporum) and locally endemic Otay tarplant (Deinandra conjugens)
are also associated with these grasslands. Two populations of the sensitive small‐flower bindweed (Convolvulus
simulans) were also detected in this habitat.
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Non‐native Eurasian grasses including ripgut grass (Bromus diandrus) and soft chess (Bromus hordeaceus) are
common, but typically comprise less than 60% of the overall cover. In some areas, clumps of the non‐native sweet
fennel (Foeniculum vulgare) are also found.
Non-Native Grassland
Much of the eastern half of the project site is comprised of non‐native grassland. A dense cover of non‐native, annual
grass species including ripgut grass, purple‐falsebrome (Brachypodium distachyon), soft chess, wild oat (Avena
barbata), and red brome (Bromus madritensis ssp. rubens) dominate these areas. The perennial darnel (Festuca
temulenta) grass is also common in some areas of mesic soils. Numerous perennial and annual non‐native forbs
including short‐pod mustard (Hirschfeldia incana), tocalote (Centaurea melitensis), Russian thistle (Salsola tragus),
Crete hedypnois (Hedypnois cretica), smooth cat’s ears (Hypochaeris glabra), sweet fennel (Foeniculum vulgare),
crown daisy (Glebionis coronaria), and wild radish (Raphanus sativus) are found throughout this habitat amongst the
grasses. Some native annual forbs including silver puffs (Uropappus lindleyi), California cottonrose (Logfia
filaginoides), everlasting bedstraw (Stylocline gnaphaloides) and tread lightly (Cardionema ramosissima) occur
occasionally in this habitat. Although Otay tarplant is more common in native grassland, it is also found in the non‐
native grassland on site. Individual and small groupings of lemonadeberry surrounded by thatched non‐ native grasses
are found in some locations of the non‐native grassland on site; however, the lemonadeberry shrubs within the non‐
native grassland consist of no more than 5% absolute cover (AECOM et al. 2011).
Non-Native Vegetation
Non‐native vegetation is mapped for areas supporting individual or clusters of non‐native tree and shrub species
such as tamarisk (Tamarix parviflora), eucalyptus (Eucalyptus spp.), and cyclops acacia (Acacia cyclops). Typical
ornamental landscape plants which are less invasive such as pine (Pinus spp.) and mission olive (Olea europaea)
are also included in this category and can be found near the southwest border of the site immediately adjacent to
existing residential urban development (Figure 5.3-2).
Southern Willow Scrub
Southern willow scrub vegetation was planted within the created Poggi Creek channel as part of installation of Poggi
Canyon wetland mitigation for the Sunbow II, Phase 1, development project, which was originally approved in a
1987 EIR. Mature arroyo willow (Salix lasiolepis) and black willow (Salix gooddingii) occur in patches along the
channel and shade an understory of mostly freshwater marsh vegetation. In drier areas, tall, hydrophytic shrubs
such as mule fat (Baccharis salicifolia) and narrow‐leaved willow (Salix exigua) occur in the understory. In saturated
soils, low growing herbaceous species including watercress (Nasturtium officinale), yerba mansa (Anemopsis
californica), and salt marsh fleabane (Pluchea odorata) were noted.
In addition, a presumed seep from the hillside on the City property to the south extends on to the project site along
the southern boundary. On‐site, saturated soils support a small patch of southern willow scrub consisting of one
black willow tree, a few tamarisk shrubs and lower‐growing forbs such as willow herb (Epilobium ciliatum) and bristly
ox‐tongue (Helminthotheca echioides).
Mule Fat Scrub
A small stand of mulefat occurs at the base of drainage that feeds into Poggi Creek channel, in the western half of
the project site.
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Coastal and Valley Freshwater Marsh
Perennial water flow along Poggi Creek channel results in permanently saturated soils that support freshwater
marsh vegetation. This habitat is dominated by dense stands of southern cattail (Typha domingensis) with smaller
groupings of southern bulrush (Schoenoplectus californicus). Moist soils along the periphery of this habitat
accommodate relatively large groupings of two sensitive species, San Diego marsh ‐elder (Iva hayesiana) and
southwestern spiny rush (Juncus acutus ssp. leopoldii).
Wildlife Resources
Butterflies
Eighteen butterfly species were observed on site during spring protocol surveys conducted for the federally endangered
Quino checkerspot butterfly (Euphydryas editha quino). Painted Lady (Vanessa cardui) was the most commonly
encountered butterfly throughout upland vegetation types. Other frequently observed species included funereal dusky
wing (Erynnis funeralis), anise swallowtail (Papilio zelicaon), checkered white (Pontia protodice), and pacific sara orange‐
tip (Anthocharis sara sara). Each of these species are considered generalists that typically sip nectar from a wide variety
of plant species from the sunflower, carrot, buckwheat, mustard, pea, and mint families. Less commonly encountered
species included western tailed blue (Everes amyntula), marine blue (Leptotes marina), grey hairstreak (Strymon melinus
pudica), and Behr’s metalmark (Apodemia mormo virgulti). Except for the Behr’s metalmark, the caterpillars of these
species typically feed on pea family plants such as coastal deerweed, ocean locoweed (Astragalus trichopodus var.
lonchus) and western false‐indigo (Amorpha fruticosa), which are all found on site. Behr’s metalmark was typically
associated with flat‐top buckwheat which is the primary caterpillar food source for this species.
Amphibians
Baja California tree frog (Pseudacris hypochondriaca hypochondriaca) was commonly detected within Poggi Creek
channel, located within the northern portion of the site, and in adjacent coastal sage scrub and grassland habitats
during the winter and spring months. Although not detected, western toad (Anaxyrus boreas) is also expected to
utilize the creek channel and immediately adjacent vegetation communities. Bullfrog (Lithobates catesbeiana) may
also breed within areas of the creek where water is stagnant. Another common amphibian sp ecies, the garden
slender salamander (Batrachoseps major major), is expected to occur in upland habitats. This species prefers cool,
damp soils below leaf litter and debris.
Reptiles
Reptiles observed on‐site include several snake species including Southern Pacific rattlesnake (Crotalus oreganus
ssp. helleri), gophersnake (Pituophis catenifer), and California striped racer (Masticophis lateralis lateralis). The
sensitive two‐striped gartersnake (Thamnophis hammondii) was observed in coastal sage scrub vegetation in
preserved habitat just west of the proposed development area. This aquatic species is expected to primarily utilize
wetland habitats of Poggi Creek channel but also refuge in immediately adjacent upland mammal burrows during
the winter. Other expected snake species include the common kingsnake (Lampropeltis getula) and the sensitive
red‐diamond rattlesnake (Crotalus ruber). The red‐diamond rattlesnake has been observed within the last year
occurring east of the site on the banks of Poggi Creek channel. Lizard species observed on‐site include the western
fence lizard (Sceloporus occidentalis), side‐blotched lizard (Uta stansburiana), and southern alligator lizard (Elgaria
multicarinata). A motion activated camera placed along the edge of Poggi Creek channel captured an image of the
sensitive orange‐throated whiptail (Aspidoscelis hyperythra beldingi) within a sandy wash area of one of the
drainages that connects to Poggi Creek. This species is expected to also utilize adjacent coastal sage scrub and
grassland habitats.
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Birds
Numerous bird species were observed in Diegan coastal sage scrub habitat. Typical bird species detected in this
habitat include California towhee (Melozone crissalis), spotted towhee (Pipilo maculates), bushtit (Psaltriparus
minimus), Bewick’s wren (Thryomanes bewickii) Anna’s hummingbird (Calypte anna), and western scrub‐jay
(Aphelocoma californica). Fall migrant species observed included white‐crowned sparrow (Zonotrichia leucophrys)
and yellow‐rumped warbler (Dendroica coronata). Other less commonly encountered species included California
thrasher (Toxostoma redivivum), blue grosbeak (Passerina caerulea), lark sparrow (Chondestes grammacus),
orange‐crowned warbler (Oreothlypis celata), Pacific slope flycatcher (Empidonax difficilis), and ash‐ throated
flycatcher (Myiarchus cinerascens).
The coastal California gnatcatcher (Polioptila californica californica) was observed within coastal sage scrub habitat
during protocol surveys for this species. Two male territories were mapped. This listed species is discussed further
in the Sensitive Fauna section below.
Poggi Creek channel supported a variety of riparian bird species. Typical year‐long resident bird species including song
sparrow (Melospiza melodia) and common yellowthroat (Geothlypis trichas) were detected. Various migrant species
including Wilson’s warbler (Wilsonia pusilla), black‐throated gray warbler (Dendroica nigrescens), western tanager
(Piranga ludoviciana), and warbling vireo (Vireo gilvus) were detected during spring surveys. Sensitive migrant bird
species including yellow warbler (Dendroica petechial), yellow‐breasted chat (Icteria virens) and the federally listed
endangered least Bell’s vireo (Vireo bellii pusillus) were also detected on‐site within Poggi Creek channel. The least Bell’s
vireo’s territory appears to extend from the eastern‐most 200 feet of the channel to a willow scrub basin located just
upstream of the project site to the east. Least Bell’s vireo is discussed further in the Sensitive Fauna section below.
Common yellowthroat, red‐winged blackbird (Agelaius phoeniceus), marsh wren (Cistothorus palustris) and Virginia Rail
(Rallus limicola) forage and nest in freshwater marsh habitat found within the channel.
Grassland habitats (including both native and non‐native grassland) provide foraging habitat for a variety of raptor
species. Observed species included urban tolerant species such as red‐tailed hawk (Buteo jamaicensis), red‐
shouldered hawk (Buteo lineatus), Cooper’s hawk (Accipiter cooperii) and American kestrel (Falco sparverius).
During early spring (i.e., March), a red‐tailed hawk pair nested in a Eucalyptus tree snag near the southeast corner
of the project site. Three eggs were visibly observed in this nest in mid‐March, but it later appeared that only one
of the young hatched. Surveys in early April did not reveal the nestling, and it was presumed that it was predated
upon by one of the many predatory birds (e.g., Cooper’s hawk, common raven) observed in the area. It should be
noted that the location of this nest was identified during the previous survey of the site and it is possible that it has
been routinely used by red‐tailed hawks if not other raptors throughout its existence.
Sensitive raptor species such as the northern harrier (Circus cyaneus) and white‐tailed kite (Elanus leucurus) were
also observed foraging over grassland habitat. No nests of these species were observed during the site
investigations. It should be noted that the northern harrier nests on the ground with the nest concealed within a
marsh or other dense vegetation (Appendix D). Grasshopper sparrow (Ammodramus savannarum) is a sensitive
species that was historically identified to occur on site but was not observed during the recent surveys.
Given the abundance of grassland habitat throughout the site, western burrowing owl (Athene cunicularia) was
sought during the site investigations. No burrowing owls were observed during the numerous surveys of the site. In
addition, no burrows with evidence of sign (i.e., molted feathers, cast pellets, prey remains, eggshell fragments,
excrement) were observed during the surveys. Urban adapted bird species such as house finch (Haemorhous
mexicanus), house sparrow (Passer domesticus), and hooded oriole (Icterus cucullatus) were common within non‐
native, ornamental plantings that border the southwest project site boundary.
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Mammals
Mammal species detected on‐site include coyote (Canis latrans clepticus), California ground squirrel (Spermophilus
beecheyi nudipes), Botta’s pocket gopher (Thomomys bottae), and desert cottontail (Sylvilagus audubonii
sanctidiegi). Raccoon (Procyon lotor psora) tracks were observed along the muddy creek bottom of Poggi Creek
channel. Other urban adapted mammals such as the striped skunk (Mephitis mephitis holzneri) and Virginia
opossum (Didelphis virginiana) are also expected to scavenge for food along the channel at night. The dusky‐footed
woodrat (Neotoma fuscipes macrotis) is another mostly nocturnal species that is expected to occur on‐site.
Although no stick nests were detected, images of what is believed to be this species were captured by a motion
activated camera placed along the edge of the channel. Other species expected to occur on‐site include, California
vole (Microtus californicus sanctidiegi), agile kangaroo rat (Dipodomys agilis) and various species of mice including
western harvest mouse (Reithrodontomys megalotis longicaudus) and deer mouse (Peromyscus maniculatus).
These small mammals provide a food source for the various previously mentioned raptor species.
Other potentially occurring mammal species include bobcat (Lynx rufus) and the relatively urban adapted gray fox
(Urocyon cinereoargenteus californicus).
Watersheds found within the southern part of the County including the Tijuana River Valley, the Otay River Valley
and the Sweetwater River Valley support a relatively large diversity of bat species (Appendix D). Relatively common
species including the Mexican free‐tailed bat (Tadarida brasiliensis) and Yuma myotis (Myotis yumanensis) are
expected to forage for insects over the site, especially along Poggi Creek channel.
Jurisdictional Wetlands and Non-Wetlands Resources
ACOE, RWQCB, CDFW, and/or City of Chula Vista jurisdictional wetlands and non‐wetland waters are delineated for
the project site as described further below and shown in Figure 5.3-3, Wetland Delineation Map. Jurisdictional
wetland habitat types on the site include southern willow scrub, mule fat scrub, and coastal and valley freshwa ter
marsh. Jurisdictional non‐wetland waters (NWW), jurisdictional waters as defined by the ACOE that isn’t considered
a wetland, were also delineated where applicable. Table 5.3-2 summarizes the acreages of jurisdictional resources
within the project site and the following text discusses these habitats with regard to hydrophytic vegetation, hydric
soils, and wetland hydrology. Wetland determination data forms and photo points that support the delineation are
provided in Appendix D.
Table 5.3-2. Summary of Jurisdictional Resources Present within the Project Site
Jurisdictional Resources
On-Site Total
(Acres)
Jurisdiction
ACOE/RWQCB/ CDFW/City RWQCB CDFW/City
Coastal and Valley Freshwater Marsh 7.66 7.44 0.00 0.22
Southern Willow Scrub 2.06 1.85 0.01 0.20
Mule Fat Scrub 0.03 <0.01 0.00 0.03
Non-wetland Waters of the U.S./
Waters of the State/Streambed
0.17 (2,044
linear feet)
0.17 (2,044 linear feet) 0.00 0.00
Total 9.92 9.46 0.01 0.45
Source: Appendix D.
Notes: ACOE = Army Corps of Engineers; RWQCB = Regional Water Quality Control Board; CDFW = California Department of Fish and
Wildlife; City = City of Chula Vista.
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Southern Willow Scrub
Southern willow scrub is primarily found along Poggi Creek channel and includes a tree stratum dominated by
various facultative wetland plants (FACW), plants that occur usually in wetlands, but can also occur in non-wetlands,
of willow species including arroyo willow, black willow, and Pacific willow (Salix lasiandra ssp. lucida). Species within
the shrub stratum included mule fat (facultative plants; plants with a similar likelihood of occurring in both wetlands
and non-wetlands [FAC]), San Diego marsh elder (FACW), and coyote brush. The herb stratum included mostly
obligate wetland plants (OBL), plants that occur almost always in wetlands under natural conditions but that may
also occur rarely in non-wetland areas, species such as southern cattail, southern bulrush, yerba mansa, and
watercress. Several FACW species including Mexican rush (Juncus mexicanus) and great‐marsh evening primrose
(Oenothera elata) were noted at higher elevations within this stratum. Areas in which hydrophytic vegetation
extends beyond the ordinary high water mark of the creek are mapped as CDFW jurisdiction only.
Soil tests pits revealed a relatively dark matrix with redox depletions within the upper 8 inches of the profile. Highly
decomposed organic matter in the surface layer and a sulfidic odor was also characteristic of the soils in these test
pits. Primary hydrology indicators included water stained leaves and hydrogen sulfide odor. Secondary hydrology
indicators included drainage patterns and drift deposits.
A small patch of willow scrub represented by one black willow (FACW), a few tamarisk (FAC) shrubs and low‐growing
forbs such as willow herb (FACW) and bristly ox‐tongue (FAC) occurs near the southern project site boundary. The
hydric plant species in this area are supported by a seep that occurs off site, to the south on City owned property.
No hydric soil indicators were observed within the excavated soils pit; however, hydrology was indicated by the
presence of surface water and saturated soils. Since this area lacks a defined bed, bank, and ordinary high water
mark and has no defined drainage connection to Poggi Creek channel it’s not jurisdictional under ACOE or CDFW
but rather it is considered Regional Water Quality Control Board Jurisdiction only.
Mule Fat Scrub
A small stand of mulefat (FAC) occurs within a narrow drainage ditch that feeds into Poggi Creek channel. Hydrology
was indicated by the presence of secondary indicators including drainage patterns and sediment deposits.
Coastal and Valley Freshwater Marsh
Perennial water flow along Poggi Creek channel results in permanently saturated soils that support freshwater marsh
vegetation. Two OBL species, southern cat‐tail and southern bulrush characterize this habitat. Other lower‐growing
species within the herb stratum include water cress (OBL), yerba mansa (OBL), and curly dock (Rumex crispus) (FAC).
Soils in these areas exhibited a loamy gleyed matrix with redox features noted within the upper 6 inches. Primary
hydrology indicators included inundation and oxidized rhizospheres within living roots. Secondary hydrology
indicators included drift deposits and drainage patterns.
Jurisdictional Non‐Wetland Waters and Streambeds
Jurisdictional non-wetland waters of the United States/streambeds were mapped for drainages with a defined bed
and bank but lacking hydric vegetation and soils.
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Functions and Values of Jurisdictional Resources
Poggi Creek runs east–west within the project site along the northern boundary and directly adjacent to Olympic
Parkway (Figure 5.3-1). Surface flow is relatively slow throughout the year. This is fostered by upstream
manufactured design features associated with wetland mitigation created for the construction of Olympic Parkway.
These design features include riprap drop structures with shallow wading pools and rock-ribbed sandbars that force
flows to slow and meander down the channel, dropping sediment and allowing for the planted wetland vegetation
to effectively treat runoff. As a result, wetland functions such as groundwater recharge, flood flow alteration, and
sediment/toxicant retention is considered relatively high. The presence of significant woody (i.e., willow) and
herbaceous (i.e., cattail) vegetation contributes to high nutrient transformation and streambed stabilization
throughout the channel. The created wetlands within the channel have proven to provide significant wildlife value,
especially for birds. A high diversity of resident and migratory bird species use the channel, which is further
enhanced by the presence of the native Diegan coastal sage scrub that was planted on the channel banks to buffer
the wetlands. Sensitive migrant bird species including the least Bell’s vireo, yellow warbler, and yellow ‐breasted
chat breed within the created wetlands during the spring and summer months. The created coastal sage scrub on
the channel banks provides potential habitat for the resident coastal California gnatcatcher.
Rare, Threatened, Endangered, Endemic, and/or Sensitive or MSCP Covered Species
Sensitive species are those considered sensitive by the City or any state or federal agency. For purposes of this
report, species listed as endangered or threatened under the federal Endangered Species Act (ESA ; federally
endangered [FE] or federally threatened [FT]) and California Endangered Species Act (state endangered [SE] or
state threatened [ST]); species designated as California Species of Special Concern (SSC) or Fully Protected species
by the CDFW; and species listed as MSCP Narrow Endemic Species or Covered Species (Covered) by the City of
Chula Vista (2003) are considered “sensitive.” Species considered rare by the California Native Plant Society as
California Rare Plant Rank (CRPR) species (CNPS 2020) or as Special Plants or Special Animals in the California
Natural Diversity Database (CNDDB) (CDFW 2020a, 2019), may be considered “sensitive” if they meet the CEQA
Guidelines Section 15380 definition for “endangered, rare or threatened species.”
Sensitive Flora
Twelve sensitive floral species were identified within the project study area during the general biological surveys:
Otay tarplant (FT, SE, MSCP Narrow Endemic Species, MSCP Covered), Orcutt’s birds‐beak (CRPR 2B.1, Special
Plant, MSCP Covered), decumbent goldenbush (Special Plant, CRPR 1B.2), coast barrel cactus (Special Plant, CRPR
2B.1), San Diego bursage (CRPR 2B.1), San Diego marsh elder (Special Plant, CRPR 2B.2), small‐flowered bindweed
(CRPR 4.2), Palmer’s sagewort (Special Plant, CRPR 4.2), San Diego County needlegrass (CRPR 4.2), San Diego
viguiera (Special Plant, CRPR 4.3), southwestern spiny rush (Special Plant, CRPR 4.2), and ashy spike‐moss (CRPR
4.1) (Table 5.3-3; Figure 5.3-2).
According to the California Native Plant Society’s website, the CRPR system ranges from 1A (for plants presumed
extirpated in California and either rare or extinct elsewhere) to 4 (plants of limited distribution) (CNPS 2020). The
sensitive flora found within the project study area include CRPR 1B, 2B, and 4. CRPR 1B are plants th at are rare
throughout their range with the majority of them endemic to California , and most of the plants that are ranked 1B
have declined significantly over the last century. CRPR 2B is used for plants that are rare, threatened, or endangered
in California but more common elsewhere. Plants with a California Rare Plant Rank of 4 are of limited distribution
or infrequent throughout a broader area in California, and their status should be monitored regularly.
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Ranks at each level also include a threat rank (e.g., CRPR 4.3), and are determined as follows (CNPS 2020):
• 0.1 – Seriously threated in California (over 80% of occurrences threatened/high degree and immediacy of threat)
• 0.2 – Moderately threatened in California (20%–80% occurrences threatened/moderate degree and
immediacy of threat)
• 0.3 – Not very threatened in California (less than 20% of occurrences threatened/low degree and
immediacy of threat or not current threats known).
Otay tarplant was the only City Narrow Endemic Species identified and expected on site. Surveys were conducted
in 2020 during the flowering period (April–July) for this species. In addition, remaining remnants of plants from the
2019 growth season were mapped during the late fall of 2019. The 2020 Otay tarplant mapped locations and plant
numbers were combined with the 2019 Otay tarplant survey results taking the largest numbers if the locations
overlapped to estimate the on-site Otay tarplant population. It is recognized that the number and locations of
individual plants in any Otay tarplant population varies each year, due to a number of factors, including rainfall,
temperature, soil conditions, and seed bank (USFWS 2004). Table 5.3-3 identifies sensitive plant species detected
on site and their location relative to Preserve boundaries (Figure 5.3-2).
Table 5.3-3. Sensitive Flora Located On Site Inside and Outside Preserve Boundaries
Species Inside Preserve Outside Preserve Total
*Ashy spike‐moss (Selaginella cinerascens) 0 2 2
Coast barrel cactus (Ferocactus viridescens) 1 1 2
Decumbent goldenbush (Isocoma menziesii var. decumbens) 533 270 803
Orcutt’s bird’s‐beak (Dicranostegia orcuttiana) 705 206 911
Otay tarplant (Deinandra conjugens) 4,044 1,405 5,449
Palmer’s sagewort (Artemisia palmeri) 16 28 44
San Diego bursage (Ambrosia chenopodiifolia) 7 17 24
San Diego County needlegrass (Stipa diegoense) 9 1 10
San Diego County viguiera (Bahiopsis laciniata) 2,745 4,902 7,647
San Diego marsh elder (Iva hayesiana) 641 175 816
Small‐flowered bindweed (Convolvulus simulans) 91 0 91
Southwestern spiny rush (Juncus acutus ssp. leopoldii) 489 261 750
Source: Appendix D.
Note:
* Prostrate ground cover herb quantified by number of patches.
Otay tarplant is a federal and state listed species and MSCP Narrow Endemic and Covered Species. Otay tarplant
occurs throughout the project site based on biological field surveys conducted by Merkel & Associates (M&A) on
site in 2019 and 2020. In 2019, as provided in the Functional Equivalency Analysis Report (Appendix D) biological
surveys were conducted in November and December of 2019 which is outside of the Otay tarplant flowering season
(April–July) to get a preliminary assessment of the Otay tarplant population in preparation of the Functional
Equivalency Analysis Report. Remnants of Otay tarplant from the 2019 season were still highly detectable during
the November and December 2019 surveys and were counted and mapped. In 2020, focused Otay tarplant surveys
were conducted on site between late June and July 2020 during the flowering season when this annual species is
most detectable. The 2020 Otay tarplant mapped locations and plant numbers were combined with the 2019 Otay
5.3 – Biological Resources
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tarplant survey results taking the largest numbers if the locations overlapped to estimate the on-site Otay tarplant
population. Based on the 2019–2020 Otay tarplant field surveys, the on-site population is estimated to be 5,449
plants predominantly located in the western half of the project site within the existing Preserve (4,044 plants within
the Preserve and 1,405 plants outside the Preserve). It is recognized that the number and locations of individual
plants in an Otay tarplant population varies each year, due to a number of factors, including rainfall, temperature,
soil conditions, and seed bank (USFWS 2004).
Orcutt’s bird’s‐beak is a CNDDB Special Plant and MSCP Covered Species with a CRPR 2B.1 ranking. This species
has a very limited U.S. distribution, with nearly all its documented populations occurring south of Poggi Canyon and
west of Otay Mountain. Only one population has been documented north of the site, in Rice Canyon just south of
the Rancho Del Rey development.
Other Potentially Occurring Sensitive Flora
Multiple biological surveys including focused rare plant surveys were conducted on site throughout the blooming
period for all potentially occurring sensitive species. As a result, only one species, Palmer’s grappling ‐hook
(Harpagonella palmeri) (CRPR 4.2, Special Plant), has a moderate or greater potential to occur on site despite not
being observed during the biological surveys given the cryptic nature of this inconspicuous annual plant.
No other potential sensitive floral species are expected to have at least a moderate potential to occur within the
project site, predominantly based on a lack of potentially suitable habitat, soils, and/or the number of recent field
surveys conducted by M&A biologists on site throughout the year that would have likely detected most species, if
present. All of the potentially occurring sensitive floral species are discussed in Appendix D.
Sensitive Fauna
Ten sensitive fauna species were identified within the project study area during the general biological surveys and/or
protocol surveys: least Bell’s vireo (FE, SE, Special Animal, and MSCP Covered); California gnatcatcher (Polioptila
californica californica) (FT, SSC, Special Animal, and MSCP Covered); yellow‐breasted chat (SSC, Special Animal); yellow
warbler (SSC, Special Animal, USFWS Bird of Conservation Concern); Cooper’s hawk (Special Animal, CDFW Watch List,
MSCP Covered); Nuttall’s woodpecker (Special Animal); northern harrier (SSC, Special Animal, MSCP Covered); white‐
tailed kite (CDFW Fully Protected Species, Special Animal); orange‐throated whiptail (SSC, Special Animal, and MSCP
Covered); and two‐striped gartersnake (SSC, Special Animal). Several of the sensitive avian species on site, including the
yellow warbler, yellow breasted chat, Nuttall’s woodpecker, and least Bell’s vireo, were observed within riparian habitat
along Poggi Creek. These species are discussed further below (Table 5.3-4; Figure 5.3-2). The sensitive raptors observed
on site (i.e., Cooper’s hawk, northern harrier, white‐tailed kite) were detected only flying over and/or potentially foraging
throughout the site and were not observed to be nesting and are not expected to nest on site due to the limited amount
of nesting habitat. The orange‐throated whiptail and two‐striped gartersnake were briefly detected in the central portion
of the site within native grassland and Diegan coastal sage scrub habitats, respectively. Coastal California gnatcatcher
was identified on site and is discussed further below. The following table identifies sensitive animal species detected on
site and their location relative to Preserve boundaries.
Table 5.3-4. Sensitive Fauna Located On Site Inside and Outside Preserve Boundaries
Species Inside Preserve Outside Preserve Total
Coastal California gnatcatcher (Polioptila californica
californica)
1 1 2
*Cooper’s hawk (Accipiter cooperi) N/A N/A N/A
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Table 5.3-4. Sensitive Fauna Located On Site Inside and Outside Preserve Boundaries
Species Inside Preserve Outside Preserve Total
Least Bell’s vireo (Vireo bellii pusillus) 0 1 1
*Northern harrier (Circus cyaneus) N/A N/A N/A
Nuttall’s woodpecker (Picoides nuttallii) N/A 1 1
Orange‐throated whiptail (Aspidoscelis hyperythra) 1 0 1
Two‐striped gartersnake (Thamnophis hammondii) 1 0 1
*White‐tailed kite (Elanus leucurus) N/A N/A N/A
Yellow‐ breasted chat (Icteria virens) 2 1 3
Yellow warbler (Setophaga petechia) 4 1 5
Source: Appendix D.
Notes: N/A = not applicable.
* Fly-over species not limited to inside or outside the Preserve.
Least Bell’s Vireo
One least Bell’s vireo territorial male was incidentally detected by call within the southern willow scrub in Poggi
Creek during general biological surveys as well as during protocol surveys for Quino checkerspot butterfly and
coastal California gnatcatcher conducted by M&A throughout the spring months of 2020. The observations were
relatively consistent and limited to the northeastern portion of the proposed project site (see Figure 5.3-2). The
least Bell’s vireo’s territory appears to extend from the easternmost 200 feet of the channel on site to an off-site
basin that supports southern willow scrub located just upstream of the project site to the east.
Coastal California Gnatcatcher
The project site supports approximately 37 acres of potentially suitable gnatcatcher habitat consisting of Diegan
coastal sage scrub; however, not all of the 37 acres of the Diegan coastal sage scrub on site supports suitable
nesting gnatcatcher habitat. The suitable nesting habitat is located predominantly within the existing Preserve in
the central portion of the site along four rolling hillsides north of Poggi Creek and Olympic Parkway, as well as a
smaller patch of Diegan coastal sage scrub that is located in the southeastern corner of the project site and extends
off site (see Figure 5.3-2). The suitable gnatcatcher habitat quality in these areas is moderate to high, predominantly
due to the native species composition and diversity. The remaining areas of Diegan coastal sage scrub on site,
specifically those areas that consist entirely of lemonadeberry, are not considered suitable nesting habitat for
gnatcatcher due to the lack of plant species composition preferred for nesting (e.g., Artemisia californica,
Eriogonum fasciculatum). The narrow linear areas along Poggi Creek are less suitable gnatcatcher habitat and of
lower quality for gnatcatcher due to their linear configuration and fragmented locations on site.
Based on USFWS protocol surveys conducted in April 2020 (Appendix D), two coastal California gnatcatcher
territorial males were observed and heard within the survey area in two separate areas of Diegan coastal sage
scrub on site (Appendix D). One gnatcatcher territory is located in the central portion of the site within the larger
area of high-quality Diegan coastal sage scrub. The other gnatcatcher territory is located both on site and off site
within the southeastern corner of the project site where a small amount of Diegan coastal sage scrub occurs on
site with more suitable habitat that extends off site onto the County of San Diego (County) landfill property to the
south (Figure 5.3-2).
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Quino Checkerspot Butterfly
Based on USFWS protocol surveys for the federally listed endangered Quino checkerspot butterfly conducted by
M&A in 2020, Quino checkerspot butterfly is not present within the proposed project site (Appendix D).
Other Potentially Occurring Sensitive Fauna
The red‐diamond rattlesnake (Crotalus ruber) has been recorded to occur in open space habitat near the northwest
corner of the site in 1987 and 2006 (CNDDB 2020). M&A biologists have observed this often cryptic species east
of the site in Poggi Creek Channel within the last year. This cryptic species has a moderate potential to occur on ‐
site, given the presence of suitable habitat and the most recent sightings near the project site. This is the only
sensitive potentially occurring faunal species with at least a moderate potential of occurring on the site. No other
potential sensitive faunal species are expected to have at least a moderate potential to occur within the project
site, predominantly based on a lack of potentially suitable habitat and/or the number of recent field surveys
conducted by M&A biologists on site throughout the year that would have likely detected most species if present.
All of the potentially occurring sensitive faunal species are discussed in Appendix D.
Nesting Sensitive Raptor Species
No nests of sensitive raptor species were observed or are expected to occur on site. These include nests for tree/tall
shrub nesting species such as the white‐tailed kite and Cooper’s hawk, as well as ground nesting species such as
the northern harrier. These species were only observed flying over and/or foraging over the site. As discussed
earlier, no burrowing owls or burrows with evidence of sign (i.e., molted feathers, cast pellets, prey remains, eggshell
fragments, excrement) were observed during the surveys. Further, no ground squirrel burrows or other potential
burrows were observed on site. As such, this species is not expected to occur on‐site. Nesting potential for sensitive
raptor species is also discussed in Appendix D.
Wildlife Corridors and Connectivity
The northern portion of the project site and Olympic Parkway are located in an area that was historically Poggi
Canyon. The project site is not located within a known regional wildlife corridor. However, within the northern portion
of the project site, wetlands along Poggi Creek, upland slopes, dirt trails, game trails, and drainages throughout the
upland habitat likely serve as local wildlife corridors due to their topography, vegetation cover and location. These
areas support undeveloped land within an urbanized area to the north, west, and portions to the south.
City of Chula Vista MSCP
As provided in the City Subarea Plan, the proposed project is not an MSCP Covered Project; however, a MSCP 100%
Preserve designation is overlaid within the western half and the northern edge of the project site. The eastern half
of the project site is mapped as a Development Area in the MSCP.
The western half of the project site and much of the northern edges along Poggi Creek is designated as 100%
Preserve, while the eastern half of the site is designated as MSCP Development Area (Figure 5.3-1). In addition,
there are adjacent MSCP designations to the south and southeast (Figure 5.3-1). Directly south of the project site,
is a City-owned property that is an MSCP Minor Amendment Area. As provided in the MSCP Subarea Plan, these
Minor Amendment Areas will require the processing of a Minor Amendment to the Subarea Plan before Take
Authorization will apply to any portion of the properties with this designation. Directly southeast of the project site
is a County-owned property, developed as the Otay Landfill. The Otay Landfill is designated as an MSCP Take
Authorization Area that has granted take to the County under the County Subarea Plan presumably for County
landfill activities.
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5.3.1.3 Methodology
Literature Review
Historical and currently available biological literature and data pertaining to the study area were reviewed prior to
initiation of current 2019‐2020 field investigation. This review included examination of:
1) EIR, Sunbow General Development Plan Pre‐Zone dated 1989
2) Addendum to Final EIR 88‐1 Sunbow II Draft SPA Plan dated January 1990
3) BO on Impacts to the Coastal California Gnatcatcher (Polioptila californica californica) to Result from
Construction of the Sunbow Planned Community #1‐6‐95‐F‐172
4) Analysis of ultra‐low-altitude high-resolution ortho‐rectified aerial photography of the site acquired by
Merkel & Associates on January 3, 2020
5) Regional vegetation data for the project vicinity (City of Chula Vista 2019)
6) County Geographical Information System (GIS) data (Appendix D)
7) Google Earth Pro™ [Website Image Server], 2019 and 2020
8) Geological substrates and soil types mapped on the project site (Geocon geology data and USDA
2002, respectively)
9) CDFW CNDDB and USFWS special-status species records, and designated critical habitat for the project
vicinity (CDFW 2020, USFWS 2019a and 2019b, respectively)
Survey Dates, Times, and Conditions
M&A biologists conducted several general biological field surveys within the project study area (Table 5.3-5) that
consisted of the project site parcel and two areas directly offsite consisting of a portion of the Otay Village Two
property to the east and a portion of City of Chula Vista property to the south. Further, a 50 -foot habitat mapping
buffer is included in some of the report figures for context only and is not a part of the proposed project or project
study area.
Table 5.3-5. Schedule of Survey Dates, Times, Conditions, and Staff
Date Time Weather Conditions Biologist Survey
November 8, 2019 0800–1130 Weather: 0% cc
Wind: 0–1 BS
Temperature: 70°F–71°F
Kyle Ince General Biological
Survey
November 14,
2019
1115–1630 Weather: 0% cc
Wind: 0–2 BS
Temperature: 65°F–67°F
Kyle Ince
Gina Krantz
General Biological
Survey
November 18,
2019
1045–1600 Weather: 90% cc
Wind: 0–1 BS
Temperature: 80°F–76°F
Kyle Ince
Gina Krantz
General Biological
Survey
November 22,
2019
0730–0845 Weather: 0% cc
Wind: 0–1 BS
Temperature: 55°F–57°F
Kyle Ince General Biological
Survey
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Table 5.3-5. Schedule of Survey Dates, Times, Conditions, and Staff
Date Time Weather Conditions Biologist Survey
December 20,
2019
0830–1130 Weather: 0% cc
Wind: 0–1 BS
Temperature: 60°F–66°F
Kyle Ince
Gina Krantz
Jurisdictional Wetland
Delineation
January 3, 2020 1130–1530 Weather: 0% cc
Wind: 0–1 BS
Temperature: 61°F–68°F
Jordan Volker Low Altitude Aerial
Survey
January 10, 2020 0815–1300 Weather: 0% cc
Wind: 0–1 BS
Temperature: 50°F–63°F
Kyle Ince General Biological
Survey
March 6, 2020 1020–1340 Weather: 0% cc
Wind: 0–5 mph
Temperature: 63°F–64°F
Gina Krantz
Adam Behle
Kyle Ince
Quino Checkerspot
Butterfly Protocol
Survey #1
March 11, 2020 1245–1545 Weather: 30%–50% cc
Wind: 1–5 mph
Temperature: 62°F–69°F
Gina Krantz
Adam Behle
Kyle Ince
Quino Checkerspot
Butterfly Protocol
Survey #2
March 17, 2020 1300–1645 Weather: 40%–10% cc
Wind: 0–3 mph
Temperature: 60°F–62°F
Gina Krantz
Kyle Ince
Quino Checkerspot
Butterfly Protocol
Survey #3
March 21, 2020 1115–1515 Weather: 50%–5% cc
Wind: 0–3 mph
Temperature: 66°F–68°F
Kyle Ince
Adam Behle
Quino Checkerspot
Butterfly Protocol
Survey #4
March 24, 2020 1200–1600 Weather: 40%–10% cc
Wind: 5–3 mph
Temperature: 60°F–62°F
Gina Krantz
Adam Behle
Kyle Ince
Quino Checkerspot
Butterfly Protocol
Survey #5
March 27, 2020 1045–1415 Weather: 40%–0% cc
Wind: 0–5 mph
Temperature: 60°F–62°F
Gina Krantz
Adam Behle
Kyle Ince
Quino Checkerspot
Butterfly Protocol
Survey #6
April 3, 2020 1100–1500 Weather: 20%–30% cc
Wind: 0–4 mph
Temperature: 61°F–74°F
Gina Krantz
Adam Behle
Kyle Ince
Quino Checkerspot
Butterfly Protocol
Survey #7
April 14, 2020 1100–1420 Weather: 5% cc
Wind: 1–7 mph
Temperature: 64°F–66°F
Gina Krantz
Adam Behle
Kyle Ince
Quino Checkerspot
Butterfly Protocol
Survey #8
April 15, 2020 0830–1200 Weather: 0% cc
Wind: BS 0–1
Temperature: 63°F –75°F
Gina Krantz
Kyle Ince
Coastal California
Gnatcatcher Protocol
Survey #1
April 16, 2020 1000–1505 Weather: 0% cc
Wind: 3–7 mph
Temperature: 65°F–72°F
Adam Behle
Kyle Ince
Quino Checkerspot
Butterfly Protocol
Survey #9
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Table 5.3-5. Schedule of Survey Dates, Times, Conditions, and Staff
Date Time Weather Conditions Biologist Survey
April 22, 2020 0835–1200 Weather: 0% cc
Wind: BS 0–1
Temperature: 62°F–72°F
Gina Krantz
Kyle Ince
(Adam Behle/
Brandon Stidum)2
Coastal California
Gnatcatcher Protocol
Survey #2
April 23, 2020 0900–1235 Weather: 0% cc
Wind: 1–5 mph
Temperature: 64°F–78°F
Gina Krantz
Adam Behle
Kyle Ince
Quino Checkerspot
Butterfly Protocol
Survey #10
April 28, 2020 1000–1500 Weather: 0% cc
Wind: 0–5 mph
Temperature: 70°F–72°F
Amanda Gonzales
Kyle Ince
Jurisdictional Wetland
Delineation
April 29, 2020 0840–1145 Weather: 100% cc
Wind: BS 0–1
Temperature: 63°F–67°F
Gina Krantz
Kyle Ince
(Adam Behle/
Brandon Stidum)2
Coastal California
Gnatcatcher Protocol
Survey #3
April 30, 2020 1100–1430 Weather: 100%–50% cc
Wind: 1–3 mph
Temperature: 70°F–73°F
Gina Krantz
Adam Behle
Kyle Ince
Quino Checkerspot
Butterfly Protocol
Survey #11
May 7, 2020 0845–1215 Weather: 0% cc
Wind: 0–4 mph
Temperature: 64°F–74°F
Gina Krantz
Adam Behle
Kyle Ince
Quino Checkerspot
Butterfly Protocol
Survey #12
May 7, 2020 1215–1330 Weather: 0%–5% cc
Wind: 0–3 mph
Temperature: 74°F–75°F
Kyle Ince Rare Plant Survey
May 28, 2020 1545–1630 Weather: 100% cc
Wind: 0–5 mph
Temperature: 70°F–70°F
Kyle Ince Rare Plant Survey
June 8, 2020 1115–1445 Weather: 0%–5% cc
Wind: 3–5 mph
Temperature: 75°F–81°F
Kyle Ince General Biological
Survey and Rare Plant
Survey
July 9, 2020 0840–1420 Weather: 40%–5% cc
Wind: 0–2 mph
Temperature: 64°F–74°F
Kyle Ince
Gina Krantz
Rare Plant Survey
July 15, 2020 0830– Weather: 15%–0% cc
Wind: 0–5 mph
Temperature: 69°F–74°F
Kyle Ince
Gina Krantz
Rare Plant Survey
January 13, 2021 0900-1215 Weather: 50%-0% cc
Wind: 0-5 mph
Temperature: 61-72 F
Kyle Ince General Biological
Survey for Proposed
Slope and Berm on
Otay Village 2 Property
Source: Appendix D.
Notes: cc = cloud cover; BS = Beaufort Scale; mph = miles per hour; F= Fahrenheit.
1 Merkel & Associates (M&A) biologist in training supervised by permitted biologists.
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General Biological Survey
Existing vegetation types were delineated onto a 1 inch = 100 feet scale, December 2019 color aerial photograph
of the site. Vegetation types were classified according to the Holland (1986) code classification system as modified
by Oberbauer et al. (2008). Directed searches for sensitive species with a potential to occur on site were conducted
within the study area, and any other potential occurrences were assessed in the field based on the existing
biological conditions. The scientific and common names utilized for the floral and faunal resources were noted
according to the following scientific nomenclature: flora, Rebman and Simpson (2014); butterflies, San Diego
Natural History Museum (2002); amphibians and reptiles, Crother (2017); birds, American Ornithological Society
(2019); and mammals, Wilson and Reeder (2005) for species names and Hall (1981) for subspecies. Additional
details on the survey can be found in Appendix D.
Protocol Quino Checkerspot Butterfly Surveys
Quino checkerspot butterfly surveys were conducted the first week of March 2020 and were conducted less than
a week apart when survey conditions were met to catch up to the protocol survey schedule. Specific Quino survey
dates varied within the timeframe provided in the protocol according to weather conditions and scheduling needs.
Biologists slowly walked a variable, winding course that generally followed 30‐foot transects within suitable habitat
in the pre‐ determined butterfly survey areas, carefully followed the movements of butterflies, and periodically
stopped within areas that appeared most suitable. A detailed account of the survey is present in Appendix D.
Protocol California Coastal Gnatcatcher Surveys
Three protocol surveys for coastal California gnatcatcher were conducted at least one week apart within the
gnatcatcher survey area that consisted of potentially suitable gnatcatcher habitat (e.g., Diegan coastal sage
scrub) and any immediately adjacent habitat within the project site. All on ‐site vegetation communities were
mapped, and survey routes were slowly walked in potentially suitab le gnatcatcher habitat. Taped recordings
of gnatcatcher vocalizations, as well as “pishing ,’were used to elicit initial vocal responses, and an appropriate
time interval was allowed for a response, particularly from advantageous viewpoints. A detailed account of the
survey is present in Appendix D .
Rare Plant Surveys
Rare plants were detected and mapped throughout the late winter, spring, and early summer months. All areas of
the project site were surveyed for rare plants although surveys were intensified in areas of clay soils which are
suitable for a variety of endemic sensitive species known from the area.
Surveys were conducted during the flowering period for all potentially occurring sensitive species A detailed account
of the survey is present in Appendix D
Jurisdictional Wetland Delineation
M&A, Inc. conducted a jurisdictional wetland delineation on December 20, 2019 and on April 28, 2020. The wetland
delineation surveys were conducted using the routine on-site determination methods noted in the U.S. Army Corps
of Engineers’ (ACOE) Wetland Delineation Manual (ACOE 1987) and Regional Supplement to the Corps of Engineers
Wetland Delineation Manual: Arid West Region (ACOE 2008) (Appendix D). In addition, the delineation was
expanded to identify non‐wetland federally regulated waters as well as waters of the state. The extent of
jurisdictional boundaries was determined according to the ACOE, RWQCB, CDFW, and City definitions of wetlands,
navigable waters, and non‐wetland waters of the United States/streambed (NWW).
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General Survey Limitations
Biological inventories are generally subject to various survey limitations. Depending on the season and time of day
during which field surveys are conducted, some species may not be detected due to temporal species variability.
The biological surveys conducted for this project were performed during daylight hours and included late fall, winter,
spring, and the early summer months; thus, some nocturnal animal species that were not detected by sign (e.g.,
tracks, scat) during day surveys may not have been detected. Further, based on the literature review performed, as
well as knowledge of species‐specific habitat requirements, it is anticipated that any additional species potentially
present on the project site can be fairly accurately predicted, and that the surveys conducted were sufficient in
obtaining a thorough review of the biological resources present on the project site.
5.3.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to biological resources is based on the
recommendations provided in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). A significant im pact
would occur if the project would:
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. Wildlife Service .
B. Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in
local or regional plans, policies, regulations, or by the California Department of Fish and Game or U.S. Fish
and Wildlife Service.
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 native 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.
Additionally, impacts to biological resources are further categorized as direct impacts and indirect impacts. CEQA
Guidelines Section 15358 define a “direct impact” as “effects which are caused by the project and occur at the
same time and place” that can produce a temporary or permanent biologically significant, “physical change” in
the environment.
CEQA Guidelines Section 15358 define an “indirect impact or secondary effect” as “effects which are caused by
the project and are later in time or farther removed in distance,but are still reasonably foreseeable” that can
produce a temporary or permanent biologically significant, “physical change” in the environment.
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5.3.3 Impacts
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. Wildlife Service.
Direct Impacts
Sensitive Plant Species
The proposed project would directly impact several sensitive plant species as quantified in Table 5.3 -6 and
assessed by species further below. Additionally, Figure 5.3-4, Biological Impacts Map, shows a map of biological
impacts within the project site.
Table 5.3-6. Proposed Impacts to Sensitive Plant Species
Species
(in Alphabetical Order)
Existing Conditions within Project Site
(Inside Preserve and Outside Preserve)
Proposed Impacts
(Inside Preserve and Outside Preserve)
Inside
Preserve
Outside
Preserve Total
Inside
Preserve
Outside
Preserve Total
*Ashy spike‐moss
(Selaginella cinerascens)
0 2 2 0 1 1
Coast barrel cactus
(Ferocactus viridescens)
1 1 2 0 0 0
Decumbent goldenbush
(Isocoma menziesii var.
decumbens)
533 270 803 33 256 289
Orcutt’s bird’s‐beak
(Dicranostegia orcuttiana)
705 206 911 90** 1 91
Otay tarplant (Deinandra
conjugens)
4,044 1,405 5,449 142 694 836
Palmer’s sagewort (Artemisia
palmeri)
16 28 44 0 0 0
San Diego bursage
(Ambrosia chenopodiifolia)
7 17 24 0 16 16
San Diego County
needlegrass
(Stipa diegoense)
9 1 10 0 1 1
San Diego County viguiera
(Bahiopsis laciniata)
2,745 4,902 7,647 1,133 4,825 5,958
San Diego marsh elder (Iva
hayesiana)
641 175 816 0 3 3
Small‐flowered bindweed
(Convolvulus simulans)
91 0 91 0 0 0
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Table 5.3-6. Proposed Impacts to Sensitive Plant Species
Species
(in Alphabetical Order)
Existing Conditions within Project Site
(Inside Preserve and Outside Preserve)
Proposed Impacts
(Inside Preserve and Outside Preserve)
Inside
Preserve
Outside
Preserve Total
Inside
Preserve
Outside
Preserve Total
Southwestern spiny rush
(Juncus acutus ssp. leopoldii)
489 261 750 0 0 0
Source: Appendix D.
Notes:
* Prostrate ground cover herb quantified by number of patches.
** Impacts within Preserve are entirely within proposed Future Facility-Detention Basin footprint (see Figure 5.3-4).
Otay Tarplant
The proposed project would impact an estimated 836 Otay tarplants (142 located inside of the Preserve; 694
located outside of the Preserve) out of the total 5,449 Otay tarplants present on site (Table 5.3-4). Of the total Otay
tarplant impacts, the proposed residential development would permanently impact 142 Otay tarplant inside the
Preserve (including some impacted Otay tarplants within the Future Facility‐Detention Basin) (see Figure 5.3-4) and
424 Otay tarplants outside the Preserve. Further, construction related vegetation clearing and grading activities
would temporarily impact 270 Otay tarplants outside the Preserve.
Based on the sensitivity of this federally endangered and narrow endemic species, impacts to Otay tarplant would
be considered potentially significant (Impact BIO-1) under CEQA and would require appropriate mitigation that
would consist of on-site habitat mitigation (i.e., native grassland) within appropriate on-site conserved lands in the
Preserve. Mitigation Measure (MM) BIO-1 through MM-BIO-3 (see Section 5.3.5, Mitigation Measures) would be
implemented to reduce impacts to the Otay tarplant. The project also proposes habitat restoration efforts (soil
salvage, seed transplant) within appropriate on-site areas within the Preserve (Project Design Feature [PDF] BIO-1;
see Section 4.4.8, Project Design Features, of this EIR).
Orcutt’s Bird’s-Beak
Implementation of the proposed project would impact approximately 10% of the population of Orcutt’s bird’s‐ beak
population estimated to be present on site (91 out of 911 plants). The proposed impacts to Orcutt’s bird’s‐ beak
would occur from development of the proposed Future Facility-Detention Basin, located within Diegan coastal sage
scrub, just south of the previously restored slope along Poggi Creek, where the majority of the Orcutt’s bird’s beak
is located (Figure 5.3-4). The proposed impacts to Orcutt’s bird’s‐beak would be considered significant under CEQA
based on the sensitivity of this species and the rarity of this species in the region and the extent of impacts to the
on-site population.
The proposed project’s impacts to Orcutt’s bird’s-beak would be potentially significant (Impact BIO-2) and would
require appropriate mitigation that would consist of preserving 90% (820 out of 911) of the Orcutt’s bird’s-beak
estimated on-site population within the on-site Preserve (MM-BIO-3) and habitat mitigation (i.e., Diegan coastal
sage scrub) and habitat restoration efforts (soil salvage, seed translocation) within appropriate on-site conserved
lands in the Preserve (MM-BIO-3).
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Decumbent Goldenbush
Implementation of the proposed project would impact approximately 36% of the decumbent goldenbush on-site
population (289 out of 803 plants). A majority of the impacts to this species are associated with non ‐native
grassland habitat located within the proposed development area (Figure 5.3-4). The proposed impacts to
decumbent goldenbush would be considered potentially significant (Impact BIO-3). Therefore, require appropriate
mitigation that may consist of preserving 64% (513 out of 803) of the decumbent goldenbush estimated on -site
population within the on-site Preserve (MM-BIO-3) and habitat mitigation (i.e., native grassland) and habitat
restoration efforts (soil salvage, seed translocation) within appropriate on-site conserved lands in the Preserve, as
discussed further in Section 5.3.5 (MM-BIO-3).
San Diego Viguiera
Implementation of the proposed project would impact approximately 78% of the San Diego viguiera population
(5,958 out of 7,647 plants). Impacts to this species are associated with impacts to Diegan coastal sage scrub along
the western edge of the proposed development, discussed in further detail under Threshold B (Figure 5.3-4). The
proposed impacts to San Diego viguiera, a CNDDB Special Plant with a CRPR 4.3 ranking, would be considered
significant under CEQA primarily due to potential impacts to 5,958 plants out of 7,647 plants. The impacts to San
Diego viguiera would be potentially significant (Impact BIO-4). MM-BIO-3, which consists of habitat mitigation (i.e.,
Diegan coastal sage scrub) and may also include habitat restoration within appropriate on-site conserved lands in
the Preserve, would be implemented to reduce impacts to the San Diego viguiera.
San Diego County Needlegrass
Implementation of the proposed project would impact approximately 10% of the San Diego County needlegrass
population present on site (1 out 10 plants). Impacts to this species are associated with impacts to Diegan coastal
sage scrub along the western edge of the proposed development, which are discussed in further detail under
Threshold B (Figure 5.3-4, Biological Impacts Map). In the City’s MSCP, the impacts within Development Areas
outside of Covered Projects require that impacts to Narrow Endemic Species be avoided. Where impacts are
demonstrated to be unavoidable, impacts within these Development areas shall be limited to 20% of the total
Narrow Endemic Species population with the project areas. However, San Diego County Needlegrass is not listed
as a Narrow Endemic Species under the City’s MSCP, therefore there are no MSCP specific impact avoidance
guidelines. The CRPR for San Diego County Needlegrass is 4.2. As discussed earlier, CRPR 4 is the lowest rank
designated for plants “of limited distribution or infrequent throughout a broader area in California” (CNPS 2020).
Additionally, the threat level is 0.2 which is considered “moderately threatened in Cal ifornia.” Due to San Diego
County Needlegrass not being listed as a Narrow Endemic Species under the City’s MSCP, its low rank on the CRPR
list, and the impacts potentially affecting only 1 out of the 10 plants found within the project site, proposed impacts
would be less than significant.
Ashy Spike-Moss
Implementation of the proposed project would impact 100% (two patches) of ashy spike‐moss on site. Impacts to this
species are associated with impacts to coastal sage scrub vegetation near the southeast corner and non‐native
grassland along the eastern boundary of the site. In the City’s MSCP, the impacts within Development Areas outside of
Covered Projects require that impacts to Narrow Endemic Species be avoided. Where impacts are demonstrated to be
unavoidable, impacts within these Development Areas will be limited to 20% of the total Narrow Endemic Species
population with the project area. However, ashy spike-moss is not listed as a Narrow Endemic Species under the City’s
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MSCP. Therefore, there are no MSCP-specific impact avoidance guidelines. The CRPR for ashy spike-moss is 4.1. As
discussed earlier, CRPR 4 is the lowest rank designated for plants “of limited distribution or infrequent throughout a
broader area in California” (CNPS 2020). Additionally, the threat level is 0.1, which is considered “seriously threatened
in California.” However, because ashy spike-moss is only found in two patches within the project site, ashy spike-moss is
not listed as a Narrow Endemic Species within the City’s MSCP, and the plant’s CRPR is relatively low, the proposed
impacts to ashy spike‐moss would be less than significant based on the limited amount of proposed impact, sensitivity
of this species, and its local and regional abundance throughout the County.
Small-Flowered Bindweed, Coast Barrel Cactus, San Diego Bursage, Southwestern Spiny Rush, San Diego Marsh
Elder, and Palmer’s Sagewort
Implementation of the project result in no impacts to existing populations (within the project site) of coast barrel
cactus, palmer’s sagewort, small-flowered bindweed, and southwestern spiny rush (Table 5.3-6). The proposed
project would potentially result in impacts to 16 out of the 24 (66.7%) existing San Diego bursage plants, and 3 out
of the 816 (0.37%) existing San Diego marsh elder plants. None of the previously mentioned plants are listed as a
Narrow Endemic Species within the City MSCP.
San Diego marsh elder is ranked CRPR 2B.2, and San Diego bursage plant is ranked CRPR 2B.1. CRPR 2B is
designated for plants that are rare, threatened, or endangered in California but are more common elsewhere (CNPS
2020). Threat rank 0.2 is defined as “moderately threatened in California” (20%–80% of occurrences threatened
and a moderate degree and immediacy of threat), and threat rank 0.1 is defined as “seriously threatened in
California” (over 80% of occurrences threatened and a high degree and immediacy of threat). Although the rank for
San Diego marsh elder is relatively high, the amount that would be impacted resulting from implementation of the
proposed project (0.37% of the existing San Diego marsh elder plant population within the project site ) would be
considered less than significant. However, 66.7% of existing San Diego bursage plants would be impacted due to
implementation of the proposed project. Impacting 16 out of 24 existing San Diego bursage plants, paired with the
plant’s CRPR, would result in a potentially significant impact (Impact BIO-5). Impacts would be mitigated through
biological construction monitoring and implementation of construction best management practices (BMPs; MM-
BIO-12) and preparation of a Worker Environment Awareness Program (MM-BIO-13).
Sensitive Wildlife Species
Coastal California Gnatcatcher
Two coastal California gnatcatcher territories were determined to be present on site during the USFWS gnatcatcher
protocol surveys conducted by M&A in 2020 (Appendix D). One gnatcatcher territory is located in the central portion
of the site west of the proposed western access road within the larger area of high quality Diegan coastal sage
scrub, while the other gnatcatcher territory is located along the southeastern site boundary where a small amount
of Diegan coastal sage scrub occurs on site along with more suitable habitat that extends off site onto the County
of San Diego landfill property to the south (Figure 5.3-4).
The one gnatcatcher territory located along the southeastern parcel boundary would be directly impacted by the
proposed project vegetation clearing, grubbing, and grading activities (Figure 5.3-4) through the loss of a portion of
nesting habitat (i.e., Diegan coastal sage scrub). This project impact would be potentially significant (Impact BIO-6)
and would require implementation of mitigation measures (MM-BIO-1 through MM-BIO-2, and MM-BIO-4 and MM-
BIO-5). Further, gnatcatcher specific MSCP Conditions of Coverage, such as area-specific management directives
that must include measures to reduce edge effects and minimize disturbance during the nesting period, fire
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protection measures to reduce the potential for habitat degradation due to unplanned fire, management measures
to maintain or improve habitat quality including vegetation structure, and prohibition of clearing of occupied habitat
in the County of San Diego Multiple Habitat Planning Area may occur from March 1 through August 15, would apply
(City of Chula Vista 2003).
The other on-site gnatcatcher territory located in the central portion of the project site is not expected to be directly
impacted by the project. The gnatcatchers observed in this area were limited to the Diegan coastal sage scrub
located west of the proposed western main access road, largely within the existing Preserve that would remain
protected as proposed by the project. In addition, although suitable gnatcatcher habitat occurs in other surrounding
areas, no gnatcatchers were observed during the protocol surveys and/or any of the other biological surveys on
site. Nonetheless, the reduction of potentially suitable and contiguous habitat and the potential for nesting failure
due to the adjacent on-site construction related activities would result in potentially significant direct impacts
(Impact BIO-7) to gnatcatcher and would require implementation of MM-BIO-1 through MM-BIO-2, and MM-BIO-4
and MM-BIO-5 to reduce impacts to a level below significance.
Least Bell’s Vireo
The least Bell’s vireo that occurs on site is located entirely within Poggi Creek, where no development is proposed.
Therefore, least Bell’s vireo would not be directly impacted by the proposed project. Nonetheless, the potential for
nesting failure due to the adjacent on-site construction related activities would result in potential direct impacts to
vireo that would be considered potentially significant (Impact BIO-8) and would require implementation of MM-BIO-
6 in order to reduce impacts to a level below significance.
Quino Checkerspot Butterfly
Based on USFWS Quino checkerspot butterfly protocol surveys conducted by M&A in 2020, no Quino
checkerspot butterfly (USFWS federally endangered), were observed or detected to be present within the
project site and none are expected to occur (Appendix D). Therefore, the proposed project would have no
impact to Quino checkerspot butterflies.
Yellow Warbler, Yellow-Breasted Chat, and Nuttall’s Woodpecker
The proposed project is not expected to directly impact yellow warbler, yellow‐breasted chat, and Nuttall’s
woodpecker since these species occur in the riparian habitat within Poggi Creek , within the Preserve, or within an
existing conservation easement where the project proposes to avoid direct impacts. Therefore, the proposed project
would have no impact to yellow warblers, yellow-breasted chats, and Nuttall’s woodpeckers.
Sensitive Raptors
No nesting activities or potential nests of any sensitive raptor species, including white‐tailed kite, northern harrier,
and Cooper’s hawk were observed on site and therefore no potential nesting habitat for sensitive raptor species is
proposed to be impacted as a result of the project. Further, no indirect impacts such as construction elevated noise
levels during the breeding season would affect nesting sensitive raptors since none are expected to nest on site.
Raptors including sensitive species such as the white-tailed kite, northern harrier, and Cooper’s hawk were
observed flying over and potentially foraging on site and may be negatively affected by the loss of this potential
foraging habitat in the project area. The project would have direct impacts to potential raptor foraging habitat for
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white-tailed kite, northern harrier, and Cooper’s hawk associated with the loss of 61.0 acres of grassland habitat
(i.e., 53.28 acres of non‐native grassland, 7.72 acres of native grassland). As an important note, the potential
raptor foraging habitat proposed to be impacted is located almost entirely inside the MSCP Development Area and
is of lower habitat quality due to its densely thatched condition, while the proposed raptor foraging habitat mitigation
consists of higher quality native grassland, patches of non‐native grassland in a matrix of native habitats, and
proposed habitat restoration areas that is either currently or proposed to be in the Preserve. The proposed impact
to potential foraging habitat for white‐tailed kite, northern harrier, and Cooper’s hawk would be a potentially
significant impact (Impact BIO-9). and would require implementation of MM-BIO-1, which requires habitat mitigation
(i.e., native grassland, open Diegan coastal sage scrub) to reduce impacts to a level below significance.
Birds Protected under the Federal Migratory Bird Treaty Act and California Fish and Game Code
The project site has the potential to support active nests for regionally common migratory birds and raptors that are
not designated as special status species under CEQA but are protected under the federal Migratory Bird Treaty Act
(MBTA) and California Fish and Game (CFG) Code Sections 3503 and 3513.
The project could result in impacts to active bird and/or raptor nests protected under the federal MBTA and/or CFG
Code Sections 3503 and 3513 if construction-related activities were to occur during the avian and/or raptor
breeding season. The project construction activities undertaken for the project should comply with the regul atory
requirements of the federal MTBA and CDFG Codes Sections 3503 and 3513. As discussed previously, here is an
abundance of grassland onsite which is a potentially suitable habitat for burrowing owl; however, much of the
grassland is dense and/or thatched and thus not preferred by this species. Further, no burrowing owls were
observed during the numerous surveys of the site throughout the burrowing owl nesting and migratory season. In
addition, no potential burrows with evidence of burrowing owl sign (i.e., molted feathers, cast pellets, prey remains,
eggshell fragments, excrement) were observed during the surveys. As such, this species is not expected to occur
onsite. However, there is potential for burrowing owls to subsequently occupy the project site as a result of
construction vegetation clearing and grading activities that may temporarily create attractive conditions for
burrowing owl. The potential impact to active nests of birds (including burrowing owl) protected under MBTA and/or
CDFG Codes would be a potentially significant impact (Impact BIO-10) and would require avoidance of the avian
breeding season or conduct pre-construction active nest surveys through implementation of MM-BIO-7, which
requires to reduce impacts to a level below significance.
Sensitive Reptiles
Orange-Throated Whiptail and Two-Striped Gartersnake
Both the orange‐throated whiptail and two‐striped gartersnake were observed near the central portion of the site
within the existing Preserve. Both species are not expected to be abundant on site as they were each only observed
on one occasion during the numerous surveys that were conducted. Both species are expected to use riparian
habitat associated with Poggi Creek as well as adjacent coastal sage scrub vegetation. All riparian habitat and much
of the adjacent coastal sage scrub would be protected as part of the project. Therefore, the proposed project would
have no impacts to orange-throated whiptails and two-striped gartersnakes.
No other sensitive wildlife species are expected to occur on site based on recent negative focused surveys and/or
the lack of suitable habitat and thus would not be impacted by the proposed project.
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Indirect Impacts
There would be no indirect impacts to sensitive wildlife species. There are few indirect impacts to the remaining
native vegetation. Many of these are related to habitat fragmentation, which occurs when a native vegetation
community is not entirely altered or developed, but what remains has a diminished wildlife habitat value due to
edge effects and lack of connectivity. Indirect impacts to native vegetation are further discussed in Threshold B.
B. Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in
local or regional plans, policies, regulations, or by the California Department of Fish and Game or U.S. Fish and
Wildlife Service.
Vegetation Community
Based on the proposed project design, the proposed project would result in direct permanent and temporary
impacts to sensitive vegetation communities/habitats consisting of native grassland (Tier I), Diegan coastal sage
scrub (Tier II), and non‐native grassland (Tier III) habitats (see Table 5.3-7; Figure 5.3-4). Impacts would result in a
total of 69.28 acres of on-site impacts and 1.15 acres of off-site impacts (Table 5.3-7). Permanent project impacts
to sensitive vegetation communities would result from vegetation clearing, grading, and residential development
including houses, fuel modification zone activities, detention basins, and roadways. Temporary impacts to sensitive
vegetation communities would result from vegetation clearing, construction vehicular temporary access and
activities, grading in some areas, and subsequent revegetation efforts to ensure erosion control and/or native
habitat restoration activities to ensure long‐term biological functions and values.
Table 5.3-7. Quantitative Summary of Vegetation Community Impacts from the Proposed Project
Vegetation Type
MSCP
Tier
Habitat
Type
On-Site Impacts (Acres) Off-Site Impacts (Acres)
Total
On-
Site
Impact
Preserve
Development
Area
Total
Off-Site
Impact
City
Minor
Amend-
ment
Area
Otay
Ranch
Village 2 Perm Temp Perm Temp
Southern willow
scrub
Wetland 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Mule fat scrub Wetland 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Coastal and valley
freshwater marsh
Wetland 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Native grassland I 7.72 3.22 0.18 4.21 0.11 0.04 0.00 0.03 temp/
0.01 perm
Diegan coastal
sage scrub
II 8.25* 2.24 0.39 5.08* 0.54 0.32 0.22
temp
0.05 perm/
0.05 temp
Non-native
grassland
III 53.28 1.66 0.10 48.61 2.91 0.79 0.35
temp
0.02 perm/
0.42 perm
Non-native
vegetation
IV 0.02 0.00 0.00 0.02 0.00 0.00 0.00 0.00
Urban/developed N/A 0.01 0.00 0.00 0.00 0.01 0.00 0.00 0.00
Total 69.28 7.12 0.67 57.92 3.57 1.15 0.57 0.58
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Source: Appendix D.
Notes: MSCP = Multiple Species Conservation Program; N/A = not applicable.
* The proposed project would permanently impact 7.58 acres of Diegan coastal sage scrub in the Development Area; however, the
2.5 acres of Diegan coastal sage scrub impact as documented in the USFWS 1995 BO has been applied to this proposed impact
acreage resulting in a residual amount of 5.08 acres impact.
In association with direct impacts to native vegetation communities, there are usually indirect impacts to the
remaining native vegetation. Many of these are related to habitat fragmentation, which occurs when a native
vegetation community is not entirely altered or developed, but what remains has a diminished wildlife habitat value
due to edge effects and lack of connectivity. Fragmented habitats may no longer be able to support large predators.
The presence of native predators has been demonstrated to hold in check populations of meso‐predators such as
domestic/feral cats. Without the presence of such predators, avian and small mammal diversity and abundance
declines, presumably due to increased depredation pressure from non‐native meso‐predators (Appendix D). Edge
effects may include increased predation pressure, increased brood parasitism, increased competition for nesting
cavities from non‐native species, and increased floral competition from weedy species. Outside of those effects
associated with fragmentation, indirect impacts may include elevated noise above 60 A-weighted decibels (dBA)
equivalent measured sound level (Leq), artificial night lighting within wildlife habitat, increased human disturbance,
change in duration and amount of surface water within a floodplain, and increased erosion or sedimentation. These
types of indirect impacts can affect vegetation communities or alter habitat use by sensitive species.
The project proposes to fill in gaps of the MSCP Preserve where areas have not been previously included in the in
the 2003 City Subarea Plan configuration with areas of the Preserve along Poggi Creek by adjusting the proposed
BLA. The proposed project would also extend the native habitat buffer widths between Poggi Creek and the
proposed project footprint that will be included in the Preserve.
Per Table 5.3-7, permanent impacts (totaling on-site 64.05 acres) and temporary impacts (totaling on-site 4.24
acres) to native grassland, Diegan coastal sage scrub, and non-native grassland from construction activities such
as vegetation clearing, grading, residential development, and construction vehicular temporary access and
activities would be considered potentially significant (Impact BIO-11) and would require implementation of MM-MM-
BIO-1, MM-BIO-2, MM-BIO-12, and MM-BIO-13, consistent with the City MSCP Subarea Plan as well as the HLIT, to
reduce impacts to a level below significance.
It is expected that the portions of the MSCP Preserve directly adjacent and closest to the proposed project
development boundaries would potentially be negatively affected by edge effects such as invasive plant invasion,
habitat degradation, increased predation pressure from domestic pets (i.e., cats), lighting, noise, irrigation, and human
disturbance. These potential indirect impacts would be considered potentially significant (Impact BIO-12) and would
require mitigation measures MM-BIO-8 through MM-BIO-13 to reduce impacts to a level below significance.
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.
Wetlands within the proposed project are located largely along the northern border of the project site within Poggi
Creek. Two streambeds are located along the western half of the project site (see Figure 5.3-3). As shown on Figure
5.3-4, the proposed project would avoid permanent and temporary impacts to jurisdictional resources, including
wetlands and any appropriate buffer around applicable jurisdictional resources. Therefore, there would be complete
avoidance during project construction and implementation. All of the state or federally protected wetlands are
located within the Preserve, which is an area intended to remain unimproved and/or restored and its use strictly
limited, or within the isolated 0.3-acre wetland avoidance area within HOA open space along the southern property
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boundary that would be completely fenced off and inaccessible to the public. No significant development is planned
to occur within the Preserve. Therefore, direct impacts to jurisdictional wetlands would be less than significant and
no wetland mitigation or regulatory permitting would be required.
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 native wildlife nursery sites.
There are a few local wildlife corridors on site, including Poggi Creek, located along the northern extent of the project
site, as well as game trails and small drainages throughout the upland habitats particularly in the western half of
the project site. Poggi Creek includes existing culverts and creek crossings in two locations. The project proposes
to construct roadways on the existing creek crossings that currently support vegetation. Although the new access
roadways would bisect the habitat on the south side of the creek including portions of the dirt trail along the creek,
it is anticipated that wildlife movement would still be facilitated through the culverts under drier conditions as well
as across the roadways where vehicular traffic is expected to be relatively slow due to the locations near the
entrance and exit of the residential development.
Further, the project likely serves as part of a steppingstone corridor for bird species in the region due to the available
habitat on site that is generally surrounded by an urbanized area. As noted, the USFWS BO for the Sunbow II project
required off‐site habitat mitigation of sage scrub habitat associated with the further fragmentation of the habitat
connectivity associated with development of the proposed project. A BO (Biological Opinion) is a USFWS document
that states the opinion of the USFWS as to whether the federal action is likely to jeopardize the continued existence
of listed species or result in the destruction or adverse modification of critical habitat. As a result, the anticipation
of habitat connectivity impact associated with project development has been captured in regional conservation
planning and project-specific regulatory actions.
The wildlife species known or expected to occur on site consist of urban tolerant species such as coyote and raccoon
that are expected to continue to move throughout the site and along Poggi Creek after implementation of the
proposed project. Therefore, the proposed project is not expected to significantly impact any of the function and
use of the local wildlife corridors on site predominantly due to the urban tolerant nature of the wildlife species that
occur on site. Although there are local wildlife corridors present on site, the project site is not located within or in
the vicinity of a known regional wildlife corridor.
In addition, the project site likely serves as part of a steppingstone corridor for avian species in the region due to
the available habitat on site that is generally surrounded by urban development. Although the entire site may
provide habitat as part of a stepping stone corridor, the higher quality habitats are located in the western half and
northern portions of the project site that would located within the Preserve.
In addition, the 1995 USFWS BO for the Sunbow II project required off‐site habitat mitigation of coastal sage scrub
habitat associated with the further fragmentation of the habitat connectivity associated with development of Sunbow II
Phase 3. The proposed project would be required to implement the 1995 USFWS BO. As a result, the anticipation of
habitat connectivity impact associated with Phase 3 development has been captured in regional conservation planning
and project specific regulatory actions. Therefore, the proposed project would not interfere substantially with the
movement of any native resident or migratory fish or wildlife species. Impacts would be less than significant.
E. Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy
or ordinance.
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The proposed project would develop a 67.5-acre area composed of 44.2 acres of residential area, a 0.9 -acre
Community Purpose Facility site, 5.9 acres of public streets , and 16.5 acres of manufactured slopes/basins
within the City. The proposed project would not plan to remove any trees . The City does not have any codes
specific to tree removal or tree preservation. The closest related code would refer to the City of Chula Vista
Municipal Code 12.32.160, which state s that any tree, palm, shrub or plant shall be authorized (by the City’s
Department of Public Works) to be removed to remedy a dangerous condition. The proposed project would
abide by all local policies or ordinances protecting biological resources in the Cit y of Chula Vista. Therefore,
impacts would be less than significant.
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.
City of Chula Vista MSCP Consistency
Habitat Loss and Incidental Take Ordinance
The proposed project was assessed to ensure consistency with the City of Chula Vista’s HLIT Ordinance and City of
Chula Vista MSCP Subarea Plan. As discussed in Section 5.3.1.2, Existing Biological Resources, the proposed
project is not a Covered Project and is designated within the MSCP as a Development Area outside of Covered
Projects. A portion of the project site is designated as MSCP 100% Preserve. For projects within Development Areas
outside of Covered Projects that contain sensitive biological resources, the HLIT Ordinance will require biological
evaluation of all resources on site. The surveys discussed earlier and detailed in Appendix D meet the biological
evaluation requirements. In addition, the HLIT does not limit encroachment into MSCP Tier I, II, and III except where
necessary to avoid and/or minimize potential impacts to Narrow Endemic Species and/or Wetlands. As discussed
earlier, where impacts are demonstrated to be unavoidable, impacts within these Development Areas will be limited
to 20% of the total Narrow Endemic Species population within the project site. The only Narrow Endemic Species
listed in the MSCP found within the project site is Otay tarplant, of which 836 out of the 5,449 existing Otay tarplant
would be impacted by the proposed project (Table 5.3-6). The impacts to Otay tarplant consist of approximately
15% of the existing population, which would be under the 20% of the total Narrow Endemic Species population
threshold as stated in the MSCP. Within areas mapped as 100% Preserve, impacts to Narrow Endemic Species
must be limited to 5% of the total population within a project site. The existing Otay tarplant population within the
Preserve is 4,044 plants, 142 of which would potentially be impacted by the proposed project. This would constitute
approximately 3.5% of the Otay tarplant population within the Preserve, which complies with the thresholds outlined
in the MSCP. The proposed project would comply with the HLIT Ordinance as stated within the MSCP and impacts
would be less than significant.
Boundary Line Adjustment
The current project proposes an MSCP Preserve BLA, as discussed further in the Functional Equivalency Analysis
Report (Appendix D). A biological function equivalency would demonstrate how the proposed MSCP Preserve BLA
within the project property would result in equal or higher biological value as compared to the existing Preserve in
accordance with meeting the six BLA functional equivalency criteria. The six BLA functional equivalency criteria are
further discussed below.
There is a conflict between the currently proposed development boundaries and the mapped Preserve on site.
The MSCP states that “these 100% Conservation Areas-Preserve are either already in public ownership or will be
dedicated into Preserve as part of the development approval process for Covered Projects ”. However, the
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placement of the 100% Conservation Areas/Preserve overlay rather than a 75%–100% Preserve was premature
on the project site based on the fact that the proposed project was not identified as a Covered Project and design
had not developed to the extent necessary to fully establish limits of preserve and d evelopment. The conflict
between the proposed project and the mapped Preserve requiring an MSCP Preserve BLA today would not have
existed if the preservation were 75%–100%. To rectify these issues between MSCP planned conservation and
the proposed developm ent, a MSCP Preserve boundary correction , or a BLA, would be required. A boundary
correction is characterized as a corrective action to address an inadvertent error in the initial mapping of the
preserve areas within the City. The proposed Preserve BLA would modify the existing Preserve boundary
predominantly in two distinct areas to accommodate the proposed project development footprint on either side
of the main access road where these areas are different from the mapped MSCP Development Areas on site
(Figure 5.3-4; Figure 5.3-5, MSCP Preserve BLA Map). The proposed Preserve BLA provided as Give and Take
areas is depicted on Figure 5.3-5.
As a part of the MSCP BLA process, the project would need to propose a potentially suitable area(s) currently located
outside of the Preserve to “Give” to the MSCP Preserve of equal size to the portion of land that would “Take” from the
Preserve (1:1 acreage ratio). In addition, a proposed Preserve BLA would need to result in equal or higher biological value
as compared to the existing Preserve in accordance with meeting the six Count of San Diego Multiple Habitat Planning
Area BLA functional equivalency criteria (Appendix D). These six criteria are outlined in detail below.
1. Effects on significantly and sufficiently conserved habitats
The applicable project site habitats that are considered significantly and/or sufficiently conserved include Diegan
coastal sage scrub, riparian scrub, and freshwater marsh. The MSCP BLA, as summarized in Table 5.3-8, would
result in a higher acreage of conservation of riparian habitat (i.e., southern willow scrub), and freshwater marsh
(i.e., coastal and valley freshwater marsh) through on-site preservation in the proposed Give; and equal
conservation for Diegan coastal sage scrub through on -site preservation of Diegan coastal sage scrub within the
proposed Give and habitat restoration of non‐native grassland restored to Diegan coastal sage scrub within
additional areas of proposed Give (Figures 5.3-4 and 5.3-5). It is estimated that 2.91 acres out of the total 4.53
acres of habitat restoration areas include proposed manufactured slopes that would be restored to support Diegan
coastal sage scrub habitat. It is expected that the proposed BLA exchange would maintain the conservation acreage
and status of these significantly and sufficiently conserved habitats.
2. Effects on Preserve configuration and management
The proposed project MSCP BLA, as shown on Figure 5.3 -5 and summarized in Table 5.3-8, would result in an
equal to or greater conservation corridor and configuration as compared to the existing Preserve. The proposed
MSCP Preserve BLA includes the addition of a wider conservation corridor along the easternmost portion of Poggi
Creek, a slight reduction of the Preserve conservation corridor along the central reach of Poggi Creek, and an
addition to the Preserve located just west of the main access entry that includes a portion of Poggi Creek itself
as well as the adjacent upland habitat that supports sensitive species to the south resulting in an equal to or
greater Preserve configuration (Figure 5.3-5 and Table 5-3-8). Further, the proposed BLA includes smaller areas
along the Poggi Creek habitat corridor to fill in gaps of Preserve that were not included in the Preserve
configuration in the 2003 City Subarea Plan. In addition, the proposed BLA would reduce the Preserve along the
southeastern extent of the existing Preserve that connects with off -site the MSCP Minor Amendment Area to the
south but is generally consistent with the on -site Preserve boundary geometry . As a note, there are three distinct
areas of proposed Take from temporary construction impacts that encroach into the existing Preserve where native
habitat restoration is proposed in the northeastern portion of the project site (Table 6 and Figure 6 of Appendix D2).
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These three Take areas are surrounded and contiguous with the existing Preserve and proposed Give-habitat
restoration areas that will be included in the Preserve and as such after habitat restoration is complete would
provide a biological function to the ultimate Preserve, despite being a Take in this proposed BLA. It is expected that
the proposed BLA exchange would maintain the Preserve general configuration and management as intended
and provided in the City’s MSCP Subarea Plan .
3. Effects on ecotones or other conditions affecting species diversity
The proposed project MSCP BLA would generally result in an equal or greater ecotone condition considering the
wider habitat buffer between Poggi Creek and the proposed development area in the eastern half of the project
site, the proposed addition of smaller areas to fill in the gaps of the existing Preserve, as well as the reduction of
edge in the proposed Preserve in the location where the proposed western main access bisects the existing
Preserve, as shown on Figure 5.3-5. In addition, the project proposes native habitat restoration in a majority of the
Give areas that currently support non‐native grassland in the vicinity of the eastern access road. These habitat
restoration areas are expected to improve the habitat quality, species diversity, and overall biological function within
the ecotones located between the proposed development and the proposed Preserve including Poggi Creek.
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Table 5.3-8. City of Chula Vista MSCP Preserve Boundary Line Adjustment Habitats and Acreages
Habitat Type/
Biological Resources
MSCP Tier
Habitat Type
Total on Site
(Acres)
City of Chula Vista MSCP Preserve BLA (Acres)
Existing Proposed
Preserve
Development
Area
Proposed Preserve
Addition/Give
Proposed Preserve
Removal/Take
Net Change to
100% Preserve
Southern willow scrub Wetland 2.06 1.14 0.92 0.22 0.00 +0.22
Mule fat scrub Wetland 0.03 0.03 0.00 0.00 0.00 0.00
Coastal and valley
freshwater marsh
Wetland 7.66 6.31 1.35 0.24 0.00 +0.24
Native grassland I 24.09 19.38 4.71 0.37 3.40 -3.03
Diegan coastal sage
scrub
II 37.08 24.46 12.62 0.91 1.48 and 0.04 Habitat
Restoration**
-0.61
Non-native grassland III 64.19 10.31 53.88 0.46 and 4.53
Habitat Restoration*
1.64 and 0.11 Habitat
Restoration**
+3.23
Non-native vegetation IV 0.53 0.44 0.09 0.04 0.00 +0.04
Urban/developed N/A 0.06 0.00 0.06 0.00 0.00 0.00
Total 135.70 62.07 73.63 6.77 6.68 +0.09
Source: Appendix D.
* Proposed habitat restoration (4.53 acres) from non‐native grassland to native grassland and Diegan coastal sage scrub within Give areas located in the eastern portion of the
site. A portion of these habitat restoration areas (2.91 acres) are located within proposed manufactured slopes.
** Proposed habitat restoration within three distinct areas of take from temporary impacts that encroach into the existing Preserve.
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4. Effects to species of concern not on the Covered Species list
The proposed project MSCP BLA would result in an equal to or greater Preserve that would include native grassland
and Diegan coastal sage scrub habitat restoration within the proposed Give Preserve areas. The proposed Preserve
BLA would benefit Covered Species as well as other sensitive species that are not covered under the City’s MSCP
Subarea Plan such as decumbent goldenbush, San Diego viguiera, San Diego marsh elder, southwestern spiny
rush, and potentially grasshopper sparrow (not currently present within the project site but may be potentially in
future) within the Give areas including the proposed habitat restoration areas that are contiguous with existing
Preserve that supports native habitat within a widened conservation buffer along Poggi Creek. These non-covered
species within the proposed Give areas would be conserved and managed within the Proposed Preserve and as
such benefit the onsite populations of these species. There are a few sensitive species not on the Covered Species
list (i.e., decumbent goldenbush, San Diego viguiera) found on site that will decrease in numbers due to the
proposed Take; however, the proposed native habitat restoration within the proposed Give areas would include
these species in the plant palette and therefore, it is expected that the on-site populations of these species would
be maintained in the proposed Preserve.
5. Effects to Covered Species
The proposed project MSCP BLA would affect the following Covered Species: Otay tarplant and coastal California
gnatcatcher. Approximately 142 Otay tarplant would be removed from the existing Preserve in the take area of
proposed BLA, as shown in Figure 5.3-5. The areas that are proposed to be added to the Preserve per the BLA
would support 718 Otay tarplant (400% greater counts) and the proposed Give‐habitat restoration from non‐native
grassland to native grassland would be restored to support Otay tarplant and other rare plants through clay soil
salvage and seed translocation (Appendix D). The combination of Give and Give-habitat restoration areas in the
proposed project BLA exchange would increase the conservation of Otay tarplant in the Preserve.
USFWS designated Otay tarplant critical habitat in 2001. The City of Chula Vista MSCP Subarea Plan adopted in
2003 included the extent of Otay tarplant critical habitat that occurs on site within the Preserve. The proposed
project BLA would overlap with Otay tarplant critical habitat in some areas (Appendix D). City MSCP Section 5.9
Critical Habitat, specifically addresses critical habitat for three Covered Species including Otay tarplant. It states
that in approving the MSCP, the USFWS included in their BO for the MSCP findings regarding whether activities
permitted under the Section 10(a)(1)(B) permit would result in the destruction or adverse modification of the critical
habitat. The MSCP permits development in nonessential areas for each of the Covered Species, establishes a
hardline Preserve, employs long‐term conservation for the protection of Covered Species, and employs added
protections for Narrow Endemic species (including Otay tarplant) and wetlands. Because of these factors, it is
anticipated that no additional special management considerations or protection would be necessary for the Otay
tarplant, as a result of either the implementation of the MSCP or any future federally permitted Covered Activity
within the areas designated as critical habitat for those species. Therefore, since the City MSCP provided for future
BLAs, the proposed BLA Take of Otay tarplant critical h abitat would be addressed by implementing the long-term
conservation and added protections for Narrow Endemic Species in the MSCP.
The proposed BLA would affect coastal California gnatcatcher suitable habitat through the take of Diegan coastal
sage scrub in the existing Preserve; however, the proposed Give to the Preserve includes additional good quality
Diegan coastal sage scrub located northeast of the gnatcatcher territory in the central portion of the project site
(Figure 5.3-5). In addition, the proposed BLA includes habitat restoration from non‐native grassland to Diegan
coastal sage scrub within the northeastern portion of the site that are not currently occupied by gnatcatcher but
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are located in proximity to existing Diegan coastal sage that would benefit gnatcatcher through an increase in
potential foraging and nesting habitat on site.
6. Effects on habitat linkages and functions of Preserve areas
The proposed project MSCP BLA would generally maintain the habitat linkages and functions of the Preserve.
In some areas of the proposed BLA, habitat linkages would be improved, but in other areas habitat linkages
would be reduced . More specifically, the p roposed BLA would result in a greater habitat linkage connectivity
and function in the Preserve along Poggi Creek due to the addition of smaller areas within Poggi creek to the
Preserve and the larger habitat buffers south of the creek that would better fa cilitate wildlife use and
movement in this area of the Preserve (Figure 5.3 -5). The proposed BLA along the southeastern extent of the
Preserve would result in less conserved habitat connectivity along the southern boundary to other habitat to
the south into the Minor Amendment Area.
Conclusion
The proposed project’s BLA would comply with the six Multiple Habitat Planning Area BLA functional equivalency
criteria, which is a requirement of the City MSCP BLA guidelines. Therefore, impacts would be less than significant
and no mitigation measures are required.
Facilities Siting Criteria
The proposed project includes a MSCP Future Facility (i.e., detention basin) that would be located partially in the
existing Preserve on site (see Figure 5.3-5). The relocation of this basin was considered in the project design to
avoid or minimize impacts to the Preserve but was determined to be site specific due to the necessary topography
for drainage and the confined development configuration due to the avoidance of wetlands and Otay tarplant (a
narrow endemic) in this area; however, the size and configuration of the basin was modified to reduce impacts to
the Preserve to the maximum extent practicable. The City MSCP, Chapter 6.0 Land Use Considerations in the
Preserve, identifies permitted uses including Future Facilities within the Preserve. Future Facilities are subject to
the MSCP Facilities Siting Criteria which ensures that the facilities located within the Preserve have been sited
within the least environmentally sensitive areas and that impacts to the Preserve have been minimized to the
maximum extent practical. The City of Chula Vista is allotted up to 50 acres of impact/”Take” for Future Facilities.
The cumulative impacts to covered habitats from Future Facilities, including the proposed Sunbow Future Facility
(i.e., detention basin) within the City of Chula Vista are summarized in Table 5.3-9 below. The proposed Future
Facility‐Detention Basin (1.12 acres) is partially within an area of the existing Preserve on site. The Future Facility-
Detention Basin can be seen in Figure 5.3-4.
Table 5.3-9. Cumulative Impacts to Covered Habitat from Future Facilities
Project Project Permanent Impacts to Covered Habitat (acres)
Village Eleven 0.50
Village Two 0.10
Village Eight West 0.09
Village Nine 0.20
Village Three North, Village Eight East, Village Ten 6.10
Village Four 1.23
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Table 5.3-9. Cumulative Impacts to Covered Habitat from Future Facilities
Project Project Permanent Impacts to Covered Habitat (acres)
UID 4.00
Sunbow II Phase 3 (Proposed Project) 1.12
Total Cumulative Impacts 13.34
Remaining Acres (out of 50 acres) 36.66
Source: Appendix D.
The proposed project has been designed to completely avoid any wetland habitat impacts and would predominantly
result in impacts to non‐native grassland consisting primarily of densely thatched non‐native grasses (Impact BIO-
11). In addition, the proposed project would result in significant impacts to Diegan coastal sage scrub, specifically
within the proposed Future Facility-Detention Basin area, as well as impacts to native grassland, within the
southwestern portion of the area proposed for residential uses, as discussed in Threshold B (Impact BIO-11). The
siting of the proposed Future Facility-Detention Basin within the Preserve is analyzed in the project Facility Siting
Criteria Report(Appendix D).
100% Preserve Compatible and Conditionally Compatible Uses
Projects within Preserve areas outside Covered Projects are limited to certain Compatible Uses or Allowed Uses
within the Preserve, as described in the City’s MSCP. The project’s consistency with Compatible Uses or Allowed
Uses within the Preserve is outlined below.
Compatible uses and conditionally compatible uses in the Preserve are land uses and activities that are compatible
with the biological objectives of the MSCP Subregional Plan and the City’s MSCP. 100% Preserve compatible uses
include public access and recreation, preserve management, including scientific and biological activities, and
emergency safety and police services. Conditionally compatible uses consist of mining, flood control, and
road/infrastructure activities that include planned and future facilities. As discussed in Chapter 4, Project
Description, of this EIR, the Preserve is intended to remain unimproved and/or restored and its use strictly limited.
Vegetation would consist of native plants that already occur on site. Only under limited circumstances may certain
amenities and facilities, as determined by the City to be compatible with the goals and objectives of the City’s MSCP,
be permitted within the Preserve. Any proposed amenities or facilities within the MSCP Preserve area shall be
subject to the prior review and approval of the Director of Development Services.
The project proposes a Future Facility-Detention Basin that is partially within an area of the existing Preserve on
site (see Figure 5.3-5). The relocation of this basin was considered in the project design to avoid or minimize impacts
to the Preserve but was determined to be site specific due to the necessary topography for drainage and the
confined development configuration due to the avoidance of wetlands and Otay tarplant (a narrow endemic) in this
area; however, the size and configuration of the basin was modified to reduce impacts to the Preserve to the
maximum extent practicable. This encroachment would qualify as a Future Facility in the Preserve.
Therefore, the proposed project would remain consistent with land uses within the Preserve and impacts would be
less than significant.
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Narrow Endemic Policy and Wetland Protection Program Narrow Endemic Policy
Otay tarplant is the only Narrow Endemic Species that is known and/or expected to occur within the project site.
Based on 2019 ‐2020 Otay tarplant field surveys completed on the project site, the on-site population is
estimated to be 5,449 plants predominantly located in the western half of the project site within the existing
Preserve (4,044 plants within the Preserve and 1,405 plants outside the Preserve). Of the 5,449 on-site Otay
tarplant population, the proposed project would impact an estimated 142 Ota y tarplant plants (2.6%) inside the
Preserve and 694 Otay tarplant plants (12.7%) outside the Preserve/within Development Area (Table 5.3 -6).
Impacts to Otay tarplant would be potentially significant, as discussed in Threshold A (Impact BIO-1). However,
to ensure consistency with the City’s MSCP Narrow Endemic Policy, the proposed project would minimize impacts
to Otay tarplant to less than 5% within the Preserve and less than 20% within the Development Area with
implementation of MM-BIO-1 through MM-BIO-3.
The proposed project would meet the MSCP Narrow Endemic Policy based on the estimated Otay tarplant population
on-site totals and estimated plants to be impacted in the Preserve and the Development Area that are below the
Narrow Endemic Policy impact thresholds, as provided in Table 5.3-10. The proposed project would ensure
consistency with MSCP Narrow Endemic Policy Section 5.2.3.3 for Development Areas outside of Covered Projects,
where applicable by limiting the proposed impacts to the existing Otay tarplant population within the project site to
less than 5% of the population within the Preserve and less than 20% of the population outside of the Preserve
(see Table 5.3-10). Therefore, impacts related to plan consistency would be less than significant.
Table 5.3-10. Narrow Endemic Policy – Estimated Otay Tarplant Impact Assessment
Total Estimated Otay
Tarplant Population in
Project Area/ On Site
Preserve Development Area (Outside Preserve)
Individual
Impact Percent
Narrow Endemic
Policy (<5%)
Individual
Impact Percent
Narrow Endemic
Policy (<20%)
5,449 142 2.6% Consistent/
Meets Policy
694 12.7% Consistent/
Meets Policy
Source: Appendix D.
Wetlands Protection Program
As discussed under Threshold C, the project proposes to completely avoid any impacts to wetland; therefore, the
project would be consistent with the Wetlands Protection Program provided in the City’s MSCP, Section 5.2.4.
Therefore, impacts would be less than significant.
MSCP Conditions of Coverage
Coastal California Gnatcatcher Condition of Coverage
The MSCP Condition of Coverage for coastal California gnatcatcher specifies that the area specific management
directives must include measures to reduce edge effects and minimize disturbance during the nesting period, fire
protection measures to avoid habitat degradation due to unplanned fire, management measures to maintain and
improve habitat quality, and prohibit clearing of occupied habitat during gnatcatcher breeding season (March 1‐August
15) within the Preserve. Therefore, prior to implementation of mitigation, impacts would be potentially significant (Impact
BIO-6 and BIO-7). However, the proposed project would comply with and address the applicable Conditions of Coverage
as specified in Section 5.3.5, Mitigation Measures (see MM-BIO-4 through MM-BIO-5). Therefore, with implementation
of MM-BIO-4 through MM-BIO-5, impacts would be reduced to a less-than-significant level.
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Least Bell’s Vireo Condition of Coverage
The MSCP Condition of Coverage for least Bell’s vireo specifies that the area specific management directives must
include measures consistent with the ACOE 404(b)(1) Guidelines into the project where applicable. In addition,
measures to provide appropriate successional habitat, upland buffers for known populations, cowbird control, and
measures to reduce edge effects, as well as, prohibit clearing of occupied habitat during vireo breeding season
(March 15‐September 15). Therefore, prior to implementation of mitigation, impacts would be potentially significant
(Impact BIO-8). However, the proposed project would completely avoid direct impacts to least Bell’s vireo through
implementation of MM-BIO-6) and would provide a conserved upland buffer to the one vireo pair on site that is
limited to the northeastern most portion of riparian habitat on site. Further, the project proposes measures such as
vegetation barriers, fencing, and night light shielding to avoid and/or reduce potential edge effects (MM-BIO-8
through MM-BIO-13) to the vireo pair within Poggi Creek. Due to the limited vireo presence/population on site and
uncertainty regarding a least Bell’s vireo population within Poggi Creek upstream to the east, the project does not
propose a brown‐headed cowbird control program on site. These cowbird control programs are typically
implemented and most cost effective within a river system where a larger known vireo population within conserved
lands would benefit. Although the project does not propose any direct impacts to vireo occupied habitat, the project
proposes to comply and address the applicable Conditions of Coverage as specified in Section 5.3.5 (MM-BIO-7).
Therefore, with implementation of MM-BIO-7, impacts would be reduced to a less-than-significant level.
Orange-Throated Whiptail Condition of Coverage
The MSCP Condition of Coverage for orange‐throated whiptail specifies that the area specific management
directives must include measures to address edge effects. However, as discussed in Threshold A, the orange-
throated whiptail is not expected to be abundant within the project site as it was observed on one occasion during
the numerous surveys conducted during the 2019-2020 field survey effort, as summarized in the Table 5.3-5
above. Therefore, impacts would be less than significant.
Cooper’s Hawk Condition of Coverage
The MSCP Condition of Coverage for Cooper’s hawk specifies that the area specific management directives
must include 300 ‐foot impact avoidance areas aro und active nests and minimization of disturbance to oak
woodlands and oak riparian forests. No Cooper’s hawk potentially suitable nesting habitat including oak
woodlands and oak riparian forests occur within the proposed development area. This species was not
observed nesting or exhibiting any nesting behavior on site. Therefore, the Conditions of Coverage are not
applicable and there would be no impacts .
Northern Harrier Condition of Coverage
The MSCP Condition of Coverage for northern harrier specifies that the area specific management directives must
include the following: (1) manage agricultural and disturbed lands (which become part of the Preserve) within four
miles of nesting habitat to provide foraging habitat; (2) include an impact avoidance area (900 feet or maximum
possible within the Preserve) around active nests; and (3) include measures for maintaining winter foraging habitat
in Preserve areas in Proctor Valley, around Sweetwater Reservoir, San Miguel Ranch, Otay Ranch east of Wueste
Road, Lake Hodges, and San Pasqual Valley. No nesting northern harrier occur on site and none are expected. The
northern harriers on site were only flying over and potentially foraging on site. No agricultural or disturbed lands
occur within the proposed Preserve or within the project site; however, the non‐native grassland along with the
other potential raptor foraging habitat within the on-site Preserve will be managed to provide potential foraging
habitat for a variety of raptors including northern harrier. Therefore, impacts would be less than significant.
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Otay Tarplant Condition of Coverage
The MSCP Condition of Coverage for Otay tarplant specifies that the area specific management directives must
include measures for monitoring of populations, adaptive management of preserves, and measures to protect
against detrimental edge effects. The project proposes to comply and address the Conditions of Coverage where
applicable as specified in Section 5.3.5. Additionally, impacts to Otay tarplant (Impact BIO-1) would be mitigated
with the implementation of MM-BIO-1 and MM-BIO-2. Therefore, with implementation of MM-BIO-1 and MM-BIO-2,
impacts would be reduced to less than significant.
Orcutt’s Bird’s-Beak Condition of Coverage
The MSCP Condition of Coverage for Orcutt’s bird’s‐beak specifies that strategies to provide protection for this
species within the Minor Amendment Area must be included at the time any MSCP Minor Amendments are
proposed. The proposed project temporary grading impacts in the Minor Amendment Area directly south of the
Sunbow property does not support Orcutt’s bird’s‐beak. Therefore, no impacts would occur.
Coast Barrel Cactus Condition of Coverage
The MSCP Condition of Coverage for coast barrel cactus specifies that the area specific management directives
must include measures to address edge effects, unauthorized collection, and fire management/control practices.
The project proposes to comply and address the Conditions of Coverage where applicable as specified in Section
5.3.5. Therefore, impacts would be less than significant.
Adjacency Management Guidelines
The City of Chul a Vista requires that land uses adjacent to the MSCP Preserve be managed to avoid and
minimize impacts to the preserve; therefore, project mitigation measures pertaining to lighting (MM-BIO-9),
noise (MM-BIO-4 through MM-BIO-6 ), landscaping (MM-BIO-10), access (MM-BIO -8), and drainage (MM-BIO-
11) would be required to ensure consistency with the City’s MSCP , Section 7.5.2, Adjacency Management
Guidelines , and ensure the long ‐term viability of wildlife and sensitive habitats in the Preserve. These
Guidelines and applicability to the proposed project are summarized below and incorporated where applicable
into project mitigation measures as provided in Section 5.3.5.
Drainage
1. All developed and paved areas must prevent the release of toxins, chemicals, petroleum products, exotic
plant materials and other elements that might degrade or harm the natural environment or ecosystem
processes within the Preserve through the use of a variety of methods including natural detention basins,
grass swales or mechanical trapping devices.
2. Develop and implement urban runoff and drainage plans which will create the least impact
practicable for all development adjacent to the Preserve. All development projects will be required
to meet NPDES standards and incorporate BMP s as defined by the City ’s Standard Urban Storm
Water Mitigation Plan (SUSMP).
3. Pursuant to the San Diego RWQCB Municipal Permit, and the City of Chula Vista Storm Water Management
Standards Requirements Manual, all development and redevelopment located within or directly adjacent
to or discharging directly to an environmentally sensitive area are required to implement site design, source
control, and treatment control BMPs.
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4. Require all NPDES‐regulated projects to implement a combination of BMPs as close to potential pollutant
sources as feasible. The proposed project would comply with the applicable drainage and storm water
permits and implement features such as vegetated detention basins to avoid the potential release of toxins,
chemicals, and other elements from entering the Preserve and ensure consistency with the Guidelines.
The proposed project would comply with the applicable drainage and storm water permits and implement features such
as vegetated detention/water quality basins to avoid the potential release of toxins, chemicals, and other elements from
entering the Preserve and ensure consistency with the Guidelines. Therefore, impacts would be less than significant.
Toxic Substances
All agricultural uses, including animal ‐keeping activities, and recrea tional uses that use chemicals or general
by‐products that are impactive to biological resources or water quality need to incorporate methods on their
site to reduce impacts caused by the application and/or drainage of such materials into the Preserve. Met hods
shall be consistent with requirements of the San Diego RWQCB and NPDES standards and therefore impacts
would be less than significant.
The proposed project does not include any agricultural uses or recreational uses that would result in potential
impacts from toxic substances entering into the Preserve.
Lighting
Lighting of all developed areas adjacent to the Preserve should be directed away from the Preserve wherever
feasible and consistent with public safety. Where necessary, development should prov ide adequate shielding with
non‐invasive plant materials (preferably native), berming, and/or other methods to protect the Preserve and
sensitive species from night lighting. As provided in the City’s MSCP, consideration should be given to the use of
low‐pressure sodium lighting.
Although the specificity of the proposed lighting plan is not available at this time, the proposed project would include
the use of outdoor lighting along roadways and in association with proposed buildings that may have the p otential
to spill into the adjacent Preserve (Impact BIO-12). Therefore, the proposed project would result in potentially
significant impacts. Due to this potential impact, the project would incorporate MM-BIO-9, which requires adequate
shielding and the potential use of low‐pressure sodium lighting to ensure consistency with the Guidelines.
Noise
Uses in or adjacent to the Preserve should be designed to minimize noise impacts. Berms or walls should be
constructed adjacent to commercial areas and any other use that may introduce noises that could impact or
interfere with wildlife utilization of the Preserve. Excessively noisy uses or activities adjacent to breeding areas,
including temporary grading activities, must incorporate noise reduction measures or be curtailed during the
breeding season of sensitive bird species, consistent with Table 3‐5 of the MSCP Subregional Plan.
The Poggi Creek portion of the Preserve and the north ‐facing slope directly adjacent to the creek are close to
Olympic Parkway, a busy roadway that is a source of consistent noise from vehicular traffic. The northern portion of
the project site likely has a higher ambient noise level than the southern portion of the site due to the Olympic
Parkway traffic noise levels and thus the proposed noise levels may or may not result in substantially greater noise
levels. Conversely, the proposed project may potentially introduce elevated noise levels into the Preserve
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particularly along the southwestern boundary of the proposed development where the current conditions are
relatively quiet. Therefore, impacts would be potentially significant (Impact BIO-12). Due to this potential impact,
the project would implement MM-BIO-4, MM-BIO-5, MM-BIO-6 and MM-BIO-7, which requires the avoidance of the
breeding season for construction activities to ensure consistency with the Guidelines.
Invasives
No invasive non‐native plant species shall be introduced into areas immediately adjacent to the Preserve. All open
space slopes immediately adjacent to the Preserve should be planted with native species that reflect the adjacent
native habitat. The plant list contained in the Wildland / Urban Interface: Fuel Modification Standards (Appendix K
of the City’s MSCP), must be utilized to the maximum extent practicable when developing landscaping plans in
areas adjacent to the Preserve.
The proposed project includes fuel modification zones within the project development adjacent to the Preserve as
well as landscape areas that have the potential to introduce invasive non-native species into the Preserve
Therefore, impacts would be potentially significant (Impact BIO-12). Due to this potential impact, the project would
incorporate MM-BIO-10, which requires the prohibition of invasive plant species in the planting palette as well as
the maintenance and monitoring of the adjacent areas to ensure consistency with the Guidelines.
Buffers
There are no requirements for buffers outside the Preserve, except as required for Wetlands pursuant to Federal
and/or State permits, or by local agency CEQA mitigation conditions. All open space requirements for the Preserve
shall be limited to the Preserve and do not include any buffers that extend beyond the Preserve boundary. Fuel
modification zones must be consistent with City’s MSCP, Section 7.4.4.
The proposed project has incorporated appropriate wetland buffers to ensure avoidance from project construction and
implementation. In addition, proposed fuel modification zones are included in the project development footprint as a
proposed impact. The proposed Preserve includes open space to be conserved in perpetuity as well as some areas of
proposed habitat restoration that will include sensitive plant species. Therefore, impacts would be less than significant.
MSCP Minor Amendment Area
The City-owned property directly south of the proposed project site is designated a Minor Amendment Area (Figure
5.3-1; Figure 5.3-4). Designated Minor Amendment Areas throughout the City are not currently a part of the City’s
MSCP and do not receive any take authorization or coverage benefits. Minor Amendment Areas may be incorporated
into the City’s MSCP through the Minor Amendment Process described in the City’s MSCP, Section 5.1.3.1.
The Applicant is working with the City to request a Minor Amendment to allow off-site temporary grading impacts
that would encroach 25 feet onto the City’s property and within this Minor Amendment Area, which is located directly
south of the proposed project (see Figure 5.3-1) (Impact BIO-15). This request for a Minor Amendment would also
require Wildlife Agency concurrence.
This potential encroachment onto the City property would consist of a 25‐foot grading buffer for temporary construction
equipment access and grading as well as a minor excavation and fill for a buttress to address slope stability that would be
located entirely within the 25‐foot construction buffer. The temporary impact areas in the 25‐foot grading buffer within the
Minor Amendment Area from project construction activities and buttress construction (Impact BIO-15) would be revegetated
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with a native erosion control hydroseed mix acceptable to the City and Wildlife Agencies to ensure soil stability and prevent
subsequent erosion (MM-BIO-14); further, these temporary impacts would be fully mitigated within the proposed project
site inside the Preserve. The requested off-site temporary impacts onto City property are included in the total proposed
project impacts and proposed on-site mitigation as provided above in the impact analysis and quantified in Tables 5.3-4
and 5.3-7. Because the proposed project would result in temporary impacts to the Minor Amendment Area, impacts would
be potentially significant (Impact BIO-15) and would require implementation of MM-BIO-14 through MM-BIO-16 to reduce
impacts to a level below significance.
HLIT Draft Findings
In order for the City of Chula Vista to approve or conditionally approve a HLIT permit, all of the draft Section
17.35.080 HLIT Findings such as those that demonstrate the project and associated mitigation are consistent with
the Subarea Plan and the project results in minimum disturbance to sensitive biological resources, except impacts
to natural vegetation in mapped development areas, shall be made by the decision maker.
The project is consistent with the HLIT Ordinance including the Findings the City needs to make for Issuance of HLIT
Permit (Section 17.35.080) and applicable MSCP Subarea Plan Sections 5.2.3 and 5.2.4 that addresses impacts
to Narrow Endemics and Wetlands, as discussed above. Further, the project is consistent with applicable general
and specific MSCP development regulations/standards as specified in the HLIT, Section 17.35.090, including but
not limited to those summarized below:
• Project impacts located on the least environmentally sensitive portions of the site to minimize impacts to
sensitive biological resources to the maximum extent practicable.
• Wetland impacts shall be avoided.
• Grading during applicable wildlife breeding seasons shall be avoided.
• Temporary impact areas to sensitive biological resources shall be revegetated with native species.
The draft HLIT Findings for the project are included in Appendix D. The City shall finalize the HLIT Findings during
the HLIT Permit process. Therefore, impacts would be less than significant.
5.3.4 Level of Significance Prior to Mitigation
Prior to mitigation, the proposed project would have potentially significant impacts associated with sensitive flora, sensitive
fauna, loss of sensitive and important habitats, inconsistencies with the City’s MSCP, and temporary construction impacts
within the Minor Amendment Area. Impacts prior to mitigation would be potentially significant. Impacts would be reduced
to a less-than-significant level after implementation of the mitigation measures listed in Section 5.3.5.
5.3.5 Mitigation Measures
The following mitigation measures would reduce identified significant impacts associated with biological
resources to a less than significant level. Refer also to Table 5.3 -11 for the project habitat impact areas and
mitigation requirements.
Impacts to Sensitive Upland Habitats Consisting of Native Grassland, Diegan Coastal Sage Scrub, Non -native
Grassland (Impact BIO-11) that support Sensitive Wildlife and Plant Species (Impacts BIO-1 through BIO-7) and
Raptor Foraging Habitat (Impact BIO-9) would be mitigated by MM-BIO-1 and MM-BIO-2:
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MM-BIO-1 The Applicant shall include an irrevocable offer of dedication (IOD) to the City of Chula Vista on the
first final map for 62.16 acres of onsite Preserve land within Preserve Management Area 3,
Subunits 3-1a, 3-1b, and 3-1c of the Chula Vista Central City Preserve lands. The MSCP Preserve
land shall be conserved, maintained, and managed by the City of Chula Vista or its designee in
perpetuity as directed in the Chula Vista Central City Preserve Area-Specific Management Directives
(ASMDs) for Preserve Management Area 3 (PMA 3) (RECON Environmental, April 26, 2004) and
funded by the Sunbow Preserve Community Facilities District (No. 98-3). The City of Chula Vista
Preserve Habitat Manager shall be responsible for the long-term Preserve management activities
identified in the Central City Preserve ASMD. Said IOD for the 62.16 acres Proposed MSCP Preserve
shall include 48.95 acres to mitigate for significant habitat impacts to 7.79 acres of native
grassland, 8.55 acres of Diegan coastal sage scrub, and 55.61 of non‐native grassland as well as
the following sensitive species significant impacts:
• Coastal California Gnatcatcher- occupied Diegan coastal sage scrub to mitigate for significant
direct impacts to coastal California gnatcatcher occupied habitat;
• Otay Tarplant- 0.34 acre of Otay tarplant occupied habitat (i.e.,native grassland) to mitigate for
direct impacts to 0.34 acre of Otay tarplant occupied habitat that currently supports 836 Otay
tarplant individual plants;
• Orcutt’s Bird’s-beak- Orcutt’s bird’s-beak habitat (i.e., Diegan coastal sage scrub) to mitigate
for significant direct impacts to onsite Diegan coastal sage scrub that currently supports 91
Orcutt’s bird’s‐beak individual plants;
• Decumbent Goldenbush- Decumbent goldenbush habitat (i.e., Diegan coastal sage scrub and
native grassland), that includes at least 289 decumbent goldenbush individual plants) to
mitigate for significant direct impacts to onsite native grassland and Diegan coastal sage scrub
that currently supports 289 decumbent goldenbush individual plants; and
• San Diego Viguiera - San Diego viguiera habitat (i.e., Diegan coastal sage scrub) that
includes at least 2,979 San Diego viguiera individual plants) to mitigate for significant
direct impacts to onsite Diegan coastal sage scrub that currently supports 5,958 San Diego
viguiera individual plants.
MM-BIO-2 Prior to initiation of construction related activities including clearing and grubbing or prior to
vegetation/ground disturbance or prior to site mobilization activities or issuance of a grading
permit, the Applicant shall submit documentation to the City demonstrating that the Applicant has
contracted with a qualified biologist(s) to monitor the project construction activities and avoid a ny
inadvertent impacts to sensitive biological and ensure complete avoidance of jurisdictional
resources. Each qualified biologist shall have demonstrated expertise with the sensitive habitats,
special status species of the project region. The qualified biologist(s) shall monitor the installation
of the construction temporary fencing and/or flagging, silt fencing, and other best management
practices (BMPs) along the construction limits prior to construction activities. The qualified biologist
shall be present full‐time during all initial vegetation clearing and grubbing activities, and
potentially on a less frequent basis during grading activities to ensure construction remains within
the approved project development area. The Applicant shall report results of biological monitoring
activities to the City on a regular basis through the preparation and submission of summary
monitoring reports.
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Impacts to Sensitive Plant Species (Otay tarplant [Impact BIO-1], Orcutt’s bird’s-beak [Impact BIO-2], decumbent
goldenbush [Impact BIO-3], and San Diego County viguiera [Impact BIO-4]) would be mitigated by MM-BIO-1 and
MM-BIO-2 listed above, and MM-BIO-3:
MM-BIO-3 Prior to the issuance of any land development permits including for clearing and grubbing or grading,
the Applicant shall prepare a Restoration Plan prepared by a qualified biologist to mitigate for impacts
to sensitive plant species consisting of Otay tarplant, Orcutt’s bird’s-beak, decumbent goldenbush, and
San Diego County viguiera consistent with the Habitat Restoration and Sensitive Plant Specifies
Mitigation Plan (Merkel & Associates, Inc. 2021, Appendix D). The Applicant shall implement the 5-year
maintenance and monitoring activities consistent with the Conceptual Restoration Plan to the
satisfaction of the Development Services Director (or their designee). The revegetation plan must be
prepared by a qualified City approved biologist familiar with the City’s MSCP Subarea Plan and must
include, but not be limited to, an implementation plan; appropriate seed mixtures and planting method;
irrigation method; quantitative and qualitative success criteria; maintenance, monitoring, and reporting
program; estimated completion time; and contingency measures. The Project Applicant shall be
required to prepare and implement the revegetation plan subject to the oversight and approval of the
Development Services Director (or their designee). NOTE: Since the revegetation is critical to approving
the MSCP Boundary Line Adjustment, the applicant will be required to enter into a Secured Agreement
with the City and will be required to provide a cash deposit.
Impacts to coastal California gnatcatcher territories (Impact BIO-6) and coastal California gnatcatcher potential
suitable habitats (Impact BIO -7 ) would be mitigated by MM-BIO -1 to MM-BIO-2 above and MM-BIO-4 and MM-
BIO -5 below:
MM-BIO-4 To avoid any direct impacts to nesting coastal California gnatcatcher, all vegetation clearing,
grubbing and grading activities within gnatcatcher occupied habitat (i.e., Diegan coastal sage
scrub) shall be conducted outside of the gnatcatcher breeding season (February 15 to August 15).
MM-BIO-5 Prior to initiating any construction related activities requiring a clearing and grubbing or grading
permit, the Applicant shall delineate coastal California gnatcatcher occupied habitat located
adjacent to the proposed project development area during the breeding season (February 15 to
August 15) by orange biological fencing or comparable materials to ensure that no work shall occur
within these habitats. In addition, a minimum 300 -foot buffer and on-site noise
reduction/attenuation techniques shall be incorporated, as appropriate to avoid impacts to
breeding gnatcatcher from elevated construction noise levels. The City Development Services
Director (or their designee) shall have the discretion to modify the buffer width depending on site-
specific conditions. Noise monitoring may be required to ensure that the elevated construction
noise levels are appropriately attenuated at the edge of occupied habitat to a level that is not
expected to adversely affect nesting bird behavior (i.e., not to exceed an hourly average of 60 A-
weighted decibels (dBA) or ambient at the edge of occupied habitat).
Impacts to potentially suitable and contiguous habitat for least Bell’s vireo and nesting least Bell’s vireo (Impact BIO-8)
would be mitigated by MM-BIO-6:
MM-BIO-6 Prior to initiating any construction related activities requiring a clearing and grubbing or grading
permit, the Applicant shall delineate least Bell’s vireo occupied habitat by orange biological fencing
or comparable to avoid direct impact to vireo within occupied habitat located adjacent to the
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proposed project during the breeding season (March 15 to September 15). In addition, a minimum
300-foot buffer and on-site noise reduction/attenuation techniques shall be incorporated, as
appropriate to avoid impacts to breeding vireo from elevated construction noise levels. The City
Development Services Director (or their designee) shall have the discretion to modify the buffer
width depending on site-specific conditions. Noise monitoring may be required to ensure that the
elevated construction noise levels are appropriately attenuated at the edge of occupied habitat to
a level that is not expected to adversely affect nesting bird behavior (i.e., not to exceed an hourly
average of 60 dBA or ambient at the edge of occupied habitat).
Impacts to nesting birds protected under MBTA and CDFG Code Sections 3503 and 3513 (Impact BIO-10) would
be mitigated by MM-BIO-7:
MM-BIO-7 To avoid any direct impacts to migratory birds and/or raptors protected under the federal Migratory
Bird Treaty Act and California Fish and Game Code Sections 3503 and 3513, removal of habitat
that supports active nests on the proposed area of disturbance should occur outside of the
breeding season for these species. The breeding season is defined as January 15 –August 31 for
raptor species and February 15–August 15 for other non-raptor birds (excluding listed species). If
removal of habitat on the proposed area of disturbance must occur during the breeding season,
then prior to initiating any construction related activities requiring a clearing and grubbing or
grading permit, the Applicant shall retain a City-approved biologist to conduct a pre-construction
survey to determine the presence or absence of nesting birds (including burrowing owl) on the
proposed area of disturbance. The pre-construction survey must be conducted within 10 calendar
days prior to the start of construction, and the results must be submitted to the City for review and
approval prior to initiating any construction activities. If nesting birds are detected, a letter report
or mitigation plan, as deemed appropriate by the City, shall be prepared and include proposed
measures to be implemented to ensure that disturbance of breeding activities are avoided. The
report or mitigation plan shall be submitted to the City for review and approval and implemented
to the satisfaction of the City. The City’s mitigation monitor shall verify and approve that all
measures identified in the report or mitigation plan are in place prior to and/or during construction.
To reduce potential impacts to burrowing owl during construction, the City-approved biologist shall
perform pre-construction inspection of potential habitat, and, at minimum, twice weekly
inspections be performed while rough grading is ongoing. All pre-construction survey efforts shall
be conducted prior to any project activities that could result in habitat disturbance to soil,
vegetation or other sheltering habitat for burrowing owl. If any burrowing owls or sign of burrowing
owls are detected, the Wildlife Agencies (jointly, CDFW and USFWS) shall be contacted; efforts shall
be made to determine the breeding status of the species on site, and whether it is safe at that
point to exclude burrowing owls from occupied burrows. Active or passive relocation methods shall
only be employed with concurrence by CDFW and USFWS.
The Applicant shall implement mitigation measures MM-BIO-4 to MM-BIO-6 above and the following mitigation
measures (MM-BIO-8 to MM-BIO-11) to further reduce indirect impacts including edge effects (Impact BIO-12) in
accordance with the City’s MSCP Adjacency Guidelines:
MM-BIO-8 Prior to approval of the first final map, the Applicant shall submit a Landscape Master Plan for the entire
project which shall demonstrate compliance with the proposed fence and wall plan for the project. The
proposed fence and wall plan shall include appropriate fencing and barriers (e.g., vegetation) where
applicable to shield human presence and deter human intrusion into the Preserve.
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MM-BIO-9 Concurrent with design review and prior to issuance of a building permit for any development
located adjacent to the Preserve, the Applicant shall prepare, a lighting plan and photometric
analysis for review and approval the Development Services Director (or their designee). The lighting
plan shall illustrate the location of the proposed lighting standards and type of shielding measures.
Low-pressure sodium lighting shall be used, if feasible, and shall be subject to the approval of the
Development Services Director (or their designee).
MM-BIO-10 Prior to approval of the first final map, the Applicant shall submit a Landscape Master Plan for the entire
project which shall demonstrate compliance with the proposed plant palette for the project. The proposed
plant palette shall prohibit invasive non‐native plant species on the California Exotic Pest Plant Council
List of Exotic Pest Plants of Greatest Ecological Concern in California that could spread into the adjacent
Preserve. No invasive non-native plant species shall be introduced into areas immediately adjacent to the
preserve. All slopes immediately adjacent to the Preserve shall be planted with native species that reflect
the adjacent native habitat. Further, the proposed plant palette shall be consistent with the plant list
contained in the “Wildland/Urban Interface: Fuel Modification Standards,” and provided as Appendix L of
the Subarea Plan, must be reviewed and utilized to the maximum extent practicable when developing
landscaping plans in areas adjacent to the Preserve.
MM-BIO-11 To avoid habitat degradation to the adjacent Preserve lands, project irrigation shall be contained
to the project development and fuel modification zones and shall not drain or overspray resulting
in potential erosion/sedimentation, spread of invasive plant species, and/or non ‐native species
such as Argentine ants.
Inadvertent direct impacts to biological resources (Impacts BIO-5, BIO-11, and BIO-12) would be mitigated with
implementation of MM-BIO-12 and MM-BIO-13:
MM-BIO-12 Prior to initiating any construction related activities requiring a clearing and grubbing or grading
permit, the Applicant shall demonstrate how the project would avoid or minimize applicable
inadvertent impacts during construction. To ensure the avoidance and minimization of impacts to
biological resources during construction the following construction BMPs shall be implemented:
a) Prior to ground disturbance, all permanent and temporary disturbance areas shall be clearly
delineated by orange construction fencing and the identification of environmentally sensitive
areas with flagging and/or fencing.
b) To minimize disturbance of areas outside the project site, all construction and operation vehicle
traffic shall be restricted to established roads, construction areas, and other designated areas.
These areas shall be included in pre‐construction surveys and, to the extent possible, shall be
established in locations disturbed by previous activities to prevent further impacts.
c) Construction and operation vehicles shall observe appropriate safe speed limits and adhere to
safety practices.
d) Dust suppression shall occur during construction activities when necessary to meet air quality
standards and protect biological resources.
e) No vehicles or equipment shall be refueled or undergo maintenance within 100 feet of a
jurisdictional waters feature. Spill kits shall be maintained on the site in sufficient quantity to
accommodate at least three complete vehicle tank failures of 50 gallons each. Any vehicles
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driven or operated within or adjacent to drainages or wetlands shall be checked and
maintained daily to prevent leaks of contaminated fluids.
f) All general trash, food‐related trash items (wrappers, cans, bottles, food scraps, cigarettes,
etc.), and other human‐generated debris scheduled to be removed shall be stored in animal‐
proof containers and removed from the site on a regular basis (weekly during construction, and
at least monthly during operations). No deliberate feeding of wildlife shall be allowed.
g) Use of chemicals, fuels, lubricants, or biocides shall comply with all local, state, and fede ral
regulations. All uses of such compounds shall observe label and other restrictions mandated
by the U.S. Environmental Protection Agency, California Department of Food and Agriculture,
and other state and federal legislation. Use of first‐and second‐ generation rodenticides shall
not be permitted except for the limited use of zinc phosphide, or a rodenticide approved by the
City, and only after other means of pest control (e.g. rodent traps) have proven to be ineffective.
MM-BIO-13 Prior to issuance of a grading permit, prior to vegetation clearing, grubbing, grading, or any ground
disturbing activities, the Applicant shall submit evidence to the City that the Applicant has retained
qualified biologists to prepare a Worker Environmental Awareness Program that shall be presented to all
construction personnel and employees before any ground‐disturbing activities commence at the project
site and shall be continued through the construction phase for all new construction personnel. The
program shall consist of a brief presentation going over the on-site sensitive biological resources and
compliance with project impact and open space boundaries, and applicable environmental laws and
requirements with all personnel involved in the project. This presentation shall explain to construction
personnel how best to avoid impacts sensitive resources during construction. The program shall include
a description of all special status species potentially on the project site and their habitat needs; an
explanation of the status of the species and their protection under the state and federal regulations;
specific mitigation measures applicable to listed and other special status species; permit conditions, and
the penalties for violation of applicable laws. The program shall also explain to construction personnel how
to avoid impacts to jurisdictional waters, including wetlands. The program shall include a map and
description of jurisdictional waters on the site to be avoided and measures to implement to ensure the
protection and avoidance of jurisdictional waters.
Temporary impacts to the Minor Amendment Area (Impact BIO-15) would require implementation of the following
mitigation measure:
MM-BIO-14 Prior to initiating any construction related activities requiring a clearing and grubbing or grading permit,
the Applicant shall prepare a revegetation plan for the temporary impact areas within the 25-foot grading
buffer in the Minor Amendment Area that utilizes a native erosion control hydroseed mix acceptable to the
City and the Wildlife Agencies (U.S. Fish and Wildlife Service and California Department of Fish and Wildlife)
to ensure soil stability and prevent subsequent erosion. The revegetation plan must be prepared by a
qualified City approved biologist familiar with the City’s MSCP Subarea Plan and must include, but not be
limited to, an implementation plan; appropriate seed mixtures and planting method; irrigation method;
quantitative and qualitative success criteria; maintenance, monitoring, and reporting program; estimated
completion time; and contingency measures. The Project Applicant shall be required to prepare and
implement the revegetation plan subject to the oversight and approval of the Development Services
Director (or their designee).The proposed project MSCP BLA and Minor Amendment would require
implementation of the following mitigation measure:
5.3 – Biological Resources
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 5.3-50
MM-BIO-15 Prior to initiating any construction related activities requiring a clearing and grubbing or grading
permit, the Applicant shall receive approval by the City and Wildlife Agencies for the MSCP BLA. The
Applicant shall be required to implement conditions associated with the BLA subject to the
oversight and approval of the Development Services Director (or their designee).
MM-BIO-16 Prior to initiating any construction related activities requiring a clearing and grubbing or grading permit,
the Applicant shall receive approval by the City and Wildlife Agencies for the MSCP Minor Amendment.
The Applicant shall be required to implement conditions associated with the Minor Amendment subject
to the oversight and approval of the Development Services Director (or their designee).
5.3 – Biological Resources
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 5.3-51
Table 5.3-11. Project Habitat Mitigation Ratios and Acreages
Vegetation Type
MSCP Tier
Habitat Type
Total on Site
(Acres)
Proposed On-Site and Off-Site Impacts (Acres)
Mitigation Ratio
Required Project Mitigation (Acres)
Available in Existing
Preserve for On-Site
Mitigation (Acres)
Proposed On-Site
Habitat Mitigation/
Surplus Preserved
Habitat (Acres)
Inside Preserve Outside Preserve
Total
Impact Inside
Preserve
Impact Outside
Preserve Total Perm Temp Perm Temp
Southern willow scrub Wetland 2.06 0.00 0.00 0.00 0.00 0.00 1:1 to 2:1 0.00 0.00 0.00 1.14 N/A
Mule fat scrub Wetland 0.03 0.00 0.00 0.00 0.00 0.00 1:1 to 2:1 0.00 0.00 0.00 0.03 N/A
Coastal and valley
freshwater marsh
Wetland 7.66 0.00 0.00 0.00 0.00 0.00 1:1 to 2:1 0.00 0.00 0.00 6.31 N/A
Native grassland I 24.09 3.22 0.18 4.22 0.17 7.79 2:1 (Impact Inside
Preserve)
1:1 (Impact Outside
Preserve)
6.80 4.39
11.19
15.98 11.19
(Existing Preserve)/
4.79
(Surplus)
Diegan coastal sage scrub II 37.08 2.24 0.39 5.15 0.77 8.55 1:5:1 (Impact
Inside Preserve)
1:1 (Impact Outside
Preserve)
3.94 5.92 9.86 21.83 9.86
(Existing Preserve)/
11.97
(Surplus)
Non-native grassland III 64.19 1.66 0.10 49.62 3.63 55.01 1:1 (Impact Inside
Preserve)
0.5:1 (Impact
Outside Preserve)
1.76 26.62 28.38 8.55 8.55
(NNG Existing
Preserve) and 16.76
(NG & DCSS Existing
Preserve), and 3.07
(NNG Proposed
Preserve)
Non-native vegetation IV 0.53 0.00 0.00 0.02 0.00 0.02 N/A 0.00 0.00 0.00 0.00 0.00
Urban/developed N/A 0.06 0.00 0.00 0.00 0.01 0.01 N/A 0.00 0.00 0.00 0.00 0.00
Total 135.70 7.12 0.67 59.01 4.58 71.38 N/A 12.50 36.93 49.43 54.33 46.36
(Existing Preserve)
3.07
(Proposed Preserve)
Source: Appendix D.
Notes: MSCP = Multiple Species Conservation Program; N/A = not applicable; NG = native grassland; NNG = non -native grassland; DCSS = Diegan coastal sage scrub.
5.3 – Biological Resources
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
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INTENTIONALLY LEFT BLANK
5.3 – Biological Resources
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
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5.3.6 Level of Significance After Mitigation
The mitigation measures listed in Section 5.3.5 would reduce potential impacts associated with biological resources
to a less-than-significant level.
5.3 – Biological Resources
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 5.3-54
INTENTIONALLY LEFT BLANK
0 1,000 2,000500FeetSoilsPoggi CreekFEMA 100 Year FloodplainFEMA 500 Year FloodplainOtay Tarplant Final Critical HabitatMSCP City of Chula Vista 100% PreserveMSCP Minor Amendment AreaMSCP County of San Diego Take Authorized AreaProject SiteLocal Environmental Setting MapSunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II, Phase 3 Project EIRFIGURE 5.3-1Path: Z:\Projects\j1261201\MAPDOC\DOCUMENT\EIRSOURCE: Merkel & Associates 2020
5.3 – Biological Resources
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 5.3-56
INTENTIONALLY LEFT BLANK
0300600150
Feet
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7RWDO2EVHUYHG2QVLWHIRU(DFK6SHFLHV
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Otay Tarplant (Deinandra conjugens)- 5,449
Decumbent Goldenbush (Isocoma menziessii var. decumbens)- 803
Orcutt's Bird's-beak (Dicranostegia orcuttianus)- 911
Ashy Spike-moss (Selaginella cinerascens)- 2
Coast Barrel Cactus (Ferocactus viridescens)- 2
Palmer's Sagwort (Artemisia palmeri)- 44
San Diego County Needlegrass (Stipa diegoense)- 10
San Diego Bursage (Ambrosia chenopodifolia)- 24
San Diego Marsh Elder (Iva hayesiana)- 816
Small-flowered Bindweed (Convolvulus simulans)- 91
Southwestern Spiny Rush (Juncus acutus ssp. leopoldii)- 750
San Diego County Viguiera (Bahiopsis laciniata)- 7,647
6SHFLDO6WDWXV)DXQD
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Coastal California Gnatcatcher (Polioptila californica californica)- 2
Least Bell's Vireo (Vireo belli pusillus)- 1
Nuttall's Woodpecker (Picoides nuttallii)- 1
Yellow Breasted Chat (Icteria virens)- 3
Yellow Warbler (Dendroica petechia)- 5
Orange-throated Whiptail (Aspidoscelis hyperythra)- 1
Two-striped Garter Snake (Thamnophis hammondii)- 1
Cooper's Hawk (Accipiter cooperii)
White-tailed Kite (Elanus leucurus)
Northern Harrier (Circus cyaneus)
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Coastal and Valley Freshwater Marsh
Southern Willow Scrub
Mule Fat Scrub
Diegan Coastal Sage Scrub
Native Grassland
Non-native Grassland
Non-native Vegetation
Urban/Developed
Waters of the State (RWQCB)/Streambed (CDFW)
Biological ResourceV Map
Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II, Phase 3 Project EIR
FIGURE 5.3-2SOURCE: Merkel & Associates 2020Path: Z:\Projects\j1261201\MAPDOC\DOCUMENT\EIR
5.3 – Biological Resources
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 5.3-58
INTENTIONALLY LEFT BLANK
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FeetCoastal and Valley Freshwater Marsh
Southern Willow Scrub
Mule Fat Scrub
Waters of the State (RWQCB)/Streambed (CDFW)
ACOE, CDFW, RWQCB
CDFW Only
RWQCB Only
Wetland (ACOE) Sampling Point
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Upland Sampling Point
Map Reference Point
Aquatic Resource Delineation Survey Area
50ft Offsite Mapping Buffer
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Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II, Phase 3 Project EIR
FIGURE 5.3-3SOURCE: Merkel & Associates 2020Path: Z:\Projects\j1261201\MAPDOC\DOCUMENT\EIR
5.3 – Biological Resources
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 5.3-60
INTENTIONALLY LEFT BLANK
0300600150
Feet
Coastal California Gnatcatcher - 2
Least Bell's Vireo - 1
Nuttall's Woodpecker - 1
Yellow Breasted Chat - 3
Yellow Warbler - 5
Orange-throated Whiptail - 1
Two-striped Garter Snake - 1
Cooper's Hawk
White-tailed Kite
Northern Harrier
Otay Tarplant - 5,449
Decumbent Goldenbush - 803
Orcutt's Bird's-beak - 911
Ashy Spike-moss - 2
Coast Barrel Cactus - 2
Palmer's Sagwort - 44
San Diego County Needlegrass - 10
San Diego County Viguiera - 7,647
San Diego Bursage - 24
San Diego Marsh Elder - 816
Small-flowered Bindweed - 91
Southwestern Spiny Rush - 750
,
,
,
,
,
Coastal and Valley Freshwater Marsh
Southern Willow Scrub
Mule Fat Scrub
Diegan Coastal Sage Scrub
Native Grassland
Non-native Grassland
Non-native Vegetation
Urban/Developed
Waters of the State (RWQCB)/Streambed (CDFW)
ACOE, CDFW, RWQCB
CDFW Only
RWQCB Only
Permanent Impacts
Temporary Impacts
Fuel Modification Zone
MSCP City of Chula Vista 100% Preserve
MSCP Minor Amendment Area
MSCP County of San Diego Take Authorized Area
50ft Offsite Mapping Buffer
Project Site
Site Plans - September 2020 Hunsaker
Biological Impacts Map
Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II, Phase 3 Project EIR
FIGURE 5.3-4SOURCE: Merkel & Associates 2020Path: Z:\Projects\j1261201\MAPDOC\DOCUMENT\EIR
5.3 – Biological Resources
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 5.3-62
INTENTIONALLY LEFT BLANK
0300600150
Feet
Northern Harrier
Coastal and Valley Freshwater Marsh
Southern Willow Scrub
Mule Fat Scrub
Diegan Coastal Sage Scrub
Native Grassland
Non-native Grassland
Non-native Vegetation
Urban/Developed
Waters of the State (RWQCB)/Streambed (CDFW)
Coastal California Gnatcatcher - 2
Least Bell's Vireo - 1
Nuttall's Woodpecker - 1
Yellow Breasted Chat - 3
Yellow Warbler - 5
Orange-throated Whiptail - 1
Two-striped Garter Snake - 1
Cooper's Hawk
White-tailed Kite
Otay Tarplant - 5,449
Decumbent Goldenbush - 803
Orcutt's Bird's-beak - 911
Ashy Spike-moss - 2
Coast Barrel Cactus - 2
Palmer's Sagwort - 44
San Diego County Needlegrass - 10
San Diego County Viguiera - 7,647
San Diego Bursage - 24
San Diego Marsh Elder - 816
Small-flowered Bindweed - 91
Southwestern Spiny Rush - 750
,
,
,
,
,
MSCP Minor Amendment Area
MSCP County of San Diego Take Authorized Area
MSCP Proposed Preserve Habitat Restoration
50ft Offsite Mapping Buffer
Project Site
MSCP City of Chula Vista 100% Preserve
Site Plans - September 2020 Hunsaker
MSCP Proposed Preserve (Hunsaker September 2020)
MSCP Preserve BLA Map
Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II, Phase 3 Project EIR
FIGURE 5.3-5SOURCE: Merkel & Associates 2020Path: Z:\Projects\j1261201\MAPDOC\DOCUMENT\EIRMapping Correction
5.3 – Biological Resources
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5.4 – Cultural and Tribal Cultural Resources
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 5.4-1
5.4 Cultural and Tribal Cultural Resources
This section of the environmental impact report (EIR) addresses potential impacts to cultural and tribal cultural
resources resulting from the proposed Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II,
Phase 3 Project (project or proposed project). The discussion in this section is based on the Negative Cultural and
Paleontological Resources Inventory Report for the project, prepared for the project by Dudek (Appendix E).
5.4.1 Existing Conditions
5.4.1.1 Regulatory Framework
Federal
National Historic Preservation Act
The National Historic Preservation Act (NHPA) (16 United States Code (USC) 470 et seq.) establishes the nation’s
policy for historic preservation and a program for the preservation of historic properties by requiring federal
agencies to consider effects to significant cultural resources (e.g., historic properties) prior to undertakings , which
includes a project, activity, or program either funded, permitted, licenses, or approved by a federal agency.
Section 106 of the NHPA requires federal agencies to consider the effects of projects on historic properties
(resources included in or eligible for the National Register of Historic Places (NRHP)). It also gives the Advisory
Council on Historic Preservation and the state historic preservation offices an opportunity to consult. Federal
agencies issuing permits for the proposed project will be required to comply with NHPA requirements.
Executive Order 11593, “Protection and Enhancement of the Cultural Environment”
Executive Order 11593 (36 Federal Register 8921) (1) orders the protection and enhancement of the cultural
environment through requiring federal agencies to administer the cultural properties under their control in a spirit
of stewardship and trusteeship for future generations; (2) initiates measures necessary to direct their policies,
plans, and programs in such a way that federally owned sites, structures, and objects of historical, architectural, or
archaeological significance are preserved, restored, and maintained for the inspiration and benefit of the people;
and (3) in consultation with the Advisory Council on Historic Preservation, institutes procedur es to ensure that
federal plans and programs contribute to the preservation and enhancement of non-federally owned sites,
structures, and objects of historical, architectural, or archaeological significance (16 USC 470-1).
National Register of Historic Places
The NRHP is the nation’s official list of historic places. The register is overseen by the National Park Service and
requires that a property or resource eligible for listing in the register meet one or more of the following four criteria
at the national, state, or local level to ensure integrity and obtain official designation:
• The property is associated with events that have made a significant contribution to the broad patterns of
our history.
• The property is associated with the lives of persons significant to our past. Eligible properties based on this
criterion are generally those associated with the productive life of the individual in the field in which the
person achieved significance.
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• The property embodies the distinctive characteristics of a type, period, or method of construction, or
represents the work of a master, or possesses high artistic value, or represents a significant and
distinguishable entity whose components lack individual distinction.
• The property has yielded, or is likely to yield, information important to prehistory or history.
In addition to meeting at least one of these four criteria, listed properties must also retain sufficient physical integrity
of those features necessary to convey historic significance. The register has identified the following seven aspects
of integrity: (1) location, (2) design, (3) setting, (4) materials, (5) workmanship, (6) feeling, and (7) association.
Properties are nominated to the register by the state historic preservation officer of the state in which the property
is located, by the federal preservation officer for properties under federal ownership or control, or by the tribal
preservation officer if on tribal lands. Listing in the NRHP provides formal recognition of a property’s historic,
architectural, or archaeological significance based on national standards used by every state. Once a property is
listed in the NRHP, it becomes searchable in the NRHP database of research information. Documentation of a
property’s historic significance helps encourage preservation of the resource.
State
California Environmental Quality Act
The California Environmental Quality Act (CEQA) requires that all private and public activities not specifically exempted be
evaluated for the potential to impact the environment, including effects to historical resources. Historical resources are
recognized as part of the environment under CEQA. It defines historical resources as “any object, building, structure, site,
area, or place, which is historically significant in the architectural, engineering, scientific, economic, agricultural, educational,
social, political, military, or cultural annals of California” (Division I, Public Resources Code, Section 5021.1(b)).
Lead agencies have a responsibility to evaluate historical resources against the California Register of Historical
Resources (CRHR) criteria prior to making a finding as to a proposed project’s impacts to historical resources. Mitigation
of adverse impacts is required if the proposed project will cause substantial adverse change. Substantial adverse change
includes demolition, destruction, relocation, or alteration such that the significance of an historical resource would be
impaired. While demolition and destruction are fairly obvious significant impacts, it is more difficult to assess when
change, alteration, or relocation crosses the threshold of substantial adverse change. The CEQA Guidelines provide that
a project that demolishes or alters those physical characteristics of an historical resource that convey its historical
significance (i.e., its character-defining features) can be considered to materially impair the resource’s significance.
The CRHR is used in the consideration of historic resources relative to significance for purposes of CEQA. The CRHR
includes resources listed in, or formally determined eligible for, some California State Landmarks and Points of
Historical Interest. Properties of local significance that have been designated under a local preservation ordinance
(local landmarks or landmark districts), or that have been identified in a local historical resources inventory may be
eligible for listing in the CRHR and are presumed to be significant resources for purposes of CEQA unless a
preponderance of evidence indicates otherwise.
Generally, a resource is considered by the lead agency to be “historically significant” if the resource meets the
criteria for listing in the CRHR (California Public Resources Code Section 5024.1; Title 14 California Code of
Regulations [CCR], Section 4852) consisting of the following:
1. It is associated with events that have made a significant contribution to the broad patterns of local or
regional history, or the cultural heritage of California or the United States; or
2. It is associated with the lives of persons important to local, California, or national history; or
5.4 – Cultural and Tribal Cultural Resources
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
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3. It embodies the distinctive characteristics of a type, period, region, or method of construction, or represents
the work of a master, or possesses high artistic values; or
4. It has yielded, or has the potential to yield, information important to the prehistory or history of the local
area, California, or the nation.
A “unique” archaeological resource, as defined by the California Public Resources Code Section 21083.2, may be
considered significant under CEQA. If a significant archaeological resource is identified, defined mitigation would
be appropriately implemented. As used in this section, “unique archaeological resource” means an archaeological
artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body
of knowledge, there is a high probability that it meets any of the following criteria:
1. Contains information needed to answer important scientific research questions and that there is a
demonstrable public interest in that information.
2. Has a special and particular quality such as being the oldest of its type or the best available example of its type.
3. Is directly associated with a scientifically recognized important prehistoric or historic event or person.
CEQA was amended in 2014 through Assembly Bill (AB) 52, which created a new category of “tribal culture
resources” that must be considered under CEQA, and applies to all projects that file a Notice of Preparation or notice
of negative declaration or mitigated negative declaration on or after July 1, 2015. AB 52 requires lead agencies to
provide notice to and begin consultation with California Native American tribes that are traditionally and culturally
affiliated with the geographic area of a project if that tribe has requested, in writing, to be kept informed of projects
by the lead agency prior to the determination whether a negative declaration, mitigated negative declaration, or
environmental impact report will be prepared. If a tribe requests consultation within 30 days upon receipt of the
notice, the lead agency must consult with the tribe. AB 52 also specifies mitigation measures that may be considered
to avoid or minimize impacts on tribal cultural resources. Specifically, California Public Resources Code Section
21074 provides the following guidance:
(a) Tribal Cultural Resources are either of the following:
(1) Sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a
California Native American tribe that are either of the following:
(A) Included or determined to be eligible for inclusion in the California Register of
Cultural Resources.
(B) Included in a local register of cultural resources as defined in subdivision (k) of §5020.1.
(2) A resource determined by the lead agency, in its discretion and supported by substantial
evidence, to be significant pursuant to criteria set forth in subdivision (c) of §5024.1. In
applying the criteria set forth in subdivision (c) of §5024.1 for the purposes of this
paragraph, the lead agency shall consider the significance of the resource to a California
Native American tribe.
(b) A cultural landscape that meets the criteria of subdivision (a) is a tribal cultural resource to the
extent that the landscape is geographically defined in terms of the size and scope of the landscape.
(c) A historical resource described in Section 21084.1, a unique archaeological resource as
defined in subdivision (g) of Section 21083.2, or a “nonunique archeological resource” as
defined in subdivision (h) of Section 21083.2 may also be a tribal cultural resource if it
conforms with the criteria of subdivision (a).
5.4 – Cultural and Tribal Cultural Resources
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In the event that Native American human remains or related cultural material are encountered, Section 15064.5(e) of
the state CEQA Guidelines (as incorporated from California Public Resources Code Section 5097.98) and Health and
Safety Code Section 7050.5 define the subsequent protocol. In the event of the accidental discovery or recognition of
any human remains, excavation or other disturbances shall be suspended of the site or any nearby area reasonably
suspected to overlie adjacent human remains or related material. Protocol requires that a county-approved coroner be
contacted in order to determine if the remains are of Native American origin. Should the coroner determine the remains
to be Native American, the coroner must contact the Native American Heritage Commission (NAHC) within 24 hours. The
most likely descendent may make recommendations to the landowner or the person responsible for the excavation work,
for means of treating, with appropriate dignity, the human remains and any associated grave goods as provided in
California Public Resources Code Section 5097.98 (14 CCR 15064.5[e]).
Senate Bill 18
SB 18, approved in 2004, amends the California Civil Code and the California Government Code, requiring cities and
counties to contact and consult with California Native American tribes prior to adopting or amending any general plan or
specific plan, or designating land as open space in order to preserve or mitigate impacts to specified Native American
places, features and objects that are located within the city’s or county’s jurisdiction. SB 18 also requires cities and
counties to hold in strict confidence any information about the specific identity, location, character or use of these
resources. In 2005, OPR published Tribal Consultation Guidelines to guide cities and counties on the process of engaging
in consultation in accordance with SB 18. The NAHC maintains a list of California Native American Tribes with whom
cities and counties must consult pursuant to SB 18.
Local
City of Chula Vista Historic Designation Ordinance
The City of Chula Vista Historic Designation Ordinance (Title 21, Chula Vista Municipal Code (CVMC) Section
21.04.100) (CVMC 2011) establishes general standards by which the Historical Significance of a Historical
Resource is judged as eligible for designation:
1. A Resource is at least 45 years old; and
2. A Resource possesses historical Integrity defined under the CVMC §21.04.100 (discussed
below) and the resource is determined to have historical significance by meeting at least one
of the following criteria:
1. It is associated with an event that is important to prehistory or history on a national, state,
regional, or local level.
2. It is associated with a person or persons that have made significant contributions to
prehistory or history on a national, state or local level.
3. It embodies those distinctive characteristics of a style, type, period, or method of
construction, or represents the work of a master or important creative individual, and/or
possesses high artistic values.
4. It is an outstanding example of a publicly owned Historic Landscape, that represents the
work of a master landscape architect, horticulturalist, or landscape designer, or a publicly
owned Historical Landscape that has potential to provide important information to the
further study of landscape architecture or history.
5. It has yielded or may be likely to yield information important in prehistory or the history of
Chula Vista, the state, region, or nation.
5.4 – Cultural and Tribal Cultural Resources
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Additionally, the designation of an exceptional historical resource may be considered only if:
1. The Historic Preservation Committee (HPC) considered and makes a recommendation to the Council; and
2. It has been demonstrated through expert technical analysis and verifiable evidence that all of the following
findings of fact are made:
a. The resource meets criteria and the findings of fact for designation found in subsections (A)(1) and
(A)(2) of this section; and
b. The resource is the best representative sample of its kind or the last of its kind; and
c. The resource is an exceptionally important component of the City’s history and loss or impairment of
the resource would be detrimental to the City’s heritage; and
3. Four-fifths vote of the Council vote to designate the resource as an exceptional historical resource.
City of Chula Vista Historic Preservation Program
The City’s Historic Preservation Program (HPP) establishes a screening process for determining historical significant of
potential historical resources that are 45 years or older, that have not previously been surveyed or designated as historic,
and that are proposed for alteration or demolition (City of Chula Vista 2011). The HPP is intended to be a resource
document that will educate and inform the user on the City's goals, policies, and procedures for preservation of historical
resources and may be used for all preservation activities in the City. The HPP provides the following:
1. Provides user-friendly preservation guides and procedures for both city staff and members of the public.
2. Establish consistency between historic preservation goals and land-use policies by incorporating a historical
significance review process and Certificate of Appropriateness permit process for historical resources into
the building permit and discretionary project review process.
3. Adopt a more detailed Historic Preservation Ordinance that provides clear and easy to follow processes and
procedures and complies with the requirements for Certified Local Government (CLG) status.
4. Attain and maintain CLG status.
5. Establish process and procedures for the identification and survey of historical resources.
6. Provide reference and technical assistance for preservation activities.
7. Utilize the State Historical Building Code.
8. Encourage the use of the Secretary of the Interior Standards for Treatment of Historical Properties:
Preservation, Rehabilitation, Restoration, and Reconstruction.
City of Chula Vista General Plan – Environmental Element
The Environmental Element of the City of Chula Vista General Plan (Chapter 9, Section 3.1.9) (City of Chula Vista
2005) specifically addresses potential impacts to cultural resources and outlines policies to mitigate negative
impacts. The objective and policies protecting cultural and historical resources are outlined below:
• Objective E-9: Protect Chula Vista’s important cultural resources and support and encourage their
accessibility to the public
• Policy E-9.1: Continue to assess and mitigate the potential impacts of private development and public facilities
and infrastructure to cultural resources, in accordance with the California Environmental Quality Act.
5.4 – Cultural and Tribal Cultural Resources
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
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• Policy E-9.2: Support and encourage the accessibility of Chula Vista’s important cultural resources to the
public for educational; religious; cultural; scientific; and other purposes, including the establishment of
museums and facilities accessible to the public, where such resources can be appropriately studied,
exhibited, curated, etc.
• Policy E-9.3: Discourage disruption, demolition, and other negative impacts to historic cultural resources.
5.4.1.2 Existing Cultural Setting
Prehistoric and Ethnohistoric Periods
Evidence for continuous human occupation in the San Diego region spans the last 10,000 years. Various attempts
to parse variability in archaeological assemblages over this broad time frame have led to the development of several
cultural chronologies; some of these are based on geologic time, most are based on temporal trends in
archaeological assemblages, and others are interpretive reconstructions. Each of these reconstructions describes
essentially similar trends in assemblage composition in more or less detail. This research employs a common set of
generalized terms used to describe chronological trends in assemblage composition: Paleoindian (pre-5500 BC),
Archaic (8000 BC.–AD 500), Late Prehistoric (AD 500–1750), and Ethnohistoric (post-AD 1750). A detailed
discussion on the prehistoric and ethnohistoric periods are available in Appendix E.
NAHC Sacred Lands File Search and Outreach
Dudek requested a Native American Heritage Commission (NAHC) search of the Sacred Lands File on April 8,
2020, for Traditional Cultural Properties or Sacred Sites that have been identified to be within the proposed
project’s APE (Appendix E). The Sacred Lands file search found no Native American cultural resources within a
one-half mile distance of the proposed project area. The NAHC additionally provided a list of Native American
tribes and individuals/organizations that might have knowledge of cultural resources in this area.
Following the NAHC response, letters were sent to NAHC-listed tribal representatives with the intent of requesting
information, opinions or concerns relating to the proposed project impacts (Appendix E). These letters contained a brief
description of the planned project, reference maps, and a summary of the NAHC Sacred Lands File search results.
On April 27, 2020, Dudek archaeologist, Jessica Colston, sent an Information Request letter to John Christman
(Viejas Band of Kumeyaay Indians), John Flores (San Pasqual Band of Diegueno Mission Indians), Michael Garcia
(Ewiiaapaayp Tribe), Ralph Goff (Campo Band of Diegueno Mission Indians), Allen E. Lawson (San Pasqual Band
of Diegueno Mission Indians), Clint Linton (Ipay Nation of Santa Ysabel), Michael Linton (Mesa Grande Band of
Dieguneo Mission Indians), Carmen Lucas (Kwaaymii Laguna Band of Mission Indians), Cody Martinez (Sycuan
Band of the Kumeyaay Nation), Javaughn Miller (La Posta Band of Diegueno Missi on Indians), Kristi Orosco
(Sycuan Band of the Kumeyaay Nation), Rebecca Osuna (Inaja-Cosmit Band of Indians), Gwendolyn Parada (La
Posta Band of Diegueno Mission Indians), Virgil Perez (Iipay Nation of Santa Ysabel), Ernest Pingleton (Viejas Band
of Kumeyaay Indians), Erica Pinto (Jamul Indian Village), Robert Pinto (Ewiaapaayp Tribe), Edwin (Thorpe) Romero
(Barona Group of the Capitan Grande), and Angela Elliott Santos (Manzanita Band of Kumeyaay Nation). No
responses to these outreach attempts have been received to date. The lead agency will be provided with any
responses should they be received from tribal representatives.
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Tribal Consultation
The proposed project is also subject to compliance with AB 52 (California Public Resources Code Section 21074)
which requires consideration of impacts to “tribal cultural resources” as part of the CEQA process. AB 52 requires
the City, lead agency responsible for CEQA compliance for the proposed project, to notify any groups (who have
requested notification) of the proposed project who are traditionally or culturally affiliated with the geographic
area of the project. Because AB 52 is a government-to-government process, all records of correspondence related
to AB 52 notification and any subsequent consultation are on file with the City.
SB 18 requires the City to contact and consult with California Native American tribes prior to adopting or amending
any general plan or specific plan, or designating land as open space in order to preserve or mitigate impacts to
specified Native American places, features and objects that are located within the city’s or county’s jurisdiction.
On December 14, 2020, the City sent notification letters pursuant to SB 18 to tribes listed on the NAHC contact
list. To date, one response from the San Pasqual Band of Mission Indians has been received, which deferred
consultation to other tribes and recommended the consideration of Native American monitoring. Consultation with
Native American tribes is ongoing.
Records Search and Previous Cultural Resource Investigations
Dudek conducted a California Historical Resources Information System records search through the South Coastal
Information Center (SCIC) database on April 2, 2020, for the proposed project and a 1-mile search buffer
surrounding the project. This search included their collection of mapped prehistoric, historical and built -
environment resources, Department of Parks and Recreation (DPR) Site Records, technical reports, archival
resources, and ethnographic references. Additional consulted sources included the National Register of Historic
Places, California Inventory of Historical Resources/CRHR and listed Office of Historic Preservation Archaeological
Determinations of Eligibility, California Points of Historical Interest, California Historical Landmarks, and Caltrans
Bridge Survey information.
Survey Methods
Dudek Archaeologists Patrick Hadel, Jessica Colston, and Loukas Barton conducted a pedestrian survey of the APE
for cultural resources on April 11, 2020. Areas throughout the APE were inspected at 10- and 15-meter transects.
Archaeological survey exceeded the applicable Secretary of Interior Professional Qualifications Standards for
archaeological survey and evaluation. Areas with a slope exceeding 25% are avoided as a matter of safety. The
survey crew was equipped with a GPS receiver. Location-specific photographs were taken using an Apple 3rd
Generation iPad equipped with 8 MP resolution and georeferenced PDF maps of the proposed project area.
Accuracy of this device ranged between 3 meters and 10 meters. Evidence for buried cultural and paleontological
deposits was sought through inspection of natural or artificial erosion exposures and the spoils from rodent burrows.
Disturbances
All areas of the project site showed evidence of surface disturbances from disking/plowing activities, as indicated
by the presence of furrows and irregular surface topography. Other areas have been previously subject to grading
and other mechanical earth-work. All areas have been subject to natural erosion processes. The presence of
numerous rodent burros throughout the site suggests that the site soils are likely heavily disturbed by wildlife. The
exact depth and character of past disturbances is unclear, allowing for the possibility that deeper strat a may have
been unaffected. This indicates that undisturbed resources could be present.
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Results
Archival Review – Cultural Resources
A records search conducted on April 2, 2020, resulted in a total of 68 reports within the 1-mile buffer, of which only
16 reports fall within the proposed project APE (Table 5.4-1). One of these (SD- 10448) outlines the study of impacts
for a proposed pipeline through the middle of the proposed project APE. To date, only one intersecting report was
available at the SCIC.
Table 5.4-1. Reports within the Proposed Project APE
Report No. Year Title Publisher
SD-02690 1993 Final Cultural Resources Evaluation of the 23,088-Acre Otay
Ranch, San Diego County
Ogden Environmental
SD-03625 1999 A Cultural Resources Study for the Olympic Parkway Project The City of Chula Vista
SD-03625 1999 A Cultural Resources Study for the Olympic Parkway Project The City of Chula Vista
SD-03726 1996 Archaeological Survey Report for the Otay Annex Landfill
Project
Woodward-Clyde
Consultants
SD-03824 2000 Cultural Resource Survey for the Proposed Olympic Parkway
Project, City of Chula Vista, California
Kyle Consulting
SD-03824 2000 Cultural Resource Survey for the Proposed Olympic Parkway
Project, City of Chula Vista, California
Kyle Consulting
SD-03950 1997 Cultural Resources Report for the Otay Annex Landfill Project Gallegos and Associates
SD-04657 1992 Draft Program Environmental Impact Report, Otay Ranch Ogden Environmental and
Energy Services Co., Inc.
SD-06805 1987 Archaeological Overview and Planning Document for the
Proposed Rancho Otay Project
TMI Environmental
Services
SD-07163 1999 A Cultural Resources Study for the Olympic Parkway Project Brian F. Smith
SD-07668 2001 Archaeological Mitigation of Impact to Prehistoric Site SDI-
13864, Otay Ranch Village One West
Brian F. Smith & Assoc.
SD-07775 2000 A Report of an Archaeological Evaluation of Cultural
Resources at the Otay Ranch Village Two SPA
Brian F. Smith and
Associates
SD-10448 2005 Site Significance Evaluation of a Portion of Prehistoric
Archaeological Site CA-SDI-17668 located along the
Proposed Otay Water District, 30-Inch Recycled Water
Pipeline Route, in the Otay River Valley, San Diego County,
California
Mooney, Jones & Stokes
SD-10821 2007 Final Cultural Resources Mitigation Monitoring Report for the
Otay Water District 30- Inch Recycled Water Pipeline San
Diego County, California
Mooney, Jones & Stokes
SD-11502 1995 Results of an Archaeological Survey and the Evaluation of
Cultural Resources at the Otay Ranch Sectional Planning
Area One and Annexation Project
Brian F. Smith &
Associates
SD-12397 2009 Archaeological Monitoring of the Otay Ranch Village 2 Project Brian F. Smith &
Associates
Source: Appendix E.
Note: APE = area of potential effect; SPA = Sectional Planning Area.
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SD-12397
Report SD-12397 is a summary of the archaeological monitoring effort in support of the Otay Ranch Village 2
Project, an 855-acre parcel located immediately to the east of (but not overlapping) the current proposed project
APE (Appendix E). Conducted by Brian F. Smith and Associates, from June 2006 to April 2007, the report
summarizes recoveries at three archaeological sites and four cultural isolates. None of the monitoring discoveries
were considered significant and the authors determined that construction of the Otay Ranch Village 2 Project would
not induce an adverse effect on cultural resources and recommended that no further archaeological mitigation was
necessary (Appendix E).
Archival Review – Cultural Resources found within the Project APE
The SCIC record search indicates that no cultural resources have been identified within the project APE. However, 82
cultural resources have been recorded within the 1-mile search buffer (Table 5.4-2). Of these, only 3 are historic resources,
while 79 are prehistoric resources. The density of resources within this 1-mile buffer attests to the potential for buried
resources within the proposed project APE, even though none have yet been identified (Appendix E).
Historic resources within the 1-mile buffer include the Otay Ranch Farm Complex (approximately 830 meters to the
east of the current proposed project APE), a farmhouse at 5401 Main Street, and a structure mapped on the 1903
map. Of the 79 prehistoric resources already identified within the 1-mile buffer, there is evidence of four temporary
camps, 27 light scatters of artifacts, most notably chipped stone, a single bedrock milling station, and 47 isolated
artifacts that include simple flake tools, cores, millingstones, and pestles. Though the majority of these have not been
fully evaluated, the nature and character of them attest to fairly light land-use patterns within the 1-mile buffer.
Table 5.4-2. Resource within Proposed Project Research Area (1-Mile Buffer)
Primary Trinomial Period Description CRHP Eligibility Intersect?
37-008065 SDI-008065 Prehistoric Lithic and artifact scatter Potentially Eligible No
37-008912 SDI-008912 Prehistoric Artifact scatter Potentially Eligible No
37-010471 SDI-010471 Prehistoric Artifact scatter Potentially Eligible No
37-010472 SDI-010472 Prehistoric Lithic scatter Potentially Eligible No
37-010473 SDI-010473 Prehistoric Artifact scatter Potentially Eligible No
37-010489 SDI-010489 Prehistoric Lithic scatter Potentially Eligible No
37-011145 SDI-011145 Prehistoric Lithic scatter Potentially Eligible No
37-011146 SDI-011146 Prehistoric Lithic scatter Potentially Eligible No
37-011387 SDI-011387 Historic Otay Ranch Farm Complex Not Eligible No
37-011968 SDI-011968 Prehistoric Lithic scatter Potentially Eligible No
37-012289 SDI-012289 Prehistoric Temporary Camp Not Eligible No
37-012290 SDI-012290 Prehistoric Lithic scatter Not Eligible No
37-012292 SDI-012292 Prehistoric Lithic scatter Not Eligible No
37-012293 SDI-012293 Prehistoric Artifact scatter Potentially Eligible No
37-013226 SDI-013226 Prehistoric Temporary camp Not Eligible No
37-013771 SDI-013776 Prehistoric Bedrock milling Potentially Eligible No
37-013872 SDI-013862 Prehistoric Lithic scatter Potentially Eligible No
37-013873 SDI-013863 Prehistoric Lithic scatter Potentially Eligible No
37-013874 SDI-013864 Prehistoric Lithic scatter Not Eligible No
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Table 5.4-2. Resource within Proposed Project Research Area (1-Mile Buffer)
Primary Trinomial Period Description CRHP Eligibility Intersect?
37-013875 SDI-013865 Prehistoric Lithic scatter Not Eligible No
37-013876 SDI-013866 Prehistoric Lithic scatter Potentially Eligible No
37-013877 SDI-013867 Prehistoric Lithic scatter Not Eligible No
37-013878 SDI-013868 Prehistoric Temporary camp Potentially Eligible No
37-014153 N/A Prehistoric Isolate – Flake and core Not Eligible No
37-014154 N/A Prehistoric Isolate – Millingstone Not Eligible No
37-014155 N/A Prehistoric Isolate – Flake Not Eligible No
37-014156 N/A Prehistoric Isolate – Simple Flake Tool Not Eligible No
37-014157 N/A Prehistoric Isolate – Core Not Eligible No
37-014159 N/A Prehistoric Isolate – Simple Flake Tool
and Flake
Not Eligible No
37-014160 N/A Prehistoric Isolate – Flake Not Eligible No
37-014161 N/A Prehistoric Isolate – Core Not Eligible No
37-014162 N/A Prehistoric Isolate – Core and flake Not Eligible No
37-014163 N/A Prehistoric Isolate – Flake Not Eligible No
37-014164 N/A Prehistoric Isolate – Flake Not Eligible No
37-014165 N/A Prehistoric Isolate – 2 Flakes Not Eligible No
37-014166 N/A Prehistoric Isolate – Retouched Flake
Tool
Not Eligible No
37-014167 N/A Prehistoric Isolate – Simple Flake Tool Not Eligible No
37-014168 N/A Prehistoric Isolate – Simple Flake Tool Not Eligible No
37-014178 N/A Prehistoric Isolate – Simple Flake Tool Not Eligible No
37-014179 N/A Prehistoric Isolate – 2 flakes Not Eligible No
37-014180 N/A Prehistoric Isolate – Core Not Eligible No
37-014181 N/A Prehistoric Isolate – Simple Flake Tool Not Eligible No
37-014182 N/A Prehistoric Isolate – Simple Flake Tool Not Eligible No
37-014183 N/A Prehistoric Isolate – Flake Not Eligible No
37-014184 N/A Prehistoric Isolate – 2 Simple Flake Tools Not Eligible No
37-014185 N/A Prehistoric Isolate – Simple Flake Tool Not Eligible No
37-014186 N/A Prehistoric Isolate – 2 Simple Flake Tools Not Eligible No
37-014187 N/A Prehistoric Isolate – Flake Not Eligible No
37-014188 N/A Prehistoric Isolate – 2 Flakes Not Eligible No
37-014189 N/A Prehistoric Isolate – Simple Flake Tool Not Eligible No
37-014190 N/A Prehistoric Isolate – Simple Flake Tool
and Flake
Not Eligible No
37-014191 N/A Prehistoric Isolate – Pestle Not Eligible No
37-014192 N/A Prehistoric Isolate – Simple Flake Tools Not Eligible No
37-014193 N/A Prehistoric Isolate – Flake Not Eligible No
37-014223 SDI-014055 Prehistoric Temporary Camp Potentially Eligible No
37-014224 SDI-014056 Prehistoric Artifact scatter Potentially Eligible No
37-014529 N/A Prehistoric Isolate – Core Not Eligible No
37-014542 SDI-014175 Prehistoric Lithic Scatter Potentially Eligible No
37-014544 SDI-014177 Prehistoric Lithic Scatter Not Eligible No
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Table 5.4-2. Resource within Proposed Project Research Area (1-Mile Buffer)
Primary Trinomial Period Description CRHP Eligibility Intersect?
37-014570 SDI-014203 Prehistoric Artifact Scatter Potentially Eligible No
37-015009 N/A Prehistoric Isolate – Flake Not Eligible No
37-015010 N/A Prehistoric Isolate – Core fragment Not Eligible No
37-015148 N/A Prehistoric Isolate – Simple Flake Tool Not Eligible No
37-015149 N/A Prehistoric Isolate – Core Not Eligible No
37-015231 N/A Prehistoric Isolate – Core Not Eligible No
37-015332 N/A Prehistoric Isolate – Flake Not Eligible No
37-015333 N/A Prehistoric Isolate – Flake Not Eligible No
37-015334 N/A Prehistoric Isolate – Assayed cobble and
flake
Not Eligible No
37-015335 N/A Prehistoric Isolate –Core and Flake Not Eligible No
37-015336 N/A Prehistoric Isolate – Flake Not Eligible No
37-015525 N/A Prehistoric Isolate – Flake Not Eligible No
37-015526 N/A Prehistoric Isolate – Flake Not Eligible No
37-015975 N/A Prehistoric Isolate – Flake Not Eligible No
37-025521 N/A Historic Farmhouse at 4501 Main St. Potentially Eligible No
37-026550 N/A Historic Structure mapped on 1903
map
Potentially Eligible No
37-028497 SDI-014303 Prehistoric Lithic Scatter Potentially Eligible No
37-030154 SDI-019219 Prehistoric Lithic Scatter Potentially Eligible No
37-030158 N/A Prehistoric Isolate – Flake Not Eligible No
37-030568 N/A Prehistoric Isolate – Flake Not Eligible No
37-030569 SDI-019432 Prehistoric Lithic Scatter Potentially Eligible No
37-032800 SDI-020737 Prehistoric Lithic Scatter Potentially Eligible No
37-032801 SDI-020738 Prehistoric Lithic Scatter Potentially Eligible No
Source: Appendix E.
Notes: CRHP = California Register of Historical Places; N/A = not applicable.
Two previously recorded prehistoric artifact scatter sites, approximately 160 meters upslope from the proposed
project APE, are reflective of the kinds of resources that may be encountered within the proposed project APE. These
sites might also be subject to erosion and result in artifact drift downslope into the proposed project APE.
P-37-010471 (CA-SDI-10471)
This resource is a prehistoric artifact scatter found immediately upslope of the proposed project APE, on the adjacent
property to the south. The site measures roughly 45 meters in diameter. The site consists of moderate amounts of
large tools, cores, and flakes, as documented by Fink in 1973. A representative surface collection of the tools was
taken. The area had been recently burned; therefore, the presence of midden soils was impossible to determine.
P-37-010473 (CA-SDI-10473)
This resource is a prehistoric artifact scatter, consisting of large flakes, tools, cores situated on the crest of the
southern side of Poggi Canyon, upslope from the project’s southern boundary. The site measures approximately 32
meters in diameter. This site was heavily surface collected during recordation by Fink in 1974 and was subjected
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to subsurface testing at that time. The shovel test pits yielded no subsurface com ponent. The interpretation was
that this site constituted as surface scatter of a San Dieguito III lithic workshop.
Aerial Imagery Analysis
A review of historic aerial imagery for the proposed project APE extends back to 1953 (Appendix E) with photos
present from 1953, 1964, 1966, 1968, 1971, 1981, 1989, 1994, 1996, 2002, 2003, 2005, 2009, 2010,
2012, 2014, and 2016. The aerial imagery showed that for the vast majority of the proposed project APE, no
development of the property had been on site from the earliest aerial image in 1953. The proposed project APE is
located at the western end of Poggi Canyon, occupying the southern slope. The construction of Olympic Parkway
along the northern border of the proposed project APE began as a small dirt road visible in the 1953 photo but was
paved as a split lane highway between 1996 and 2002. The addition of the median and development of Olympic
Parkway also impacted the project APE with improvements related to Poggi Creek running parallel to Olympic
Parkway. The proposed project APE includes the culvert as well as engineered animal crossing overpasses with
surface vegetation. This impact runs along the northern 40 feet of the proposed project APE. From at least the early
1960s, the eastern section of the proposed project APE has been subject to cultivation as indicated by patterns of
mechanical plowing; this practice appears to have ended in the 1980s. Historic topographic maps consulted were
from 1904, 1908, 1911, 1915, 1920, 1928, 1932, 1941, 1943, 1955, 1960, 1962, 1977, 2002, 2012, 2015, and
2018. The topographical maps show the current location of the landfill to have been a historic borrow pit, as early
as 1904, with continuous use into the present.
Survey Results
The intensive pedestrian survey of the APE, conducted April 11, 2020, identified no new cultural resources within
the current APE limits. Visibility was overwhelmingly obscured by vegetation, allowing for less than one -third of the
ground surface to be viewed in many areas. In addition, the westernmost sector of the project site was inaccessible
due to the presence of an active, inhabited homeless camp located within the proposed open space and the MSCP
Preserve area. Fortunately, this section of the project site is not scheduled for either grading or residential
development. Across the proposed project site, surface visibility was confined to scattered exposures near stands of
lemonade berry (Rhus integrifolia), gopher and ground squirrel burrow spoils, and to a series of recently graded
roadways. Several different vegetation communities have been identified across the proposed project APE
(Appendix D), with elements of the Diegan Coastal Sage Scrub (namely, large stands of lemonade berry), as well as
Southern Willow Scrub (composed mainly of arroyo and black willows, Salix lasiolepis and Salix gooddingii
respectively) being particularly impenetrable. Recent growth in both native and non-native grasslands due to heavy
rains obscured surface visibility nearly everywhere else. Recent notable growth included blue-eyed grass
(Sisyrinchium bellum) sweet fennel (Foeniculum vulgare) and wild oat (Avena barbata). The invasive white garden
snail (Theba pisana) was in high abundance throughout the proposed project APE.
Crisscrossing the western sector of the project site is a network of recently graded roadways. These provided the most
extensive and unobstructed view of the ground surface, revealing rounded alluvial cobbles and pebbles embedded in a
clay-rich, fine-grained, and currently water-logged sediment matrix. Though the recorded roadways exposed roughly
2,350 square meters of bare ground, Dudek did not encounter any cultural resources in those areas.
Other notable disturbances, namely colluvial slope wash at the bottoms of the small tributary feeder drainages, on
the north side of the project site, obscured bedrock, active vegetation, and likely all cultural resources in the immediate
area. Indeed, the colluvial movement of sediment and gravels downslope during seasonal heavy rains would ensure
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that cultural resources at the bottom of the hill, in and adjacent to Poggi Canyon, located along the northern boundary
of the project site, are deeply buried, wherever present.
5.4.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to cultural and tribal cultural resources is based on
the recommendations provided in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). A significant impact
would occur if the project would:
A. Cause a substantial adverse change in the significance of a historical resource as defined in CEQA
Guidelines Section 15064.5.
B. Cause a substantial adverse change in the significance of an archaeological resource as defined in CEQA
Guidelines Section 15064.5.
C. Disturb any human remains, including those interred outside of formal cemeteries.
D. Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public
Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically
defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a
California Native American tribe, and that is:
a. 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
b. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to
be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1.
In applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead
agency shall consider the significance of the resource to a California Native American tribe.
5.4.3 Impacts
A. Cause a substantial adverse change in the significance of a historical resource as defined in CEQA Guidelines
Section 15064.5.
As described in Section 5.4.1. Existing Conditions, no historic sites were identified in previous cultural
investigations, records search, or pedestrian survey. Therefore, construction and operation of the proposed project
would not cause a substantial change in the significance of an historical resource as defined in CEQA Guidelines
Section 15064.5, and no impact would occur.
B. Cause a substantial adverse change in the significance of an archaeological resource as defined in CEQA
Guidelines Section 15064.5.
Based on Appendix E of this EIR, no known cultural resources will be impacted as a result of project implementation.
However, while no cultural resources have been identified or recorded within the proposed project APE, the
proximity to known sites beyond the southern boundary of the project site, P-37-010473 (CA-SDI-10473) and P-37-
010471 (CA-SDI-10471), indicates a high sensitivity of encountering intact subsurface cultural resources. The hills
dividing Poggi Canyon and its affiliated seasonal drainage (located within the northern portion of the site) from the
more substantial Otay River (located 1 mile directly south of the proposed project APE) likely housed numerous
trails connecting them, and may have hosted occasional gatherings or other activities. As with the existing
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archaeological record of the broader area, the proposed project APE may contain intact, buried evidence of
prehistoric or historic transit, transportation, short-term encampments, and/or resource acquisition. There is
potential to encounter previously unidentified subsurface cultural deposits. Therefore, impacts would be potentially
significant and mitigation, as required and detailed in MM-CUL-1, would reduce potentially significant impacts to a
level below significance.
C. Disturb any human remains, including those interred outside of formal cemeteries.
No evidence of human remains, including those interred outside of formal cemeteries, was discovered during the
records search, literature review, field survey, or site testing and evaluation. Further, the site has been previously
disturbed and never used as a formal cemetery. However, the possibility exists that human remains may be
discovered during project grading and construction. Any disturbance of human remains that may occur during
project grading or construction would be potentially significant. Therefore, impacts would be potentially significant
and mitigation, as required by mitigation measure MM-CUL-1 would reduce potentially significant impacts to a level
below significance.
D. 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 define d in terms
of the size and scope of the landscape, sacred place, or object with cultural value to a California Native
American tribe, and that is:
a. 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).
As discussed under Threshold A, no historical resources, as defined by California Public Resources Code Section
5020.1(k), are present within areas that would be impacted by the proposed project. No previously recorded
tribal cultural resources (TCRs) listed in the CRHR or a local register were identified within the proposed project APE.
However, there is still potential to disturb unknown TCRs. Mitigation measure MM-CUL-1 would be implemented to
reduce potentially significant impacts to a level below significance.
b. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be
significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In
applying the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1, the lead agency
shall consider the significance of the resource to a California Native American tribe.
No TCRs have been identified that could be impacted by the proposed project. However, there is still potential for
unknown subsurface TCRs to be present on site. Proposed grading activities have potential to disturb unknown
subsurface TCRs. Therefore, impacts would be potentially significant. Mitigation measure MM-CUL-1 would be
implemented to reduce potentially significant impacts to a level below significance.
5.4.4 Level of Significance Prior to Mitigation
Prior to mitigation, the proposed project would have potentially significant impacts associated with cultural and
tribal cultural resources. Impacts prior to mitigation would be potentially significant. Impacts related to historic
resources would be less than significant.
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5.4.5 Mitigation Measures
The following mitigation measure is recommended to reduce potentially significant impacts to unrecorded
subsurface archaeological resources, unrecorded human remains, and tribal cultural resources within the proposed
project site:
MM-CUL-1 A. Prior to beginning construction activities, the project archaeologist and Native American
representative shall attend any pertinent preconstruction meetings with the construction manager
and/or grading contractor in order to provide recommendations and answer questions relating to
the archaeological monitoring program. The project archaeologist shall be familiar with the cultural
inventory conducted for the current project and shall be prepared to introduce any pertinent
information concerning expectations and probabilities of discovery during ground-disturbing
activities. Prior to the initiation of construction, the cultural consultant shall acquire all evaluation
information and the draft evaluation report, if a report was prepared.
B. Both an archaeological monitor familiar with local resources and a Native American monitor
shall be present full time during the initial disturbance of soil with potential to contain cultural
deposits. All areas of initial project-related subsurface disturbance shall be assumed to
have the potential to contain cultural deposits. Monitoring of initial ground disturbance shall
not exceed a depth of 5 feet (1.5 meters) unless cultural resources are identified or if, through
direct inspection of subsurface exposures by the project Archaeologist, an area is observed
to have the potential to support the presence of archaeological deposits at greater depths.
Cultural resources monitoring may be reduced from initial full-time monitoring to periodic
spot checks, or discontinued if appropriate, once the project archaeologist determines that
there is little or no risk of encountering cultural material.
C. Daily archaeological and Native American monitoring logs shall be prepared. Logs shall include
monitor names and affiliations, a description of general activities observed, cultural discoveries,
as well as comments or concerns as applicable.
D. In the event of an archaeological discovery, and when requested by the archaeological monitor or
Native American monitor, the resident contractor will divert, redirect, or temporarily halt ground
disturbing activities in the area of discovery or impacts to allow for preliminary inspection of
potentially significant archaeological resources or impacts. The significance of the discovered
resources or impacts shall be determined by the archaeologist, in consultation with the City of Chula
Vista (City). For significant cultural resources, a Research Design and Data Recovery Program shall
be prepared and carried out to mitigate impacts before grading activities in the area of discovery
shall be allowed to resume.
E. The project archaeologist shall be responsible for ensuring that all cultural materials collected
will be cleaned, catalogued, and curated permanently with an appropriate institution; that a
letter of acceptance from the curation institution has been submitted to the City; that all
artifacts are analyzed to identify function and chronology as they relate to the history of the area;
that faunal material will be identified as to species; and that specialty studies are completed, as
appropriate. The project archaeologist shall make a good-faith effort to ensure that all
archaeological material collected through previous work is appropriately curated with any
material recovered through construction monitoring.
F. If human remains are discovered, work shall halt in that area and procedures set forth in the
California Public Resources Code (Section 5097.98) and State Health and Safety Code (Section
7050.5) shall be followed by the archaeological monitor after notification to the County Coroner by
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the project Archaeologist. If Native American remains are present, the County Coroner shall contact
the Native American Heritage Commission to designate a Most Likely Descendant, who shall
arrange for the dignified disposition and treatment of the remains.
G. Within 3 months following the completion of monitoring, two copies of a monitoring results
report (even if negative) and/or evaluation report, if applicable, that describes the results,
analysis, and conclusions of the archaeological monitoring program (with appropriate graphics)
shall be submitted to City.
H. For significant archaeological resources encountered during monitoring, the Research Design
and Data Recovery Program shall be included as part of the final evaluation monitoring report.
Two copies of the final monitoring report for significant archaeological resources, if required,
shall be submitted to the City. This final monitoring report should also incorporate a summary
of the evaluation results and analyses previously conducted within the project area.
I. The archaeologist shall be responsible for recording (on the appropriate CA DPR 523 Series
forms) any significant or potentially significant resources encountered during the
archaeological monitoring program in accordance with Section 106 and the City’s Cultural
Resources Guidelines, and submittal of such forms to the South Coastal Information Center at
San Diego State University with the final monitoring results report.
5.4.6 Level of Significance After Mitigation
Implementation of MM-CUL-1 would reduce potentially significant impacts associated with archeological, human
remains and tribal cultural resources to a less-than-significant level.
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5.5 Energy
This section of the environmental impact report (EIR) addresses potential impacts to energy resulting from the
proposed Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II, Phase 3 Project (project or
proposed project). The discussion in this section is based on the Air Quality and Greenhouse Gas Emissions
Technical Report prepared for the proposed project by Dudek in September 2020. The complete report is provided
in Appendix C and the energy use calculations are provided as Appendix F of this EIR.
5.5.1 Existing Conditions
5.5.1.1 Regulatory Framework
Federal
Federal Energy Policy and Conservation Act
In 1975, Congress enacted the Federal Energy Policy and Conservation Act, which established the first fuel
economy standards for on-road motor vehicles in the United States. Pursuant to the act, the National Highway
Traffic Safety Administration is responsible for establishing additional vehicle standards. In 2012, new fuel
economy standards for passenger cars and light trucks were approved for model years 2017 through 2021 (77
FR 62624–63200). Fuel economy is determined based on each manufacturer’s average fuel economy for the
fleet of vehicles available for sale in the United States.
Energy Independence and Security Act of 2007
On December 19, 2007, the Energy Independence and Security Act of 2007 (EISA) was signed into law. In addition
to setting increased corporate average fuel economy standards for motor veh icles, the EISA includes the following
other provisions related to energy efficiency:
• Renewable fuel standard (RFS) (Section 202)
• Appliance and lighting efficiency standards (Sections 301–325)
• Building energy efficiency (Sections 411–441)
This federal legislation (the RFS) requires ever -increasing levels of renewable fuels to replace petroleum (EPA
2017). The U.S. Environmental Protection Agency is responsible for developing and implementing regulations
to ensure that t ransportation fuel sold in the United States contains a minimum volume of renewable fuel. The
RFS program regulations were developed in collaboration with refiners, renewable fuel producers, and many
other stakeholders.
The RFS program was created under the Energy Policy Act of 2005 and established the first renewable fuel
volume mandate in the United States. As required under the Energy Policy Act, the original RFS program (RFS1)
required 7.5 billion gallons of renewable fuel to be blended into gasoline b y 2012. Under the EISA, the RFS
program was expanded in several key ways that laid the foundation for achieving significant reductions of
greenhouse gas (GHG) emissions through the use of renewable fuels, for reducing imported petroleum, and for
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encouraging the development and expansion of our nation’s renewable fuels sector. The updated program
(“RFS2”) includes the following:
• EISA expanded the RFS program to include diesel, in addition to gasoline.
• EISA increased the volume of renewable fuel required to be blended into transportation fuel from 9 billion
gallons in 2008 to 36 billion gallons by 2022.
• EISA established new categories of renewable fuel and set separate volume requirements for each one.
• EISA required the U.S. Environmental Protection Agency (EPA) to apply lifecycle GHG performance threshold
standards to ensure that each category of renewable fuel emits fewer GHGs than the petroleum fuel it replaces.
Additional provisions of the EISA address energy savings in government and public institutions, promoting research for
alternative energy, additional research in carbon capture, international energy programs, and the creation of green jobs.
State
Warren-Alquist Act
The California Legislature passed the Warren-Alquist Act in 1974. The Warren-Alquist Act created the California
Energy Commission (CEC). The legislation also incorporated the following three key provisions designed to address
the demand side of the energy equation:
• It directed the CEC to formulate and adopt the nation’s first energy conservation standards for both
buildings constructed and appliances sold in California.
• The act removed the responsibility of electricity demand forecasting from the utilities, which had a financial
interest in high demand projections, and transferred it to a more impartial CEC.
• The CEC was directed to embark on an ambitious research and development program, with a particular
focus on fostering what were characterized as non-conventional energy sources.
State of California Energy Action Plan
The CEC and the California Public Utilities Commission (CPUC) approved the first State of California Energy Action
Plan in 2003. The plan established shared goals and specific actions to ensure that adequate, reliable, and
reasonably priced electrical power and natural gas supplies are provided, and identified policies, strategies, and
actions that are cost-effective and environmentally sound for California's consumers and taxpayers. In 2005, a
second Energy Action Plan was adopted by the CEC and CPUC to reflect various policy changes and actions of the
prior 2 years.
At the beginning of 2008, the CEC and CPUC determined that it was not necessary or productive to prepare a new
energy action plan. This determination was based in part on a finding that the state’s en ergy policies have been
significantly influenced by the passage of Assembly Bill (AB) 32, the California Global Warming Solutions Act of
2006 (discussed below). Rather than produce a new energy action plan, the CEC and CPUC prepared an “update”
that examines the state’s ongoing actions in the context of global climate change.
California Code of Regulations Title 20 and Title 24
Title 24, Part 6. Title 24 of the California Code of Regulations was established in 1978 and serves to enhance and
regulate California’s building standards. Part 6 of Title 24 specifically establishes Building Energy Efficiency
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Standards that are designed to ensure that new and existing buildings in California achieve energy efficiency and
preserve outdoor and indoor environmental quality. These energy efficiency standards are reviewed every few years by
the Building Standards Commission and the CEC (and revised if necessary) (California Public Resources Code, Section
25402[b][1]). The regulations receive input from members of industry, as well as the public, with the goal of “reducing
of wasteful, uneconomic, inefficient, or unnecessary consumption of energy” (California Public Resources Code Section
25402). These regulations are carefully scrutinized and analyzed for technological and economic feasibility (California
Public Resources Code Section 25402[d]) and cost effectiveness (California Public Resources Code Sections
25402[b][2] and [3]). These standards are updated to consider and incorporate new energy-efficient technologies and
construction methods. As a result, these standards save energy, increase electricity supply reliability, increase indoor
comfort, avoid the need to construct new power plants, and help preserve the environment.
The 2019 Standards will continue to improve upon the 2016 Standards for new construction of, and additions and
alterations to, residential and nonresidential buildings. Significant efficiency improvements to residential
standards include the introduction of photovoltaic into the prescriptive package, improvements for attics, walls,
water heating, and lighting. Significant efficiency improvements to nonresidential standards include alignment
with the ASHRAE 90.1 2017 national standards. The 2019 Standards became effective on January 1, 2020. In
general, single-family residences built to the 2019 standards are anticipated to use approximately 7% less energy
due to energy efficiency measures than those built to the 2016 standards; once rooftop solar electricity generation
is factored in, single-family residences built under the 2019 standards will use approximately 53% less energy
than those under the 2016 standards (CEC 2018).
The 2022 Building Energy Efficiency Standards would improve upon the 2019 Energy Code for new construction
of, and additions and alterations to, residential and nonresidential buildings. The proposed standards would be
adopted in 2021 with an effective date of January 1, 2023 (CEC 2020a).
Title 24, Part 11. In addition to the CEC’s efforts, in 2008, the California Building Standards Commission adopted
the nation’s first green building standards. The California Green Building Standards Code is commonly referred to
as CALGreen and establishes minimum mandatory standards as well as voluntary standards pertaining to the
planning and design of sustainable site development, energy efficiency (in excess of the California Energy Code
requirements), water conservation, material conservation, and interior air quality. The CALGreen standards first
took effect in January 2011 and instituted mandatory minimum environmental performance standards for all
ground-up, new construction of commercial, low-rise residential and state-owned buildings and schools and
hospitals. The California Building Standards Code is published and updated every 3 years. The updated CALGreen
2019 standards have mandatory standards require the following that are related to energy-use (CALGreen 2019):
• Inclusion of electric vehicle charging stations or designated spaces capable of supporting future charging stations
The CALGreen standards also include voluntary efficiency measures that are provided at two separate tiers and
implemented at the discretion of local agencies and applicants. CALGreen’s Tier 1 standards call for a 15%
improvement in energy requirements, stricter water conservation, 65% diversion of construction and demolition
waste, 10% recycled content in building materials, 20% permeable paving, 20% cement reduction, and cool/sola r-
reflective roofs. CALGreen’s more rigorous Tier 2 standards call for a 30% improvement in energy requirements,
stricter water conservation, 75% diversion of construction and demolition waste, 15% recycled content in building
materials, 30% permeable paving, 25% cement reduction, and cool/solar-reflective roofs (CALGreen 2019).
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The CEC’s 2019 Integrated Energy Policy Report indicates that California’s Renewables Portfolio Standard (RPS)
calls for 33% of the retail sales to be served with renewable resources by 2020, and by 2018 the state achieved
approximately 34% (CEC 2020a). In 2017, 52% of total electricity generation, including in-state generation and
imported power, came from zero-carbon generation sources.
Title 20. Title 20 of the California Code of Regulations requires manufacturers of appliances to meet state and
federal standards for energy and water efficiency. Performance of appliances must be certified through the CEC to
demonstrate compliance with standards. New appliances regulated under Title 20 include refrigerators,
refrigerator-freezers, and freezers; room air conditioners and room air-conditioning heat pumps; central air
conditioners; spot air conditioners; vented gas space heaters; gas pool heaters; plumbing fittings and plumbing
fixtures; fluorescent lamp ballasts; lamps; emergency lighting; traffic signal modules; dishwaters; clothes washers
and dryers; cooking products; electric motors; low voltage dry-type distribution transformers; power supplies;
televisions and consumer audio and video equipment; and battery charger systems. Title 20 presents protocols for
testing for each type of appliance covered under the regulations, and appliances must meet the standards for
energy performance, energy design, water performance, and water design. Title 20 contains three types of
standards for appliances: federal and state standards for federally regulated appliances, state standards for
federally regulated appliances, and state standards for non-federally regulated appliances.
Senate Bill 1
SB 1 (2006) established a $3 billion rebate program to support the goal of the state to install rooftop solar energy
systems with a generation capacity of 3,000 megawatts through 2016. SB 1 added sections to the California Public
Resources Code, including Chapter 8.8 (California Solar Initiative), that require building projects applying for
ratepayer-funded incentives for photovoltaic systems to meet minimum energy efficiency levels and performance
requirements. Section 25780 established that it is a goal of the state to establish a self-sufficient solar industry in
which solar energy systems are a viable mainstream option for both homes and businesses within 10 years of
adoption and to place solar energy systems on 50% of new homes within 13 years of adoption. SB 1, also termed
“GoSolarCalifornia,” was previously titled “Million Solar Roofs.”
Senate Bill 1078
This bill established the California RPS Program and required that a retail seller of electricity purchase a specified
minimum percentage of electricity generated by eligible renewable energy resources as defined in any given year,
culminating in a 20% standard by December 31, 2017. These retail sellers include electrical corporations, community
choice aggregators, and electric service providers. The bill relatedly required the CEC to certify eligible renewable
energy resources, design and implement an accounting system to verify compliance with the RPS by retail sellers, and
allocate and award supplemental energy payments to cover above-market costs of renewable energy.
Senate Bills 107 (2006), X1-2 (2011), 350 (2015), and 100 (2018)
Senate Bill (SB) 107 (2006) accelerated the RPS established by SB 1078 by requiring that 20% of electricity retail sales
be served by renewable energy resources by 2010 (not 2017). Additionally, SB X1-2 (2011) requires all California utilities
to generate 33% of their electricity from eligible renewable energy resources by 2020. Specifically, SB X1-2 sets a three-
stage compliance period: by December 31, 2013, 20% shall come from renewables; by December 31, 2016, 25% shall
come from renewables; and by December 31, 2020, 33% shall come from renewables.
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SB 350 (2015) requires retail seller and publicly owned utilities to procure 50% of their electricity from eligible
renewable energy resources by 2030, with interim goals of 40% by 2024 and 45% by 2027.
SB 100 (2018) accelerated and expanded the standards set forth in SB 350 by establishing that 44% of the total
electricity sold to retail customers in California per year by December 31, 2024, 52% by December 31, 2027, and
60% by December 31, 2030 be secured from qualifying renewable energy sources. SB 100 also states that it is the
policy of the state that eligible renewable energy resources and zero-carbon resources supply 100% of the retail
sales of electricity to California. This bill requires that the achievement of 100% zero-carbon electricity resources
does not increase the carbon emissions elsewhere in the western grid and that the achievement not be achieved
through resource shuffling.
Consequently, utility energy generation from non -renewable resources is expected to be reduced based on
implementation of the 60% RPS in 2030. Therefore, any project’s reliance on non-renewable energy sources would
also be reduced.
Assembly Bill 1470
This bill established the Solar Water Heating and Efficiency Act of 2007. The bill makes findings and declarations
of the Legislature relating to the promotion of solar water heating systems and other technologies that reduce
natural gas demand. The bill defines several terms for purposes of the act. The bill requires the commiss ion to
evaluate the data available from a specified pilot program and, if it makes a specified determination, to design and
implement a program of incentives for the installation of 200,000 solar water heating systems in homes and
businesses throughout the state by 2017.
Assembly Bill 1109
Enacted in 2007, AB 1109 required CEC to adopt minimum energy efficiency standards for general purpose lighting,
to reduce electricity consumption 50% for indoor residential lighting and 25% for indoor commercial lighting.
Assembly Bill 1007 (2005)
AB 1007 (2005) required the CEC to prepare a statewide plan to increase the use of alternative fuels in California
(State Alternative Fuels Plan). The CEC prepared the plan in partnership with the California Air Resources Board
(CARB) and in consultation with the other state, federal, and local agencies. The plan assessed various alternative
fuels and developed fuel portfolios to meet California’s goals to reduce petroleum consumption, increase
alternative fuels use, reduce GHG emissions, and increase in-state production of biofuels without causing a
significant degradation of public health and environmental quality.
Assembly Bill 32 (2006) and Senate Bill 32 (2016)
In 2006, the Legislature enacted AB 32, the California Global Warming Solutions Act of 2006. AB 32 requires
California to reduce its GHG emissions to 1990 levels by 2020. In 2016, the Legislature enacted SB 32, which
extended the horizon year of the state’s codified GHG reduction planning targets from 2020 to 2030, re quiring
California to reduce its GHG emissions to 40% below 1990 levels by 2030. In accordance with AB 32 and SB 32,
CARB prepares scoping plans to guide the development of statewide policies and regulations for the reduction of
GHG emissions. Many of the policy and regulatory concepts identified in the scoping plans focused on increasing
energy efficiencies and the use of renewable resources and reducing the consumption of petroleum -based fuels
(such as gasoline and diesel). As such, the state’s GHG emissions reduction planning framework creates co-benefits
for energy-related resources.
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California Long-Term Energy Efficiency Strategic Plan
In 2008, the California Energy Commission (CEC) and CPUC, working with a broad range of stakeholders, developed
the first long-term strategic plan for California's energy efficiency efforts. The Strategic Plan was most recently
updated in January 2011. The plan outlines numerous policy and program objectives, including net-zero goals for
residential (2020) and (2030) commercial new construction. The Plan seeks to effect substantial and sustained
progress towards more efficient technologies and practices in each of the customer end use sectors (e.g.,
Commercial, Industrial, Residential, Agricultural). Likewise, the Plan describes the market transformation efforts
necessary in each of the cross-cutting areas discussed (e.g., Codes and Standards, Workforce Education and
Training, Marketing Education and Outreach, and Research and Technology) (CPUC 2011).
Energy Upgrade California
Energy Upgrade California is a statewide energy management initiative designed to help residents and small businesses
learn the best ways to improve energy efficiency, save money and be more comfortable at home and at work. This new
initiative will help our communities meet our energy efficiency and clean energy goals. Energy Upgrade California is a
program of the CPUC in collaboration with the CEC, California counties, cities, nonprofit organizations, and the state’s
investor-owned utilities. Funding comes from the utilities' ratepayers under the auspices of the CPUC in addition to
incremental funding from the DOE. Energy Upgrade California offers a wide variety of incentives and rebates to choose
from to help homeowners replace appliances, pool pumps, HVAC systems, hot water heaters, install windows, insulation,
and more. Incentives and rebates can help offset the cost of energy efficient products (Energy Upgrade California 2018).
California Air Resources Board (CARB) Climate Change Scoping Plan
CARB’s Climate Change Scoping Plan (Scoping Plan) was adopted on December 2008, pursuant to AB 32 (CARB 2008).
The Scoping Plan called for expanding and strengthening existing energy efficiency programs as well as building and
appliance standards and achieving statewide renewables energy mix of 33%. The Scoping Plan also calls for local
governments to reduce GHG emissions to 15% below 2008 levels by 2020.
Senate Bill 1368
On September 29, 2006, Governor Arnold Schwarzenegger signed into law SB 1368 (Perata, Chapter 598, Statutes
of 2006). The law limits long-term investments in baseload generation by the state’s utilities to those power plants
that meet an emissions performance standard jointly established by the CEC and the CPUC.
The CEC has designed regulations that accomplish the following (Perata, Chapter 598, Statutes of 2006):
• Establish a standard for baseload generation owned by, or under long-term contract to publicly owned
utilities, of 1,100 pounds carbon dioxide (CO2) per megawatt-hour. This would encourage the development
of power plants that meet California’s growing energy needs while minimizing their emissions of GHGs.
• Require posting of notices of public deliberations by publicly owned utilities on long-term investments on
the CEC website. This would facilitate public awareness of utility efforts to meet customer needs for energy
over the long-term while meeting the state’s standards for environmental impact.
• Establish a public process for determining the compliance of proposed investments with the emissions
performance standard (EPS).
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Assembly Bill 1493
Adopted in 2002 by the state legislature, Assembly Bill (AB) 1493 (“Pavley” regulations) required that the CARB
develop and adopt, no later than January 1, 2005, regulations to achieve the maximum feasible and cost-effective
reduction of GHG emissions from motor vehicles.
The first California request to implement GHG standards for passenger vehicles, known as a waive r request, was
made in December 2005 and was denied by the EPA in March 2008. That decision was based on a finding that
California’s request to reduce GHG emissions from passenger vehicles did not meet the Clean Air Act requirement
of showing that the waiver was needed to meet “compelling and extraordinary conditions.”
The EPA granted California the authority to implement GHG emission reduction standards for new passenger cars,
pickup trucks, and sport utility vehicles on June 30, 2009. On September 24, 2009, CARB adopted amendments to
the Pavley regulations that reduce GHG emissions in new passenger vehicles from 2009 through 2016. These
amendments are part of California’s commitment to a nationwide program to reduce new passenger vehicle GHGs
from 2012 through 2016. CARB’s September 2009 amendments will allow for California’s enforcement of the Pavley
rule while providing vehicle manufacturers with new compliance flexibility. The amendments also prepare California
to harmonize its rules with the federal rules for passenger vehicles.
It is expected that the Pavley regulations will reduce GHG emissions from California passenger vehicles by approximately
22% in 2012 and approximately 30% in 2016, while improving fuel efficiency and reducing motorists’ costs.
Executive Order S-1-07
Issued on January 18, 2007, Executive Order (EO) S-1-07 sets a declining Low Carbon Fuel Standard for GHG emissions
measured in CO2-equivalent (CO2e) grams per unit of fuel energy sold in California. The target of the Low Carbon Fuel
Standard is to reduce the carbon intensity of California passenger vehicle fuels by at least 10% by 2020. The carbon
intensity measures the amount of GHG emissions in the lifecycle of a fuel, including extraction/feedstock production,
processing, transportation, and final consumption, per unit of energy delivered. CARB adopted the implementing regulation
in April 2009. The regulation is expected to increase the production of biofuels, including those from alternative sources,
such as algae, wood, and agricultural waste. In addition, the Low Carbon Fuel Standard would drive the availability of plug-
in hybrid, battery electric, and fuel-cell power motor vehicles. The Low Carbon Fuel Standard is anticipated to lead to the
replacement of 20% of the fuel used in motor vehicles with alternative fuels by 2020.
Sustainable Communities Strategy
The Sustainable Communities and Climate Protection Act of 2008, or SB 375, coordinates land use planning, regional
transportation plans, and funding priorities to help California meet its GHG emissions reduction mandates. As codified
in California Government Code, Section 65080, SB 375 requires metropolitan planning organizations (San Diego
Association of Governments) to include a sustainable communities strategy in its regional transportation plan. The main
focus of the sustainable communities strategy is to plan for growth in a fashion that will ultimately reduce GHG emissions,
but the strategy is also a part of a bigger effort to address other development issues within the general vicinity, including
transit and vehicle miles traveled (VMT), which influence the consumption of petroleum-based fuels.
Advanced Clean Cars Program
In January 2012, CARB approved the Advanced Clean Cars program, a new emissions-control program for model years
2015 through 2025. The program combines the control of smog- and soot-causing pollutants and GHG emissions into a
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single coordinated package. The package includes elements to reduce smog-forming pollution, reduce GHG emissions,
promote clean cars, and provide the fuels for clean cars (CARB 2011). To improve air quality, CARB will propose new
emission standards to reduce smog-forming emissions beginning with 2015 model year vehicles. It is estimated that in
2025 cars will emit 75% less smog-forming pollution than the average new car sold today. To reduce GHG emissions,
CARB, in conjunction with the EPA and the NHTSA, has adopted new GHG standards for model year 2017 to 2025
vehicles; the new standards are estimated to reduce GHG emissions by 34% in 2025. The zero-emissions vehicles (ZEV)
program will act as the focused technology of the Advanced Clean Cars program by requiring manufacturers to produce
increasing numbers of ZEVs and plug-in hybrid electric vehicles in the 2018 to 2025 model years. The Clean Fuels Outlet
regulation will ensure that fuels such as electricity and hydrogen are available to meet the fueling needs of the new
advanced technology vehicles as they come to the market.
Executive Order B-16-12
Governor Brown issued EO S-16-12 on March 23, 2012. The EO requires that state entities under the governor’s
direction and control support and facilitate the rapid commercialization of ZEVs. It orders CARB, the CEC, the CPUC,
and other relevant agencies work with the Plug-in Electric Vehicle Collaborative and the California Fuel Cell
Partnership to establish benchmarks to help achieve the following by 2015:
• The state’s major metropolitan areas will be able to accommodate ZEVs, each with infrastructure plans and
streamlined permitting.
• The state’s manufacturing sector will be expanding ZEV and component manufacturing.
• The private sector’s investment in ZEV infrastructure will be growing.
• The state’s academic and research institutions will be contributing to ZEV research, innovation, and education.
CARB, the CEC, and CPUC are also directed to establish benchmarks to help achieve the following goals by 2020:
• The state’s ZEV infrastructure will be able to support up to one million vehicles.
• The costs of ZEV will be competitive with conventional combustion vehicles.
• ZEVs will be accessible to mainstream consumers.
• There will be widespread use of ZEVs for public transportation and freight transport.
• Transportation sector GHG emissions will be falling as a result of the switch to ZEVs.
• Electric vehicle charging will be integrated into the electricity grid.
• The private sector’s role in the supply chain for ZEV component development and manufacturing will be expanding.
Benchmarks are also to be established to help achieve the following goals by 2025:
• Over 1.5 million ZEVs will be on California roads and their market share will be expanding.
• Californians will have easy access to ZEV infrastructure.
• The ZEV industry will be a strong and sustainable part of California’s economy.
• California’s clean, efficient vehicles will annually displace at least 1.5 billion gallons of petroleum fuels.
On a statewide basis, the EO establishes a target reduction of GHG emissions from the transportation sector
equaling 80% less than 1990 levels by 2050.
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Local
San Diego Gas & Electric Company 2020 Individual Integrated Resource Plan
San Diego Gas & Electric Company (SDG&E) filed its 2020 Individual Integrated Resource Plan (IIRP) to the CPUC
on September 1, 2020 (SDG&E 2020a). The IIRP is guided by the following key statutory principles: (1) ensuring
reliability, (2) reducing GHG emissions with the best-fit resources at the lowest possible cost, and (3) meeting the
state’s RPS Program goals. The IIRP provides two conforming portfolios. One portfolio achieves the 46 million metric
tons (MMT) GHG benchmark, and the second portfolio achieves the 38 MMT GHG benchmark.
International Council of Environmental Initiatives Local Governments for Sustainability
In 1992, the City of Chula Vista (City) participated in the Cities for Climate Protection Program, which aimed at
developing municipal action plans for the reduction of GHGs. This program was sponsored and developed by the
International Council of Environmental Initiatives and the United Nations Environment Program in response to the
United Nations Framework Convention on Climate Change, while recognizing that all local planning and
development has direct consequences on energy consumption, and cities exercise key powers over urban
infrastructure, including neighborhood design, and over transportation infrastructure, such as roads, streets,
pedestrian areas, bicycle lanes, and public transport.
City of Chula Vista Climate Action Plan
Since 2000, Chula Vista has been implementing a Climate Action Plan (CAP) to address climate change issues and
its impacts on the City. The City’s Climate Action Plan is a group of documents including various GHG emission
inventories, the original Carbon Dioxide Reduction Plan (2000), Climate Mitigation Plan (2008), new Climate
Adaptation Plan (2011), and Municipal Action (2014). The City’s Increased Energy Efficiency Ordinance, Green
Building Standards, and Solar Ready Ordinances are products of the Climate Action Plan. Actions and goals of the
2017 CAP relate to energy and water efficient buildings, smart growth and clean transit, zero waste, increased local
energy and water resources, leading by example, and community resilience (City of Chula Vista 2017).
Chula Vista Climate Adaptation Strategies – Implementation Plans
The Climate Adaptation Strategies – Implementation Plans document developed by the Climate Change Working
Group includes 11 strategies to adapt Chula Vista to the potential impacts of global climate change, including
energy supply. The strategies to reduce energy demand include cool paving, shade trees, and cool r oofs. For each
strategy, the plans outline specific implementation components, critical steps, costs, and timelines. To limit the
necessary staffing and funding required to implement the strategies, the plans were also designed to build upon
existing municipal efforts rather than create new, stand-alone policies or programs. Initial implementation of all 11
strategies is intended to be phased in over a 3-year period from plan adoption (City of Chula Vista 2011).
Chula Vista Green Building Standards
The City of Chula Vista amended the City Municipal Code Ordinance 15.12 pertaining to green building practices to
include residential and non-residential remodels and additions. The Code contains Residential Mandatory
Measures and Non-Residential Mandatory Measures and also provides Voluntary Measures that can be used by
developers to improve energy efficiency and reduce environmental impacts through design and construction.
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San Diego Regional Energy Efficiency Plan/City of Chula Vista Energy Strategy and Action Plan
The San Diego Regional Energy Plan provided policy and program recommendations to achieve energy sustainability
and security (SANDAG 1994). The San Diego Regional Energy office worked with SANDAG to update the plan with
Energy 2030, the San Diego Regional Energy Strategy. The Regional Energy Strategy is intended to create a vision
of how energy will be produced and consumed in the San Diego region in 2030. It also provides an integrated
approach to meeting energy needs and ensures that an adequate supply and distribution of electricity, natural gas
and transportation fuels is available (SANDAG 2009).
The City has adopted an energy plan to address long-term energy issues and to protect its residents from unreliable
energy supply and volatile prices. The plan, called the Chula Vista Energy Strategy and Action Plan, addresses
demand side management, energy efficient and renewable energy outreach programs for businesses and
residents, energy acquisition, power generation, and distributed energy resources and legislative actions (City of
Chula Vista 2001).
City of Chula Vista Solar Ready Ordinances
CVMC, Section 15.28.015, solar water heater pre-plumbing, and Section 15.24.065, photovoltaic pre-wiring
requirements, are referred to as the Solar Ready ordinances. Section 15.28.015 requires all new residential units
to include plumbing specifically designed to allow the later installation of a system which utilizes solar energy as
the primary means of heating domestic potable water. Section 15.24.065 requires all new residential units to
include electrical conduit specifically designed to allow the later installation of a photovoltaic system which utilizes
solar energy as a means to provide electricity.
City of Chula Vista General Plan
The City of Chula Vista General Plan (General Plan) recognizes that to ensure adequate and reliable energy service,
efficient energy efforts throughout the City and transitioning to non-fossil fuel alternatives will help to extend limited
supplies, reduce the need for expensive new regional power generators and transmission lines, and contribute to
Chula Vista’s economic sustainability and regional competitiveness. The General Plan includes objectives in the
Public Facilities and Services Element to ensure adequate energy supplies throughout Chula Vista (Objective PFS
22) and in the Environmental Element to promote conservation through the efficient use of energy and through the
development of local, non-fossil fuel-based renewable sources of energy (Objective E 7) (City of Chula Vista 2005).
5.5.1.2 Existing Conditions
Electricity
According to the U.S. Energy Information Administration (EIA), California used approximately 255,224 gigawatt
hours of electricity in 2018 (EIA 2020a). Electricity usage in California for different land uses varies substantially by
the types of uses in a building, type of construction materials used in a building, and the efficiency of all electricity -
consuming devices within a building. Due to the state’s energy efficiency building standards and efficiency and
conservation programs, California’s electricity use per capita in the residential sector is lower than any other state
except Hawaii (EIA 2020b).
SDG&E, a subsidiary of Sempra Energy, provides electric services to 3.6 million customers through 1.4 million
electric meters throughout a 4,100-square-mile service area in San Diego and Southern Orange County (SDG&E
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2020b). According to the SDG&E Final 2019 Renewables Portfolio Standard Procurement Pla n, 43% of SDG&E’s
power came from eligible renewables in 2018, including biomass/waste, geothermal, small hydroelectric, solar,
and wind sources (SDG&E 2020c). Renewable resources, including hydropower and small-scale (less than 1-
megawatt) customer-sited solar photovoltaics, supplied almost half of California’s in-state electricity generation in
2018 (EIA 2020b). California’s RPS Program establishes a goal for California to increase the amount of electricity
generated from renewable energy resources to 20% by 2010 and to 33% by 2020. Recent legislation revised the
current RPS target for California to obtain 50% of total retail electricity sales from renewable sources by 2030, with
interim targets of 40% by 2024, and 45% by 2027 (CPUC 2016). In addition, the CAP set a goal of using 100%
clean renewable energy and the City is currently evaluating the feasibility of a Community Choice Aggregation
program (City of Chula Vista 2017, 2020a).
In San Diego County, electricity demand in 2019 was 19,048 million kilowatt-hour (kWh) (CEC 2020b). More
specifically, within the City, the annual community-wide electricity consumption (encompassing both residential and
non-residential) is approximately 828 million kWh in 2016 (City of Chula Vista 2020b).
Natural Gas
According to the EIA, California used approximately 2,154,030 million cubic feet of natural gas in 2019 (EIA 2020c).
Natural gas is used for cooking, space heating, generating electricity, and as an alternative transportation fuel.
The majority of California’s natural gas customers are residential and small commercial customers (core
customers), which accounted for approximately 35% of the natural gas delivered by California utilities in 2018
(CPUC 2020). Large consumers, such as electric generators and industrial customers (noncore customers),
accounted for approximately 65% of the natural gas delivered by California utilities (CPUC 2020). The CPUC
regulates California natural gas rates and natural gas services, including in -state transportation over transmission
and distribution pipeline systems, storage, procurement, metering, and billing. Most of the natural gas used i n
California comes from out-of-state natural gas basins. Biogas (e.g., from wastewater treatment facilities or dairy
farms) is just beginning to be delivered into the gas utility pipeline systems, and the state has been encouraging its
development (CPUC 2020).
SDG&E provides natural gas services to 3.6 million customers through 873,000 natural gas meters throughout a
4,100-square-mile service area in San Diego and Southern Orange County (SDG&E 2020b). SDG&E delivered
approximately 534 million therms (53 billion kilo British thermal units [kBtu]) to San Diego County (CEC 2020c).
Within the City of Chula Vista, the annual community-wide natural gas consumption (encompassing both residential
and non-residential) is approximately 3,531,230 million British thermal units or 35.3 million therms in 2016 (City
of Chula Vista 2020b).
Petroleum
According to the EIA, California used approximately 681 million barrels of petroleum in 2018, with the majority (584
million barrels) used for the transportation sector (EIA 2020d). This total annual consumption equates to a daily
use of approximately 1.9 million barrels of petroleum. There are 42 U.S. gallons in a barrel, so California consumes
approximately 78.4 million gallons of petroleum per day, adding up to an annual consumption of 28.7 billion gallons
of petroleum. Also, countywide total petroleum use by vehicles is expected to be 1.6 billion gallons per year in 2021
and 1.3 billion gallons per year in 2028 (CARB 2020).
By sector, transportation uses utilize approximately 85.5% of the state’s petroleum, followed by 11.1% from
industrial, 2.5% from commercial, 0.9% from residential, and 0.01% from electric power uses (EIA 2018b).
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Petroleum usage in California includes petroleum products such as motor gasoline, distillate fuel, liquefied
petroleum gases, and jet fuel. California has implemented policies to improve vehicle efficiency and to support use
of alternative transportation, which are described in Section 5.5.1.1, Regulatory Framework.
5.5.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to energy is based on the recommendations provided
in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). A significant impact would occur if the project would:
A. Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project construction or operation.
B. Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
5.5.3 Impacts
A. Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption
of energy resources, during project construction or operation.
Construction
Electricity
Electrical power would be consumed to construct the proposed project. The demand would be supplied from existing
electrical services at the proposed project site. Construction activities would require minimal electricity
consumption and would not be expected to have any adverse impact on available electricity supplies and
infrastructure as the proposed project site is surrounded by developed residential parcels. The City’s noise
ordinance generally restricts construction during the hours of 7:00 a.m. and 10:00 p.m., Monday through Friday ,
and between the hours of 8:00 a.m. and 10:00 p.m., Saturday and Sunday, which would minimize the need for
nighttime lighting. The electricity used for construction would be temporary, would be substantially less than
required for proposed project operation, and would therefore have a negligible contribution to the proposed
project’s overall energy consumption.
Natural Gas
Natural gas is not anticipated to be required during construction of the proposed project. Fuels used for construction
would primarily consist of diesel and gasoline, which are discussed under the petroleum subsection, below. Any
minor amounts of natural gas that may be consumed as a result of project construction would be substantially less
than that required for project operation and would have a negligible contribution to the proposed project’s overall
energy consumption.
Petroleum
Heavy-duty construction equipment of various types would be used during each phase of project construction. The
California Emissions Estimator Model (CalEEMod) Version 2016.3.2 analysis discussed in Section 5.2, Air Quality,
and included in Appendix C lists the assumed equipment usage for each phase of construction. Potential impacts
were assessed through projected traffic trip generation during construction, as provided by CalEEMod outputs
(Appendix C). Fuel consumption from construction equipment was estimated by converting the total carbon dioxide
(CO2) emissions from each construction phase to gallons using conversion factors for CO2 to gallons of gasoline or
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diesel. The conversion factor for gasoline is 8.78 kilograms per metric ton CO2 per gallon, and the conversion factor
for diesel is 10.21 kilograms per metric ton CO2 per gallon (The Climate Registry 2020). It is assumed that
construction workers would travel to and from the project site in gasoline-powered vehicles. Fuel consumption from
worker and vendor trips was estimated by converting the total CO2 emissions from the construction phase to gallons
using the conversion factors for CO2 to gallons of gasoline or diesel. Worker vehicles are assumed to be gasoline
fueled, and vendor vehicles are assumed to be diesel fueled. Based on that analysis, over all phases of construction,
diesel-fueled construction equipment would run for an estimated 142,582 hours as summarized in Table 5.5-1.
Table 5.5-1. Hours of Operation for Construction Equipment
Construction Phase Hours of Equipment Use
Site preparation 1,680
Grading 11,264
Architectural coating 9,990
Building construction 112,880
Paving 6,768
Total 142,582
Source: Appendix F.
The estimated diesel fuel use from construction equipment is shown in Table 5.5-2.
Table 5.5-2. Construction Equipment Diesel Demand
Phase Pieces of Equipmenta Equipment CO2 (MT)a kg CO2/Gallonb Gallons
Site preparation 7 50.15 10.21 4,912.19
Grading 8 479.60 10.21 46,973.45
Architectural coating 1 212.56 10.21 20,818.63
Building construction 9 1924.42 10.21 188,484.11
Paving 6 141.19 10.21 13,829.00
Total 275,017.38
Sources:
a Appendix F.
b The Climate Registry 2020.
Notes: CO2 = carbon dioxide; MT = metric ton; kg = kilogram.
Calculations for total worker and vendor fuel consumption are provided in Tables 5.5-3 and 5.5-4.
Table 5.5-3. Construction Worker Vehicle Gasoline Demand
Phase Trips Vehicle CO2 (MT)a kg CO2/Gallonb Gallons
Site Preparation 540 1.89 8.78 215.42
Grading 3,520 12.27 8.78 1,397.81
Architectural Coating 298,035 909.17 8.78 103,550.14
Building
Construction
1,482,380 4520.05 8.78 514,812.44
Paving 2,115 7.14 8.78 812.81
Total 620,788.62
Sources:
a Appendix F.
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b The Climate Registry 2020.
Notes: CO2 = carbon dioxide; MT = metric ton; kg = kilogram.
Table 5.5-4. Construction Vendor Truck Diesel Demand
Phase Trips Vehicle CO2 (MT)a kg/CO2/Gallonb Gallons
Site Preparation 0 0.00 10.21 0.00
Grading 0 0.00 10.21 0.00
Architectural Coating 0 0.00 10.21 0.00
Building
Construction
370,180 4641.50 10.21 454,603.52
Paving 0 0.00 10.21 0.00
Total 454,603.52
Sources:
a Appendix F.
b The Climate Registry 2020.
Notes: CO2 = carbon dioxide; MT = metric ton; kg = kilogram.
As shown in Tables 5.5-3 and 5.5-4, the project is estimated to consume 1,350,410 gallons of petroleum during
the construction phase. The project would be required to comply with CARB’s Airborne Toxics Control Measure,
which restricts heavy-duty diesel vehicle idling time to 5 minutes, which would minimize fuel consumption. While
construction activities would consume petroleum-based fuels, consumption of such resources would be temporary
and would cease upon the completion of construction. Further, the petroleum consumed related to project
construction would be typical of construction projects of similar types and sizes and would not necessitate new
petroleum resources beyond what are typically consumed in California. In addition, the project site is served by
public transportation services and Interstate 805. Due to the presence of a MTS bus routes 703 and 704 bus stop
at Brandywine and Olympic Parkway, approximately 0.9 miles from the site and the East Palomar Transit Station
located approximately one mile from the project site, some construction workers would be anticipated to use public
transportation to access the project site during construction. Therefore, construction worker trips and associated
petroleum consumption would be expected to be reduced compared to similar construction projects in rural
locations. The project would also utilize Tier 3 off-road construction equipment as implemented under MM-GHG-1.
Therefore, because electricity, natural gas, and petroleum use during construction would be temporary and
relatively minimal, and would not be wasteful or inefficient, impacts would be less than significant.
Operation
Electricity
The operational phase would require electricity for multiple purposes including, but not limited to, building
heating and cooling, lighting, appliances, and electronics. Additionally, the supply, conveyance, treatment, and
distribution of water would indirectly result in electricity usage. CalEEMod was used to estimate proje ct emissions
from electricity uses (see Appendix F for calculations). Default electricity generation rates in CalEEMod were used
based on the proposed land use and climate zone and were adjusted to reflect compliance with 2019 Title 24
standards. The current Title 24, Part 6 standards, referred to as the 2019 Title 24 Building Energy Efficiency
Standards, became effective on January 1, 2020. The current version of CalEEMod assumes compliance with
the 2016 Title 24 Building Energy Efficiency Standards (CAPCOA 2017); however, the proposed project would be
required to comply with the 2019 Title 24 Standards. The project operational energy emissions were adjusted to
meet the 2019 Title 24 Standards, by assuming 53% less energy use than that under the 201 6 standards (CEC
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2018). This is because, as described in Section 5.5.1, once rooftop solar electricity generation is factored in,
residential units built under the 2019 standards will use approximately 53% less energy than those under the 2016
standards (CEC 2018). Using the 2019 Title 24 Standards , the proposed project’s estimated electricity
consumption is approximately 4,480,067 kWh per year (Appendix F). For disclosure, in comparison, for San Diego
County, electricity demand in 2019 was 19,048 million kWh (CEC 2020 b). More specifically, within the City, the
annual community-wide electricity consumption (encompassing both residential and non -residential) is
approximately 828 million kWh in 2016 (City of Chula Vista 2020b).
The proposed project’s impacts in the category of GHG emissions was determined to be potentially significant; thus,
the project would be required to comply with Mitigation Measure (MM) GHG-1, Greenhouse Gas Emissions
Reduction Measures (see Section 5.7, Greenhouse Gas Emissions, for details)., Reducing GHG emissions during
operation would help reduce operation-related electricity usage and operation related GHG emissions in the City.
The energy demand calculations do not take into account the energy saving measures from MM-GHG-1, including
installing energy-efficient lighting for all street, parking, and area lighting associated with the project and
implementing energy-efficient design practices, which include high-performance glazing, Energy Star compliant
systems and appliances, radiant heat roof barriers, insulation on all pipes, programmable thermostats, and sealed
ducts. Furthermore, the project would be consistent with the applicable measures within the City’s CAP to reduce
the proposed project’s energy use by planting 600 shade trees, installing solar photovoltaic systems consistent
with current building standards, and installing cool roof material with a greater solar reflectivity to help conserve
energy (see Section 5.7 for a complete consistency analysis with the CAP). In summary, the proposed project would
comply with the CAP and implement energy reducing measures in MM-GHG-1, as required to reduce GHG emissions,
but used to also further reduce electricity usage.
Natural Gas
The operation of the proposed project would require natural gas for space heating, water heating, and to power
appliances (EIA 2010). Default natural gas usage rates in CalEEMod for the proposed land use and climate
zone were used and adjusted based on compliance with 2019 Title 24 standards . The project’s estimated
natural gas consumption is approximately 9,841,430 kBTU per year , which is equivalent to 98,414 therms
(Appendix F).
For disclosure, 2019, SDG&E delivered approximately 534 million therms (53 billion kBtu) to San Diego County
(CEC 2020c). Within the City of Chula Vista, the annual community-wide natural gas consumption (encompassing
both residential and non-residential) is approximately 3,531,230 million Btu or 35.3 million therms in 2016 (City
of Chula Vista 2020b). Project-specific measures would be implemented under MM-GHG-1 (as listed in Section 5.7),
including energy-efficient design practices, which would minimize the proposed project’s natural gas use. The
project is subject to statewide mandatory energy requirements as outlined in Title 24, Part 6, of the California Code
of Regulations. Prior to project approval, the applicant would ensure that the project would meet Title 24
requirements applicable at that time, as required by state regulations through their plan review process.
Peak natural gas use for households typically occurs in the winter months (EIA 2016). In Southern California, peak
demand occurs in winter (California Gas and Electric Utilities 2016). As such, the proposed project’s peak natural
gas use is expected to align g enerally with typical peak use patterns in the region. In addition, the regulations
and design features described above would reduce the proposed project’s effect on peak and base periods of
natural gas demand.
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In summary, the proposed project would implement energy reducing measures through implementation of MM-
GHG-1, the effects of which would be increased through implementation of green building standards, required for
implementation of the proposed project.
Petroleum
During operations, fuel consumption resulting from the project would involve the use of motor vehicles traveling to
and from the project site by residents.
Petroleum fuel consumption associated with motor vehicles traveling to and from the project site is a function of
the vehicle miles traveled as a result of project operation. The annual unmitigated VMT attributable to the proposed
project is expected to be 10,196,784 VMT (Appendix F). The proposed project would consume an estimated
324,636 gallons of gasoline per year and 58,548 gallons of diesel per year from operation of vehicle trips traveling
to and from the project site, or 383,184 gallons of petroleum per year. By comparison, California as a whole
consumes approximately 78.4 million gallons of petroleum per day, adding up to an annual consumption of 28.7 billion
gallons of petroleum (EIA 2020d). Also, for disclosure, countywide total petroleum use by vehicles is expected to be
1.3 billion gallons per year in 2028 (CARB 2020).
Over the lifetime of the proposed project, the fuel efficiency of the vehicles being used by the residents of the
proposed project is expected to increase. As such, the amount of gasoline consumed as a result of vehicular trips
to and from the project site during operation would decrease over time. As discussed under Section 5.5.1.1, there
are numerous regulations in place that require and encourage increased fuel efficiency. For example, CARB has
adopted a new approach to passenger vehicles by combining the control of smog-causing pollutants and GHG
emissions into a single coordinated package of standards. The new approach also includes efforts to support and
accelerate the numbers of plug-in hybrids and ZEVs in California (CARB 2017). As such, operation of the proposed
project is expected to use decreasing amounts of petroleum over time, due to advances in fuel economy.
The project would implement PDF-TRA-1 (see Section 4.4.8, Project Design Features, of the EIR), which includes strategies
that would further reduce the project’s vehicle miles traveled, including providing ride share coordination services,
coordinating with nearby schools to carpool to/from school, provide on-site transit opportunities information, and
encourage bicycling by providing on-site bicycle infrastructure such as bike racks.
The proposed project’s impacts in the category of GHG emissions was determined to be potentially significant; thus,
the project would be required to implement MM-GHG-1 (see Section 5.7 for details), which include pre-wiring two
parking spots and the project’s 718 parking garages to be electric vehicle capable. Furthermore, the two pre -wired
parking spots would be designated for carpool, shared, electric, and hydrogen vehicles. Reducing GHG emissions
during operation would help reduce operation-related fuel usage. Furthermore, the proposed project would provide
pedestrian and bicycle connectivity to the neighborhood due to proximity to bicycle routes and by providing
pedestrian sidewalk connections to the Chula Vista Regional Trail located along Olympic Parkway. The proposed
project would be located near MTS bus routes 703 and 704 and Interstate 805 and the East Palomar Transit Station
would be located approximately one mile from the project site. In addition, the project is located near commercial and
employment centers in an urban setting. These project characteristics would promote pedestrian and bicycle activity
and encourage alternate forms of transportation. Lastly, the project would be consistent with the applicable
measures within the CAP to reduce the proposed project’s petroleum use (see Section 5.7 of this EIR for a complete
consistency analysis with the CAP).
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In summary, over time. vehicles would use less petroleum due to advances in fuel economy. Additionally, the proposed
project would include a variety of features that are expected to reduce the proposed project’s petroleum use and
reduce the number of vehicles traveling to and from the site during operation. Given these considerations, the
electrictiy, natural gas, petroleum consumption associated with the proposed project would not be considered
inefficient or wasteful, and impacts would be less than significant.
B. Conflict with or obstruct a state or local plan for renewable energy or energy efficiency
The proposed project would be subject to and would comply with, at a minimum, the California Building Energy
Efficiency Standards (24 CCR, Part 6). Part 6 of Title 24 establishes energy efficiency standards for residential and
non-residential buildings constructed in California in order to reduce energy demand and consumption.
Part 11 of Title 24 sets forth voluntary and mandatory energy measures that are applicable to the proposed project
under the California Green Building Standards Code. As discussed under Threshold A, the proposed project would
result in an increased demand for electricity, natural gas , and petroleum. During both construction and operation
of the project, the project would comply with all state regulations related to solid waste generation, storage, and
disposal, including the California Integrated Waste Management Act, as amended. As implemented by MM-GHG-1,
during construction, all wastes would be recycled to the maximum extent possible and exceed the City of Chula
Vista’s Construction and Demolition Debris Waste Management Plan’s 65% diversion of construction and
demolition waste. In addition, the proposed project is subject to the City’s CAP, City’s Green Building Standards,
and City’s Energy Code for Residential Development. The California Green Building Standards, on which the City’s
Green Building Standards Ordinance 15.12 is based, includes measures for reducing overall energy consumption
through water conservation, electricity and natural gas conservation, and building design. Included in these
standards is a mandate for 20% less water use than currently required by the state plumbing code. The City’s
Landscape Water Conservation Ordinance would further reduce water consumption and associated electricity use
through the use of drought-tolerant landscaping and water-efficient irrigation systems. As implemented under MM-
GHG-1, the project would install energy-efficient lighting for all street, parking, and area lighting associated with the
project. Furthermore, energy-efficient design practices, such as high-performance glazing, Energy Star compliant
systems and appliances, radiant heat roof barriers, insulation on all pipes, programmable thermostats, and sealed
ducts, shall be implemented. The project would install cool roof material with a greater solar reflectivity to help
conserve energy. In addition, the project would plant native species and drought-tolerant species would be used for a
minimum of 50% of the ornamental plant palette in non-turf areas to minimize the project’s water demand, and the project
would install purple pipes to use reclaimed water for irrigation.
The project would be consistent with the applicable measures within the CAP to reduce the proposed project’s
petroleum use and reduce the number of vehicles traveling to and from the project site. The project would implement
PDF-TRA-1 (see Section 4.4.8, Project Design Features, of the EIR), which includes the following strategies that would
further reduce the project’s vehicle miles traveled, including providing ride share coordination services, coordinating with
nearby schools to carpool to/from school, provide on-site transit opportunities information, and encourage bicycling by
providing on-site bicycle infrastructure such as bike racks. The project would pre-wire two parking spots and the project’s
718 parking garages to be electric vehicle capable. In addition, the two pre-wired parking spots would be designated
for carpool, shared, electric, and hydrogen vehicles. The project would be located near MTS bus routes 703 and
704 and I-805, and the East Palomar Transit Station is located approximately one mile from the project site. In addition,
the project is located near commercial and employment centers in an urban setting. These project characteristics would
promote pedestrian and bicycle activity and encourage alternate forms of transportation (see Section 5.7 of this
EIR for a complete consistency analysis with the CAP).
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The proposed project would use energy su pplied by SDG&E, which achieved a renewable procurement
percentage of 44% in 2017 as reported by CEC. In addition, the CAP set a goal of using 100% clean renewable
energy and the City is currently evaluating the feasibility of a Community Choice Aggregation program (City of
Chula Vista 2017, 2020a). In addition, the project would install a 1,462-kW solar photovoltaic system meeting
the minimum 2019 Title 24 standards.
Because the proposed project would comply with and exceed the existing energy standards and regulations, the
project would result in a less than significant impact associated with the potential to conflict with energy standards
and regulations.
5.5.4 Level of Significance Prior to Mitigation
Impacts prior to mitigation would be less than significant.
5.5.5 Mitigation Measures
No mitigation measures are required.
5.5.6 Level of Significance After Mitigation
There are no mitigation measures proposed and impacts would remain less than significant.
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5.6 Geology and Soils
This section of the environmental impact report (EIR) describes the existing geology and soils setting of the proposed
Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II, Phase 3 Project (project or proposed project),
identifies associated regulatory requirements, evaluates potential impacts, and identifies mitigation measures to reduce
or avoid significant impacts. The following analysis is based on the Geotechnical Investigation Report (Geotechnical
Report) prepared by Geocon Inc. and the Cultural and Paleontological Resources Inventory Report prepared by Dudek.
The reports are provided as Appendix G and Appendix E to this EIR, respectively.
5.6.1 Existing Conditions
5.6.1.1 Regulatory Framework
Federal
International Building Code
The International Building Code (IBC) is a model building code developed by the International Code Council that
provides the basis for the California Building Code (CBC). The purpose of the IBC is to provide minimum standards
for building construction to ensure public safety, health, and welfare. Prior to the creation of the IBC, several
different building codes were used; however, by 2000, the IBC had replaced these previous codes. The IBC is
updated every 3 years.
Occupational Safety and Health Administration Regulations
The Occupational Safety and Health Administration’s Excavation and Trenching standard, Title 29 of the Code of
Federal Regulations, Part 1926.650, covers requirements for excavation and trenching operations. The
Occupational Safety and Health Administration requires that all excavations where employees could potentially be
exposed to cave-ins be protected by sloping or benching the sides of the excavation, supporting the sides of th e
excavation, or placing a shield between the side of the excavation and the work area.
State
Alquist-Priolo Earthquake Fault Zoning Act
The Alquist-Priolo Earthquake Fault Zoning Act of 1972 (California Public Resources Code Sections 2621 –2630)
regulates development and construction of buildings intended for human occupancy to avoid the hazard of surface
fault rupture. The act helps define areas where fault rupture is most likely to occur. The act groups faults into
categories of active, potentially active and inactive. Historic and Holocene age faults are considered active. Late
Quaternary and Quaternary age faults are considered potentially active and pre -Quaternary age faults are
considered inactive. These classifications are qualified by the conditions that a fault must be shown to be
sufficiently active and well defined by detailed site-specific geologic explorations to determine whether building
setbacks should be established. Cities and counties affected by the zones must regulate certain development
projects within the zones. They must withhold development permits for sites within the zones until geologic
investigations demonstrate that the sites are not threatened by surface displacement from future faulting.
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California Building Code
State regulations protecting structures from geo-seismic hazards are contained in the California Code of
Regulations, Title 24, Part 2 (the California Building Code [CBC]). The purpose of the CBC is to establish minimum
standards to safeguard the public health, safety, and general welfare through structural strength, means of egress
facilities, and general stability by regulating and controlling the design, construction, quality of materials, use and
occupancy, location, and maintenance of all building and structures within its jurisdiction. The CBC is based on the
International Building Code published by the International Code Conference. The CBC contains California
amendments based on the American Society of Civil Engineers Minimum Design Standards 7 -05, which provides
requirements for general structural design and includes means for determining earthquake loads and other loads
(such as wind loads) for inclusion into building codes. The provisions of the CBC apply to the construction, alteration,
movement, replacement, and demolition of every building or structure or any appurtenances connected or attached
to such buildings or structures throughout California.
California Environmental Quality Act
Paleontological resources are limited, nonrenewable resources of scientific, cultural, and educational value and are
afforded protection under state laws and regulations, notably, the California Environmental Quality Act (CEQA)
(California Public Resources Code Section 21000 et seq.). This report satisfies project requirements in accordance
with CEQA and California Public Resources Code Section 5097.5. This analysis also complies with guidelines and
significance criteria specified by the Society of Vertebrate Paleontology (SVP 2010).
Paleontological resources are explicitly afforded protection by CEQA, specifically in Section VII(f) of CEQA Guidelines
Appendix G, the Environmental Checklist Form, which addresses the potential for adverse impacts to “unique
paleontological resource[s] or site[s] or … unique geological feature[s]” (14 CCR 15000 et seq.). This provision covers
fossils of signal importance—remains of species or genera new to science, for example, or fossils exhibiting features
not previously recognized for a given animal group—as well as localities that yield fossils significant in their abundance,
diversity, preservation, and so forth. Further, CEQA provides that, generally, a resource shall be considered “historically
significant” if it has yielded or may be likely to yield information important in prehistory (14 CCR 15064.5 [a][3][D]).
Paleontological resources would fall within this category. The California Public Resources Code, Chapter 1.7, Sections
5097.5 and 30244, also regulates removal of paleontological resources from state lands, defines unauthorized
removal of fossil resources as a misdemeanor, and requires mitigation of disturbed sites.
California Geologic Survey
The California Geologic Survey (CGS) provides guidance with regard to seismic hazards. The CGS’s Special Publication
117, Guidelines for Evaluating and Mitigating Seismic Hazards in California provides guidance for evaluation and
mitigation of earthquake-related hazards for projects within designated zones of required investigation.
State Earthquake Protection Law
The State Earthquake Protection Law (California Health and Safety Code 19100 et seq.) requires that structures be
designed to resist stresses produced by lateral forces caused by wind and earthquakes. Specific minimum seismic
safety and structural design requirements are set forth in the CBC. The CBC requires a site-specific geotechnical
study to address seismic issues and identify seismic factors that must be considered in structural design. Because
the project site is not located within an Alquist–Priolo Earthquake Fault Zone (Exhibit 5.8-3, Alquist-Priolo
Earthquake Fault Zone Map, in City of Murrieta 2011a), no special provisions would be required for project
development related to fault rupture.
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Seismic Hazards Mapping Act of 1990
The Seismic Hazards Mapping Act of 1990 (SHMA) (California Public Resources Code Section 2690 et seq.) directs
the California Department of Conservation, California Geological Survey, to identify and map areas prone to
liquefaction, earthquake-induced landslides, and amplified ground shaking. The purpose of the SHMA is to minimize
loss of life and property through the identification, evaluation, and mitigation of seismic hazards.
The SHMA provides a statewide seismic hazard mapping and technical advisory program to assist cities and
counties in fulfilling their responsibilities for protecting public health and safety from the effects of strong ground
shaking, liquefaction, landslides, other ground failure, and other seismic hazards caused by earthquakes. Mapping
and other information generated pursuant to the SHMA is made available to local governments for planning and
development purposes. The state requires local governments to incorporate site-specific geotechnical hazard
investigations and associated hazard mitigation as part of the local construction permit approval process, and
requires the agent for a property seller, or the seller if acting without an agent, to disclose to any prospective buyer
if the property is located within a seismic hazard zone. The state geologist is responsible for compiling seismic
hazard zone maps. The SHMA specifies that the lead agency for a project may withhold development permits until
geologic or soils investigations are conducted for specific sites and mitigation measures are incorporated into plans
to reduce hazards associated with seismicity and unstable soils.
Local
City of Chula Vista General Plan – Environmental Element
Individual project development proposed on property under City of Chula Vista (City) jurisdiction has requirements
similar to IBC and CBC requirements, and must comply with Objective E 14 and its three associated policies (E
14.1, E 14.2, and E 14.3) contained in the Environmental Element of the General Plan (Chapter 9, Section 3.1.10)
(City of Chula Vista 2005). Implementation of this objective and policies are intended to reduce potential impacts
associated with geological hazards and public safety.
• Objective E 14: Minimize the risk of injury, loss of life, and property damage associated with geologic hazards.
• Policy E 14.1: To the maximum extent practicable, protect against injury, loss of life, and major property
damage through engineering analyses of potential seismic hazards, appropriate engineering design, and
the stringent enforcement of all applicable regulations and standards.
• Policy E 14.2: Prohibit the subdivision, grading, or development of lands subject to potential geologic
hazards in the absence of adequate evidence demonstrating that such development would not be adversely
affected by such hazards and would not adversely affect surrounding properties.
• Policy E 14.3: Require site-specific geotechnical investigations for proposals within areas subject to
potential geologic hazards; and ensure implementation of all measures deemed necessary by the City
Engineer and/or Building Official to avoid or adequately mitigate such hazards.
Additionally, the City’s Environmental Element addresses potential impacts to non-renewable paleontological
resources and outlines policies to mitigate negative impacts (City of Chula Vista 20 05). The objective and policies
protecting paleontological resources are outlined below:
• Objective E 10: Protect important paleontological resources and support and encourage public education
and awareness of such resources.
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• Policy E 10.1: Continue to assess and mitigate the potential impacts of private development and public
facilities and infrastructure to paleontological resources in accordance with the California Environmental
Quality Act.
• Policy E 10.2: Support and encourage public education and awareness of local paleontological resources,
including the establishment of museums and educational opportunities accessible to the public.
5.6.1.2 Existing Setting
Geologic Setting
The geology underlying the project site consists of surficial soil (previously placed fill, topsoil, alluvium and
colluvium) and the San Diego, Otay, and Sweetwater Formations, which are described in more detail below.
Previously Placed Fill
Compacted fill associated with previous grading operations for Olympic Parkway is present along the northern boundary
of the project site. The northern portion of these embankments is underlain by alluvium. However, the potentially
compressible portions of this unit were removed or compressed by surcharging during prior grading operations.
Topsoil
Topsoil was encountered in several of the exploratory borings and trenches performed at the site with a maximum
thickness of 4 feet. These deposits, in general, consist of unconsolidated, clayey sands to sandy clays with a high
expansion potential and will require remedial grading where present within the development area.
Alluvium
Alluvium is present within the three main drainages on the project site and along Olympic Parkway. These
deposits vary in thickness from 6 to 12 feet and primarily consist of expansive, silty to sandy clays to clayey
sands. The alluvium would require remedial grading where structural improvements are planned.
Colluvium
Colluvial deposits are present along the hillsides above the alluvial drainages. These deposits consist of clayey
sands to silty clays with a high expansion potential and vary from 3.5 to 8-feet-thick. Remedial grading will be
required where colluvium is located in areas of planned development.
San Diego Formation
The San Diego Formation overlies the Otay Formation and typically consists of dense, fine to medium -grained
sandstone with relatively low cohesion and moderate to high permeability. In general, the San Diego Formation
exhibits adequate shear strength and “very low” to “low” expansion characteristics in either an undisturbed or
properly compacted condition. Due to the potentially friable and higher permeability characteristics of this unit,
stability fills would be required where the San Diego Formation is exposed in cut slopes.
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Otay Formation
The Otay Formation, which overlies the Sweetwater Formation and underlies the San Diego Formation, is the
predominant geologic unit on the project site. This formation consists of dense, silty to clayey, sandstone and hard,
siltstone and claystone beds with continuous to discontinuous interbeds of weak, highly plastic bentonitic claystone.
The sandy portions of the Otay Formation typically possess a “very low” to “low” expansion potential and adequate
shear strength. The siltstone and claystone portions of the formation can exhibit a “medium” to “very high”
expansion potential. With the possible exception of the bentonitic claystone, the Otay Formation is suitable for the
support of compacted fill and structural loads. The laterally extensive bentonitic claystone beds, which are well
documented in the area, can vary in thickness from several inches up to 7 feet. The beds are typically flat lying to
gently dipping (0 to 3 degrees) and possess a very high expansion potential and very low shear strength. A laterally
continuous bentonitic claystone bed is mapped across the project site between elevations 341 feet and 371 feet
above mean sea level. This unit will require important consideration with respect to slope stability and its expansion
potential and will require remedial grading measures.
The Otay Mesa Lateral Spread, commonly referred to as an ancient “intra -formational landslide” by geologists, is
mapped within the project site. This ancient landslide, which is over 8 miles wide and approximately 2.5 miles long,
is entirely contained within the Otay Formation and terminates along the La Nación Fault to the west. This feature
has been observed and mapped during the grading operations for Olympic Parkway and other neighboring
residential developments.
The basal surface of the ancient “intra-formational landslide” occurred along a single, continuous, bentonitic clay
bed that coincides with the bentonitic clay bed previously mentioned. The slide mass consists of relatively
undisturbed consolidated blocks of the Otay Formation that have low to very low compressibility characteristics.
Some areas exhibit plastically deformed bentonite which has been squeezed into the overlying mass creating
unpredictable diapirs and flame structures that vary in dimension and orientation. If present, these features can
create problems for site improvements due to their expansion potential. Although not observed within the
exploratory borings and trenches, the potential for these conditions will be evaluated during the grading phase of
project development.
Sweetwater Formation
The Sweetwater Formation, commonly referred to as the “gritstone layer” of the Otay Formation, underlies the Otay
Formation and is characterized as dense to very dense, gravelly, and fine to coarse sandstone that is locally
cemented. The Sweetwater Formation generally has a high shear strength and a low expansive potential.
Expansive Soil
Expansive soils contain minerals, such as clay, that are capable of absorbing water and expanding, and losing water
and shrinking. As discussed in the Geotechnical Report, the project site contains soils that are both non-expansive
and expansive. Colluvial deposits which are present along the hillsides above the alluvial drainages , consist of
clayey sands to silty clays with a high expansion potential. Additionally, alluvium primarily consist of expansive, silty
to sandy clays to clayey sands. The sandy portions of the Otay Formation typically possess a “very low” to “low”
expansion potential and adequate shear strength. The siltstone and claystone portions of the formation can exhibit
a “medium” to “very high” expansion potential. Furthermore, the project site contains topsoil deposits, which in
general, consist of unconsolidated, clayey sands to sandy clays with a high expansion potential.
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Liquefaction
Liquefaction typically occurs when a site is located in a zone with seismic activity, on -site soils are cohesionless,
groundwater is encountered within 50 feet of the surface, and soil densities are less than about 70% of the relative
density. The Geotechnical Report states that the potential for liquefaction on the project site is considered negligible
due to the dense formational material on the project site, shallow groundwater table, and remedial grading
recommendation that will be discussed in Section 5.6.3, Impacts (refer to Appendix E for further details).
Groundwater Seepage
Groundwater was identified on site at depths of 165 and 275 feet, respectively, below the existing ground surface. Minor
seepage was observed along the alluvium and bedrock contact approximately 7 feet below existing grade (see Appendix
G for further details). The groundwater elevations and seepage conditions are expected to fluctuate seasonally.
Slope
The General Plan designates the majority of the project site as being in a steep slope area (City of Chula Vista
2005). Steep slope areas are classified as areas with slopes 25 degrees or steeper. Such areas are prone to
hazards such as slope instability, debris flow, rock falls, erosion, and slope creep (City of Chula Vista 2005). As
such, the Geotechnical Report analyzed the stability of the proposed and natural slopes on the project site.
Faulting and Seismicity
The closest known active fault” is the Newport-Inglewood Fault Zone, located approximately 9 miles west of the
project site. An active fault is defined by the CGS, as a fault showing evidence of activity roughly within the last
11,000 years (Holocene time). Table 5.6-1 presents active faults in proximity to the project site. In addition, the
main strand of the La Nación Fault is mapped approximately 0.3 miles west of the project site and has been
classified as potentially active, which is defined by CGS as a fault showing evidence of activity within the last 1.8
million years. Furthermore, published geologic maps depict a north–south-striking fault within the eastern portion
of the project site. However, the Geotechnical Report did not identify the origin or activity of the fault.
Table 5.6-1. Principal Active Faults Near Project Site
Fault Name Distance from Project Site (Miles) Maximum Earthquake Magnitude (Mmax)
Newport–Inglewood 9 7.5
Rose Canyon 9 6.9
Coronado Bank 17 7.4
Palos Verdes Connected 17 7.7
Elsinore 42 7.9
Earthquake Valley 46 6.8
Source: Appendix G.
Landslides
The Geotechnical Report found no evidence of landslide deposits on the project site, or within the geologic literature
review other than the ancient “intra-formational landslide” within the Otay Formation that underlies the region. This
ancient landslide, which is more than 8 miles wide and approximately 2.5 miles long, is entirely contained within
the Otay Formation and terminates along the La Nación Fault to the west (Appendix E).
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Paleontological Resources
Paleontological resources are the fossilized remains or traces of plants and animals that are preserved in the
earth’s crust, and per the Society of Vertebrate Paleontology guidelines (Appendix E), are older than written history
or older than approximately 5,500 years.
Methods
A pedestrian survey of the area of potential effect (APE) for cultural and paleontological resources was conducted
on April 11, 2020. Areas throughout the APE were inspected at 10- and 15-meter transects.
Additionally, a paleontological records search from the San Diego Natural History Museum (SDNHM) was conducted
on April 9, 2020. The records search request included the project APE and a 1-mile-radius buffer around the
proposed project. The purpose of the paleontological records search was to assist in identifying geological units
within the proposed project APE and determine if any paleontological localities exist within the proposed project
APE and 1-mile-radius buffer (refer to Appendix E for further details).
Results
Archival Review
The results of the archival review found that the project is underlain by Holocene (< 11,700 years ago) to late Pleistocene
(approximately 129,000 to 11,700 years ago) young alluvial floodplain deposits (map unit Qya), the late Pliocene to early
Pleistocene (approximately 3.6 million years ago to 1.8 million years ago) San Diego Formation (map unit Tsdss), and the
late Oligocene (approximately 1 million years ago) Otay Formation (map unit To) (Appendix E).
The San Diego National History Museum (SDNHM) paleontological records results were received on April 14, 2020,
and no records were found of fossil localities within the boundaries of the project APE. However, 14 fossil localities
are located within a 0.5-mile radius of the study area (Appendix E). Of these, two localities are from the Otay
Formation and 12 localities are from the San Diego Formation.
Survey Results
The pedestrian survey of the (APE) conducted April 11, 2020, identified no new paleontological resources within
the current APE limits. Visibility was overwhelmingly obscured by vegetation, allowing for less than one -third of the
ground surface to be viewed in many areas. In addition, the western-most sector of the proposed project site was
inaccessible due to the presence of an active, inhabited homeless camp located within the western portion of the
site, where open space/Preserve is proposed.
5.6.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to geology and soils is based on the recommendations
provided in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). A significant impact w ould occur if the
project would:
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).
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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 waste water 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.
5.6.3 Impacts
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).
An active fault is defined by the CGS as a fault showing evidence for activity within the last 11,000 years. According
to the Geotechnical Report, the project site is not located on any known active, potentially active, or inactive fault
traces or within a State of California Earthquake Special Study Zone or Alquist-Priolo Zone. Additionally, the
Geotechnical Report concluded that no active, potentially active, or inactive faults are present underlying or trending
toward the site (Appendix G). However, as discussed in Section 5.6.1, Existing Conditions, the Newport–Inglewood
and Rose Canyon Fault Zones are located approximately 9 miles from the project site. Newport–Inglewood and
Rose Canyon Fault Zones are the nearest known active faults and are the dominant source of potential ground
motion. Nonetheless, the proposed project would be constructed in accordance with the City’s Grading Ordinance,
current seismic design specifications, current CBC standards, and other regulatory requirements, which would
reduce the potential for risks related to seismic events. Therefore, since development would not be located within
an Alquist-Priolo Zone, and would be in compliance with applicable regulatory requirements, impacts associated
with the rupture of a known earthquake fault would be less than significant.
ii. Strong seismic ground shaking.
Earthquakes that might occur on the Newport–Inglewood and Rose Canyon Fault Zones or other faults within the
Southern California and northern Baja California area are potential generators of significant ground motion at the
site. As previously discussed, the Newport–Inglewood and Rose Canyon Fault Zones are both located approximately
9 miles from the project site. Newport–Inglewood and Rose Canyon Fault Zones are the nearest known active faults
and are the dominant source of potential ground motion. In the event of a major earthquake on any of the active
faults within the Southern California and northern Baja California region, the project site, as with other sites in the
general vicinity, could be subject to moderate to severe ground shaking. However, the proposed project would be
constructed in accordance with the City’s Grading Ordinance, current seismic design specifications, current CBC
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standards, and other regulatory requirements, which would reduce the potential for risks related to seismic events.
Therefore, impacts associated with strong seismic ground shaking would be less than significant.
iii. Seismic-related ground failure, including liquefaction.
As discussed in the Geotechnical Report, the potential for liquefaction at the project site is considered to be
negligible due to the dense formational material encountered on the project site, lack of a shallow groundwater
condition, and the recommendations for remedial grading. Remedial grading shall be required for areas with
expansive soils including topsoil, alluvium, and colluvial deposits (Refer to threshold D in this section for further
details). However, seismically induced settlement may occur whether the potential for liquefaction exists or not.
Although there is potential for seismic-related ground failure to occur, compliance with the City’s Grading Ordinance,
current seismic design specifications, current CBC standards, and other regulatory requirements, impacts
associated with seismic-related ground failure, including liquefaction would be less than significant.
iv. Landslides.
The General Plan designates the majority of the project site as being in a steep slope area. However, the
Geotechnical Report found no evidence of landslide deposits on the project site, or within the geologic literature
review other than the ancient “intra-formational landslide” within the Otay Formation that underlies the region.
Additionally, as discussed in the Geotechnical Report, a slope stability analysis was conducted to evaluate the
stability of proposed and natural slopes. The findings indicated that a buttress, two shear keys, and stability fills
would be required to achieve surficial stability (for further details, refer to Appendix G). In addition, the project
proponent is working with the City, to request an MSCP Minor Amendment to allow off-site temporary project
impacts that would encroach 25 feet onto City’s property and within this Minor Amendment Area (see Figure 5.3-1,
Local Environmental Setting Map, and Figure 5.3-4, Biological Impacts Map). The natural ground along the
southwest boundary between project site, and the property owned by the City, is underlain by geologic conditions
that are below industry standards with respect to slope stability. Minor excavations are planned in this area as part
of the development of the project. To bring this area in compliance with code, a buttress fill will be required which
consists of over‐excavating weak materials from the natural ground and replacing them with soils of higher strength.
The dimension of the over‐excavation was calculated during slope stability analysis for the proposed project and
resulted in the proposed encroachment into the City’s property to construct the buttress (Appendix D, Biological
Resources Technical Report). The resulting condition after grading will comply with applicable codes and also
improve the existing stability of the City’s property. Although the project site and Minor Amendment Area resides in
a steep slope area, where there is potential for landslides to occur, compliance with the findings of the Geotechnical
Report, the City’s Grading Ordinance, current seismic design specifications, current CBC standards, and other
regulatory requirements ensures that impacts related to landslides would be less than significant.
B. Result in substantial soil erosion or the loss of topsoil.
Construction Impacts
Excavation and ground-disturbing activities during construction of the proposed project could potentially leave loose
soil exposed to the erosive forces of rainfall and high winds, which increase the potential for soil erosion and loss
of topsoil. As discussed in Section 5.9 of this EIR, Hydrology and Water Quality, construction of the project would
result in more than 1 acre of land disturbance; therefore, the project will be required to prepare and implement a
site-specific Storm Water Pollution Prevention Plan (SWPPP) in accordance with the State Water Resources Control
Board (SWRCB) Order No. 2009-0008-DWQ NPDES General Permit No. CAS00002 (Construction General Permit),
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amended by Order No. 2010-0014-DWQ and Order No. 2012-0006-DWQ. Conditions of these existing regulations
would include adherence to sediment and stormwater pollutant control best management practices (BMPs),
effluent monitoring and compliance, post-construction-period requirements, worker training, and various other
measures designed to minimize potential for soil erosion and loss of top soil.
Furthermore, earth-disturbing activities associated with construction would be temporary. Therefore, with
construction activities being temporary and with compliance with the General Construction Permit and BMPs
outlined in the SWPPP, impacts related to soil erosion and the loss of topsoil would be less than significant.
Operational Impacts
During operation, the project would introduce a new residential use with associated infrastructure, resulting in more
impervious area to the site. As such, the proposed area to be developed would be graded and paved, greatly reducing
the possibility for soil erosion or loss of topsoil compared to current conditions. However, introducing more impervious
area would result in more surface runoff, which could lead to more soil erosion and loss of topsoil. As such, a stormwater
quality management plan (SWQMP) has been prepared for the project and is referred to as Appendix I1. The SWQMP
has been prepared consistent with the requirements of the City’s BMP Design Manual and with the requirements of San
Diego RWQCB Order No. R9-2013-0001 (Regional MS4 Permit).
The SWQMP prepared for the proposed project specifies site design BMPs that would be implemented to minimize soil
erosion and loss of topsoil. Site design BMPs include conserving natural areas, soils, and vegetation; minimizing impervious
areas; and minimizing soil compaction. Therefore, with implementation of the SWPPP and incorporation of the BMPs
described in the SWQMP, impacts associated with substantial erosion or siltation on or off site would be less than significant.
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.
According to the Geotechnical Report, the geology of the project site consists of surficial soil (previously placed fill,
topsoil, alluvium, and colluvium) and the San Diego, Otay, and Sweetwater Formations. The project site is underlain
by compressible surficial deposits (topsoil, alluvium, and colluvium) that are unsuitable in their present condition
and would require remedial grading (Appendix G). Remedial grading would include removal of unsuitable soils in
areas where improvements are planned and compaction of fill material.
The proposed project site is not located on any known active, potentially active, or inactive fault traces, although
cracking or lateral spreading of the ground surface as a result of nearby seismic events is possible (Appendix G).
Surface ground cracking or lateral spreading related to shaking from distant events is not considered a significant
hazard because the potential for liquefaction and seismically induced settlement occurring within the project site
is considered to be very low due to the dense nature of the formational materials and the lack of a shallow
groundwater condition (Appendix G).
According to the Geotechnical Report, potentially hazardous expansive and compressible soils are currently present
on site. However, the project shall incorporate recommendations in accordance with CBC standards regarding slab
and structural design criteria (refer to Appendix G for further details). Additionally, expansive soils that occur within
5 feet of finished grade on cut lots should be removed and replaced with properly compacted fill that possesses a
“very low” to “low” expansion potential. In addition, the proposed project would be required to comply with the City’s
Grading Ordinance, current seismic design specifications, current CBC standards, and other regulatory
requirements, in addition to implementation of project design features and BMPs and following recommendations
of the Geotechnical Report (Appendix G).
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Therefore, compliance with existing regulations and recommendations of the Geotechnical Report would ensure
that the proposed project would have less than significant impacts associated with unstable geologic units.
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.
As discussed in Section 5.6.1, the project site contains soils that present characteristics susceptible to expansion.
The project would be required to incorporate recommendations of the Geotechnical Report, in accordance with
CBC standards regarding slab and structural design criteria (refer to Appendix G for further details). Additionally,
per the Geotechnical Report, expansive soils that occur within 5 feet of finish grade on cut lots would be removed
and replaced with properly compacted fill that possesses a “very low” to “low” expansion potential. Therefore,
with adherence to current CBC standards and the recommendations of the Geotechnical Report, impacts
associated with expansive soil would be less than significant.
E. Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal
systems where sewers are not available for the disposal of wastewater.
The proposed project would not include septic tanks or other alternative wastewater treatment methods. Therefore,
implementation of the proposed project would result in no impact associated with soils incapable of supporting septic
systems or alternative wastewater treatment methods.
F. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.
As discussed within the Cultural and Paleontological Resources Report (Appendix E), a review of record search data,
geological mapping, geological and paleontological literature, and on-site field survey did not identify any existing
paleontological resources within the proposed project APE boundaries. However, the paleontological records search
performed by SDNHM revealed there are 14 fossil localities within a 0.5-mile radius of the APE boundaries from the
San Diego and Otay Formations, which underlie the majority of the proposed project APE. Based on the records search
results and map and literature review, the study area has high potential to produce paleontological resources during
planned construction activities. Therefore, the project shall implement Mitigation Measure (MM) GEO-1 to reduce
potential impacts in the event paleontological resources are uncovered during construction activities. MM-GEO-1
requires that a qualified paleontologist be retained for the proposed project, in accordance with the Society of
Vertebrate Paleontology guidelines (Appendix E), and a complete paleontological monitoring program be adopted prior
to project-related earthmoving activities. Therefore, impacts would be potentially significant, but implementation of
MM-GEO-1 would reduce potentially significant impacts to a less-than-significant level.
5.6.4 Level of Significance Prior to Mitigation
Prior to mitigation, the proposed project would have potentially significant impacts associated with paleontological
resources. Impacts prior to mitigation would be potentially significant. The remaining issues addressed in this
section would be less than significant.
5.6.5 Mitigation Measures
Implementation of the following mitigation measure would reduce identified significant impacts associated with
paleontological resources to a less-than-significant level.
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MM-GEO-1 Paleontological Monitoring Program. Prior to the issuance of grading permits, the applicant shall
provide written confirmation to the City that a qualified paleontologist has been retained to carry
out an appropriate mitigation program. (A qualified paleontologist is defined as an individual with
an MS or PhD in paleontology or geology who is familiar with paleontological procedures and
techniques.) A pre-grading meeting shall be held that shall include the paleontologist and the
grading and excavation contractors.
A paleontological monitor shall be on site at all times during the original cutting of previously undisturbed
sediments of highly sensitive geologic formations (i.e., Otay Formation and San Diego Formation) to
inspect cuts for contained fossils. (A paleontological monitor is defined as an individual who has
experience in the collection and salvage of fossil materials.) The paleontological monitor shall work under
the direction of a qualified paleontologist. The monitor shall be on site on at least a half-time basis during
the original cutting of previously undisturbed sediments of moderately sensitive geologic formations (e.g.,
unnamed river terrace deposits and the Mission Valley Formation) to inspect cuts for contained fossils.
However, neither of these rock units have been mapped within the project area of potential effect (APE)
and are therefore not anticipated to be impacted during construction.
The monitor shall be on site on at least a quarter-time basis during the original cutting of previously
undisturbed sediments of low sensitivity geologic formations (e.g., Lindavista Formation and
Santiago Peak Volcanics [metasedimentary portion only]) to inspect cuts for contained fossils.
However, these deposits have not been mapped within the project APE and are therefore not
anticipated to be impacted during construction. The monitor shall periodically (every several weeks)
inspect original cuts in deposits with an unknown resource sensitivity (i.e., Quaternary alluvium).
In the event that fossils are discovered in unknown, low, or moderately sensitive formations, the
Applicant shall increase the per-day field monitoring time. Conversely, if fossils are not discovered,
the monitoring, at the discretion of the City’s Deputy City Manager/Development Services Director
or its designee, shall be reduced. A paleontological monitor is not needed during grading of rocks
with no resource sensitivity (i.e., Santiago Peak Volcanics, metavolcanic portion).
When fossils are discovered, the paleontologist (or paleontological monitor) shall recover them. In
most cases, this fossil salvage can be completed in a short period of time. However, some fossil
specimens (such as a complete whale skeleton) may require an extended salvage time. In these
instances, the paleontologist (or paleontological monitor) shall be allowed to temporarily direct,
divert, or halt grading to allow recovery of fossil remains in a timely manner. Because of the
potential for the recovery of small fossil remains such as isolated mammal teeth, it may be
necessary in certain instances and at the discretion of the paleontological monitor to set up a
screen-washing operation on the site.
Prepared fossils along with copies of all pertinent field notes, photos, and maps shall be deposited
in a scientific institution with paleontological collections such as the San Diego Natural History
Museum. A final summary report shall be completed. This report shall include discussions of the
methods used, stratigraphy exposed, fossils collected, and significance of recovered fossils.
5.6.6 Level of Significance After Mitigation
Implementation of MM-GEO-1 would reduce potential impacts associated with geology and soils to a less-than-
significant level.
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5.7 Greenhouse Gas Emissions
This section of the environmental impact report (EIR) addresses potential impacts associated with greenhouse gas
emissions resulting from the proposed Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II,
Phase 3 Project (project or proposed project). The discussion in this section is based on the Air Quality and
Greenhouse Gas Emissions Technical Report prepared for the project by Dudek. The complete report is contained
in Appendix C of this EIR.
5.7.1 Existing Conditions
5.7.1.1 Regulatory Framework
Federal
Massachusetts v. EPA
Massachusetts v. EPA. In Massachusetts v. EPA (April 2007), the U.S. Supreme Court directed the EPA administrator
to determine whether greenhouse gas (GHG) emissions from new motor vehicles cause or contribute to air pollution
that may reasonably be anticipated to endanger public health or welfare, or whether the science is too uncertain to
make a reasoned decision. In December 2009, the administrator signed a final rule with the following two distinct
findings regarding GHGs under Section 202(a) of the federal CAA:
• The administrator found that elevated concentrations of GHGs—CO2, CH4, N2O, HFCs, PFCs, and SF6—in the
atmosphere threaten the public health and welfare of current and future generations. This is the
“endangerment finding.”
• The administrator further found the combined emissions of GHGs—CO2, CH4, N2O, and HFCs—from new
motor vehicles and new motor vehicle engines contribute to the GHG air pollution that endangers public
health and welfare. This is the “cause or contribute finding.”
These two findings were necessary to establish the foundation for regulation of GHGs from new motor vehicles as
air pollutants under the CAA.
Energy Independence and Security Act. The Energy Independence and Security Act of 2007 (December 2007),
among other key measures, would do the following, which would aid in the reduction of national GHG emissions
(EPA 2007):
• Increase the supply of alternative fuel sources by setting a mandatory Renewable Fuel Standard requiring
fuel producers to use at least 36 billion gallons of biofuel in 2022.
• Set a target of 35 miles per gallon for the combined fleet of cars and light trucks by model year 2020 and
direct National Highway Traffic Safety Administration (NHTSA) to establish a fuel economy program for
medium- and heavy-duty trucks and create a separate fuel economy standard for work trucks.
• Prescribe or revise standards affecting regional efficiency for heating and cooling products and procedures
for new or amended standards, energy conservation, energy efficiency labeling for consumer electronic
products, residential boiler efficiency, electric motor efficiency, and home appliances.
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Federal Vehicle Standards. In response to the U.S. Supreme Court ruling discussed above, the Bush Administration
issued Executive Order (EO) 13432 in 2007 directing the EPA, the Department of Transportation, and the
Department of Energy to establish regulations that reduce GHG emissions from motor vehicles, non -road vehicles,
and non-road engines by 2008. In 2009, NHTSA issued a final rule regulating fuel efficiency and GHG emissions
from cars and light-duty trucks for model year 2011, and in 2010, EPA and NHTSA issued a final rule regulating
cars and light-duty trucks for model years 2012–2016 (75 FR 25324–25728).
In 2010, President Obama issued a memorandum directing the Department of Transportation, Department of
Energy, EPA, and NHTSA to establish additional standards regarding fuel efficiency and GHG reduction, clean fuels,
and advanced vehicle infrastructure. In response to this directive, the EPA and NHTSA proposed stringent,
coordinated federal GHG and fuel economy standards for model years 2017–2025 light-duty vehicles. The
proposed standards projected to achieve 163 grams/mile of CO2 in model year 2025, on an average industry fleet-
wide basis, which is equivalent to 54.5 miles per gallon if this level were achieved solely through fuel efficiency. The
final rule was adopted in 2012 for model years 2017–2021 (77 FR 62624–63200), and NHTSA intends to set
standards for model years 2022–2025 in a future rulemaking.
In addition to the regulations applicable to cars and light-duty trucks described above, in 2011, the EPA and NHTSA
announced fuel economy and GHG standards for medium- and heavy-duty trucks for model years 2014–2018. The
standards for CO2 emissions and fuel consumption are tailored to three main vehicle categories: combination tractors,
heavy-duty pickup trucks and vans, and vocational vehicles. According to the EPA, this regulatory program will reduce GHG
emissions and fuel consumption for the affected vehicles by 6%–23% over the 2010 baselines (76 FR 57106–57513).
In August 2016, EPA and NHTSA announced the adoption of the phase two program related to the fuel economy
and GHG standards for medium- and heavy-duty trucks. The phase two program will apply to vehicles with model
year 2018 through 2027 for certain trailers and model years 2021 through 2027 for semi-trucks, large pickup
trucks, vans, and all types of sizes of buses and work trucks. The final standards are expected to lower CO2
emissions by approximately 1.1 billion MT and reduce oil consumption by up to 2 billion barrels over the lifetime of
the vehicles sold under the program (EPA and NHTSA 2016).
Clean Power Plan and New Source Performance Standards for Electric Generating Units. In October 2015, EPA
published a final rule (effective December 2015) establishing the Carbon Pollution Emission Guidelines for Existing
Stationary Sources: Electric Utility Generating Units (80 FR 64510–64660), also known as the Clean Power Plan.
These guidelines prescribe how states must develop plans to reduce GHG emissions from existing fossil-fuel-fired
electric generating units. The guidelines establish CO2 emission performance rates representing the best system of
emission reduction for two subcategories of existing fossil-fuel-fired electric generating units: (1) fossil-fuel-fired
electric utility steam-generating units and (2) stationary combustion turbines. Concurrently, EPA published a final
rule in October 2015 establishing Standards of Performance for Greenhouse Gas Emissions from New, Mo dified,
and Reconstructed Stationary Sources: Electric Utility Generating Units (80 FR 64661–65120). The rule prescribes
CO2 emission standards for newly constructed, modified, and reconstructed affected fossil-fuel-fired electric utility
generating units. Implementation of the Clean Power Plan has been stayed by the U.S. Supreme Court pending
resolution of several lawsuits; additionally, President Trump has called on EPA to review the Clean Power Plan.
State
The statewide GHG emissions regulatory framework is summarized below by category: state climate change targets,
building energy, renewable energy and energy procurement, mobile sources, solid waste, water, and other state
regulations and goals. The following text describes EOs, legislation, regulations, and other plans and policies that
would directly or indirectly reduce GHG emissions and/or address climate change issues.
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State Climate Change Targets
EO S-3-05. EO S-3-05 (June 2005) established the following statewide goals: GHG emissions should be reduced to
2000 levels by 2010; GHG emissions should be reduced to 1990 levels by 2020; and GHG emissions should be
reduced to 80% below 1990 levels by 2050.
AB 32 and CARB’s Climate Change Scoping Plan. In furtherance of the goals established in EO S-3-05, the
Legislature enacted AB 32, the California Global Warming Solutions Act of 2006. AB 32 requires California to reduce
its GHG emissions to 1990 levels by 2020.
Under AB 32, CARB is responsible for and is recognized as having the expertise to carry out and develop the programs
and requirements necessary to achieve the GHG emissions reduction mandate of AB 32. Under AB 32, CARB must
adopt regulations requiring the reporting and verification of statewide GHG emissions from specified sources. This
program is used to monitor and enforce compliance with established standards. CARB also is required to adopt
rules and regulations to achieve the maximum technologically feasible and cost-effective GHG emission reductions.
AB 32 also authorized CARB to adopt market-based compliance mechanisms to meet the specified requirements.
Finally, CARB is ultimately responsible for monitoring compliance and enforcing any rule, regulation, order, emission
limitation, emission reduction measure, or market-based compliance mechanism adopted.
In 2007, CARB approved a limit on the statewide GHG emissions level for year 2020 consistent with the determined
1990 baseline (427 million metric tons [MMT] CO2e). CARB’s adoption of this limit is in accordance with Health and
Safety Code Section 38550.
Further, in 2008, CARB adopted the Climate Change Scoping Plan: A Framework for Change (Scoping Plan) in
accordance with Health and Safety Code Section 38561. The Scoping Plan establishes an overall framework for
the measures that will be adopted to reduce California’s GHG emissions for various emission sources/sectors to
1990 levels by 2020. The Scoping Plan evaluates opportunities for sector -specific reductions, integrates all CARB
and Climate Action Team early actions and additional GHG reduction features by both entities, identifies additional
measures to be pursued as regulations, and outlines the role of a cap-and-trade program. The key elements of the
Scoping Plan include the following (CARB 2008a):
1. Expanding and strengthening existing energy efficiency programs, as well as building and appliance standards.
2. Achieving a statewide renewable energy mix of 33%.
3. Developing a California cap-and-trade program that links with other Western Climate Initiative partner programs
to create a regional market system and caps sources contributing 85% of California’s GHG emissions.
4. Establishing targets for transportation-related GHG emissions for regions throughout California, and
pursuing policies and incentives to achieve those targets.
5. Adopting and implementing measures pursuant to existing state laws and policies, including California’s
clean car standards, goods movement measures, and the Low Carbon Fuel Standard.
6. Creating targeted fees, including a public goods charge on water use, fees on high global warming potential
(GWP) gases, and a fee to fund the administrative costs of the State of California’s long-term commitment to
AB 32 implementation.
In the Scoping Plan, CARB determined that achieving the 1990 emissions level in 2020 would require a reduct ion
in GHG emissions of approximately 28.5% from the otherwise projected 2020 emissions level; i.e., those emissions
that would occur in 2020, absent GHG-reducing laws and regulations (referred to as “Business-As-Usual”). For
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purposes of calculating this percent reduction, CARB assumed that all new electricity generation would be supplied
by natural gas plants; no further regulatory action would impact vehicle fuel efficiency; and building energy efficiency
codes would be held at 2005 standards.
In the 2011 Final Supplement to the AB 32 Scoping Plan Functional Equivalent Document (CARB 2011a), CARB revised
its estimates of the projected 2020 emissions level in light of the economic recession and the availability of updated
information about GHG reduction regulations. Based on the new economic data, CARB determined that achieving the
1990 emissions level by 2020 would require a reduction in GHG emissions of 21.7% (down from 28.5%) from the
Business-As-Usual conditions. When the 2020 emissions level projection also was updated to account for newly
implemented regulatory measures, including Pavley I (model years 2009–2016) and the Renewables Portfolio Standard
(RPS; CPUC 2015; 12%–20%), CARB determined that achieving the 1990 emissions level in 2020 would require a
reduction in GHG emissions of 16% (down from 28.5%) from the Business-As-Usual conditions.
More recently, in 2014, CARB adopted the First Update to the Climate Change Scoping Plan: Building on the Framework
(First Update). The stated purpose of the First Update is to “highlight California’s success to date in reducing its GHG
emissions and lay the foundation for establishing a broad framework for continued emission reductions beyond 2020,
on the path to 80% below 1990 levels by 2050” (CARB 2014a). The First Update found that California is on track to meet
the 2020 emissions reduction mandate established by AB 32 and noted that California could reduce emissions further
by 2030 to levels squarely in line with those needed to stay on track to reduce emissions to 80% below 1990 levels by
2050 if the state realizes the expected benefits of existing policy goals.
In conjunction with the First Update, CARB identified “six key focus areas comprising major components of the
state’s economy to evaluate and describe the larger transformative actions that will be needed to meet the state’s
more expansive emission reduction needs by 2050” (CARB 2014a). Those six areas are: (1) energy, (2)
transportation (vehicles/equipment, sustainable communities, housing, fuels, and infrastructure), (3) agriculture,
(4) water, (5) waste management, and (6) natural and working lands. The First Update identifies key recommended
actions for each sector that will facilitate achievement of EO S-3-05’s 2050 reduction goal.
CARB’s research efforts presented in the First Update indicate that it has a “strong sense of the mix of technologies
needed to reduce emissions through 2050” (CARB 2014a). Those technologies include energy demand reduction
through efficiency and activity changes; large-scale electrification of on-road vehicles, buildings, and industrial
machinery; decarbonizing electricity and fuel supplies; and the rapid market penetration of efficient and clean
energy technologies.
As part of the First Update, CARB recalculated the state’s 1990 emissions level using more recent GWPs identified
by IPCC. Using the recalculated 1990 emissions level (431 MMT CO2e) and the revised 2020 emissions level
projection identified in the 2011 Final Supplement, CARB determined that achieving the 1990 emissions level by
2020 would require a reduction in GHG emissions of approximately 15% (instead of 28.5% or 16%) from the
Business-As-Usual conditions.
On January 20, 2017, CARB released the 2017 Climate Change Scoping Plan Update (Second Update) for public
review and comment (CARB 2017a). This update presents CARB’s strategy for achieving the state’s 2030 GHG
target as established in SB 32 (discussed below), including continuing the Cap-and-Trade Program through 2030,
and includes a new approach to reduce GHGs from refineries by 20%. The Second Update incorporates approaches
to cutting short-lived climate pollutants (SLCPs) under the Short-Lived Climate Pollutant Reduction Strategy (SLCP
Reduction Strategy; CARB 2017b) and acknowledges the need for reducing emissions in agriculture and highlights
the work underway to ensure that California’s natural and working lands increasingly sequester carbon. During
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development of the Second Update, CARB held a number of public workshops in the Natural and Working Lands,
Agriculture, Energy, and Transportation sectors to inform development of the Second Update (CARB 2017a). When
discussing project-level GHG emissions reduction actions and thresholds, the Second Update states “achieving no
net increase in GHG emissions is the correct overall objective, but it may not be appropriate or feasible for every
development project. An inability to mitigate a project’s GHG emissions to zero does not necessarily imply a
substantial contribution to the cumulatively significant environmental impact of climate change under CEQA” (CARB
2017a). The Second Update was adopted by CARB’s Governing Board on December 14, 2017.
EO B-30-15. EO B-30-15 (April 2015) identified an interim GHG reduction target in support of targets previously
identified under S-3-05 and AB 32. EO B-30-15 set an interim target goal of reducing statewide GHG emissions to
40% below 1990 levels by 2030 to keep California on its trajectory toward meeting or exceeding the long-term goal
of reducing statewide GHG emissions to 80% below 1990 levels by 2050 as set forth in S-3-05. To facilitate
achievement of this goal, EO B-30-15 calls for an update to CARB’s Scoping Plan to express the 2030 target in
terms of MMT CO2e. The EO also calls for state agencies to continue to develop and implement GHG emission
reduction programs in support of the reduction targets. EO B-30-15 does not require local agencies to take any
action to meet the new interim GHG reduction target.
SB 32 and AB 197. SB 32 and AB 197 (enacted in 2016) are companion bills that set a new st atewide GHG
reduction targets, make changes to CARB’s membership and increase legislative oversight of CARB’s climate
change–based activities, and expand dissemination of GHG and other air quality-related emissions data to enhance
transparency and accountability. More specifically, SB 32 codified the 2030 emissions reduction goal of EO B-30-
15 by requiring CARB to ensure that statewide GHG emissions are reduced to 40% below 1990 levels by 2030. AB
197 established the Joint Legislative Committee on Climate Change Policies, consisting of at least three members
of the Senate and three members of the Assembly, in order to provide ongoing oversight over implementation of
the state’s climate policies. AB 197 also added two members of the Legislature to CA RB as nonvoting members;
requires CARB to make available and update (at least annually via its website) emissions data for GHGs, criteria air
pollutants, and TACs from reporting facilities; and requires CARB to identify specific information for GHG emissions
reduction measures when updating the Scoping Plan.
SB 605 and SB 1383. SB 605 (2014) requires CARB to complete a comprehensive strategy to reduce emissions
of SLCPs in the state, and SB 1383 (2016) requires CARB to approve and implement that stra tegy by January 1,
2018. SB 1383 also establishes specific targets for the reduction of SLCPs (40% below 2013 levels by 2030 for
CH4 and HFCs and 50% below 2013 levels by 2030 for anthropogenic black carbon) and provides direction for
reductions from dairy and livestock operations and landfills. Accordingly, and as mentioned above, CARB adopted
its SLCP Reduction Strategy in March 2017. The SLCP Reduction Strategy establishes a framework for the statewide
reduction of emissions of black carbon, CH4, and fluorinated gases.
Building Energy
Title 24, Part 6. Title 24 of the California Code of Regulations was established in 1978 and serves to enhance and
regulate California’s building standards. While not initially promulgated to reduce GHG emissions, Part 6 of Title 24
specifically establishes Building Energy Efficiency Standards that are designed to ensure that new and existing buildings
in California achieve energy efficiency and preserve outdoor and indoor environmental quality. These energy efficiency
standards are reviewed every few years by the Building Standards Commission and the California Energy Commission
(CEC) (and revised if necessary) (California Public Resources Code, Section 25402[b][1]). The regulations receive input
from members of industry, as well as the public, with the goal of “reducing of wasteful, uneconomic, inefficient, or
unnecessary consumption of energy” (California Public Resources Code, Section 25402). These regulations are carefully
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scrutinized and analyzed for technological and economic feasibility (California Public Resources Code, Section 25402[d])
and cost effectiveness (California Public Resources Code, Sections 25402[b][2] and [3]). These standards are updated
to consider and incorporate new energy-efficient technologies and construction methods. As a result, these standards
save energy, increase electricity supply reliability, increase indoor comfort, avoid the need to construct new power plants,
and help preserve the environment.
The 2016 Title 24 standards became effective on January 1, 2017. In general, single -family homes built to the
2016 standards are anticipated to use about 28% less energy for lighting, heating, cooling, ventilation, and water
heating than those built to the 2013 standards, and nonresidential buildings built to the 2016 standards will use
an estimated 5% less energy than those built to the 2013 standards (CEC 2015a).
The 2019 Standards will continue to improve upon the 2016 Standards for new construction of, and additions and
alterations to, residential and nonresidential buildings. The 2019 Standards came into effect on January 1, 2020.
Nonresidential buildings built under the 2019 Title 24 Standards would use about 30% less energy than those built
under the 2016 Title 24 Standards due mainly to lighting upgrades (CEC 2018).
Title 24, Part 11. In addition to the CEC’s efforts, in 2008, the California Building Standards Commission adopted
the nation’s first green building standards. The California Green Building Standards Code is commonly referred to
as CALGreen and establishes minimum mandatory standards as well as voluntary standards pertaining to the
planning and design of sustainable site development, energy efficiency (in excess of the California Energy Code
requirements), water conservation, material conservation, and interior air quality. The CALGreen standards first
took effect in January 2011 and instituted mandatory minimum environmental performance standards for all
ground-up, new construction of commercial, low-rise residential and state-owned buildings and schools and
hospitals. The updated CALGreen 2016 standards became effective on January 1, 2017. The mandatory standards
require the following (CALGreen 2016):
• Mandatory reduction in indoor water use through compliance with specified flow rates for plumbing fixtures
and fittings.
• Mandatory reduction in outdoor water use through compliance with a local water efficient landscaping
ordinance or the California Department of Water Resources’ Model Water Efficient Landscape Ordinance.
• 65% of construction and demolition waste must be diverted from landfills.
• Mandatory inspections of energy systems to ensure optimal working efficiency.
• Inclusion of electric vehicle charging stations or designated spaces capable of supporting future
charging stations.
• Low-pollutant-emitting exterior and interior finish materials, such as paints, carpets, vinyl flooring, and
particle boards.
The CALGreen standards also include voluntary efficiency measures that are provided at two separate tiers and
implemented at the discretion of local agencies and applicants. CALGreen’s Tier 1 standards call for a 15%
improvement in energy requirements, stricter water conservation, 65% diversion of construction and demolition
waste, 10% recycled content in building materials, 20% permeable paving, 20% cement reduction, and cool/solar-
reflective roofs. CALGreen’s more rigorous Tier 2 standards call for a 30% improvement in energy requirements,
stricter water conservation, 75% diversion of construction and demolition waste, 15% recycled content in building
materials, 30% permeable paving, 25% cement reduction, and cool/solar-reflective roofs.
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CPUC, CEC, and CARB also have a shared, established goal of achieving zero net energy (ZNE) for new construction
in California. The key policy timelines include (1) all new residential construction in California will be ZNE by 2020
and (2) all new commercial construction in California will be ZNE by 2030 (CPUC 2013).1 As most recently defined
by CEC in its 2015 Integrated Energy Policy Report, a ZNE code building is “one where the value of the energy
produced by on-site renewable energy resources is equal to the value of the energy consumed annually by the
building” using CEC’s Time Dependent Valuation metric (CEC 2015b).
Title 20. Title 20 of the California Code of Regulations requires manufacturers of appliances to meet state and
federal standards for energy and water efficiency. Performance of appliances must be certified through CEC to
demonstrate compliance with standards. New appliances regulated under Title 20 include refrigerators,
refrigerator-freezers, and freezers; room air conditioners and room air-conditioning heat pumps; central air
conditioners; spot air conditioners; vented gas space heaters; gas pool heaters; plumbing fittings and plumbing
fixtures; fluorescent lamp ballasts; lamps; emergency lighting; traffic signal modules; dishwaters; clothes washers
and dryers; cooking products; electric motors; low voltage dry-type distribution transformers; power supplies;
televisions and consumer audio and video equipment; and battery charger systems. Title 20 presents protocols for
testing for each type of appliance covered under the regulations, and appliances must meet the standards for
energy performance, energy design, water performance, and water design. Title 20 contains three types of
standards for appliances: federal and state standards for federally regulated appliances, state standards for
federally regulated appliances, and state standards for non-federally regulated appliances.
SB 1. SB 1 (2006) established a $3 billion rebate program to support the goal of the state to install rooftop solar
energy systems with a generation capacity of 3,000 megawatts through 2016. SB 1 added sections to the California
Public Resources Code, including Chapter 8.8 (California Solar Initiative), that require building projects applying for
ratepayer-funded incentives for photovoltaic systems to meet minimum energy efficiency levels and performance
requirements. Section 25780 established that it is a goal of the state to establish a self-sufficient solar industry in
which solar energy systems are a viable mainstream option for both homes and businesses within 10 years of
adoption and to place solar energy systems on 50% of new homes within 13 years of adoption. SB 1, also termed
“GoSolarCalifornia,” was previously titled “Million Solar Roofs.”
AB 1470. This bill established the Solar Water Heating and Efficiency Act of 2007. The bill makes findings and
declarations of the Legislature relating to the promotion of solar water heating systems and other technologies that
reduce natural gas demand. The bill defines several terms for purposes of the act. The bill requires the commission
to evaluate the data available from a specified pilot program and, if it makes a specified determination, to design
and implement a program of incentives for the installation of 200,000 solar water heating systems in homes and
businesses throughout the state by 2017.
AB 1109. Enacted in 2007, AB 1109 required CEC to adopt minimum energy efficiency standards for general
purpose lighting, to reduce electricity consumption 50% for indoor residential lighting and 25% for indoor
commercial lighting.
Renewable Energy and Energy Procurement
SB 1078. SB 1078 (2002) established the RPS program, which requires an annual increase in renewable
generation by the utilities equivalent to at least 1% of sales, with an aggregate goal of 20% by 2017. This goal was
subsequently accelerated, requiring utilities to obtain 20% of their power from renewable sources by 2010.
1 It is expected that achievement of the ZNE goal will occur via revisions to the Title 24 standards.
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SB 1368. SB 1368 (2006) requires CEC to develop and adopt regulations for GHG emission performance standards for
the long-term procurement of electricity by local publicly owned utilities. These standards must be consistent with the
standards adopted by CPUC. This effort will help protect energy customers from financial risks associated with
investments in carbon-intensive generation by allowing new capital investments in power plants for which GHG emissions
are as low as or lower than new combined-cycle natural gas plants by requiring imported electricity to meet GHG
performance standards in California and by requiring that the standards be developed and adopted in a public process.
SB X1 2. SB X1 2 (2011) expanded the RPS by establishing that 20% of the total electricity sold to retail customers
in California per year by December 31, 2013, and 33% by December 31, 2020, and in subsequent years be secured
from qualifying renewable energy sources. Under the bill, a renewable electrical generation facility is one that uses
biomass, solar thermal, photovoltaic, wind, geothermal, fuel cells using renewable fuels, small hydroelectric
generation of 30 megawatts or less, digester gas, municipal solid waste conversion, landfill gas, ocean wave, ocean
thermal, or tidal current and that meets other specified requirements with respect to its location. In addition to the
retail sellers previously covered by the RPS, SB X1 2 added local, publicly owned electric utilities to the RPS.
SB 350. SB 350 (2015) further expanded the RPS by establishing that 50% of the total electricity sold to retail
customers in California per year by December 31, 2030, be secured from qualifying renewable energy sources. In
addition, SB 350 includes the goal of doubling the energy efficiency savings in electricity and natural gas final end
uses (such as heating, cooling, lighting, or class of energy uses on which an energy-efficiency program is focused) of
retail customers through energy conservation and efficiency. The bill also requires CPUC, in consultation with CEC, to
establish efficiency targets for electrical and gas corporations consistent with this goal.
SB 100. SB 100 (2018) increased the standards set forth in SB 350 establishing that 44% of the total electricity sold to
retail customers in California per year by December 31, 2024, 52% by December 31, 2027, and 60% by December 31,
2030, be secured from qualifying renewable energy sources. SB 100 states that it is the policy of the state that eligible
renewable energy resources and zero-carbon resources supply 100% of the retail sales of electricity to California. This
bill requires that the achievement of 100% zero-carbon electricity resources do not increase the carbon emissions
elsewhere in the western grid and that the achievement not be achieved through resource shuffling.
Mobile Sources
AB 1493. In a response to the transportation sector accounting for more than half of California’s CO 2 emissions, AB
1493 was enacted in July 2002. AB 1493 required CARB to set GHG emission standards for passenger vehicles, light-
duty trucks, and other vehicles determined by the state board to be vehicles that are primarily used for
noncommercial personal transportation in the state. The bill required that CARB set GHG emission s tandards for
motor vehicles manufactured in 2009 and all subsequent model years. CARB adopted the standards in September
2004. When fully phased in, the near-term (2009–2012) standards will result in a reduction of about 22% in GHG
emissions compared to the emissions from the 2002 fleet, while the mid-term (2013–2016) standards will result
in a reduction of about 30%.
EO S-1-07. Issued on January 18, 2007, EO S-1-07 sets a declining Low Carbon Fuel Standard for GHG emissions
measured in CO2e grams per unit of fuel energy sold in California. The target of the Low Carbon Fuel Standard is to
reduce the carbon intensity of California passenger vehicle fuels by at least 10% by 2020. The carbon intensity
measures the amount of GHG emissions in the lifecycle of a fuel, including extraction/feedstock production,
processing, transportation, and final consumption, per unit of energy delivered. CARB adopted the implementing
regulation in April 2009. The regulation is expected to increase the production of biofuels, including those from
alternative sources, such as algae, wood, and agricultural waste.
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SB 375. SB 375 (2008) addresses GHG emissions associated with the transportation sector through regional
transportation and sustainability plans. SB 375 required CARB to adopt regional GHG reduction targets for the
automobile and light-truck sector for 2020 and 2035. Regional metropolitan planning organizations are then
responsible for preparing an SCS within their Regional Transportation Plan (RTP). The goal of the SCS is to establish
a forecasted development pattern for the region that, after considering transportation measures and policies, will
achieve, if feasible, the GHG reduction targets. If an SCS is unable to achieve the GHG reduction target, a
metropolitan planning organization must prepare an Alternative Planning Strategy demonstrating how the GHG
reduction target would be achieved through alternative development patterns, infrastructure, or additional
transportation measures or policies.
Pursuant to Government Code Section 65080(b)(2)(K), an SCS does not: (1) regulate the use of land; (2) supersede
the land use authority of cities and counties; or (3) require that a city’s or county’s land use policies and regulations,
including those in a general plan, be consistent with it. Nonetheless, SB 375 makes regional and local planning
agencies responsible for developing those strategies as part of the federally required metropolitan transportation
planning process and the state-mandated housing element process.
In 2010, CARB adopted the SB 375 targets for the regional metropolitan planning organizations. The targets for the
San Diego Association of Governments (SANDAG) are a 7% reduction in emissions per capita by 2020 and a 13%
reduction by 2035.
Advanced Clean Cars Program. In January 2012, CARB approved the Advanced Clean Cars program, a new
emissions-control program for model years 2015 through 2025. The program combines the control of smog- and
soot-causing pollutants and GHG emissions into a single coordinated package. The package includes elements to
reduce smog-forming pollution, reduce GHG emissions, promote clean cars, and provide the fuels for clean cars
(CARB 2011a). To improve air quality, CARB has implemented new emissions standards to reduce smog- forming
emissions beginning with 2015 model year vehicles. It is estimated that, in 2025, cars will emit 75% less smog-
forming pollution than the average new car sold before 2012. To reduce GHG emissions, CARB, in conjunction with
EPA and NHTSA, has adopted new GHG standards for model year 2017 to 2025 vehicles; the new standards are
estimated to reduce GHG emissions by 34% in 2025. The Zero -Emissions Vehicle (ZEV) program will act as the
focused technology of the Advanced Clean Cars program by requiring manufacturers to produce increasing numbers
of ZEVs and plug-in hybrid electric vehicles in the 2018 to 2025 model years. The Clean Fuels Outlet regulation will
ensure that fuels such as electricity and hydrogen are available to meet the fueling needs of the new advanced
technology vehicles as they come to the market.
EO B-16-12. EO B-16-12 (2012) directs state entities under the governor’s direction and control to support and
facilitate development and distribution ZEVs. This EO also sets a long-term target of reaching 1.5 million ZEVs on
California’s roadways by 2025. On a statewide basis, EO B-16-12 also establishes a GHG emissions reduction target
from the transportation sector equaling 80% less than 1990 levels by 2050. In furtherance of this EO, the Governor
convened an Interagency Working Group on ZEVs that has published multiple reports regarding the progress made
on the penetration of ZEVs in the statewide vehicle fleet.
AB 1236. AB 1236 (2015) as enacted in California’s Planning and Zoning Law, requires local land use jurisdictions
to approve applications for the installation of electric vehicle charging stations, as defined, through the issuance of
specified permits, unless there is substantial evidence in the record that the proposed installation would have a
specific, adverse impact on public health or safety and there is no feasible method to satisfactorily mitigate or avoid
the specific adverse impact. The bill provides for appeal of that decision to the planning commission, as specified.
The bill requires local land use jurisdictions with a population of 200,000 or more residents to adopt an ordinance
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by September 30, 2016, that creates an expedited and streamlined permitting process for electric vehicle charging
stations, as specified. Prior to this statutory deadline, in August 2016, the County Board of Supervisors adopted
Ordinance No. 10437 (N.S.) adding a section to its County Code related to the expedited processing of electric
vehicle charging stations permits consistent with AB 1236.
SB 350. In 2015, SB 350—the Clean Energy and Pollution Reduction Act—was enacted into law. As one of its
elements, SB 350 establishes a statewide policy for widespread electrification of the transportation sector,
recognizing that such electrification is required for achievement of the state’s 2030 and 2050 reduction targets
(see California Public Utilities Code, Section 740.12).
Solid Waste
AB 939 and AB 341. In 1989, AB 939, known as the Integrated Waste Management Act (California Public Resources
Code, Sections 40000 et seq.), was passed because of the increase in waste stream and the decrease in landfill
capacity. The statute established the California Integrated Waste Management Board, which oversees a disposal
reporting system. AB 939 mandated a reduction of waste being disposed where jurisdictions were required to meet
diversion goals of all solid waste through source reduction, recycling, and composting activities of 25% by 1995
and 50% by the year 2000.
AB 341 (2011) amended the California Integrated Waste Management Act of 1989 to include a provision declaring
that it is the policy goal of the state that not less tha n 75% of solid waste generated be source-reduced, recycled,
or composted by the year 2020 and annually thereafter. In addition, AB 341 required the California Department of
Resources Recycling and Recovery (CalRecycle) to develop strategies to achieve the state’s policy goal. CalRecycle
has conducted multiple workshops and published documents that identify priority strategies that CalRecycle
believes would assist the state in reaching the 75% goal by 2020.
Water
EO B-29-15. In response to the ongoing drought in California, EO B-29-15 (April 2015) set a goal of achieving a
statewide reduction in potable urban water usage of 25% relative to water use in 2013. The term of the EO extended
through February 28, 2016, although many of the directives have since become permanent water-efficiency
standards and requirements. The EO includes specific directives that set strict limits on water usage in the state.
In response to EO B-29-15, the California Department of Water Resources has modified and adopted a revised
version of the Model Water Efficient Landscape Ordinance that, among other changes, significantly increases the
requirements for landscape water use efficiency and broadens its applicability to include new development projects
with smaller landscape areas.
Other State Regulations and Goals
SB 97. SB 97 (Dutton) (August 2007) directed the Governor’s Office of Planning and Research to develop guidelines
under CEQA for the mitigation of GHG emissions. In 2008, the Office of Planning and Research issued a technical
advisory as interim guidance regarding the analysis of GHG emissions in CEQA documents. The advisory indicated
that the lead agency should identify and estimate a project’s GHG emissions, including those associated with
vehicular traffic, energy consumption, water usage, and construction activities (OPR 2008). The advisory further
recommended that the lead agency determine significance of the impacts and impose all mitigation measures
necessary to reduce GHG emissions to a level that is less than significant. The California Natural Resources Agency
adopted the CEQA Guidelines amendments in December 2009, which became effective in March 2010.
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Under the amended CEQA Guidelines, a lead agency has the discretion to determine whether to use a quantitative
or qualitative analysis or apply performance standards to determine the significance of GHG emissions resulting
from a particular project (14 CCR 15064.4[a]). The CEQA Guidelines require a lead agency to consider the extent
to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local
plan for the reduction or mitigation of GHG emissions (14 CCR 15064.4[b]). The Guidelines also allow a lead agency
to consider feasible means of mitigating the significant effects of GHG emissions, including reductions in emissions
through the implementation of project features or off-site measures. The adopted amendments do not establish a
GHG emission threshold, instead allowing a lead agency to develop, adopt, and apply its own thresholds of
significance or those developed by other agencies or experts. The California Natural Resources Agency also
acknowledges that a lead agency may consider compliance with regulations or requirements implementing AB 32
in determining the significance of a project’s GHG emissions (CNRA 2009).
With respect to GHG emissions, the CEQA Guidelines state in Section 15064.4(a) that lead agencies should “make
a good faith effort, to the extent possible on scientific and factual data, to describe, calculate or estimate” GHG
emissions. The CEQA Guidelines note that an agency may identify emissions by either selecting a “model or
methodology” to quantify the emissions or by relying on “qualitative analysis or other performance based
standards” (14 CCR 15064.4[a]). Section 15064.4(b) states that the lead agency should consider the following
when assessing the significance of impacts from GHG emissions on the environment: (1) the extent a p roject may
increase or reduce GHG emissions as compared to the existing environmental setting; (2) whether the project
emissions exceed a threshold of significance that the lead agency determines applies to the project; and (3) the
extent to which the project complies with regulations or requirements adopted to implement a statewide, regional,
or local plan for the reduction or mitigation of GHG emissions (14 CCR 15064.4[b]).
EO S-13-08. EO S-13-08 (November 2008) is intended to hasten California’s response to the impacts of global
climate change, particularly sea-level rise. Therefore, the EO directs state agencies to take specified actions to
assess and plan for such impacts. The final 2009 California Climate Adaptation Strategy report was issued in
December 2009 (CNRA 2009), and an update, Safeguarding California: Reducing Climate Risk, followed in July
2014 (CNRA 2014). To assess the state’s vulnerability, the report summarizes key climate change impacts to the
state for the following areas: Agriculture, Biodiversity and Habitat, Emergency Management, Energy, Forestry, Ocean
and Coastal Ecosystems and Resources, Public Health, Transportation, and Water. Issuance of the Safeguarding
California: Implementation Action Plans followed in March 2016 (CNRA 2016). Currently, a draft of the
Safeguarding California Plan: 2017 Update is being prepared to communicate current and needed actions that the
state government should take to build climate change resiliency (CNRA 2017).
2015 State of the State Address. In January 2015, Governor Brown in his inaugural address and annual report to the
Legislature established supplementary goals that would further reduce GHG emissions over the next 15 years.
These goals include an increase in California’s renewable energy portfolio from 33% to 50%, a reduction in vehicle
petroleum use for cars and trucks by up to 50%, measures to double the efficiency of existing buildings, and
decreasing emissions associated with heating fuels.
2016 State of the State Address. In his January 2016 address, Governor Brown established a statewide goal to
bring per capita GHG emissions down to 2 tons per person, which reflects the goal of the Global Climate Leadership
Memorandum of Understanding to limit global warming to less than 2°C by 2050. The Global Climate Leadership
Memorandum of Understanding agreement pursues emission reductions of 80% to 95% below 1990 levels by 2050
and/or reach a per capita annual emissions goal of less than 2 MT by 2050. A total of 187 jurisdictions representing
38 countries and 6 continents, including California, have signed or endorsed the Global Climate Leadership
Memorandum of Understanding (Under 2 Coalition 2017).
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Local
San Diego Association of Governments
2050 Regional Transportation Plan/Sustainable Communities Strategy
SANDAG completed and adopted its 2050 RTP/SCS in October 2011 (SANDAG 2011). In November 2011, CARB,
by resolution, accepted SANDAG’s GHG emissions quantification analysis and determination that, if implemented,
the SCS would achieve CARB’s 2020 and 2035 GHG emissions reduction targets for the region.
After SANDAG’s 2050 RTP/SCS was adopted, a lawsuit was filed by the Cleveland National Forest Foundation and
others. The matter is pending before the California Supreme Court (Case No. S223603) for determination of
whether an environmental impact report for an RTP must include an analysis of the plan’s consistency with the GHG
reduction goals reflected in EO S-3-05 to comply with CEQA.
Although the environmental impact report for SANDAG’s 2050 RTP/SCS is pending before the California Supreme
Court, in 2015, SANDAG adopted the next iteration of its RTP/SCS in accordance with statutorily mandated
timelines, and no subsequent litigation challenge was filed. More specifically, in October 2015, SANDAG adopted
the Regional Plan. Like the 2050 RTP/SCS, this planning document meets CARB’s 2020 and 2035 reduction
targets for the region (SANDAG 2015). In December 2015, CARB, by resolution, accepted SANDAG’s GHG emissions
quantification analysis and determination that, if implemented, the SCS would achieve CARB’s 2020 and 2035
GHG emissions reduction targets for the region.
City of Chula Vista
International Council of Environmental Initiatives Local Governments for Sustainability
In 1992, the City of Chula Vista (City) participated in the Cities for Climate Protection Program, which aimed at
developing municipal action plans for the reduction of GHGs. This program was sponsored and developed by the
International Council of Environmental Initiatives and the United Nations Environment Program in response to the
United Nations Framework Convention on Climate Change, while recognizing that all local planning and
development has direct consequences on energy consumption, and cities exercise key powers over urban
infrastructure, including neighborhood design, and over transportation infrastructure, such as roads, streets,
pedestrian areas, bicycle lanes, and public transport.
Chula Vista Carbon Dioxide (CO2) Reduction Plan
Each participant in the International Council of Environmental Initiatives program was to create local policy
measures to ensure multiple benefits to the City and, at the same time, identify a carbon reduction goal through
the implementation of those measures. The carbon reduction goal was to fit within the realm of international climate
treaty reduction goals.
In its CO2 Reduction Plan, developed in 1996 and officially adopted in 2000, the City committed to lowering its CO2
emissions by diversifying its transportation system and using energy more efficiently in all sectors. To focus efforts
in this direction, the City adopted the international CO2 reduction goal of returning to pre-1990 levels by 2010. In
order to achieve this goal, eight actions were identified, which when fully implemented, were anticipated to save
100,000 tons of CO2 each year.
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As a result of the 2005 GHG Emissions Inventory Report, in May 2007, staff reported to the City Counci l that City-
wide GHG emissions had increased by 35% (mainly due to residential growth) from 1990 to 2005, while emissions
on a per capita basis and from municipal operations decreased by 17% and 18%, respectively. The City Council
directed staff to convene a Climate Change Working Group to develop recommendations to reduce the community’s
GHGs in order to meet the City’s 2010 GHG emissions reduction targets.
As a result of the 2012 GHG Emissions Inventory Report, staff reported to the City Council that citywide GHG levels are
1,011,481 MT CO2e. Compared to 2005, the City’s GHG emissions have increased by 8%. However, 2012 per capita
emissions are approximately 5% below 2005 levels and 33% below 1990 levels. Unlike the last two inventories, 2009
and 2010, there was a slight increase in City-wide energy consumption over the last couple of years due most likely to
local economic recovery. As with past inventories, community transportation activity has continued increasing with 2012
vehicle miles traveled about 29% higher than in 2005. In order to reach the current community emissions reduction goal
of 20% below 1990 emission levels, the City will have to reduce its GHG emissions by more than 359,332 MT CO2e
(35%); however, statewide initiatives are expected to help achieve some of these reductions by 2020.
Climate Change Working Group
The Climate Change Working Group, which is composed of residents, businesses, and community organization
representatives, helps the City develop climate-related programs and policies. In 2008, the group reviewed more than
90 carbon reduction measures and ultimately chose 7 measures to recommend for adoption to the City Council,
which the Council subsequently adopted. The measures were designed to reduce or mitigate climate change
impacts by reducing GHG emissions within the City to 20% below 1990 levels, in keeping with its CO2 Reduction
Plan and United Nations Framework Convention on Climate Change goals.
In October 2009, the City Council directed the group to evaluate how the City could adapt to potential climate
change impacts. The group met throughout 2011 to develop recommendations based on the City’s vulnerabilities
and risks to climate change. In May 2011, the group adopted the Climate Adaptation Strategies – Implementation
Plans, described below, and in 2014, the group released the 2014 Climate Action Plan Update –
Recommendations, described below.
Chula Vista Climate Adaptation Strategies – Implementation Plans. The Climate Adaptation Strategies – Implementation
Plans document developed by the Climate Change Working Group includes 11 strategies to facilitate the City’s adaptation
to the potential impacts of global climate change related to energy and water supply, public health, wildfires, ecosystem
management, coastal infrastructure, and local economy sectors. The strategies include cool paving, shade trees, cool roofs,
local water supply and reuse, stormwater pollution prevention and reuse, education and wildfires, extreme heat plans, open
space management, wetlands preservation, sea-level rise and land development codes, and green economy. For each
strategy, the plans outline specific implementation components, critical steps, costs, and timelines. In order to limit the
necessary staffing and funding required to implement the strategies, the plans were also designed to build on existing
municipal efforts, rather than create new, stand-alone policies or programs. Initial implementation of all 11 strategies were
phased over a 3-year period after adoption of the plan in 2011.
Chula Vista Climate Protection Measures. On July 10, 2008, the City Council adopted implementation plans for
seven climate protection measures to reduce GHG emissions to 20% below 1990 levels by 2012. The
implementation plans outline the detailed strategy for initiating, funding, and tracking the following measures:
1. Clean Vehicle Replacement Policy for City Fleet: When City fleet vehicles are retired, they will be replaced
through the purchase or lease of alternative fuel or hybrid substitutes. In addition, the City fleet will begin
to pursue installing new fuel tanks to allow heavy-duty vehicles to convert to biodiesel fuel immediately.
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2. Clean Vehicle Replacement Policy for City-Contracted Fleets: As contracts for City-contracted fleet services
(such as transit buses, trash haulers and street sweeper trucks) are renewed, the City will encourage
contractors to replace their vehicles with alternative fuel or hybrid substitutes through the contract bid
process. In addition, the City will pursue implementing two hydrogen vehicle demonstration projects.
3. Business Energy Evaluations: Businesses with storefronts or offices need to participate in a no-cost energy
assessment of their facilities to help identify opportunities for them to reduce monthly energy costs. The
business assessment will be integrated into the existing business licensing process and codified through a
new municipal ordinance.
4. Green Building Standard: The City will implement a citywide, mandatory green building standard for new
residential and non-residential construction projects and major renovations. The standard includes four
components: 1) adopting a citywide Green Building Standard, 2) adopting a citywide Enhanced Energy
Efficiency Standard, 3) launching a Green Building Awareness program for builders, permit applicants and
the general public, and 4) developing design guidelines for sustainable development.
5. Solar and Energy Efficiency Conversion Program: The City will create a community program to provide
residents and businesses with a streamlined, cost-effective opportunity to implement energy efficiency
improvements and to install solar/renewable energy systems on their properties. The City will develop a
funding mechanism to allow program participants to voluntarily choose to place the improvement costs on
their property’s tax rolls, thereby avoiding large upfront capital costs. In addition, the program will promote
vocational training, local manufacturing, and retail sales op portunities for environmental products and
services. To help stimulate the private-sector renewable market and lower the cost for installing renewable
energy systems on new homes, the City will require all new residential buildings to include pre -wiring and
pre-plumbing for solar photovoltaic and solar hot water systems, respectively.
6. Smart Growth Around Trolley Stations: The City will continue to implement the smart growth design
principles, which promote mixed-use and walkable and transit-friendly development, particularly in and
around the E, H, and Palomar trolley stations. These principles were emphasized in the revised Chula Vista
General Plan and the Urban Core Specific Plan. In particular, the City will initiate site planning, design
studies and specific area plan development to further support smart growth development that
complements GHG reductions.
7. Turf Lawn Conversion Program: The City will create a community program to provide residents and businesses with
a streamlined, cost-effective opportunity to replace their turf lawns with water-saving landscaping and irrigation
systems. Some municipal turf lawn areas (such as medians, fire stations and non-recreational park areas) will also
be converted to act as public demonstration sites and to reduce monthly water costs. The City will establish the
model for water-wise landscaping for new development through an update of the Chula Vista Municipal Landscape
Ordinance and Water Conservation Plan guidelines.
Chula Vista Climate Protection Measures – 2013 Progress Report. Since 2000, the City has been implementing a
“Climate Action Plan” (CO2 Reduction Plan) to address the threat of climate change to the local community. This
original plan has been revised to incorporate new climate mitigation (2008) and adaptation (2011) measures to
strengthen the City’s climate action efforts and to facilitate the numerous community co-benefits, such as utility
savings, better air quality, reduced traffic congestion, local economic development, and improved quality of life.
Based on available funding, staff has been implementing the 18 climate -related actions and their 57 associated
components. Overall, 70% of the components have been successfully completed and/or are being implemented on
an ongoing basis, which represents a 7% increase since the last reporting period. Another 26% are still being
actively pursued, while only two components remain on hold (City of Chula Vista 2013).
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2014 Climate Action Plan Update – Recommendations by the Climate Change Working Group. The Climate Change
Working Group has been evaluating new opportunities to help reach the Chula Vista Climate Action Plan (CAP) GHG
gas reduction goal of 30% below 2005 levels. As such, they have identified 12 action areas that could generate up
to 166,000 MT in reductions by 2020, while improving local air quality, generating utility savings, reducing traffic
congestion, and promoting a healthier community (City of Chula Vista 2014).
2017 Climate Action Plan. The latest version of the CAP was adopted on September 26, 2017, by the City Council
and provides updated goals, policies, actions, and the latest City -wide inventory and projections. The CAP is not
considered a CEQA “qualified” plan under CEQA Guidelines Section 15183.5, as it has not been adopted in a public
process following environmental review. The Climate Change Working Group has been evaluating new opportunities
to help reach the CAP’s GHG gas reduction goals, which are based on the Second Update goals of 6 MT CO2e per
person by 2030 and 2 MT CO2e per person by 2050. As such, they have identified the following 11 action areas
that could generate up to 208,220 MT in reductions by 2020, while improving local air quality, generating utility
savings, reducing traffic congestion, and promoting a healthier community (City of Chula Vista 2017):
Water Conservation & Reuse [Estimated Annual GHG Reductions = 12,357 MT CO2e]
1. Water Education & Enforcement
A. Expand education and enforcement [through fines] targeting landscape water waste
2. Water Efficiency Upgrades
A. Update the City’s Landscape Water Conservation Ordinance to promote more water ‐wise
landscaping designs
B. Require water‐savings retrofits in existing buildings at a specific point in time (not point of sale)
3. Water Reuse Plan & System Installations
A. Develop a Water Reuse Master Plan to maximize the use of storm water, graywater [recycled water]
and onsite water reclamation
B. Facilitate simple graywater systems for laundry-to-landscape applications
C. Streamline complex graywater systems’ permit review
Waste Reduction [Estimated Annual GHG Reductions = 38,126 MT CO2e]
1. Zero Waste Plan
A. Develop a Zero Waste Plan to supplement statewide green waste, recycling and plastic bag ban efforts
Renewable & Efficient Energy [Estimated Annual GHG Reductions = 70,763 MT CO2e]
1. Energy Education & Enforcement
A. Expand education targeting key community segments [e.g., do-it-yourselfers and Millennials] and
facilitating energy performance disclosure (e.g., Green Leases, benchmarking and Home Energy Ratings)
B. Leverage the building inspection process to distribute energy‐related information and to deter unpermitted,
low performing energy improvements
2. Clean Energy Sources
A. Incorporate solar photovoltaic into all new residential and commercial buildings [on a project-level basis]
B. Provide more grid ‐delivered clean energy (up to 100%) through Community Choice Aggregation
or other mechanism
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3. Energy Efficiency Upgrades
A. Expand the City’s “cool roof” standards to include re‐roofs and western areas
B. Facilitate more energy upgrades in the community through incentives [e.g., tax breaks and rebates),
permit streamlining (where possible) and education [e.g., more local energy efficiency programming]
C. Require energy‐savings retrofits in existing buildings at a specific point in time (not at point of sale)
4. Robust Urban Forests
A. Plant more shade trees to save energy, address heat island issues and improve air quality
Smart Growth & Transportation [Estimated Annual GHG Reductions = 86,974 MT CO2e]
1. Complete Streets & Neighborhoods
A. Incorporate “Complete Streets” principles into municipal capital projects and plans [e.g., the Bicycle
and Pedestrian Master Plans and Capital Improvement Program]
B. Encourage higher density and mixed‐use development in Smart Growth areas, especially around trolley
stations and other transit nodes
2. Transportation Demand Management
A. Utilize bike facilities, transit access/passes and other Transportation Demand Management and
congestion management offerings
B. Expand bike-sharing, car-sharing and other “last mile” transportation options
3. Alternative Fuel Vehicle Readiness
A. Support the installation of more local alternative fueling stations
B. Designate preferred parking for alternative fuel vehicles
C. Design all new residential and commercial buildings to be “Electric Vehicle Ready”
Chula Vista Green Building Standards. Consistent with Measure 4 of the Chula Vista Climate Protection Measures,
the City Council adopted the Green Building Standards Ordinance (Ordinance No. 3140) on October 6, 2009, which
became effective November 5, 2009. The Green Building Standards Ordinance includes standards for energy
efficiency, pollutant controls, interior moisture control, improved indoor air quality and exhaust, indoor water
conservation, stormwater management, and construction waste reduction and recycling.
Building permit applications are required to indicate on project construction plans and specifications the Green
Building Standards measures that comply with the ordinance. Prio r to final building approval or issuance of a
certificate of occupancy, the Building Official reviews the information submitted by the applicant and determines
whether the applicant has constructed the project in accordance with the permitted plans and documents, and
whether the plans are in compliance with the Green Building Standards. In 2013, Chula Vista adopted CALGreen
for residential and non-residential development effective January 1, 2014.
Chapter 15.12 Green Building Standards. Title 24, Part 11 (CALGreen), was adopted as the Green Building Code of
the City for enhancing the design and construction of buildings, building additions, and alterations through the use
of building concepts having a reduced negative impact or positive environmental impact and encouraging
sustainable construction practices, excepting such portions as are hereinafter deleted, modified, or amended.
Chula Vista Increased Energy Efficiency Standards. On January 26, 2010, the City Council adopted the Increased Energy
Efficiency Standards Ordinance (Ordinance No. 3149). This ordinance became effective February 26, 2010, as Section
15.26 of the Municipal Code. Permit applications are required to comply with these energy efficiency standards.
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Chula Vista Municipal Code (CVMC) Section 15.26.030 requires permit applications to comply with increased
energy efficiency standards that achieve 15% to 20% greater efficiency than the requirements of the Title 24 2008
standards, depending on climate zone. The City falls within two climate zones, Zone 7 and Zone 10. The project site
is within Zone 7. For Zone 7, the code requires the following:
• All new low-rise residential building or additions, remodels or alterations to existing low-rise residential buildings
where the additions, remodels or alterations are greater than 1,000 square feet of conditional floor area, shall
use at least 15% less energy than the 2008 Title 24 Building Energy Efficiency Standards allow.
• All new non-residential, high-rise residential or hotel/motel buildings, or additions, remodels or alterations
to existing non-residential, high-rise residential or hotel/motel buildings where the additions, remodels or
alterations are greater than 10,000 square feet of conditioned floor area, shall use at least 15% less energy
than the 2008 Title 24 Building Energy Efficiency Standards.
• No city building permit shall be issued unless the permit application demonstrates to the Building Official
compliance with the requirements of Section 15.26.030. Compliance is to be demonstrated based on a
performance approach, using a CEC-approved energy compliance software program, as specified in the
Title 24 2008 Building Energy Efficiency Standards.
In 2013, the City adopted the Energy Code for Residential and Non-Residential development, effective July 1, 2014.
Energy efficiency measures adopted by the CVMC are as follows:
• Section 15.26.010 – California Energy Code. The California Energy Code is adopted as the energy code of
the City for the purpose of regulating building design and construction standards to increase efficiency in
the use of energy for new residential and nonresidential buildings.
• Section 15.26.020 – Outdoor Lighting Zones. The City has adopted an outdoor lighting zones map
amending state default lighting zones as applied to certain areas of the City. The location of outdoor lighting
zones in the City are per the adopted Outdoor Lighting Zones Map, dated September 2, 2005, and kept on
file with the City Planning and Building Department.
• Section 15.28.015 Solar Water Heater Pre-Plumbing (specific to the City). All new residential units shall
include plumbing specifically designed to allow the later installation of a system that utilizes solar energ y
as the primary means of heating domestic potable water. No building permit shall be issued unless the
requirements of this section and the Chula Vista Solar Water Heater Pre -Plumbing Installation
Requirements are incorporated into the approved building plans.
• Section 15.24.065 Pre-Wiring for Photovoltaic (specific to the City). All new residential units shall include
electrical conduit specifically designed to allow the later installation of a photovoltaic system that utilizes
solar energy as a means to provide electricity. 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.
• Section 15.28.020 Residential Graywater Stub-out (specific to the City). All new detached single-family dwellings
and duplexes shall include a single-source clothes washer graywater outlet and an outside stub-out to allow the
later installation of a clothes washer graywater irrigation system that complies with the requirements of Section
1602.1.1 of the 2013 California Plumbing Code. The outlet and stub-out shall be installed in accordance with
the Chula Vista Clothes Washer Graywater Pre-Plumbing and Stub-Out for New Residential Construction or an
equivalent alternate method and/or material approved by the Building Official.
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City of Chula Vista Mandatory Construction and Demolition Debris Recycling Ordinance. Section 8.25.095 of the
Chula Vista Municipal Code requires that 90% of inert materials and a minimum of 50% of all other materials be
recycled and/or reused from certain covered projects. Covered projects include the following:
• Any project requiring a permit for demolition or construction, which has a project valuation of $20,000 or more
• Housing subdivision construction or demolition and/or any sequenced development will be considered a
project in its entirety and not a series of individual projects
• Tenant improvements greater than 1,000 square feet but less than 10,000 square feet and individual
single-family home construction, remodel, addition or renovation, shall submit a Waste Management
Report only (no deposit required)
• All City projects
Covered projects must submit a waste management plan to the Chula Vista Public Works Department,
Environmental Services Division, which must be reviewed and approved prior to the issuance of a demolition or
building permit. The waste management plan will indicate how the applicant will recycle and/or reuse 90% of inert
materials and at least 50% of the remaining construction and demolition debris generated from the project.
City of Chula Vista Clean Transportation Energy Roadmap (2012). The Clean Transportation Energy Roadmap
(Roadmap) can serve as a resource for the City as it continues to promote clean transportation measures, both in
its municipal operations and in the community. The Roadmap identifies petroleum reduction measures and tools
specific to the City that generally result in cost savings and benefits to the environment, including the following:
• An assessment of alternative fuel vehicles and fuel availability for the City’s vehicle fleet
• Commuter programs, including vanpools, carpools, and teleworking that the City could promote to its employees
• Online tools to establish a baseline of petroleum consumed and GHGs emitted from employee commutes,
as well as annual tracking tools
• Smart growth and active transportation policies that enhance local walking and biking options
• Outreac h materials on Clean Transportation programs that can be shared with local residents,
schools, and businesses
The Roadmap also recognizes the significant steps that the City has taken already. Since 2000, Chula Vista has
been implementing a “Climate Action Plan” (CO2 Reduction Plan) that includes measures to reduce energy and fuel
use at municipal facilities and throughout the community.
City of Chula Vista General Plan
The General Plan (City of Chula Vista 2005) includes various policies related to reducing GHG emissions (both
directly and indirectly). Applicable policies include the following:
Land Use and Transportation Element
• Policy LUT-23.1: Encourage the use of bicycles and walking as alternatives to driving.
• Policy LUT-23.2: Foster the development of a system of inter-connecting bicycle routes throughout the City
and region.
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• Policy LUT-23.5: Provide linkages between bicycle facilities that utilize circulation element alignments and
open space corridors.
• Policy LUT-23.8: Provide and maintain a safe and efficient system of sidewalks, trails, and pedestrian crossings.
• Policy LUT-23.14: Require new development projects to provide internal bikeway systems with connections
to the citywide bicycle networks.
Environmental Element
• 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.
• Policy E-6.5: Ensure that plans developed to meet the City’s energy demand use the least polluting
strategies, wherever practical. Conservation, clean renewables, and clean distributed generation should be
considered as part of the City’s energy plan, along with larger natural gas-fired plants.
• Policy 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.
• Policy E-6.8: Support the use of alternative fuel transit, City fleet and private vehicles in Chula Vista.
• Policy 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.
• Policy E-7.6: Encourage the construction and operation of green buildings, considering such programs as
the Leadership in Energy and Environmental Design (LEED) Green Building Rating System.
• Policy E-7.8: Ensure that residential and non-residential construction complies with all applicable City
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.
• Policy E-8.1: Promote efforts to reduce waste, minimize the need for additional landfills, and provide
economically and environmentally sound resource recovery, management, and disposal facilities.
• Policy E-8.3: Implement source reduction strategies, including curbside recycling, use of small collection
facilities for recycling, and composting.
5.7.1.2 Climate Change Overview
Climate change refers to any significant change in measures of climate, such as temperature, precipitation, or
wind patterns, lasting for an extended period (decades or longer). The Earth’s temperature depends on the
balance between energy entering and leaving the planet’s system. Many factors, both natural and human, can
cause changes in Earth’s energy balance, including variations in the Sun’s energy reaching Earth, changes in the
reflectivity of Earth’s atmosphe re and surface, and changes in the greenhouse effect, which affects the amount
of heat retained by Earth’s atmosphere (EPA 2017).
The greenhouse effect is the trapping and buildup of heat in the atmosphere near the Earth’s surface (the
troposphere). The greenhouse effect traps heat in the troposphere through a threefold process as follows: short-
wave radiation emitted by the Sun is absorbed by the Earth; the Earth emits a portion of this energy in the form of
long-wave radiation; and GHGs in the upper atmosphere absorb this long-wave radiation and emit it into space and
toward the Earth. The greenhouse effect is a natural process that contributes to regulating the Earth’s temperature
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and creates a pleasant, livable environment on the Earth. Human activities that emit additional GHGs to the
atmosphere increase the amount of infrared radiation that gets absorbed before escaping into space, thus
contributing substantially to the greenhouse effect and causing the Earth’s surface temperature to rise.
The scientific record of the Earth’s climate shows that the climate system varies naturally over a wide range of time
scales and that, in general, climate changes prior to the Industrial Revolution in the 1700s can be explained by
natural causes, such as changes in solar energy, volcanic eruptions, and natural changes in GHG concentrations.
However, recent climate changes, in particular the warming observed over the past century, cannot be explained
by natural causes alone. Rather, it is extremely likely that human activities have been the dominant cause of that
warming since the mid-20th century and that they are the most significant driver of observed climate change (IPCC
2013; EPA 2017). Human influence on the climate system is evident from the increasing GHG concentrations in
the atmosphere, positive radiative forcing, observed warming, and improved understanding of the climate system
(IPCC 2013). The atmospheric concentrations of GHGs have increased to levels unprecedented in the last 800,000
years, primarily from fossil fuel emissions and secondarily from emissions associated with land use changes (IPCC
2013). Continued emissions of GHGs will cause further warming and changes in all components of the climate
system, which is discussed further in Appendix C.
5.7.1.3 Greenhouse Gases
A GHG is any gas that absorbs infrared radiation in the atmosphere; in other words, GHGs trap heat in the
atmosphere. GHGs include, but are not limited to, carbon dioxide (CO 2), methane (CH4), nitrous oxide (N2O), O3,
water vapor, hydrofluorocarbons (HFCs), hydrochlorofluorocarbons (HCFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF6).2 Some GHGs, such as CO2, CH4, and N2O, occur naturally and are emitted to the atmosphere
through natural processes and human activities. Of these gases, CO2 and CH4 are emitted in the greatest quantities
from human activities. Manufactured GHGs, which have a much greater heat-absorption potential than CO2, include
fluorinated gases, such as HFCs, HCFCs, PFCs, and SF6, which are associated with certain industrial products and
processes. A summary of the most common GHGs and their sources is included in the following text. Also included
is a discussion of other climate-forcing substances.
Carbon Dioxide. CO2 is a naturally occurring gas and a by-product of human activities and is the principal
anthropogenic GHG that affects the Earth’s radiative balance. Natural sources of CO 2 include respiration of bacteria,
plants, animals, and fungus; evaporation from oceans; volcanic out-gassing; and decomposition of dead organic
matter. Human activities that generate CO2 involve the combustion of fuels, such as coal, oil, natural gas, and wood,
and changes in land use.
Methane. CH4 is produced through both natural and human activities. CH4 is a flammable gas and is the main
component of natural gas. CH4 is produced through anaerobic (without oxygen) decomposition of waste in landfills,
flooded rice fields, animal digestion, decomposition of animal wastes, production and distribution of natural gas
and petroleum, coal production, and incomplete fossil fuel combustion.
Nitrous Oxide. N2O is produced through natural and human activities, mainly through agricultural activities and natural
biological processes, although fuel burning and other processes also create N2O. Sources of N2O include soil cultivation
practices (microbial processes in soil and water), especially the use of commercial and organic fertilizers, manure
2 California Health and Safety Code 38505 identifies seven GHGs that CARB is responsible for monitoring and regulating to reduce
emissions: CO2, CH4, N2O, SF6, HFCs, PFCs, and nitrogen trifluoride (NF3).
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management, industrial processes (such as in nitric acid production, nylon production, and fossil- fuel-fired power plants),
vehicle emissions, and using N2O as a propellant (such as in rockets, race cars, and aerosol sprays).
Fluorinated Gases. Fluorinated gases (also referred to as F-gases) are synthetic, powerful GHGs emitted from many
industrial processes. Fluorinated gases are commonly used as substitutes for stratospheric O3-depleting
substances (e.g., chlorofluorocarbons [CFCs], HCFCs, and halons). The most prevalent fluorinated gases include
the following:
• Hydrofluorocarbons: HFCs are compounds containing only hydrogen, fluorine, and carbon atoms. HFCs are
synthetic chemicals used as alternatives to O3-depleting substances in serving many industrial, commercial, and
personal needs. HFCs are emitted as byproducts of industrial processes and are used in manufacturing.
• Perfluorocarbons: PFCs are a group of human-made chemicals composed of carbon and fluorine only.
These chemicals were introduced as alternatives, with HFCs, to the O3-depleting substances. The two main
sources of PFCs are primary aluminum production and semiconductor manufacturing. Since PFCs have
stable molecular structures and do not break down through the chemical processes in the lower
atmosphere, these chemicals have long lifetimes, ranging between 10,000 and 50,000 years.
• Sulfur Hexafluoride: SF6 is a colorless gas soluble in alcohol and ether and slightly soluble in water. SF6 is
used for insulation in electric power transmission and distribution equipment, semiconductor
manufacturing, the magnesium industry, and as a tracer gas for leak detection.
• Nitrogen Trifluoride: NF3 is used in the manufacture of a variety of electronics, including semiconductors,
and flat panel displays.
Chlorofluorocarbons. CFCs are synthetic chemicals that have been used as cleaning solvents, refrigerants, and
aerosol propellants. CFCs are chemically unreactive in the lower atmosphere (troposphere), an d the production of
CFCs was prohibited in 1987 due to the chemical destruction of stratospheric O3.
Hydrochlorofluorocarbons. HCFCs are a large group of compounds with a structure very close to that of CFCs—
containing hydrogen, fluorine, chlorine, and carbon atoms—but including one or more hydrogen atoms. Like HFCs,
HCFCs are used in refrigerants and propellants. HCFCs were also used in place of CFCs for some applications;
however, their use in general is being phased out.
Black Carbon. Black carbon is a component of fine particulate matter (PM 2.5), which has been identified as a
leading environmental risk factor for premature death. It is produced from the incomplete combustion of fossil
fuels and biomass burning, particularly from older diesel engines an d forest fires. Black carbon warms the
atmosphere by absorbing solar radiation, influences cloud formation, and darkens the surface of snow and
ice, which accelerates heat absorption and melting. Black carbon is a short -lived species that varies spatially,
which makes it difficult to quantify the GWP. DPM emissions are a major source of black carbon and are TACs
that have been regulated and controlled in California for several decades to protect public health. In relation
to declining DPM from CARB’s regula tions pertaining to diesel engines, diesel fuels, and burning activities,
CARB estimates that annual black carbon emissions in California have reduced by 70% between 1990 and
2010, with 95% control expected by 2020 (CARB 2014 b).
Water Vapor. The primary source of water vapor is evaporation from the ocean, with additional vapor generated by
sublimation (change from solid to gas) from ice and snow, evaporation from other water bodies, and transpiration
from plant leaves. Water vapor is the most important, abundant, and variable GHG in the atmosphere and maintains
a climate necessary for life.
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Ozone. Tropospheric O3, which is created by photochemical reactions involving gases from both natural sources
and human activities, acts as a GHG. Stratospheric O3, which is created by the interaction between solar ultraviolet
radiation and molecular oxygen (O2), plays a decisive role in the stratospheric radiative balance. Depletion of
stratospheric O3, due to chemical reactions that may be enhanced by climate change, results in an increased
ground-level flux of ultraviolet-B radiation.
Aerosols. Aerosols are suspensions of particulate matter in a gas emitted into the air through burning biomass
(plant material) and fossil fuels. Aerosols can warm the atmosphere by abso rbing and emitting heat and can cool
the atmosphere by reflecting light.
5.7.1.4 Global Warming Potential
Gases in the atmosphere can contribute to climate change both directly and indirectly. Direct effects occur when
the gas itself absorbs radiation. Indirect radiative forcing occurs when chemical transformations of the substance
produce other GHGs, when a gas influences the atmospheric lifetimes of other gases, and/or when a gas affects
atmospheric processes that alter the radiative balance of the Earth (e.g., affect cloud formation or albedo) (EPA
2016). The Intergovernmental Panel on Climate Change (IPCC) developed the Global Warming Potential (GWP)
concept to compare the ability of each GHG to trap heat in the atmosphere relative to another gas. The G WP of a
GHG is defined as the ratio of the time-integrated radiative forcing from the instantaneous release of 1 kilogram of
a trace substance relative to that of 1 kilogram of a reference gas (IPCC 2014). The reference gas used is CO 2;
therefore, GWP-weighted emissions are measured in metric tons (MT) of carbon dioxide equivalent (CO2e).
The current version of CalEEMod (version 2016.3.2) assumes that the GWP for CH4 is 25 (so emissions of 1 MT of
CH4 are equivalent to emissions of 25 MT of CO2), and the GWP for N2O is 298, based on the IPCC Fourth
Assessment Report (IPCC 2007). The GWP values identified in CalEEMod were applied to the project.
5.7.1.5 Potential Effects of Climate Change
Globally, climate change has the potential to affect numerous environmental resources through uncertain impacts
related to future air temperatures and precipitation patterns. In California, climate change impacts have the
potential to affect sea-level rise, agriculture, snowpack and water supply, forestry, wildfire risk, public health, and
electricity demand and supply (CCCC 2006). The effects of climate change are discussed in detail in Appendix C.
5.7.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts associated with greenhouse gas emissions is based
on the recommendations provided in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). A significant
impact would occur if the project would:
A. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact
on the environment .
B. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gases.
Global climate change is a cumulative impact; a project participates in this potential impact through its incremental
contribution combined with the cumulative increase of all other sources of GHGs. There are currently no established
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thresholds for assessing whether the GHG emissions of a project, such as the project, would be considered a
cumulatively considerable contribution to global climate change; however, all reasonable efforts should be made
to minimize a project’s contribution to global climate change. In addition, while GHG impacts are recognized
exclusively as cumulative impacts (CAPCOA 2008), GHG emissions impacts must also be evaluated on a project
level under CEQA.
The CEQA Guidelines do not prescribe specific methodologies for performing an assessment, do not establish
specific thresholds of significance, and do not mandate specific mitigation measures. Rather, the CEQA Guidelines
emphasize the lead agency’s discretion to determine the appropriate methodologies and thresholds of significance
consistent with the manner in which other impact areas are handled in CEQA (CNRA 2009). The State of California
has not adopted emissions-based thresholds for GHG emissions under CEQA. The Governor’s Office of Planning
and Research’s Technical Advisory “CEQA and Climate Change: Addressing Climate Change through California
Environmental Quality Act Review” states that “public agencies are encouraged but not required to adopt thresh olds
of significance for environmental impacts. Even in the absence of clearly defined thresholds for GHG emissions, the
law requires that such emissions from CEQA projects must be disclosed and mitigated to the extent feasible
whenever the lead agency determines that the project contributes to a significant, cumulative climate change
impact” (OPR 2008). Furthermore, the advisory document indicates that “in the absence of regulatory standards
for GHG emissions or other scientific data to clearly define what constitutes a ‘significant impact,’ individual lead
agencies may undertake a project -by- project analysis, consistent with available guidance and current CEQA
practice.” Section 15064.7(c) of the CEQA Guidelines specifies that “when adopting thresholds o f significance, a
lead agency may consider thresholds of significance previously adopted or recommended by other public agencies,
or recommended by experts, provided the decision of the lead agency to adopt such thresholds is supported by
substantial evidence” (14 CCR 15064.7[c]).
Neither the State of California, nor the City, nor SDAPCD has adopted emission-based thresholds of significance for
GHG emissions under CEQA.
An efficiency threshold sets a per capita emissions limit. The total emissions from a given project are summed and
divided by a project’s service population (SP) to determine emissions per capita and are compared to the efficiency
threshold.3 Efficiency thresholds have been proposed by various agencies and air districts, including both the B ay
Area Air Quality Management District and South Coast Air Quality Management District (SCAQMD). The Bay Area Air
Quality Management District and SCAQMD have each developed an efficiency threshold of 6.6 MT CO2e/SP for plan
level developments. Additionally, the Bay Area Air Quality Management District suggested a project-level efficiency
threshold of 4.6 MT CO2e per SP, while SCAQMD suggested a project-level efficiency threshold of 4.8 MT CO2e per
SP. The fault in these proposed thresholds is that they rely on CARB’s Scoping Plan reduction goal and statewide
population for 2020. The California Supreme Court’s decision on the Center for Biological Diversity vs. California
Department of Fish and Wildlife determined that project-level analyses should not rely on statewide data. A more
localized efficiency threshold must be developed based on the population at the city level. These thresholds were
developed assuming compliance with AB 32’s 2020 goals.
To develop an efficiency threshold that would satisfy the requirements of Center for Biological Diversity vs. California
Department of Fish and Wildlife and EO B-30-15, the City’s 1990 emissions inventory, less 40%, must be divided by the
City’s 2030 SP (residents and employees). Project level emissions can then be directly evaluated against a threshold
based on local emission reduction goals and local population densities in accordance with the Court’s decision on Center
for Biological Diversity vs. California Department of Fish and Wildlife. It should be noted that the downward trajectory
3 Service population is defined as the number of residents plus the number of employees within the City.
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from AB 32 to SB 32 is greater than that from AB 32 to EO S-3-05, of 80% below 1990 by 2050 (CARB 2017a). By
analyzing the project against the quantitative efficiency metric thresholds for the buildout year and for the milestone year
for the next legislatively adopted target (2030), this analysis demonstrates that the project would demonstrate progress
toward, and be on the trajectory toward, helping the state comply with its long- term targets in EO S-3-05. Developing
community-wide mass reduction goals using this approach is consistent with CARB recommendations to determine the
targets “based on local emissions sectors” and to “develop community- wide GHG emissions reduction goals necessary
to reach 2030 and 2050 climate goals” (CARB 2017a, pp. 100–101).
As provided in the City’s 2012 Greenhouse Gas Emissions Inventory, the City’s 1990 GHG emissions inventory
totals approximately 847,166 MT CO2e. Based on the 1990 US Census (U.S. Census Bureau 1992), the City’s SP
in 1990 was 235,344 (135,243 residents + 100,101 employees). Dividing the City’s 1990 GHG emissions of
847,166 MT CO2e by the 1990 SP gives an efficiency metric of 3.60 MT CO2e per SP.
Consistent with EO B-30-15, the City’s 2030 goal is 508,300 MT CO2e (847,166 × [1−0.40]). Based on the SANDAG
Series 13 model (SANDAG 2013), the City’s SP in 2030 is estimated at 407,524 (313,474 residents + 94,050
employees).4 Dividing the City’s 2030 GHG emissions goal by the City’s 2030 population results in an efficiency
metric of 1.25 MT CO2e per SP.
To develop an efficiency metric for the project’s buildout year of 2028, it is necessary to interpolate between the
efficiency metrics in 1990 and 2030. Table 5.7-1 shows the calculated efficiency metric for 2028, which is consistent
with EO B-30-15.
Table 5.7-1. 2028 Interpolated Efficiency Metric
1990 Efficiency Metric (MT/SP/yr) 2030 Efficiency Metric (MT/SP/yr) 2028 Efficiency Metrica (MT/SP/yr)
3.60 1.25 1.37
Source: Appendix C
Notes: MT = metric tons; SP = service population; yr = year.
a The 2028 efficiency metric was calculated as follows: {[(2030 Efficiency Metric − 1990 Efficiency Metric) ÷ (2030 − 1990)] × (2028 −
1990)} + (1990 Efficiency Metric).
As shown in Table 5.7-1, the calculated efficiency metric for 2028 based on the City’s emissions inventory in 2012
and GHG emissions reduction goal for 2030 was 1.37 MT CO2e per SP, based on the statewide targets. If the project
achieves the 2028 efficiency metric, it would not interfere with attainment of the 2030 and 2050 statewide
emission reduction targets and therefore would not interfere with the state’s and the City’s ability to achieve the
mid-term and long-term GHG reduction targets in the CAP.
5.7.3 Impacts
A. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment.
Construction Impacts
Construction of the project would result in GHG emissions, which are primarily associated with use of off-road
construction equipment, on-road hauling and vendor (material delivery) trucks, and worker vehicles. GHG emissions
4 The SANDAG Series 13 model provides forecasts for years 2020 and 2035. The forecast for year 2030 was interpolated using
the forecasts for 2020 and 2035.
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associated with temporary construction activity were quantified using CalEEMod. A detailed depiction of the
construction schedule—including information regarding phasing, equipment used during each phase, haul trucks,
vendor trucks, and worker vehicles—is included in Appendix C.
Table 5.7-2 shows the estimated annual GHG construction emissions associated with the project, as well as the
amortized construction emissions over a 30-year project life.
Total construction-related GHG emissions for the project were 12,928 MT CO2e. Estimated 30-year amortized
project- generated construction emissions would be approximately 431 MT CO2e per year. However, because there
is no separate GHG threshold for construction emissions alone, the evaluation of significance is discussed in the
operational emissions analysis below.
Table 5.7-2. Estimated Annual Construction Greenhouse Gas Emissions
Year
CO2 CH4 N2O CO2e
Metric Tons
2021 557.82 0.16 0.00 561.77
2022 2,235.46 0.22 0.00 2,240.93
2023 1,970.91 0.15 0.00 1,974.59
2024 1,945.56 0.14 0.00 1,949.18
2025 1,898.52 0.14 0.00 1,902.07
2026 1,863.72 0.14 0.00 1,867.21
2027 1,832.90 0.14 0.00 1,836.35
2028 595.08 0.05 0.00 596.21
Total emissions 12,928.31
30-year amortized emissions 430.94
Source: Appendix C.
Notes: CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent.
See Appendix A of Appendix C for complete results.
Operational Emissions
Operation of the project would generate GHG emissions through motor vehicle trips to and from the project site;
landscape maintenance equipment operation; energy use (natural gas and generation of electricity consumed by
the project); solid waste disposal; and generation of electricity associated with water supply, treatment, and
distribution and wastewater treatment. CalEEMod was used to calculate the annual GHG emissions based on the
operational assumptions described in Appendix C. Although GHG emission reductions from implementation of PDF-
TRA-1 (see Section 4.4.8, Project Design Features) were not quantified, implementation of the following strategies
would further reduce the project’s vehicle miles traveled, which include providing ride share coordination services,
coordinating with nearby schools to carpool to/from school, provide on-site transit opportunities information, and
encourage bicycling by providing on-site bicycle infrastructure such as bike racks.
The estimated operational (year 2028) project-generated GHG emissions from area sources, energy usage, motor
vehicles, solid waste generation, and water usage and wastewater generation are shown Table 5.7-3.
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Table 5.7-3. Estimated Annual Operational Greenhouse Gas Emissions
Emission Source
CO2 CH4 N2O CO2e
Metric Tons per Year
Area 8.74 0.01 0.00 8.95
Energy 1,150.05 0.04 0.01 1,155.24
Mobile 3,448.08 0.18 0.00 3,452.51
Solid waste 33.62 1.99 0.00 83.28
Water supply and wastewater 178.62 1.54 0.04 228.13
Total 4,928.10
Amortized Construction Emissions 430.94
Operation + Amortized Construction Total 5,359.05
Notes: CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent.
See Appendix A for detailed results.
These emissions reflect CalEEMod “mitigated” output and operational year 2028.
As shown in Table 5.7-3, estimated annual project-generated GHG emissions in 2028 would be approximately
4,928 MT CO2e per year as a result of project operations. Estimated annual project -generated emissions in 2028
from area, energy, mobile, solid waste, water/wastewater, and amortized project construction emissions would be
approximately 5,359 MT CO2e per year.
City-Specific Efficiency Metric
As discussed in Section 5.7.2, Thresholds of Significance, a quantitative analysis using a City -specific efficiency
metric threshold for a post-2020 year (i.e., 2028) was developed. The efficiency metric calculated for 2028 (as
shown in Section 5.7.2) is 1.37 MT CO2e per SP.
The proposed project is anticipated to generate 2,321 residents.5 Using the estimated operational plus amortized
construction emissions of 5,359 MT CO2e and SP of 2,321, the project would have a GHG efficiency metric of 2.31
MT CO2e per SP. The project’s efficiency metric would exceed the significance threshold efficiency metric of 1.37
MT CO2e per SP. Therefore, impacts related to GHG emissions associated with the project would be potentially
significant. Therefore, Mitigation Measure (MM) GHG-1, outlined in Section 5.7.5, Mitigation Measures, would be
implemented and would minimize GHG emissions associated with project operations. However, approximately 64%
of the proposed project’s annual GHG emissions are from mobile sources; therefore, to reduce GHG emissions to
a less-than-significant level, the project would need to reduce its total GHG emissions by approximately 65% to
reduce the project-generated GHG emissions below the City’s efficiency threshold. Because the project’s SP-based
emissions would be more than the City’s efficiency metric of 1.37 MT CO2e per SP, potential GHG emissions impacts
associated with exceedance of the City’s efficiency metric would be considered significant and unavoidable (see
Section 5.7.6, Level of Significance After Mitigation, for more details).
B. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gases.
The project’s consistency with the CAP, SANDAG’s Regional Plan, and CARB’s Scoping Plan is discussed below.
5 Note that, while the proposed project would result in construction of 718 residential units, the Air Quality and Greenhouse Gas
Emissions Technical Report (Appendix C) assumed 720 proposed residential units for a conservative analysis.
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Consistency with the CAP
The CAP is not considered a qualified GHG reduction plan in accordance with CEQA Guidelines Section 15183.5,
as it has not been adopted in a public process following environmental review. Therefore, this consistency analysis is
included for informational purposes only and will not be used to determine significance.
The project includes several design features that will help reduce its GHG emissions in line with the CAP. Table
5.7-4 identifies the measures and goals within the CAP and the project’s consistency with them.
Table 5.7-4. City of Chula Vista Climate Action Plan Consistency Analysis
Category Policy Objective or Strategy Consistency Analysis
Water Conservation & Reuse
Water Education
& Enforcement
Expand education and enforcement
[through fines] targeting landscape water
waste
Consistent. The project would not impair the ability
of the City to expand education and enforcement
targeting landscape water waste. Furthermore, as
implemented by MM-GHG-1, native species and
drought-tolerant species shall be used for a
minimum of 50% of the ornamental plant palette in
non-turf areas to minimize the project’s water
demand. The project would install purple pipes to
use reclaimed water for irrigation.
Water Efficiency
Upgrades
Update the City’s Landscape Water
Conservation Ordinance to promote
more water‐wise landscaping designs
Consistent. The project would be consistent with
the City’s Landscape Water Conservation
Ordinance. Furthermore, as implemented by MM-
GHG-1, native species and drought-tolerant species
shall be used for a minimum of 50% of the
ornamental plant palette in non-turf areas to
minimize the project’s water demand. The project
would install purple pipes to use reclaimed water
for irrigation.
Require water‐savings retrofits in
existing buildings at a specific point in
time (not point of sale)
Not applicable. The project would not impair the
ability of the City to require water-savings retrofits
for existing buildings.
Water Reuse Plan
& System
Installations
Develop a Water Reuse Master Plan to
maximize the use of storm water,
graywater [recycled water] and onsite
water reclamation
Consistent. The project would not impair the ability
of the City to develop a Water Reuse Master Plan.
As implemented by MM-GHG-1, the project would
install purple pipes to use reclaimed water for
irrigation.
Facilitate simple graywater systems for
laundry-to-landscape applications
Consistent. As implemented by MM-GHG-1, the
project would install purple pipes to use reclaimed
water for irrigation.
Streamline complex graywater systems’
permit review
Not applicable. The project would not impair the
ability of the City to streamline complex graywater
systems permit review.
Waste Reduction
Zero Waste Plan Develop a Zero Waste Plan to
supplement statewide green waste,
recycling and plastic bag ban efforts
Consistent. The project would not impair the ability
of the City to develop a Zero Waste Plan. During
both construction and operation of the project, the
project would comply with all state regulations
related to solid waste generation, storage, and
5.7 – Greenhouse Gas Emissions
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Table 5.7-4. City of Chula Vista Climate Action Plan Consistency Analysis
Category Policy Objective or Strategy Consistency Analysis
disposal, including the California Integrated Waste
Management Act, as amended. As implemented by
MM-GHG-1, during construction, all wastes would
be recycled to the maximum extent possible and
exceed the City of Chula Vista’s Construction and
Demolition Debris Waste Management Plan’s 65%
diversion of construction and demolition waste.
Renewable & Energy Efficiency
Energy Education
& Enforcement
Expand education targeting key
community segments [e.g., do-it-
yourselfers and Millennials] and
facilitating energy performance
disclosure (e.g., Green Leases,
benchmarking and Home Energy
Ratings)
Not applicable. The project would not impair the
ability of the City to expand energy education.
Leverage the building inspection process
to distribute energy‐related information
and to deter unpermitted, low
performing energy improvements
Not applicable. The project would not impair the
ability of the City to distribute energy-related
information during the building inspection process.
Clean Energy
Sources
Incorporate solar photovoltaic into all
new residential and commercial
buildings [on a project-level basis]
Consistent. The project would install a 1,462-kW
solar photovoltaic system meeting the minimum
2019 Title 24 requirement.
Provide more grid‐delivered clean energy
(up to 100%) through Community Choice
Aggregation or other mechanism
Not applicable. The project would not impair the
ability of the City to provide a Community Choice
Aggregation of clean energy.
Energy Efficiency
Upgrades
Expand the City’s “cool roof” standards
to include re‐roofs and western areas
Consistent. The project would install cool roof
material, as implemented under MM-GHG-1, with a
greater solar reflectivity to help conserve energy.
Facilitate more energy upgrades in the
community through incentives [e.g., tax
breaks and rebates], permit streamlining
(where possible) and education [e.g.,
more local energy efficiency
programming]
Not applicable. The project would not impair the
ability of the City to incentivize additional energy
upgrades in the community.
Require energy‐savings retrofits in
existing buildings at a specific point in
time (not at point of sale)
Not applicable. The project would not impair the
ability of the City to require energy-savings retrofits
for existing buildings.
Robust Urban
Forests
Plant more shade trees to save energy,
address heat island issues and improve
air quality
Consistent. The project would plant 600 shade
trees on site to save energy and reduce heat island
issues, consistent with the City’s Shade Tree Policy
No. 576-19.
Smart Growth & Transportation
Complete Streets
& Neighborhoods
Incorporate “Complete Streets”
principles into municipal capital projects
and plans [e.g., the Bicycle and
Pedestrian Master Plans and Capital
Improvement Program]
Not applicable. The 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.
Furthermore, the Project would install bicycle racks.
5.7 – Greenhouse Gas Emissions
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Table 5.7-4. City of Chula Vista Climate Action Plan Consistency Analysis
Category Policy Objective or Strategy Consistency Analysis
Encourage higher density and mixed‐use
development in Smart Growth areas,
especially around trolley stations and
other transit nodes
Consistent. The Project would be building on a site
within the City and is located close to public transit
and I-805 and install bicycle racks. The East
Palomar Transit Station is located approximately one
mile from the project site. Furthermore, the project is
located near commercial and employment centers
in an urban setting.
Transportation
Demand
Management
Utilize bike facilities, transit
access/passes and other Transportation
Demand Management and congestion
management offerings
Consistent. The project would implement PDF-TRA-
1 (see Section 4.4.8, Project Design Features, of
the EIR), which includes the following strategies
that would further reduce the project’s vehicle
miles traveled, including providing ride share
coordination services, coordinating with nearby
schools to carpool to/from school, provide on-site
transit opportunities information, and encourage
bicycling by providing on-site bicycle infrastructure
such as bike racks.
Expand bike-sharing, car-sharing and
other “last mile” transportation options
Consistent. The project would implement PDF-TRA-
1 (see Section 4.4.8, Project Design Features, of
the EIR), which includes the following strategies
that would further reduce the project’s vehicle
miles traveled, including providing ride share
coordination services, coordinating with nearby
schools to carpool to/from school, provide on-site
transit opportunities information, and encourage
bicycling by providing on-site bicycle infrastructure
such as bike racks.
Alternative Fuel
Vehicle Readiness
Support the installation of more local
alternative fueling stations
Consistent. The project would be in compliance
with the current building standards. As
implemented under MM-GHG-1, the project would
pre-wire two parking spots and the project’s 718
parking garages to be electric vehicle capable.
Furthermore, the two pre-wired parking spots
would be designated for carpool, shared, electric,
and hydrogen vehicles.
Designate preferred parking for
alternative fuel vehicles
Consistent. As implemented under MM-GHG-1, the
project would pre-wire two parking spots and the
project’s 718 parking garages to be electric vehicle
capable. Furthermore, the two pre-wired parking
spots would be designated for carpool, shared,
electric, and hydrogen vehicles.
Design all new residential and
commercial buildings to be “Electric
Vehicle Ready”
Consistent. As implemented under MM-GHG-1, the
project would pre-wire two parking spots and the
project’s 718 parking garages to be electric vehicle
capable.
Source: City of Chula Vista 2017.
Notes: City = City of Chula Vista; project = Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project.
As shown in Table 5.7-4, the project would be consistent with the applicable measures within the CAP.
5.7 – Greenhouse Gas Emissions
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Consistency with San Diego Forward: The Regional Plan
Regarding consistency with SANDAG’s Regional Plan, the project would include site design elements and project
design features (PDFs) (see Section 4.4.8, Project Design Features) developed to support the policy objectives of
the RTP and SB 375.
Table 5.7-5 illustrates the project’s consistency with all applicable goals and policies of the Regional Plan (SANDAG 2015).
Table 5.7-5. San Diego Forward: The Regional Plan Consistency Analysis
Category Policy Objective or Strategy Consistency Analysis
The Regional Plan – Policy Objectives
Mobility Choices Provide safe, secure, healthy,
affordable, and convenient travel
choices between the places where
people live, work, and play.
Consistent. The project would provide pedestrian and
bicycle connectivity to the neighborhood.
Furthermore, the project would be located near MTS
bus routes 703 and 704 and I-805. The project
would implement PDF-TRA-1 (see Section 4.4.8,
Project Design Features, of the EIR), which includes
the following strategies that would further reduce the
project’s vehicle miles traveled, including providing
ride share coordination services, coordinating with
nearby schools to carpool to/from school, provide on-
site transit opportunities information, and encourage
bicycling by providing on-site bicycle infrastructure
such as bike racks.
Mobility Choices Take advantage of new technologies
to make the transportation system
more efficient and environmentally
friendly.
Not applicable. The project would not impair
SANDAG’s ability to employ new technologies to make
travel more reliable and convenient.
Habitat and Open
Space Preservation
Focus growth in areas that are
already urbanized, allowing the
region to set aside and restore more
open space in our less developed
areas.
Consistent. The project would be located close to
major urban centers, and the project would provide
housing to the area, while preserving adjacent open
space as part of the Chula Vista MSCP Subarea Plan.
Furthermore, the project is located near commercial
and employment centers in an urban setting.
Habitat and Open
Space Preservation
Protect and restore our region’s
urban canyons, coastlines, beaches,
and water resources.
Not applicable. The project would not impair the
ability of SANDAG to protect and restore urban
canyons, coastlines, beaches, and water resources.
Regional Economic
Prosperity
Invest in transportation projects that
provide access for all communities
to a variety of jobs with competitive
wages.
Not applicable. The project would not impair
SANDAG’s ability to invest in transportation projects
available to all members of the community.
Regional Economic
Prosperity
Build infrastructure that makes the
movement of freight in our
community more efficient and
environmentally friendly.
Not applicable. The project does not propose regional
freight movement, nor would it impair SANDAG’s
ability to preserve and expand options for regional
freight movement.
Partnerships/Collab
oration
Collaborate with Native American
tribes, Mexico, military bases,
neighboring counties, infrastructure
providers, the private sector, and
local communities to design a
Not applicable. The project would not impair
SANDAG’s ability to provide transportation choices to
better connect the San Diego region with Mexico,
neighboring counties, and tribal nations.
5.7 – Greenhouse Gas Emissions
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Table 5.7-5. San Diego Forward: The Regional Plan Consistency Analysis
Category Policy Objective or Strategy Consistency Analysis
transportation system that connects
to the mega‐region and national
network, works for everyone, and
fosters a high quality of life for all.
Partnerships/Collab
oration
As we plan for our region, recognize
the vital economic, environmental,
cultural, and community linkages
between the San Diego region and
Baja California.
Not applicable. The project would not impair
SANDAG’s ability to provide transportation choices to
better connect the San Diego region with Mexico.
Healthy and
Complete
Communities
Create great places for everyone to
live, work, and play.
Consistent. The project would provide pedestrian and
bicycle connectivity to the neighborhood and install
bicycle racks. Furthermore, the project would be
located near MTS bus routes 703 and 704 and I-
805. The East Palomar Transit Station is located
approximately one mile from the project site.
Furthermore, the project is located near commercial
and employment centers in an urban setting.
Healthy and
Complete
Communities
Connect communities through a
variety of transportation choices that
promote healthy lifestyles, including
walking and biking.
Consistent. The project would provide pedestrian and
bicycle connectivity to the neighborhood and install
bicycle racks. Furthermore, the project would install
bicycle racks and be located near MTS bus routes 703
and 704 and I-805. The East Palomar Transit Station
is located approximately one mile from the project site.
Furthermore, the project is located near commercial
and employment centers in an urban setting.
Environmental
Stewardship
Make transportation investments
that result in cleaner air,
environmental protection,
conservation, efficiency, and
sustainable living.
Consistent. The project would provide pedestrian and
bicycle connectivity to the neighborhood and install
bicycle racks. Furthermore, the project would be
located near MTS bus routes 703 and 704 and I-805.
The East Palomar Transit Station is located
approximately one mile from the project site.
Furthermore, the project is located near commercial
and employment centers in an urban setting. As
implemented under MM-GHG-1, the project would pre-
wire two parking spots and the project’s 718 parking
garages to be electric vehicle capable. Furthermore,
the two pre-wired parking spots would be designated
for carpool, shared, electric, and hydrogen vehicles.
Environmental
Stewardship
Support energy programs that
promote sustainability.
Consistent. The project would install a 1,462-kW
solar photovoltaic system meeting the minimum
2019 Title 24 requirement.
Sustainable Communities Strategy – Strategies
Strategy No. 1 Focus housing and job growth in
urbanized areas where there is
existing and planned transportation
infrastructure, including transit.
Consistent. The project would be located close to
major urban centers, existing MTS transit service and
the project would provide housing to the area. The
East Palomar Transit Station is located approximately
one mile from the project site. Furthermore, the
project is located near commercial and employment
centers in an urban setting.
5.7 – Greenhouse Gas Emissions
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Table 5.7-5. San Diego Forward: The Regional Plan Consistency Analysis
Category Policy Objective or Strategy Consistency Analysis
Strategy No. 2 Protect the environment and help
ensure the success of smart growth
land use policies by preserving
sensitive habitat, open space,
cultural resources, and farmland.
Consistent. The project would be located close to
major urban centers, and the project would provide
housing to the area, while preserving on-site open
space at part of the Chula Vista MSCP Subarea Plan.
Furthermore, the project is located near commercial
and employment centers in an urban setting.
Strategy No. 3 Invest in a transportation network
that gives people transportation
choices and reduces greenhouse
gas emissions.
Consistent. The project would provide pedestrian and
bicycle connectivity to the neighborhood.
Furthermore, the project would be located near MTS
bus routes 703 and 704 and I-805. The East
Palomar Transit Station is located approximately one
mile from the project site. The project would
implement PDF-TRA-1 (see Section 4.4.8, Project
Design Features, of the EIR), which includes the
following strategies that would further reduce the
project’s vehicle miles traveled, including providing
ride share coordination services, coordinating with
nearby schools to carpool to/from school, provide on-
site transit opportunities information, and encourage
bicycling by providing on-site bicycle infrastructure
such as bike racks. As implemented under MM-GHG-
1, the project would pre-wire two parking spots and
the project’s 718 parking garages to be electric
vehicle capable. Furthermore, the two pre-wired
parking spots would be designated for carpool,
shared, electric, and hydrogen vehicles.
Strategy No. 4 Address the housing needs of all
economic segments of the
population.
Consistent. The project would provide multifamily
residential units that would expand the housing
choices in the region.
Strategy No. 5 Implement the Regional Plan
through incentives and
collaboration.
Not applicable. The project would not impair
SANDAG’s ability to implement the Regional Plan
through incentives and collaboration.
Source: SANDAG 2015.
Notes: MTS = San Diego Metropolitan Transit System; project = Sunbow Sectional Planning Area Plan Amendment for the Sunbow II,
Phase 3 Project; SANDAG = San Diego Association of Governments; MSCP = Multiple Species Conservation Program.
As shown in Table 5.7-5, the project is consistent with all applicable Regional Plan policy objectives or strategies.
Consistency with CARB’s Scoping Plan
The Scoping Plan, approved by CARB on December 12, 2008, provides a framework for actions to reduce
California’s GHG emissions and requires CARB and other state agencies to adopt regulations and other initiatives
to reduce GHGs. As such, the Scoping Plan is not directly applicable to specific projects. In the Final Statement of
Reasons for the Amendments to the CEQA Guidelines, the California Natural Resources Agency observed that
“[t]he [Scoping Plan] may not be appropriate for use in determining the significance of individual projects because
it is conceptual at this stage and relies on the future development of regulations to implement the strategies
identified in the Scoping Plan” (CNRA 2009). However, under the Scoping Plan, there are several state regulatory
measures aimed at the identification and reduction of GHG emissions. CARB and other state agencies have adopted
5.7 – Greenhouse Gas Emissions
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many of the measures identified in the Scoping Plan. Most of these measures focus on area source emissions (e.g.,
energy usage, high-GWP GHGs in consumer products) and changes to the vehicle fleet (i.e., hybrid, electric, and
more fuel-efficient vehicles) and associated fuels (e.g., Low Carbon Fuel Standard), among others. The project would
comply with all applicable regulations adopted in furtherance of the Scoping Plan to the extent required by law.
The Scoping Plan recommends strategies for implementation at the statewide level to meet the goals of AB 32 and
establishes an overall framework for the measures that will be adopted to reduce California’s GHG emissions. Table
5.7-6 highlights measures that have been developed under the Scoping Plan, including the recommended
approaches for interim GHG thresholds under CEQA (CARB 2008b), and the project’s consistency with Scoping Plan
measures. The table also includes measures in the 2017 Scoping Plan Update. To the extent that these regulations
are applicable to the project and its inhabitants or uses, the project would comply with all applicable regulations
adopted in furtherance of the Scoping Plan.
Table 5.7-6 illustrates the project’s consistency with all applicable measures of the CARB Scoping Plan.
Table 5.7-6. Project Consistency with Scoping Plan Greenhouse Gas Emissions Reduction Strategies
Scoping Plan Measure Measure Number Project Consistency
Transportation Sector
Advanced Clean Cars T-1 The project’s residents would purchase vehicles in
compliance with CARB vehicle standards that are in effect
at the time of vehicle purchase.
1.5 Million Zero-Emission and
Plug-In Hybrid Light-Duty Electric
Vehicles by 2025 (4.2 Million
Zero-Emissions Vehicles by 2030)
N/A As implemented under MM-GHG-1, the project would pre-
wire two parking spots and the project’s 718 parking
garages to be electric vehicle capable. Furthermore, the
two pre-wired parking spots would be designated for
carpool, shared, electric, and hydrogen vehicles.
Low Carbon Fuel Standard T-2 Motor vehicles driven by the project’s residents would use
compliant fuels.
Low Carbon Fuel Standard (18%
reduction in carbon intensity by
2030)
N/A Motor vehicles driven by the project’s residents would use
compliant fuels.
Regional Transportation-Related
GHG Targets
T-3 The project would provide pedestrian and bicycle
connectivity to the neighborhood. Further, the project
would be located near MTS bus routes 703 and 704 and
I-805. The East Palomar Transit Station is located
approximately one mile from the project site. The project
would implement PDF-TRA-1 (see Section 4.4.8, Project
Design Features), which includes the following strategies
that would further reduce the project’s vehicle miles
traveled, including providing ride share coordination
services, coordinating with nearby schools to carpool
to/from school, provide on-site transit opportunities
information, and encourage bicycling by providing on-site
bicycle infrastructure such as bike racks. Furthermore,
the project is located near commercial and employment
centers in an urban setting.
Advanced Clean Transit N/A This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
5.7 – Greenhouse Gas Emissions
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Table 5.7-6. Project Consistency with Scoping Plan Greenhouse Gas Emissions Reduction Strategies
Scoping Plan Measure Measure Number Project Consistency
Last Mile Delivery N/A This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Reduction in Vehicle Miles
Traveled
N/A The project would provide pedestrian and bicycle
connectivity to the neighborhood and install bicycle racks.
Further, the project site is located near MTS bus routes
703 and 704 and I-805. The East Palomar Transit Station
is located approximately one mile from the project site.
The project would implement PDF-TRA-1 (see Section
4.4.8, Project Design Features, of the EIR), which includes
the following strategies that would further reduce the
project’s vehicle miles traveled. Furthermore, the project
is located near commercial and employment centers in
an urban setting.
Vehicle Efficiency Measures
1. Tire Pressure
2. Fuel Efficiency Tire Program
3. Low-Friction Oil
Solar-Reflective Automotive Paint
and Window Glazing
T-4 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Ship Electrification at Ports (Shore
Power)
T-5 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Goods Movement Efficiency
Measures
1. Port Drayage Trucks
2. Transport Refrigeration Units
Cold Storage Prohibition
3. Cargo Handling Equipment,
Anti- Idling, Hybrid,
Electrification
4. Goods Movement Systemwide
Efficiency Improvements
5. Commercial Harbor Craft
Maintenance and Design
Efficiency
6. Clean Ships
7. Vessel Speed Reduction
T-6 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
California Sustainable Freight
Action Plan
N/A This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Heavy-Duty Vehicle GHG Emission
Reduction
1. Tractor-Trailer GHG
Regulation
2. Heavy-Duty Greenhouse Gas
T-7 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
5.7 – Greenhouse Gas Emissions
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Table 5.7-6. Project Consistency with Scoping Plan Greenhouse Gas Emissions Reduction Strategies
Scoping Plan Measure Measure Number Project Consistency
Standards for New Vehicle and
Engines (Phase I)
Medium- and Heavy-Duty Vehicle
Hybridization Voucher Incentive
project
T-8 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Medium and Heavy-Duty GHG
Phase 2
N/A This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
High-Speed Rail T-9 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Electricity and Natural Gas Sector
Energy Efficiency Measures
(Electricity)
E-1 The project will comply with current Title 24, Part 6, of the
California Code of Regulations energy efficiency
standards for electrical appliances and other devices at
the time of building construction. As implemented by MM-
GHG-1, the project would install energy-efficient lighting
for all street, parking, and area lighting associated with
the Project. Furthermore, energy-efficient design
practices, such as high-performance glazing, Energy Star
compliant systems and appliances, radiant heat roof
barriers, insulation on all pipes, programmable
thermostats, and sealed ducts, shall be implemented.
The project would install cool roof material with a greater
solar reflectivity to help conserve energy. In addition, the
project would install a 1,462-kW solar photovoltaic
system meeting the minimum 2019 Title 24
requirement.
Energy Efficiency (Natural Gas) CR-1 The project will comply with current Title 24, Part 6, of the
California Code of Regulations energy efficiency
standards for electrical appliances and other devices at
the time of building construction.
Solar Water Heating (California
Solar Initiative Thermal Program)
CR-2 The project would not employ solar water heating.
However, the project would comply with the energy-
efficient requirements of the current building codes.
Combined Heat and Power E-2 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Renewables Portfolio Standard
(33% by 2020)
E-3 The project would use energy supplied by SDG&E, which
is in compliance with the Renewables Portfolio Standard.
In addition, the project would install a 1,462 -kW solar
photovoltaic system meeting the minimum 2019 Title
24 requirement.
Renewables Portfolio Standard
(50% by 2050)
N/A The project would use energy supplied by SDG&E, which
is in compliance with the Renewables Portfolio Standard.
In addition, the project would install a 1,462 -kW solar
photovoltaic system meeting the minimum 2019 Title
24 requirement.
5.7 – Greenhouse Gas Emissions
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Table 5.7-6. Project Consistency with Scoping Plan Greenhouse Gas Emissions Reduction Strategies
Scoping Plan Measure Measure Number Project Consistency
Senate Bill 1 Million Solar Roofs
(California Solar Initiative, New
Solar Home Partnership, Public
Utility Programs) and Earlier Solar
Programs
E-4 The project would install a 1,462-kW solar
photovoltaic system meeting the minimum 2019 Title
24 requirement.
Water Sector
Water Use Efficiency W-1 The project’s buildings would meet water use efficiency
standards that are in effect at the time of construction.
Furthermore, as implemented by MM-GHG-1, the project
shall install low-flow water fixtures such as low-flow
toilets, faucets, showers, etc.
Water Recycling W-2 As implemented by MM-GHG-1, The project would install
purple pipes to use reclaimed water for irrigation.
Water System Energy Efficiency W-3 This is applicable for the transmission and treatment of
water, but it is not applicable for the project.
Reuse Urban Runoff W-4 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Renewable Energy Production W-5 Applicable for wastewater treatment systems. Not
applicable for the project.
Green Buildings
State Green Building Initiative:
Leading the Way with State
Buildings (Greening New and
Existing State Buildings)
GB-1 The project would be constructed in compliance with
state or local green building standards in effect at the
time of building construction.
Green Building Standards Code
(Greening New Public Schools,
Residential and Commercial
Buildings)
GB-2 The project’s buildings would meet green building
standards that are in effect at the time of construction. As
implemented by MM-GHG-1, the project would install
energy-efficient lighting for all street, parking, and area
lighting associated with the Project. Furthermore, energy-
efficient design practices, such as high-performance
glazing, Energy Star compliant systems and appliances,
radiant heat roof barriers, insulation on all pipes,
programmable thermostats, and sealed ducts, shall be
implemented. In addition, the project would install a
1,462-kW solar photovoltaic system meeting the
minimum 2019 Title 24 requirement.
Beyond Code: Voluntary Programs
at the Local Level (Greening New
Public Schools, Residential and
Commercial Buildings)
GB-3 The project would be constructed in compliance with local
green building standards in effect at the time of building
construction. As implemented by MM-GHG-1, the project
would install energy-efficient lighting for all street,
parking, and area lighting associated with the Project.
Furthermore, energy-efficient design practices, such as
high-performance glazing, Energy Star compliant systems
and appliances, radiant heat roof barriers, insulation on
all pipes, programmable thermostats, and sealed ducts,
shall be implemented. In addition, the project would
5.7 – Greenhouse Gas Emissions
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Table 5.7-6. Project Consistency with Scoping Plan Greenhouse Gas Emissions Reduction Strategies
Scoping Plan Measure Measure Number Project Consistency
install a 1,462-kW solar photovoltaic system meeting
the minimum 2019 Title 24 requirement.
Greening Existing Buildings
(Greening Existing Homes and
Commercial Buildings)
GB-4 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Industry Sector
Energy Efficiency and Co-Benefits
Audits for Large Industrial Sources
I-1 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Oil and Gas Extraction GHG
Emission Reduction
I-2 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Reduce GHG Emissions by 20% in
Oil Refinery Sector
N/A This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
GHG Emissions Reduction from
Natural Gas Transmission and
Distribution
I-3 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan Measure.
Refinery Flare Recovery Process
Improvements
I-4 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan Measure.
Work with the Local Air Districts to
Evaluate Amendments to Their
Existing Leak Detection and
Repair Rules for Industrial
Facilities to Include Methane
Leaks
I-5 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Recycling and Waste Management Sector
Landfill Methane Control Measure RW-1 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Increasing the Efficiency of Landfill
Methane Capture
RW-2 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Mandatory Commercial Recycling RW-3 During both construction and operation of the project, the
project would comply with all state regulations related to
solid waste generation, storage, and disposal, including
the California Integrated Waste Management Act, as
amended. As implemented by MM-GHG-1, during
construction, all wastes would be recycled to the
maximum extent possible and exceed the City of Chula
Vista’s Construction and Demolition Debris Waste
Management Plan’s 65% diversion of construction and
demolition waste.
Increase Production and Markets
for Compost and Other Organics
RW-4 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
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Table 5.7-6. Project Consistency with Scoping Plan Greenhouse Gas Emissions Reduction Strategies
Scoping Plan Measure Measure Number Project Consistency
Anaerobic/Aerobic Digestion RW-5 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Extended Producer Responsibility RW-6 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Environmentally Preferable
Purchasing
RW-7 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Forests Sector
Sustainable Forest Target F-1 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
High Global Warming Potential Gases Sector
Motor Vehicle Air Conditioning
Systems: Reduction of Refrigerant
Emissions from Non-Professional
Servicing
H-1 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
SF6 Limits in Non-Utility and Non-
Semiconductor Applications
H-2 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Reduction of Perfluorocarbons in
Semiconductor Manufacturing
H-3 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Limit High Global Warming
Potential Use in Consumer
Products
H-4 The project’s residents would use consumer products that
would comply with the regulations that are in effect at the
time of manufacture.
Air Conditioning Refrigerant Leak
Test During Vehicle Smog Check
H-5 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Stationary Equipment Refrigerant
Management Program –
Refrigerant
Tracking/Reporting/Repair
Program
H-6 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Stationary Equipment Refrigerant
Management Program –
Specifications for Commercial and
Industrial Refrigeration
H-6 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
SF6 Leak Reduction Gas Insulated
Switchgear
H-6 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
40% Reduction in Methane and
Hydrofluorocarbon Emissions
N/A This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
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Table 5.7-6. Project Consistency with Scoping Plan Greenhouse Gas Emissions Reduction Strategies
Scoping Plan Measure Measure Number Project Consistency
50% reduction in black carbon
emissions
N/A This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Agriculture Sector
Methane Capture at Large Dairies A-1 This measure does not apply to the project. The project
would not inhibit CARB from implementing this Scoping
Plan measure.
Source: CARB 2008a, 2008b, 2017a.
Notes: project = Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project; CARB = California Air Resources
Board; N/A = not applicable; GHG = greenhouse gas; MTS = San Diego Metropolitan Transit System; SDG&E = San Diego Gas & Electric
Company; SF6 = sulfur hexafluoride.
As shown in Table 5.7-6, the project would be consistent with the applicable measures and policy goals of CARB’s
Scoping Plan. Because the proposed project is consistent with the applicable plans, policies, and regulations
adopted for regulation of GHG emissions, the Project would not conflict with an applicable plan, policy, or regulation
adopted for the purpose of reducing the emissions of greenhouse gases.
However, as discussed in Threshold A., above, because project’s SP-based emissions would be more than the City’s
efficiency metric of 1.37 MT CO2e per SP, the proposed project would potentially conflict with the state’s ability to
meet future GHG emission reductions. Therefore, the project’s GHG emissions impact would be potentially
significant. Although GHG emission reductions from implementation of PDF-TRA-1 (see Section 4.4.8, Project
Design Features, of the EIR) were not quantified, implementation of the following strategies would further reduce the
project’s vehicle miles traveled, which include providing ride share coordination services, coordinating with nearby schools
to carpool to/from school, provide on-site transit opportunities information, and encourage bicycling by providing on-site
bicycle infrastructure such as bike racks. The project would provide pedestrian and bicycle connectivity to the
neighborhood due to proximity to bicycle routes, provide pedestrian sidewalk connections. Furthermore, the Project
would be located near MTS bus routes 703 and 704 and I-805. These Project characteristics would promote
pedestrian and bicycle activity and alternate forms of transportation. GHG emissions associated with project would
be minimize to the extent feasible with implementation of MM-GHG-1, which include installation of low-flow water
fixtures, use of reclaimed water, pre-wiring for EV capable, installing energy-efficient appliances and design
practices, installing cool roofs, and planting 600 trees and 40 acres of shrubs. However, since the specific path to
compliance for the state with regard to the long-term goals will likely require development of technology or other
changes that are not currently known or available, specific additional mitigation measures for the proposed project
would be speculative and cannot be identified at this time. The proposed project’s GHG emissions would therefore
result in a significant and unavoidable impact (see Section 5.7.6 for more details).
5.7.4 Level of Significance Prior to Mitigation
The Project would implement PDF-TRA-1 (see Section 4.4.8, Project Design Features, of the EIR), which includes the
following strategies that would further reduce the Project’s vehicle miles traveled, including providing ride share
coordination services, coordinating with nearby schools to carpool to/from school, provide on-site transit opportunities
information, and encourage bicycling by providing on-site bicycle infrastructure such as bike racks. Furthermore, the
project would provide pedestrian and bicycle connectivity to the neighborhood due to proximity to bicycle routes,
provide pedestrian sidewalk connections. Furthermore, the project would be located near MTS bus routes 703 and
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704 and I-805, and the East Palomar Transit Station is located approximately one mile from the project site. The project
is located near commercial and employment centers in an urban setting. These project characteristics would promote
pedestrian and bicycle activity and encourage alternate forms of transportation. Prior to mitigation, the proposed
project would have potentially significant impacts associated with project’s efficiency metric and the state’s ability
to meet future GHG emission reductions. Impacts prior to mitigation would be potentially significant.
5.7.5 Mitigation Measures
The following mitigation measure would be implemented to reduce identified significant impacts associated with
climate change:
MM-GHG-1 Greenhouse Gas Emissions Reduction Measures. The following GHG emissions reduction
measures shall be implemented:
• Off-road construction equipment with engines rated at 75 horsepower or greater shall meet at
a minimum Tier 3 standard.
• Install purple pipes to provide reclaimed water for outdoor water use.
• Install low-flow water fixtures such as low-flow toilets, faucets, showers, etc.
• Two parking spaces shall be pre-wired for electric vehicle (EV) capable and designated as
preferential parking spaces shall be provided for carpool, shared, electric, and hydrogen vehicles.
• 718 parking garages shall be pre-wired to be EV capable.
• Energy-efficient lighting shall be used for all street, parking, and area lighting associated with
the proposed project, including all on-site and off-site lighting.
• Energy-efficient design practices, such as high-performance glazing, Energy Star compliant
systems and appliances, radiant heat roof barriers, insulation on all pipes, programmable
thermostats, and sealed ducts, shall be implemented.
• Native species and drought-tolerant species shall be used for a minimum of 50% of the
ornamental plant palette in non-turf areas to minimize water demand.
• Recycling of construction debris and waste shall be ensured through administration by an on-
site recycling coordinator and presence of recycling/separation areas. Exceed the City of Chula
Vista’s Construction and Demolition Debris Waste Management Plan’s 65% diversion of
construction and demolition waste.
• Install cool roofs that meet the U.S. Green Building Council standards with a greater solar
reflectivity to help conserve energy.
• Install 1,462-kilowatt solar photovoltaic system meeting the minimum 2019 Title 24 standards.
• Install bicycle racks.
• The project shall plant 600 trees and 40 acres of shrubs.
5.7.6 Level of Significance After Mitigation
Implementation of MM-GHG-1 would minimize GHG emissions associated with project construction and operations
to the extent feasible. The project would implement PDF-TRA-1 (see Section 4.4.8, Project Design Features, of the EIR),
which includes the following strategies that would further reduce the project’s vehicle miles traveled, including providing
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ride share coordination services, coordinating with nearby schools to carpool to/from school, provide on-site transit
opportunities information, and encourage bicycling by providing on-site bicycle infrastructure such as bike racks.
Furthermore, the project would provide pedestrian and bicycle connectivity to the neighborhood due to proximity to
bicycle routes, provide pedestrian sidewalk connections. Furthermore, the project would be located near MTS bus
routes 703 and 704 and I-805, and the East Palomar Transit Station is located approximately one mile from the project
site. The project is located near commercial and employment centers in an urban setting. The project would pre-wire two
parking spots and the project’s 718 parking garages to be electric vehicle capable. In addition, the two pre -wired
parking spots would be designated for carpool, shared, electric, and hydrogen vehicles. These project
characteristics would promote pedestrian and bicycle activity and encourage alternate forms of transportation.
However, approximately 64% of the project’s annual GHG emissions are from mobile sources; therefore, to reduce
GHG emissions to a less-than-significant level, the project would need to reduce its total GHG emissions by
approximately 65% to reduce the project-generated GHG emissions below the City’s efficiency threshold. Because
the project’s SP-based emissions would be more than the City’s efficiency metric of 1.37 MT CO2e per SP, potential
GHG emissions impacts would be considered significant and unavoidable .
In addition, since the specific path to compliance for the state with regard to the long-term goals will likely require
development of technology or other changes that are not currently known or available, specific additional mitigation
measures for the proposed project would be speculative and cannot be identified at this time. While implementation
of MM-GHG-1 would help reduce the GHG emissions of the proposed project, many measures are not quantifiable
and/or the extent to which some measures that may be developed in the future would apply to the project is
unknown. The proposed project’s GHG emissions would therefore result in a significant and unavoidable impact.
5.7 – Greenhouse Gas Emissions
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5.8 Hazards and Hazardous Materials
This section of the environmental impact report (EIR) addresses hazardous materials, airport hazards, wildland
fire, and emergency response and evacuation plan issues associated with the proposed Sunbow Sectional
Planning Area (SPA) Plan Amendment for the Sunbow II, Phase 3 Project (project or proposed project). This
analysis provides information on the existing c onditions of the project site, the locations of potentially hazardous
materials sites, and the potential for the proposed project to expose the public or the environment to hazards or
hazardous materials. Information provided in this section is based on the Phase 1 Environmental Site
Assessment (ESA) and Soil Vapor Investigation Memorandum (Memo) prepared by Geosyntec and included in
Appendix H1 and Appendix H2, respectively; the Fire Protection Plan (FPP), prepared by Dudek and included in
Appendix H3 of this EIR; and other sources are as cited throughout this section.
5.8.1 Existing Conditions
5.8.1.1 Regulatory Framework
Federal
Federal Toxic Substances Control Act of 1976
The Federal Toxic Substances Control Act of 1976 tasked the U.S. Environmental Protection Agency (EPA) with
authority to require reporting, record-keeping and testing requirements, and restrictions relating to chemical
substances and/or mixtures. The Federal Toxic Substances Control Act addresses the production, importation, use,
and disposal of specific chemicals including PCBs, asbestos, radon, and lead-based paint (EPA 2020a).
Resource Conservation and Recovery Act of 1976
The objectives of the Resource Conservation and Recovery Act of 1976 are to protect human health and the
environment from the potential hazards of waste disposal, conserve energy and natural resources, reduce the
amount of waste generated, and ensure that wastes are managed in an environmentally sound manner. The
Resource Conservation and Recovery Act affirmed and extended the “cradle-to-grave” system of regulating
hazardous wastes. The use of certain techniques for the disposal of some hazardous wastes was specifically
prohibited by the Hazardous and Solid Waste Act. The Hazardous and Solid Waste Amendments of 1984 also added
Subtitle I, which governs underground storage tanks (EPA 2020b).
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as “Superfund,”
was enacted by Congress on December 11, 1980. This law provided broad federal authority to respond directly to releases
or threatened releases of hazardous substances that may endanger public health or the environment. CERCLA established
requirements concerning closed and abandoned hazardous waste sites, provided for liability of persons responsible for
releases of hazardous waste at these sites, and established a trust fund to provide for cleanup when no responsible party
could be identified. CERCLA also enabled the revision of the National Contingency Plan. The National Contingency Plan
provided the guidelines and procedures needed to respond to releases and threatened releases of hazardous substances,
pollutants, or contaminants. The National Contingency Plan also established the National Priorities List, which is a list of
contaminated sites warranting further investigation by EPA. CERCLA was amended by the Superfund Amendments and
Reauthorization Act on October 17, 1986 (EPA 2018a).
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Superfund Amendments and Reauthorization Act
The Superfund Amendments and Reauthorization Act amended CERCLA on October 17, 1986. The Superfund
Amendments and Reauthorization Act had several changes and additions, including the following:
• Stressed the importance of permanent remedies and innovative treatment technologies in cleaning up
hazardous waste sites
• Required Superfund actions to consider the standards and requirements found in other state and fede ral
environmental laws and regulations
• Provided new enforcement authorities and settlement tools
• Increased state involvement in every phase of the Superfund program
• Increased the focus on human health problems posed by hazardous waste sites
• Encouraged greater citizen participation in making decisions on how sites should be cleaned up
• Increased the size of the trust fund to $8.5 billion
The Superfund Amendments and Reauthorization Act also required the EPA to revise the Hazard Ranking System
to ensure that it accurately assessed the relative degree of risk to human health and the environment posed by
uncontrolled hazardous waste sites that may be placed on the National Priorities List (EPA 2018b).
Hazardous Materials Transportation Act
The U.S. Department of Transportation regulates hazardous materials transportation between states under the Code
of Federal Regulations, Title 49, Chapter 1, Parts 100–185. In California, the California Department of Transportation
(Caltrans) and the California Highway Patrol enforce federal law related to the transport of hazardous materials.
Together, these agencies determine driver training requirements, load labelling procedures, and specifications for
container types.
Occupational Safety and Health Act of 1970 and Occupational Safety and Health Administration
The Occupational Safety and Health Act of 1970 was passed to prevent workers from being killed or seriously
harmed at work. The Occupational Safety and Health Act created the Occupational Safety and Health Administration
(OSHA), which sets and enforces protective workplace safety and health standards. OSHA also provides information,
training, and assistance to employers and workers. Under the Occupational Safety and Health Act, employers have
the responsibility to provide a safe workplace (OSHA 2014).
Federal Aviation Administration Functions
The Federal Aviation Administration (FAA) has primary responsibility for the safety of civil aviation. The FAA’s major
functions regarding hazards include (1) developing and operating a common system of air traffic control and
navigation for both civil and military aircraft, (2) developing and implementing programs to control aircraft noise and
other environmental effects of civil aviation, (3) regulating U.S. commercial space transportation, (4) researching and
developing the National Airspace System and civil aeronautics, (5) regulating civil aviation to promote safety, and (6)
encouraging and developing civil aeronautics, including new aviation technology (FAA 2019).
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Federal Response Plan
The Federal Response Plan of 1999 (FEMA 1999) is a signed agreement among 27 federal departments and
agencies, including the American Red Cross, that (1) provides the mechanism for coordinating delivery of federal
assistance and resources to augment efforts of state and local governments overwhelmed by a major disaster or
emergency; (2) supports implementation of the Robert T. Stafford Disaster Relief and Emergency Act, as well as
individual agency statutory authorities; and (3) supplements other federal emergency operations plans developed
to address specific hazards. The Federal Response Plan is implemented in anticipation of a significant event likely
to result in a need for federal assistance or in response to an actual event requiring federal ass istance under a
presidential declaration of a major disaster or emergency.
State
Hazardous Materials Management Act
Requires that businesses handling or storing certain amounts of hazardous materials prepare a hazardous
materials business plan, which includes an inventory of hazardous materials stored on site (above specified
quantities), an emergency response plan, and an employee training program.
Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65)
Requires the governor to publish and update, at least annually, a list of chemicals known to the state to cause
cancer, birth defects, or other reproductive harm and to inform citizens about exposures to such chemicals.
Hazardous Waste Management Planning and Facility Siting, also known as the Tanner Act (Assembly Bill 2948, 1986)
Requires counties to prepare, for California Department of Toxic Substance Control (DTSC) approval, hazardous waste
management plans and prescribes specific public participation activities, which must be carried out during the local land
use permit process for siting new or expanding off-site commercial treatment, storage, and disposal facilities.
California Environmental Protection Agency
The boards, departments, and offices that make up the California Environmental Protection Agency (CalEPA) include the
California Air Resources Board, the Department of Pesticide Regulation, the Department of Resources Recycling and
Recovery, DTSC, the Office of Environmental Health Hazard Assessment, and the State Water Resources Control Board.
These boards, departments, and offices were placed within the CalEPA “umbrella” to create a cabinet-level voice for the
protection of human health and the environment (such as clean air, clean water, clean soil, safe pesticides, and waste
recycling and reduction) to assure the coordinated deployment of state resources (CalEPA 2020a).
Cortese List/Government Code Section 65962.5
Pursuant to Government Code, Section 65962.5, environmental regulatory database lists are compiled to identify
and locate properties with known hazardous substance contamination (California Government Code, Section
65960 et seq.). Four state agencies are required to provide lists of facilities that have contributed to, harbor, or are
responsible for environmental contamination within their jurisdiction. The four state agencies that are required to
provide these lists to the Secretary for Environmental Protection include DTSC, the State Department fo r Health
Services, the State Water Resources Control Board, and the California Integrated Waste Management Board. The
Secretary for Environmental Protection then takes each of the four respective agency lists and forms one list,
referred to as the Hazardous Waste and Substances Site List – Site Cleanup (Cortese List), which is made available
to every city and/or county in California (CalEPA 2020b).
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California Occupational Safety and Health Administration
Cal/OSHA is the primary agency responsible for worker safety in the handling and use of chemicals in the workplace.
Cal/OSHA standards are generally more stringent than federal regulations. The employer is required to monitor
worker exposure to listed hazardous substances and notify workers of exposure (8 California Code of Regulations
[CCR], Sections 337–340). The regulations specify requirements for employee training, availability of safety
equipment, accident prevention programs, and hazardous substance exposure warnings.
California Hazardous Waste Control Law
The California Hazardous Waste Control Law (California Health and Safety Code, Division 20, Chapter 6.5) is
administered by CalEPA to regulate the management of hazardous wastes. While the California Hazardous Waste
Control Law is generally more stringent than the Resource Conservation and Recovery Act, until EPA approves the
California Hazardous Waste Control Program (which is charged with regulating the generation, treatment, storage,
and disposal of hazardous waste), both the state and federal laws apply in California. The Hazardous Waste Control
Law lists 791 chemicals and approximately 300 common materials that may be hazardous; establishes criteria for
identifying, packaging, and labeling hazardous wastes; prescribes manageme nt controls; establishes permit
requirements for treatment, storage, disposal, and transportation; and identifies some wastes that cannot be
disposed of in landfills.
California Accidental Release Prevention Program
Similar to the Federal Risk Management Program, the California Accidental Release Prevention Program includes
additional state requirements and an additional list of regulated substances and thresholds. The regulations of the
program are contained in California Code of Regulations Title 19, Division 2, Chapter 4.5. The intent of the California
Accidental Release Prevention Program is to prevent accidental releases of substances that can cause serious harm to
the public and the environment, minimize the damage if releases do occur, and satisfy community right-to-know laws.
California Health and Safety Code
The handling and storage of hazardous materials is regulated by Division 20, Chapter 6.95, of the California Health and
Safety Code. Under Sections 25500–25543.3, facilities handling hazardous materials are required to prepare a hazardous
materials business plan. Hazardous materials business plans contain basic information on the location, type, quantity, and
health risks of hazardous materials stored, used, or disposed of in the state. Chapter 6.95 of the California Health and
Safety Code establishes minimum statewide standards for hazardous materials business plans.
In addition, in the event that a facility stores quantities of specific acutely hazardous materials above the thresholds set
forth by the California Health and Safety Code, facilities are also required to prepare a risk management plan and
California accidental release plan. The risk management plan and California accidental release plan provide information
on the potential impact zone of a worst-case release and require plans and programs designed to minimize the probability
of a release and mitigate potential impacts (California Health and Safety Code, Chapter 6.95).
Title 24 California Building Standards Code
California Building Code
California Building Standards Code Title 24, Part 2 contains the California Building Code. California Building Code
Chapter 7A regulates building materials, systems, and/or assemblies used in the exterior design and construction of
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new buildings located within a fire hazard area. Fire hazard areas as defined by the California Building Code include
areas identified as a Fire Hazard Severity Zone (FHSZ) within a State Responsibility Area or a wildland–urban interface
fire area. The purpose of Chapter 7A is to establish minimum standards for the protection of life and property by
increasing the ability of structures located in a fire hazard area to resist the intrusion of flames or burning embers
projected by a wildfire, and to contribute to a systematic reduction in structural losses from a wildfire. New buildings
located in such areas must comply with the ignition-resistant construction standards outlined in Chapter 7A.
California Fire Code
California Building Standards Code Title 24, Part 9 contains the California Fire Code (CFC), which incorporates by
adoption the International Fire Code with necessary California amendments. The purpose of the CFC is to establish
the minimum requirements to safeguard the public health, safety, and general welfare from the hazards of fire,
explosion, or dangerous conditions in new and existing buildings, structures, and premises, and to provide safety
and assistance to firefighters and emergency responders during emergency operations. CFC, Chapter 49 contains
minimum standards for development in the wildland–urban interface and fire hazard areas.
The CFC and Office of the State Fire Marshal provide regulations and guidance for local agencies in the development
and enforcement of fire safety standards. The CFC is updated and published every 3 years by the California Building
Standards Commission. The 2016 CFC took effect on January 1, 2017, and the 2019 CFC took effect on January
1, 2020. The City adopted the 2016 CFC with local amendments in August 2018.
California Code of Regulations, Title 14, Division 1.5
California Code of Regulations Title 14, Division 1.5, establishes the regulations for the California Department of
Forestry and Fire Protection (CAL FIRE) and is applicable in all State Responsibility Areas—areas where CAL FIRE is
responsible for wildfire protection. Most of the unincorporated area of San Diego County is a State Responsibility
Area, and any development in State Responsibility Areas must comply with these regulations. Among other things,
Title 14 Section 1270, et seq. establishes minimum standards for emergency access, fuel modification, setback to
property line, signage, and water supply. The County of San Diego’s (County) most recent adoption of the
Consolidated Fire Code (2014) was certified by the State Board of Forestry, indicating that its code requirements
meet or exceed Title 14 Section 1270 et seq., and with that certification, the County Consolidated Fire Code
supersedes Title 14 Section 1270 et seq. in the unincorporated areas of the County.
California Emergency Services Act
Under the Emergency Services Act (California Government Code, Section 8550 et seq.), the State of California
developed an emergency response plan to coordinate emergency services provided by federal, state, and local
agencies. Rapid response to incidents involving hazardous materials or hazardous waste is an inte gral part of the
plan, which is administered by the Governor’s Office of Emergency Services. The Office of Emergency Services
coordinates the responses of other agencies, including the EPA, California Highway Patrol, Regional Water Quality
Control Boards (RWQCBs), air quality management districts, and county disaster response offices.
California Code of Regulations Title 5, Division 1, Chapter 13, Subchapter 1 – School Facilities Construction
California Code of Regulations Title 5, Division 1, Chapter 13, Subchapter 1 establishes minimum standards for
siting of schools and school construction to provide safety for students and staff. The regulation establishes
minimum distances that schools can be located from potential hazards such as power line easements and sets
screening distances for other hazards that would require a safety study, such as a railroad track easement. Section
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14010(h) states that schools shall not be located near an above-ground water or fuel storage tank or within 1,500
feet of the easement of an above-ground or underground pipeline that can pose a safety hazard as determined by
a risk analysis study. Section 14010(t) states that if the proposed site is on or within 2,000 feet of a significant
disposal of hazardous waste, the school district shall contact DTSC for a determination of whether the property
should be considered a hazardous waste property or border zone property and unsuitable for school development.
South Coast Air Quality Management District – Rule 1403
The purpose of this rule is to specify work practice requirements to limit asbestos emissions from building
demolition and renovation activities, including the removal and associated disturbance of asbestos -containing
materials (ACM). The requirements for demolition and renovation activities include asbestos surveying, notification,
ACM removal procedures and time schedules, ACM handling and clean-up procedures, and storage, disposal, and
landfilling requirements for asbestos-containing waste materials (ACWM). All operators are required to maintain
records, including waste shipment records, and are required to use appropriate warning labels, signs, and markings.
Local
San Diego County Department of Environmental Health
The San Diego County Department of Environmental Health (DEH) serves to protect the environment and enhance
public health by preventing disease, promoting environmental responsibility and, when necessary enforcing
environmental and public health laws. Within DEH, the Hazardous Materials Division (HMD) protects human health
and the environment by ensuring that hazardous materials, hazardous waste, medical waste and underground
storage tanks are properly managed. To accomplish this goal, HMD regulates facilities that handle or store
hazardous materials, are part of the California Accidental Release Prevention Program, generate or treat hazardous
wastes or medical waste, store at least 1320 gallons of aboveground petroleum, and own or operate underground
storage tanks. DEH identifies disposal locations for household hazardous waste as well as scheduled household
waste collection events (DEH 2020).
Regional Water Quality Control Board
The Regional Water Quality Control Board (RWQCB) implements the California Water Code, which regulates waste
discharges to land. If a discharge of waste threatens a water of the state, a report of waste discharge or an application
for a waiver of a report of waste discharge must be filed with the RWQCB. The RWQCB accomplishes its permitting
responsibility by issuing either a general or site-specific permit (Waste Discharge Permit) or a waiver of a permit.
San Diego County Emergency Operations Plan
The San Diego County Emergency Operations Plan is a comprehensive emergency management system that provides
for a planned response to disaster situations associated with natural disasters, technological incidents, and nuclear
defense operations. The Emergency Plan includes operational concepts relating to various emergency situations,
identifies components of the Emergency Management Organization and describes the overall responsibilities for
protecting life and property and assuring the overall well-being of the population. The plan also identifies the sources of
outside support that might be provided (through mutual aid and specific statutory authorities) by other jurisdictions, state
and federal agencies, and the private sector (County of San Diego 2018).
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County of San Diego, Consolidated Fire Code
The County, in collaboration with the local fire protection districts, created the first Consolidated Fire Code in 2001.
The Consolidated Fire Code contains the County and fire protection districts amendments to the California Fire
Code. The purpose of consolidation of the County and local fire districts’ adoptive ordinances is to promote
consistency in the interpretation and enforcement of the fire code for the protection of the public health and safety.
The ordinances include permit requirements for the installation, alteration, or repair of new and existing fire
protection systems, and penalties for violations of the Consolidated Fire Code. The Consolidated Fire Code provides
the minimum requirements for access, water supply and distribution, construction type, fire protection systems,
and vegetation management. Additionally, the Consolidated Fire Code regulates hazardous materials and
associated measures to ensure that public health and safety are protected from incidents relating to hazardous
substance releases. San Diego County’s 2020 Consolidated Fire Code (the most recent adoption) was certified by
the State Board of Forestry, resulting in its superseding California Code of Regulations Title 14, Section 1270 et
seq., as it would otherwise apply within San Diego County (County of San Diego 2020).
San Diego County Multi-Jurisdiction Hazard Mitigation Plan
The San Diego County Multi-Jurisdiction Hazard Mitigation Plan was originally prepared in July 2010 and updated
in October 2017 to meet federal and state requirements for disaster preparedness to make the County eligible for
funding and technical assistance from state and federal hazard mitigation programs. The plan includes a risk
assessment to enable local jurisdictions to identify and prioritize appropriate mitigation actions to reduce losses
from potential hazards, including flooding, earthquakes, fires, and man-made hazards. To address potential
hazards, the plan then incorporates mitigation goals and objectives, mitigation actions and priorities, an
implementation plan, and documentation of the mitigation planning process for each of the 22 participating
jurisdictions, including Chula Vista (County of San Diego 2017).
California Disaster and Civil Defense Master Mutual Aid Agreement
As provided for in the California Emergency Services Act, the California Disaster and Civil Defense Master Mutual Aid
Agreement was developed in 1950 and adopted by all 58 California counties. This statewide mutual aid system is
designed to ensure that adequate resources, facilities, and other support is provided to jurisdictions whenever their own
resources prove to be inadequate to cope with a given situation. San Diego County is located in Mutual Aid Region 6 of
the state system, which also includes Imperial, Riverside, San Bernardino, Inyo, and Mono Counties (OES 2017).
Community Emergency Response Team Program
The City of Chula Vista provides a Community Emergency Response Team (CERT) program that offers citizens
training on how to effectively and efficiently respond to emergency situations without placing themselves or others
in unnecessary danger. CERT training includes lessons on managing utilities, putting out small fires, providing basic
emergency medical aid, searching for and rescuing victims safely, effectively organizing volunteers, and collecting
disaster information to support first responders (City of Chula Vista 2020).
Airport Land Use Compatibility Plan–Brown Field
The San Diego County Regional Airport Authority, designated as the Airport Land Use Commission for all public
airports in the County of San Diego, adopted the Brown Field Airport Land Use Compatibility Plan (ALUCP) in
September 1981 (last updated in December 2010). The ALUCP assists in achieving compatible land use
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development in the area surrounding Brown Field airport located in Otay Mesa on Heritage Road, east of Interstate
(I) 805. Brown Field is a general aviation airport accommodating both propeller- and jet-powered aircraft and serves
as a port of entry for private aircraft coming into the United States from Mexico. Brown Field is also heavily used by
military and law enforcement agencies and is classified as a “reliever airport” by the Federal Aviation Administration
(SDCRAA 2010). The ALUCP designates the airport influence area and contains projected noise contours, flight
activity zones, a land use compatibility matrix, and plan recommendations for areas surrounding Brown Field. The
airport influence area is delineated by using the projected 60-decibel (dB) community noise equivalency level
(CNEL) contour and is generally the area in which current and future airport-related noise, overflight, safety, and/or
airspace protection factors may affect land uses or necessitate restrictions on uses. The airport influence area is
divided into Review Area 1 and Review Area 2.
The composition of each area is determined as follows (SDCRAA 2010):
• Review Area 1 consists of locations where noise or safety concerns may necessitate limitations on the types
of land use actions. Specifically, Review Area 1 encompasses locations exposed to aircraft noise levels of
60 dB CNEL or greater together with all of the safety zones identified in the ALUCP.
• Review Area 2 consists of locations beyond Review Area 1 but within the airspace protection and/or
overflight notification areas. Limits on the heights of structures, particularly in areas of high terrain, are the
only restrictions on land uses within Review Area 2.
A portion of the project site is within the Brown Field Airport Influence Area Review Area 2 and the entire project site
is within the FAA Height Notification Boundary (SDCRAA 2010).
City of Chula Vista General Plan
The goal of the General Plan to remediate future development sites in accordance with applicable state and federal
standards to manage household hazardous waste and to minimize the risk of injury and property damage
associated with wildland fire hazards (Objective E 16) and ensure that adequate remediation of contaminated sites
as redevelopment occurs to protect public health and safety (Objective E 17) and ways to minimize damage due to
flooding (Objective E 15) (City of Chula Vista 2005).
5.8.1.2 Regulatory Databases
Government Code Section 65962.5, referred to as the Cortese List, was originally enacted in 1985. Provisions set
forth in Section 65962.5 require that the DTSC compile and update a list of the following:
• All hazardous waste facilities subject to corrective action
• All land designated as hazardous waste property or border zone property
• All information received by the Depart of Toxic Substances Control on hazardous waste disposals on
public lands
• All sites listed pursuant to Section 25356 of the Health and Safety Code (hazardous substance release sites)
• All sites included in the Abandoned Site Assessment Program
As part of the Phase I ESA (Appendix H1), a database search report was obtained from Environmental Data
Resources, Inc. (EDR). The report documents findings of various federal, state, and local regulatory database
searches regarding properties with known or suspected releases of hazardous materials or petroleum
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hydrocarbons. The results of the search found that the project site was not identified by EDR; however, several
adjoining and nearby properties were identified by EDR and are included in Table 5.8-1.
Table 5.8-1. Database Search Report Findings
Site Name Location Site History
Distance from
Project Site*
Hernandez
Custom Paints
599
Portsmouth
Drive
The site is listed within the Resource Conservation and
Recovery Act (RCRA) small-quantity generator (SQG)
database for handling ignitable waste. No violations were
noted for this facility, and based on the benign nature of
the listing, it is unlikely this site has adversely affected the
project site.
The site is
approximately 164
feet west of the
project site.
Otay Sanitary
Landfill and
Appropriate
Technologies II
1700
Maxwell
Road
The site consists of the closed Otay Class I Landfill
adjacent to the active Otay Sanitary Annex Class landfill
(Class III). The Otay Class I Landfill is listed within the
California Waste Management Unit Database/Solid
Waste Assessment Testing (WMUDS/SWAT) and
Historical Cortese databases. Appropriate Technologies is
also listed at 1700 Maxwell Road, and is listed as a
hazardous waste facility that accepted hazardous and
non-hazardous liquid sludge and slurry wastes in bulk,
hazardous liquid/solid waste in drums or other approved
containers, as well as polychlorinated biphenyls (PCBs)
and explosive and radioactive materials. It appears that a
washout pit and unlined effluent pipes also existed at or
near this facility, which were closed under the DTSC in
1995 after a remedial feasibility investigation (RFI)
concluded that there is no further investigation necessary
for the washout pit and pipes, and the facility was closed
under the DTSC in 1996. As the case is closed, it is
unlikely to have adversely affected the project site. Refer
also to the analysis contained in Section 5.8.3 and
Appendix H2.
This site is directly
south of the project
site.
A&W Smelter
and Refinery
Silver
Queen
Road
The site is identified as A&W smelter and refinery (A&W)
on Silver Queen Road. However, A&W attempted to send
seven truckloads across the Mexico border to dispose of
unusable ore containing lead and considered hazardous
waste (Appendix H1). These trucks were detained and
temporarily impounded at the Appropriate Technologies II
facility by U.S. Customs. Soil discussed in this listing was
not present at the site and therefore is not likely to have
adversely affected the project site.
The site is reportedly
located
approximately 0.4
miles southeast of
the project site;
however, the actual
refinery is not located
near the project site.
Ecology Auto
Parks
825 Energy
Way
Two closed leaking underground storage tank (LUST) sites
are mapped at this location; one LUST received NFA from
the RWQCB in July 2019 and no information is provided
about the second LUST with the exception of a monitoring
report from 2006; it is suggested these were part of the
same investigation. Based on the closure of the cases at
this facility, the distance from the project site of 0.5 mile,
and orientation hydraulically down gradient to the project
site, it is not likely that this facility has adversely impacted
the project site.
The site is within 0.5
mile of the project
site.
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Table 5.8-1. Database Search Report Findings
Site Name Location Site History
Distance from
Project Site*
Omar Rendering
Facility
1886 Auto
Park Place
The site housed six Class I waste ponds, the contents of
which were removed in 1980. The impacted soils
beneath the pond were excavated and placed in a lined
cell in the northwest corner of the project site, which is
currently capped and used as a parking lot accessed from
Auto Park Place. One Leaking Underground Storage Tank
(LUST) is also reported at this facility; however, the
impacted soil was excavated, and the release received
closure from the Department of Environmental Health in
1993 with residual contamination below method
detection limits (MDLs). As stated in the GeoTracker
database, a “no further action (NFA)” statement was
released. Based on this facility’s distance from the project
site and its orientation hydraulically down gradient from
the project site, it is unlikely this facility has adversely
impacted the project site.
The site is
approximately 0.7
miles southeast of
the project site.
Nakano Farms 4501 Otay
Valley Road
The site (4501 Otay Valley Road) and is listed under
Nakano Farms and within the EnviroStor, Cleanup
Program Sites – Spills, Leaks, Investigations, and
Cleanups (CPS-SLIC), Statewide Environmental Evaluation
and Planning System (SWEEPS), Historical UST, and
HMMD databases. One underground storage tank is
reported at this property, and the cleanup is reported to
have been completed and closed as of May 1996. Due to
the facility’s distance to the project site, it is unlikely to
have adversely affected the project site.
The site is located
approximately 0.8
miles southwest of
the project site.
Apache
Services
4551 Otay
Valley Road
The site (4551 Otay Valley Road) is listed under the
EnviroStor and Bond Expenditure Plan databases under
Apache Services. This property was used as a salvage
yard that may have received materials from nearby naval
facilities. The property is impacted with metals, petroleum
products, and solvents and is located on fill material. No
further information was provided; however, based on
distance from the project site and nature of surficial
impacts, it is not likely this property has adversely
impacted the project site.
The site is located
approximately 0.8
miles south of the
project site.
Proposed Otay
Ranch Village 3
Elementary
School
Camino
Prado
Proposed Otay Ranch Village 3 Elementary School on
Camino Prado is listed under the Envirostor and School
databases. The potential school site is being investigated
for potential methane mitigation and is being evaluated
for suitability for school use under the Department of
Toxic Substance Control (DTSC). Based on the nature of
the listing, it is not likely this property has adversely
affected the project site.
The site is within 1
mile of the project
site.
Source: Appendix H1.
* Distance when measured from the proposed residences on -site will vary from the distance measured from the
project site boundary.
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5.8.1.3 Historical Aerial Photographs and Topographic Maps
A combination of historical aerial photographs and U.S. Geological Survey topographic maps of the project site,
from a variety of years (1949 being the earliest and 2020 the most recent), were observed. Key observations from
the aerial photographs and topographic maps include:
• The oldest available topographic maps indicate the Poggi Canyon Creek flowed through the northern portion
of the project site. The Otay River is shown south of the project site, south of a road with several small
structures. Telegraph Canyon and several additional roads are shown to the north of the project site.
• A 1949 aerial indicates a pit mine with benched side walls visible south of the project site, as well as a
property that may have been agricultural located south of the pit mine. An unpaved access road traverses
through this property to the pit mine. The surrounding area appears to be largely undeveloped native land.
• A 1953 topographic map depicted a “borrow pit” in the area south of the project site, alluding to mining of
bentonite that occurred in this area prior to landfill use. The 1953 aerial confirmed the presence of the
borrow pit and the agricultural property south of the borrow pit appeared to be a dairy or cattle feed lot. By
1964, it appears the borrow pit was converted to its landfill use and surrounding operations, including the
rendering landfill and other industrial facilities located further south. It appears borrowing or surveying for
an expansion of the Class I landfill took place around this time, based on a cleared grid around the existing
boundaries of the landfill, and what appears to be a sludge or liquid treatment area with six beds is visible
within the landfill footprint. By 1966, the water tower on the top of the hill south of the project site had
been constructed. The project site remained undeveloped.
• The 1970 aerial indicated the landfill had been expanded to the south, and a second water tower had been
constructed southwest of the project site. Grading activities are visible in the aerial to the north and appear
to be pre-construction or agriculture. The project site remained undeveloped.
• The 1975 topographic map shows the areas west, northwest, and southwest of the project site had been
developed with residential subdivisions and schools. The 1979 aerial showed subdivisions constructed
adjoining the project site to the southwest and west, and construction of the existing medical facility and
ancillary structures has begun approximately 0.5 miles north of the project site. The landfill operations in
the areas south of the project site, likely indicating the Class III landfill had begun operating. It appears soil
was borrowed from the eastern portion of the project site around this time, for landfill use or some other
purpose. By 1985, landfill operations had expanded to the east. The project site remained undeveloped.
• The 1991 topographic map depicted the landfill area to the south as a “Gravel Pit,” but the aerial appears
to indicate the area south of the project site was primarily used for landfilling. By 1994, the extent of the
Class III landfill appeared similar to its current footprint.
• By 2005, Olympic Parkway had been constructed north of the project site, and the area north of Olympic
Parkway had been developed with residences. The project site remained vacant and undeveloped, with
access points to the Site from Olympic Parkway. By 2006, a third larger water tower had been constructed
south of the project site. Landfill operations at the Class III landfill appeared similar.
• The 2018 aerial indicated the project site remained undeveloped, and landfill activiti es continued on the
adjoining property southeast of the project site. The adjoining areas southeast and east of the landfills had
either been developed with residences or were undergoing residential development.
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5.8.1.4 City Directories
In preparation of the Phase I ESA, City directories were searched by EDR for available years from 1971 to 2014 to
assess occupancy at the project site and adjoining properties (Appendix H1). The project site was not listed in the
City Directory. Properties within the vicinity of the project site along Olympic Parkway, Brandywine Avenue, East
Palomar Street, and Maxwell Road included listings from 1965 to 2014 for various residential, commercial, and
light industrial properties. Based on city directory listings obtained, no evidence of additional recognized
environmental conditions were identified. Refer to Appendix H1 for further details regarding surrounding properties.
5.8.1.5 Existing Setting
The project site is situated on a hillside and slopes steeply from the south to a permitted wetland along the northern
boundary of the project site. The project site is directly underlain by the San Diego Formation, followed by the Otay
Formation and the Mission Valley Formation. The elev ation of the site ranges from approximately 220 to 450 feet
above mean sea level. The project site has been historically known to be vacant and undeveloped. However,
properties surrounding the project site have been used for bentonite (clay mining), landfi lling, and other
industrial, commercial, and residential purposes. While the project site remains undeveloped, the site contains
seven gas probes, three vadose monitoring wells, and two monitoring wells. Additionally, monuments and vaults
labeled “CP Test,” believed to be associated with a recycled water pipeline, traverse the project site.
The project site is bounded to the north by Olympic Parkway; directly north of this is an undeveloped hillside,
followed by residential subdivisions. Portions of the Otay Annex Sanitary Landfill adjoin the project site to the
southeast, and the property directly east of the project site is vacant and undeveloped. The Otay Annex Sanitary
Landfill, also known as the Otay Class III landfill, extends west and also adjoins the project site to the south and
surrounds the adjoining Otay Class I Landfill. Residential developments are situated southwest and directly west of
the project site, and east and south of the Otay Class III landfill. Both the Class I and Class III landfills have
groundwater monitoring networks which are monitored semiannually under orders issued by the San Diego
Regional Water Quality Control Board. Groundwater flow at both landfills is generally to the south-southwest away
from the project site, and there are no indications of groundwater impacts beneath the site attributable to the two
adjoining landfills. The Class III landfill is equipped with a landfill gas control system (LFGCS) and a perimeter probe
monitoring network which is routinely monitored under the direction of the County of San Diego Local Enforcement
Agency. Methane has not been detected above 1% by volume at the perimeter probes closest to the project site.
Hazardous Risk
A Phase I ESA was prepared for the project site in January 2020, which revealed no evidence of recognized
environmental conditions (RECs) in connection with the project site. However, historical investigations performed
in the 1990s to assess potential impacts to the project site from the adjoining landfill properties identified
subsurface methane which had migrated beneath the project site from the Class III landfill adjacent to the project
site. Methane concentration was reported to be up to 3,300 parts per million (ppm), which is more than an order
of magnitude lower than the lower explosive limit (LEL) of methane (50,000 ppm, or 5% by volume). As required by
California Code of Regulations Title 27, the landfill owner is required to install and operate an LFGCS and install
and monitor a network of perimeter monitoring probes. Operation of the LFGCS at the Class III landfill is ongoing
and methane has not been detected above 1% by volume at perimeter probes closest to the project site. Therefore,
the engineering controls on the adjoining Class III landfill appear to be effectively controlling subsurface methane
migration from the landfill to the project site (refer to Appendix H1).
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The absence of recent soil vapor data for the project site was noted as a data gap in the Phase I ESA (Appendix H1). Available
data for the Class III landfill perimeter monitoring network indicates that gas concentrations at the landfill boundary
adjoining the project site are below regulatory thresholds, and historical data collected at the site in the 1990s indicated
that the methane LEL in the subsurface was not exceeded. However, recent data regarding the potential presence of volatile
organic compounds (VOCs; e.g., benzene, tetrachloroethene, trichloroethene) commonly associated with landfill gas are not
available to evaluate potential vapor intrusion concerns for future structures planned for construction at the site. Therefore,
a Soil Vapor Investigation Memo (referred to as Appendix H2 in this EIR) was prepared separately from the Phase I ESA to
address this data gap by conducting a soil vapor survey at the project site to evaluate current on-site subsurface soil vapor
conditions and potential subsurface impacts attributable to the adjoining Otay Class III landfill.
Additionally, the conditions identified on the project site included debris and several pieces of discarded furniture,
including a couch and a mattress (refer to Appendix H1). However, these environmental conditions do not present
a threat to human health or the environment and would not be subject to an enforcement action if brought to the
attention of the appropriate governmental agencies.
Wildfire Risk
The project site is within a wildland–urban interface location that is in an area statutorily designated a Local
Responsibility Area Non-FHSZ by the City and CAL FIRE. The project site is within a Supplemental Fire Hazard Zone
as designated by the City. As seen in Figure 9-9, Wildland Fire Hazards Map, of the General Plan, the project site is
designated as a High Hazard area (City of Chula Vista 2005).
As discussed in the Fire Protection Plan (FPP) prepared for the project, the project site has been subject to one
wildfire during the recorded fire history period. The Maxwell Fire in 1984 burned along the southern portion of the
project site. In addition to the one fire burning on the project site, the majority of other large wildfires historically
start east of the proposed project site area and are typically contained east of Lower Otay Lake.
The lack of recent fire history does not indicate that a fire cannot occur in the vegetation that would be adjacent to
the proposed site. It is expected that fires have not consistently spread into the proposed project site area due to
three factors: the position of the surrounding urban developments which are newer, ignition resistant construction;
the position of lower Otay Lake to the east, presenting a very wide firebreak; and the effective wildland fire fighting
capabilities of the Chula Vista Fire Department (CVFD). Refer to Appendix H3 for more details.
Airports
The nearest airport to the project site is the Brown Field Municipal Airport, which is located approximately 2.6 miles south
of the project site. A portion of the project site is located in the Brown Field Airport Influence Area, Review Area 2, but the
entire project site is located outside of safety and noise zones for Brown Field Airport (SDCRAA 2010). The entire project
site is also located within the FAA Height Notification Boundary. The project applicant would be required to notify the FAA
of the proposed project. However, no conflicts with the Brown Field ALUCP would occur.
5.8.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to hazards and hazardous materials is based on the
recommendations provided in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). A significant impact
would occur if the project would:
A. Create a significant hazard to the public or environment through the routine transport, use or disposal of
hazardous materials.
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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 that is included on a list of hazardous materials sites compiled pursuant to Government
Code Section 65962.5 and, as a result, a significant hazard to the public or the environment is created.
E. Be 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 and would result in a safety hazard or excessive noise for people
residing or working in the project area.
F. Impair implementation of or physically interferes 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.
5.8.3 Impacts
A. Create a significant hazard to the public or environment through the routine transport, use or disposal of
hazardous materials.
Construction Impacts
Construction of the proposed project would involve the transport of commonly used hazardous substances, such
as gasoline, diesel fuel, lubricating oil, grease, and solvents. All such uses of these substances would be subject to
applicable and required regulatory controls as described above under Regulatory Framework. Specifically, this
would include conformance with applicable federal, state, and local standards related to hazardous materials and
wastes, such as controls on use, handling, storage, transportation, and disposal.
Consequently, use of these materials for their intended purpose would not pose a significant risk to the public or
environment. Per regulatory ordinances adopted in the City of Chula Vista Municipal Code (CVMC) Chapter 8.34,
persons handling hazardous materials shall disclose such information to the department of health services of the
county in a manner required by the department. Additionally, a second ordinance would establish a permit system,
using the fees generally therefrom to carry out an enforcement and surveillance program (CVMC 2020a).
Furthermore, construction is temporary and use of these materials would cease upon completion. Therefore,
impacts would be less than significant impact.
Operational Impacts
Once project construction is complete, the transport, use, or disposal of hazardous materials would be limited to
consumer products such as household cleaning products, landscaping chemicals and fertilizers, and other substances
associated with household and recreation (community purpose facility) uses. As mentioned in the General Plan,
household hazardous waste generated by the City residents cannot be disposed of at the local and regional landfills
serving the City and is therefore handled separately from non-hazardous solid waste. As such, the City’s Household
Hazardous Waste Program, initiated in 1997, includes a temporary storage facility to accommodate waste from the
South Bay area, including areas outside the City limits. Although the proposed project would result in the increase in
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routine transport, use and disposal of hazardous materials and/or wastes generated by future growth, all hazardous
materials would be transported and handled in accordance with all federal, state, and local laws regulating the
management and use of hazardous materials. Therefore, impacts would be less than significant.
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.
Construction Impacts
As discussed under Threshold A, construction of the proposed project would involve the transport of commonly
used hazardous substances, such as gasoline, diesel fuel, lubricating oil, grease, and solvents. As stated in the
Phase I ESA, the project site has been historically vacant as early as 1943 (Appendix H1). Though there have been
historic agriculture operations in the surrounding area, the Phase I ESA does not identify any potential issues
resulting from hazardous materials associated with such uses . Additionally, properties within the vicinity of the
project site have been historically used for bentonite (clay) mining, landfilling, and other uses such as industrial,
commercial, and residential (Refer to Appendix H1). As discussed in the Phase I ESA, soils on the project may
contain potentially harmful levels of fixed gases or volatile organic compounds (VOCs; e.g., benzene,
tetrachloroethene, trichloroethene) that could be exposed during construction activities.
As described in Section 5.8.1.5, Existing Setting, recent data regarding the potential presence of VOCs is not
available to evaluate potential vapor intrusion concerns for future structures planned for construction at the site.
At worst, vapor intrusion can present a safety hazard when flammables are involved and result in an explosion.
Therefore, a Soil Vapor Investigation Memo (Appendix H2) was prepared to address this data gap by conducting a
soil vapor survey at the project site to evaluate current on-site subsurface soil vapor conditions and potential
subsurface impacts attributable to the adjoining Otay Class III landfill. To determine the level of existing soil vapor,
five soil vapor probes (SVPs) were constructed near the perimeter of the project site, where the project site adjoins
the Otay Landfill. The SVPs were sampled on January 27, 2020 and sent for laboratory testing to be analyzed for
fixed gases (methane, carbon dioxide, nitrogen, etc.) and VOCs. The Soil Vapor Investigation Memo found that
methane was not detected in the soil samples, indicating that the LFGCS is effectively controlling the migration of
methane from the adjoining Class III landfill.
Low-level concentrations of VOCs were detected from the soil samples, including four analytes (benzene,
bromodichloromethane, chloroform, and vinyl chloride) detected in one or more samples at concentrations above
their respective Tier 1 environmental screening levels or EPA regional screening levels for a residential site scenario.
However, none of these analyte concentrations exceeded calculated DTSC screening levels for future residential
construction. Therefore, with the understanding that the adjoining Class III landfill owner/operator will continue to
operate the LFGCS in accordance with Title 27 requirements, future earth -moving activities in preparation for site
development and construction would likely result in dissipation of residual VOC concentrations in shallow soil vapor,
and future structures would be constructed using modern building practices with competent concrete slabs.
Furthermore, as discussed under Threshold A, construction materials would be used and stored in designated
construction staging areas within the project site boundaries and materials would be transported and handled in
accordance with all federal, state, and local laws regulating the management and use. Therefore, impacts
associated with reasonably foreseeable upset and accident conditions involving the release of hazardous materials
into the environment during construction of the project would be less than significant.
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Operational Impacts
As discussed under Threshold A, once project construction is complete, the transport, use, or disposal of hazardous
materials would be limited to consumer products such as household cleaning products, landscaping chemicals and
fertilizers, and other substances associated with household and recreation (community purpose facility) uses. As
previously discussed, a soil vapor survey (Refer to Appendix H2, Soil Vapor Investigation Memo) was conducted to
evaluate current on-site subsurface soil vapor conditions and potential subsurface impacts attributable to the
adjoining Otay Class III landfill. The Soil Vapor Investigation Memo found that methane was not detected in the soil
samples, indicating that the LFGCS, owned and operated by the Otay Landfill owner/operator, is effectively
controlling the migration of methane from the adjoining Class III landfill. While low-level concentrations of VOCs
were detected in soil vapor samples collected at the site, concentrations would not exceed calculated DTSC
screening levels for future residential construction. Furthermore, it is anticipated that the Otay Landfill will cease
operation in 2030 (CalRecycle 2020). Thus, there is no apparent unacceptable risk to future residential site
occupants due to methane and/or VOC impacted soil vapor during operations.
Furthermore, as discussed under Threshold A, all hazardous materials would be transported and handled in
accordance with all federal, state, and local laws regulating the management and use of hazardous materials.
Therefore, impacts associated with reasonably foreseeable upset and accident conditions involving the release of
hazardous materials into the environment during operation of the project would be less than significant.
C. Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within
one-quarter mile of an existing or proposed school.
The only existing school located within one-quarter mile of the site is Valle Lindo Elementary School, located
approximately 0.25 miles west of the project site. Other existing schools near the project site include Hedenkamp
Elementary School, located approximately 0.38 miles north of the project site; Saburo Muraoka Elementary School,
located approximately 0.39 miles east of the project site; Parkview Elementary School, located approximately 0.45
miles north of the project site; Otay Ranch High School, located approximately 0.6 miles east of the project site;
Palomar Elementary School, located approximately 1 mile west of the project site; and Fred H Rohr Elementary
School, located approximately 0.9 miles west of the project site.
As discussed under Threshold A, construction materials would be used and stored in designated construction
staging areas within the project site boundaries and materia ls would be transported and handled in accordance
with all federal, state, and local laws regulating the management and use. Additionally, all hazardous materials
used during operation of the project would be transported and handled in accordance with all federal, state, and
local laws regulating the management and use of hazardous materials. Furthermore, the findings from the Soil
Vapor Investigation Memo determined that methane was not detected in the soil samples, indicating that the
LFGCS, owned and operated by the Otay Landfill owner/operator, is effectively controlling the migration of methane
from the adjoining Class III landfill. While low-level concentrations of VOCs were detected in soil vapor samples
collected at the site, concentrations would not exceed calculated DTSC screening levels for future residential
construction. Furthermore, it is anticipated that the Otay Landfill will cease operation in 2030 (CalRecycle 2020).
As such, the use of hazardous materials during construction and operation of the proposed project as well as the
presence of potential vapor intrusion would not result in a significant hazardous risk to the project site or surrounding
area. Therefore, impacts to schools within one-quarter mile of the project site would be less than significant.
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D. Be located on a site that is included on a list of hazardous materials sites compiled pursuant to Government
Code Section 65962.5 and, as a result, a significant hazard to the public or the environment is created.
As outlined in Section 5.8.1.2, Regulatory Databases, a database search report was obtained from EDR. The report
documents findings of various federal, state, and local regulatory database searches regarding properties with
known or suspected releases of hazardous materials or petroleum hydrocarbons. The results of the search found
that the project site was not identified by EDR on any government list of hazardous materials; however, several
adjoining and nearby properties were identified by EDR and are included in Table 5.8-1. Representatives from
RWQCB and DTSC were contacted to confirm whether hazardous materials sites identified through the EnviroStor
or GeoTracker databases were present within the project site. It was confirmed through RWQCB and DTSC that no
sites listed within either database were recorded on the project site. However, a document reporting the closure of
a listed facility adjacent to the project site was identified in the EnviroStor database. The listed facility, Appropriate
Technologies II, was closed in accordance with an approved closure plan on October 29, 1998. The facility included
a tank farm and chemical mixing plant to treat liquid waste prior to disposal at the landfill. However, disposal did
not occur at the facility and based on the ongoing monitor of the surrounding Class I landfill, it is unlikely the facility
has adversely impacted the project site.
Additionally, the RWQCB’s GeoTracker Database identified four listed sites within the vicinity of the project site. The
sites are listed in the following paragraphs.
Otay Class I Landfill: This site is located adjacent to the project site. This closed landfill accepted
hazardous waste from 1963 to 1980. This landfill does not have a liner and therefore has no leachate collection
system. A groundwater monitoring network exists at the landfill and is monitored on a semiannua l basis. Based on
the results of groundwater monitoring at the facility, no VOCs were detected in the monitoring wells closest to the
project site at this facility. Additionally, groundwater within this facility flows away from the project site; thus, it is
not likely that this facility has adversely impacted the project site. Methane monitoring is discussed under the Otay
Annex Sanitary Landfill which is another listed facility located adjacent to the Otay Class I Landfill.
Otay Annex Sanitary Landfill (Class III): This site is located adjacent to the Class I Landfill and adjoining the project site to
the southwest. The Class III landfill detached from the Class I unit in 1997 and is now operated by San Diego Landfill
Systems. The most recent semiannual groundwater monitoring report, dated October 2019, indicated that VOCs were
detected in monitoring wells in the southern portion of the project site, and no VOCs were detected in the monitoring
wells closest to the project site. VOCs were detected in wells down gradient of a subsurface slurry wall and the extraction
wells that remove groundwater and pump it to a tank used for dust control as part of the corrective action program.
Groundwater flow depicted in the October report indicates that groundwater in the Class III landfill is to the west in the
eastern portion of the landfill and to the northwest in the western portion of the landfill, both toward the project site. The
lack of detections of VOCs in the down gradient wells closest to the project site indicate impacts have not migrated onto
the project site within the intermediate aquifer, and detections at the Class I landfill in the perched zone in the
southeastern corner of the Class I landfill indicate VOCs are most likely confined to the southern portions of each landfill.
In addition to the groundwater monitoring network and corrective action program, an LFGCS also operates at the Class
III landfill, and the landfill is monitored by a network of perimeter probes. Review of several methane monitoring reports
indicate methane has not been detected in the perimeter probes closest to the project site, indicating the LFGCS is
effectively controlling landfill gas migration from the landfill.
Ecology Auto Parts (825 Energy Way): This site is located approximately 0-5-mile south of the project site. Two
closed leaking underground storage tank (LUST) sites are mapped at this location; one LUST received NFA from the
RWQCB in July 2019 and no information is provided about the second LUST with the exception of a monitoring
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report from 2006; it is suggested these were part of the same investigation. Based on the closure of the cases at
this facility, the distance from the project site of 0.5 mile, and orientation hydraulically down gradient to the project
site, it is not likely that this facility has adversely impacted the project site.
Former Omar Rendering Facility: Refer to Table 5.8-1 in Section 5.8.1.2.
As described above, the proposed project is not located on a site included in the Cortese List, or pursuant to
Government Code Section 65962.5. Although some facilities located near the project site have been previously
included in government databases related to hazardous materials, as discussed above, these facilities would not
have adverse impacts on the project (for further information regarding databases refer to Appendix H1). Therefore,
impacts associated with the project being located on a list of hazardous materials sites compiled pursuant to
Government Code Section 65962.5 would be less than significant.
E. Be 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 and would result in a safety hazard or excessive noise for people residing or
working in the project area.
As described in Section 5.8.1.5, the nearest airport to the project site is the Brown Field Municipal Airport, which is
located approximately 2.6 miles south of the project site. A portion of the project site is located in the Brown Field
Airport Influence Area, Review Area 2, but the entire project site is located outside of safety and noise zones for
Brown Field Airport. The entire project site is also located within the FAA Height Notification Boundary. The project
applicant would be required to notify the FAA of the proposed project. However, no conflicts with the Brown Field
ALUCP would occur. Therefore, impacts would be less than significant.
F. Impair implementation of or physically interferes with an adopted emergency response plan or emergency
evacuation plan.
The proposed project may result in a temporary increase in traffic on roadways surrounding the project site due to
increased truck loads or the transport of construction equipment to and from the project site during the construction
period. All construction activities including staging would occur in accordance with City requirements (such as CVMC
Chapter 12.12, which prohibits street obstructions), which would ensure that adequate emergency access would
be provided during construction of the project (CVMC 2020b). Additionally, the proposed project is incorporated
into the City’s existing emergency disaster programs, including all fire and emergency services and mutual aid
agreements. Emergency response to the project site would be serviced by the City of Chula Vista Fire Department,
Police Department, and other responsible agencies. Furthermore, the City is part of the San Diego County
Emergency Operations Plan, which includes a detailed evacuation response plan in the event of an emergency. As
stated in the Emergency Operations Plan, major ground transportation corridors shall be used as primary
evacuation routes in the event of an emergency. As such, Olympic Parkway would be the closest evacuation route
to the project site. As previously stated, all construction activities including staging would occur in accordance with
City requirements, which would ensure that adequate emergency access would be provided during construction of
the project. Thus, construction of the proposed project is not anticipated to interfere with an adopted emergency
response plan or evacuation plan, nor would it substantially impede public access or roadway circulation.
Direct access to the project site would be provided by two proposed public streets, Street ‘A’ and Street ‘B’ (Streets A and
B). Street A would extend south from Olympic Parkway, through the project site, and curve to the east to connect with
Street B. Street B would also extend south from the eastern portion of Olympic Parkway, adjacent to the project site (see
Figure 4-6, Illustrative Concept Plan, and Figure 4-9, Vehicular Circulation Plan). The proposed driveways and roadways
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providing access to the project site would comply with the requirements of the Chula Vista Fire Code (including 2019 Fire
Code and 2018 Urban–Wildland Interface Code), and would be reviewed and approved by Chula Vista Fire Department
(CVFD). Additionally, all on-site roads would be constructed to current Fire Codes and City of Chula Vista Standards for
public and private roads, including minimum 24-foot-wide unobstructed road widths.
Therefore, the proposed project would not interfere with an adopted emergency response or emergency evacuation
plan during construction or operation activities; impacts would be less than significant.
G. Expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving
wildland fires.
As discussed in Chapter 5.17, Wildfire, of this EIR, the project could result in an impact related to exacerbating
wildfire risk that exposes project occupants to pollutant concentrations from a wildfire or the uncontrollable spread
of a wildfire if it would increase the risk of a wildfire occurring and the climatic, topographic, vegetation, weather
conditions, and other factors that aid in increasing the severity of such an occurrence. The project site is within a
wildland–urban interface location that is in an area statutorily designated a Local Responsibility Area Non-FHSZ by
the City and CAL FIRE. The project site is within a Supplemental Fire Hazard Zone as designated by the City . As seen
in Figure 9-9, Wildland Fire Hazards Map, of the General Plan, the project site is designated as a High Hazard area
(City of Chula Vista 2005).
Construction
Construction of the project would introduce potential ignition sources to the project site, including the use of heavy
machinery and the potential for sparks during welding activities or other hot work. However, the project would be
required to comply with City and state requirements for activities in hazardous fire areas, including fire safety
practices, to reduce the possibility of fires during construction activities. As discussed in the FPP prepared for the
project, pre-construction requirements would be adhered to in order to reduce the potential of fire caused by
construction-related activities. These requirements include establishing perimeter fuel modification areas that are
approved by the CVFD prior to combustible materials being brought on site; reducing existing flammable vegetation
by 50% on vacant lots upon commencement of construction; removing dead fuel, ladder fuel (fuel which can spread
fire from ground to trees), and downed fuel; and ensuring that on-site trees/shrubs shall be properly limbed, pruned,
and spaced. While vegetation management would not be required on vacant lots until constriction begins, perimeter
fuel modification zones (FMZs) must be implemented prior to commencement of construction utilizing combustible
materials. In addition, vacant lots adjacent to active construction areas/lots would be required to implement
vegetation management if they are within 50 feet of the active construction area. Prior to issuance of a permit for
any construction, grading, digging, installation of fences, etc., on a vacant lot, the 50 feet at the perimeter of the lot
shall be maintained as a vegetation management zone.
Operational
As mentioned previously, the project site is located in an area statutorily designated as an LRA Non-FHSZ. However,
the project site is within a Supplemental Fire Hazard Zone as designated by the City. The General Plan designates
the project site as a High Hazard area (City of Chula Vista 2005). Thus, the project includes fire resistance-related
measures that shall lessen the potential impact of the project exacerbating wildfire risk.
All new structures within the project site would be in accordance with the enhanced ignition-resistant construction
standards of the 2019 CBC (Chapter 7A) and the Urban–Wildland Interface code Chapter 5, except where buildings
require enhanced ignition resistance as part of an alternative material and method proposal. These re quirements
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address roofs, eaves, exterior walls, vents, appendages, windows, and doors and result in hardened structures that
have been proven to perform at high levels (resist ignition) during the typically short duration of exposure to burning
vegetation from wildfires. Buildings that include higher occupancies shall meet all California Fire and Building
requirements for higher occupancy structures. Included in the high occupancy category are multi-family residences
over three units, attached condominiums, and attached townhomes up to three stories, but less than 30 feet overall
height. In addition, the project would include fire protection systems including fire hydrants, automatic fire sprinkler
system, and fire alarm systems and residential hazard detectors (see Appendix H3 for further details).
Per CVMC Chapter 15.36 , the City shall incorporate vegetation management and clearance standards set by the
California Fire Code (CVMC 2020c). As such, all non-maintained combustible vegetation, and or other such
accumulations of combustible vegetation materials in open space areas, as determined by the Fire Code Official,
shall not be located within one hundred feet of any building or structu re designated or intended for occupancy by
humans or animals. As described in the FPP, FMZs shall be implemented to provide vegetation buffers that
gradually reduce fire intensity and flame lengths from advancing fire by strategically placing thinning zone s,
restricted vegetation zones, and irrigated zones adjacent to each other. FMZs would be located on the perimeter of
all structures and along both ingress/egress roadways to and from Olympic Parkway. Typical fuel modification
includes establishment of a minimum 50-foot-wide irrigated zone (Zone 1) and a 50-foot-wide thinned zone (Zone
2) on the periphery of the project site, beginning from the rear or side yard lot line (For further details regarding
Zone 1 and Zone 2 criteria refer to Appendix H3). As discussed in the FPP, FMZ areas experience a significant reduction
in flame length and intensity. Reduction of flame lengths and intensities are assumed to occur within the full 100 feet of
fuel modification (a combination of Zones 1 and 2). However, due to site constraints, it is not feasible to achieve a 100-
foot FMZ width on the south side of the project site. As such, to potential structure fire exposure related to the
provided FMZs for buildings along the southern edge of the project site would be potentially significant. Mitigation
Measure (MM)-WF-1 would be incorporated, applying only to the walls of the structures that face the open space
areas adjacent to the project site, to ensure impacts would be less than significant.
5.8.4 Level of Significance Prior to Mitigation
Prior to mitigation, the proposed project would have potentially significant impacts associated with wildfire. The
remaining issues addressed in this section would be less than significant.
5.8.5 Mitigation Measures
The following mitigation measure would reduce identified significant impacts associated with wildfire to a less than
significant level.
MM-WF-1 Site Access
Site access, including fire lane, driveway, and entrance road widths, primary and secondary access,
gates, turnarounds, dead end lengths, signage, aerial fire apparatus access, surface, and other
requirements will comply with the requirements of the 2019 California Fire Code and the Chula
Vista Fire Department (CVFD) Standards. Fire access will be reviewed and approved by CVFD prior
to construction (see the FPP, Appendix H3, for additional details).
The developer will provide information illustrating the new roads, in a format acceptable to the City,
for updating of City maps.
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Ignition Resistant Construction
All new structures within the Proposed Project will be constructed to at least the California Fire
Code standard. Each of the proposed buildings will comply with the enhanced ignition -resistant
construction standards of the 2019 CBC (Chapter 7A) and Chapter 5 of the Urban -Wildland
Interface code, except where buildings require enhanced ignition resistance as part of an
alternative material and method p roposal. These requirements address roofs, eaves, exterior
walls, vents, appendages, windows, and doors and result in hardened structures that have
been proven to perform at high levels (resist ignition) during the typically short duration of
exposure to burning vegetation from wildfires (see the FPP, Appendix H3, for additional details).
Fire Protection Systems
1. Water supply requirements specified in the California Fire Code (see FPP, Appendix H3, for
additional details) including for hydrants and interior sprinklers will be provided for the
proposed project.
2. Hydrants shall be located along fire access roadways and cul-de-sacs as determined by the CVFD
Fire Marshal to meet operational needs. Hydrants will be consistent with CVFD Design Standards
and provided every 500 feet (on-center).
3. All structures within the Proposed Project will include interior sprinklers, per code requirements
(see FPP, Appendix H3, for additional details). Sprinklers will be specific to each occupancy
type and based on the most recent National Fire Protection Association (NFPA) 13, 13R, or
13D, requirements.
4. All residential units shall have a fire alarm system be installed in accordance with NFPA 72,
Fire Protection Signaling System and CVFD requirements. The fire alarm system will be
supervised by a third-party alarm company. The system will be tested annually, or as needed,
with test results provided to CVFD.
Additionally, all residences will be equipped with residential smoke detectors and carbon monoxide
detectors and comply with current CBC, CFC, and California Residential Code standards.
All residential dwelling units shall have electric-powered, hard-wired smoke detectors with battery
backup per CVFD.
Defensible Space and Vegetation Management
Fuel Modification Zones (FMZs) would be located on the perimeter of all structures and along both
ingress/egress roadways to and from Olympic Parkway. All brush management zones and related
fuel modification activities shall occur outside of the Preserve. FMZs shall be a minimum of 100
feet in width. A 100-foot-wide FMZ will be installed for lots abutting designated Preserve Lands to
the north and west of the Project Site. To ensure long-term identification and maintenance, each
respective FMZ shall be identified by a permanent marker system meeting the approval of CVFD.
Other Vegetation Management
1. New roads will be subject to fuel modification zones with Zone 1 and/or Zone 2 standards
described above. The combustible vegetation will be modified within 30 feet from each side of
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Streets A and B. Roadway-adjacent fuel modification does not preclude the planting of street trees
in these fuel modification zones, as long as they are not found on the Prohibited Plant List (Appendix
D of the FPP) and are included in the Approved Plant Palette (Appendix C of the FPP).
2. Pre-Construction Requirements:
• Perimeter fuel modification areas must be implemented and approved by the CVFD prior
to combustible materials being brought on site.
• Existing flammable vegetation shall be reduced by 50% on vacant lots upon commencement
of construction.
• Dead fuel, ladder fuel (fuel which can spread fire from ground to trees), and downed fuel shall
be removed, and trees/shrubs shall be properly limbed, pruned, and spaced per this plan.
3. Undesirable Plants. Certain plants are considered to be undesirable in the landscape due to
characteristics that make them highly flammable. These characteristics can be physical
(structure promotes ignition or combustion) or chemical (volatile chemicals increase
flammability or combustion characteristics). The plants included in the Prohibited Plant List
(Appendix D of Appendix H3, FPP) are unacceptable from a fire safety standpoint and will not
be planted on the site or allowed to establish opportunistically within fuel modification zones
or landscaped areas. No fuel modification zones are proposed within the MSCP areas, thus no
vegetation within the MSCP will be removed.
Tree Notes for Publicly Owned Areas.
The project shall maintain all trees in publicly owned areas, per the project's FPP. These
requirements include, but are not limited to (see Appendix H3 for additional details):
• All standard form (single trunk) trees to include a single strong central leader with no branches
extending at an angle narrower than 30 degrees from the main trunk. If the tree does not
display a single strong central leader, a tree may be approved if the Developer’s arborist or
landscape architect of record can demonstrate that a single strong central leader can be
achieved through structural pruning.
• No grafted species that sucker from the base stock will be allowed as a street tree.
Vacant Parcels and Lots
The project shall comply with requirements of the project's FPP related to vacant parcels and lots.
These requirements include, but are not limited to:
• Vegetation management would not be required on vacant lots until construction begins.
However, perimeter FMZs must be implemented prior to commencement of construction
utilizing combustible materials.
• Vacant lots adjacent to active construction areas/lots would be required to implement
vegetation management if they are within 50 feet of the active construction area. Perimeter
areas of the vacant lot would be maintained as a vegetation management zone extending 50
feet from roadways and adjacent construction areas.
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• Prior to issuance of a permit for any construction, grading, digging, installation of fences, etc.,
on a vacant lot, the 50 feet at the perimeter of the lot is to be maintained as a vegetation
management zone.
• FMZ on slope L&I does not have to be completed prior to construction starting, but all
flammable vegetation and plants found on the Prohibited Plant List, needs to grubbed and
graded or mowed prior to any construction.
Fuel Modification Area Vegetation Maintenance
All fuel modification area vegetation management shall be completed annually by May 1 of each
year and more often as needed for fire safety, as determined by the CVFD.
Annual Fuel Modification Area Vegetation Maintenance
The property owner would obtain an FMZ inspection and report from a qualified CVFD-approved
3rd party inspector in May of each year certifying that vegetation management activities throughout
the Project Site have been performed pursuant to this FPP. A copy of the annual inspection report
would be provided to the proposed project homeowner association (HOA) and a copy made
available to CVFD, if requested.
Reduced Fuel Modification Zone Discussion
Due to site constraints, it is not feasible to achieve a 100-foot FMZ width on the south side of the
proposed development. This FPP incorporates additional fire protection measures as described in
this mitigation measure that shall be implemented to compensate for potential fire related threats.
These measures are were customized for this site based on the analysis results and focus on
providing functional equivalency for reduced defensible space.
Landscape and Building Hardening.
1. Provide exterior glazing in windows (and sliding glass doors, garage doors, or decorative or
leaded glass doors) facing the open space areas to be dual pane with both panes tempered
glass, exceeding the fire-building code requirement.
2. Ensure no eave overhangs and combustible construction in portion of yards facing natural open
space areas.
3. Install 1-hour rated walls (Type X- 5/8-inch thickness of gypsum) behind non-combustible covering
(stucco, fiber cement siding) for a façade facing the open space areas to the east and south.
4. Conduct a formal landscaping plan review for structures with a façade facing open space area.
Landscape plans shall be reviewed and approved by the Chula Vista Fire Department.
5. Annually hire a third-party inspector to evaluate whether designated fuel modification zone
areas meet the requirements of the project Fire Protection Plan.
6. Provide a non-combustible fire-rated 6-foot-tall masonry block or view wall at the property line
on the south and east sides of the proposed project to provide a physical, non-combustible
barrier that would deflect heat and flame and would capture ground-blowing embers before
they reached the proposed project’s developed areas.
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The proposed project’s slopes to the south provide an opportunity to place a non-combustible, 6-foot-tall,
heat-deflecting wall (or view wall with lower 1 to 2 feet block wall and upper 4 to 5 feet dual-pane, one
pane tempered glazing) to provide additional deflection for these lots to compensate for the reduced fuel
modification zones. The wall shall meet any of the following specifications:
• Be constructed of multi-pane glazing with a minimum of one tempered pane meeting the
requirements of Section 2406 Safety Glazing, or
• Have a fire-resistance rating of not less than 20 minutes when tested according to NFPA 257, or
• Be tested to meet the performance requirements of SFM Standard 12-7A-2.
Homeowner’s Wildfire Education Program
Per the FPP, the proposed project’s residents shall be provided a proactive educational component
disclosing the potential wildfire risk and this report’s requirements as part of their purchase documents.
Property owners shall be required to sign notice of receiving this information during escrow. This
educational information must include maintaining the landscape and structural components according
to the appropriate standards and embracing a “Ready, Set, Go” stance on evacuation.
5.8.6 Level of Significance After Mitigation
Implementation of MM-WF-1 would reduce potential impacts associated wildfire to a less-than-significant level.
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5.9 Hydrology and Water Quality
This section of the environmental impact report (EIR) describes the hydrologic setting within the proposed Sunbow
Sectional Planning Area (SPA) Plan Amendment for the Sunbow II, Phase 3 Project (project or proposed project)
site, and evaluates the potential for changes in drainage, runoff, and water quality resulting from implementation
of the proposed project. The discussion in this section is based on the Stormwater Quality Management Plan
(SWQMP) and the Drainage Study for the project, which were prepared by Hunsaker and Associates. The complete
reports are provided in Appendices I1 and I2 of this EIR.
5.9.1 Existing Conditions
5.9.1.1 Regulatory Framework
Federal
Clean Water Act
The federal Clean Water Act (CWA) was enacted with the primary purpose of restoring and maintaining the chemical,
physical, and biological integrity of the nation’s navigable waters. The State Water Resources Control Board
(SWRCB) and the Regional Water Quality Control Boards (RWQCBs) are responsible for enforcing water quality
standards within the state. As mandated by Section 303(d) of the CWA, the SWRCB maintains and updates a lis t of
“impaired water bodies” (i.e., water bodies that do not meet state and federal water quality standards). This list is
known as the Section 303(d) list of impaired water bodies. The state is required to prioritize waters/watersheds for
development of total maximum daily load (TMDL) regulations. Section 303(d) of the CWA bridges the technology -
based and water-quality-based approaches for managing water quality and requires each state to make a list of
waters that are not attaining standards after implementation of the technology-based limits. For waters on this list
(and where the U.S. Environmental Protection Agency [EPA] administrator deems it appropriate), the states develop
TMDLs that are established at the level necessary to implement applicable water quality standards. A TMDL must
account for all sources of pollutants that cause the water to be listed. Federal regulations require that TMDLs, at a
minimum, account for contributions from point sources and nonpoint sources. This information is compiled in a list
and submitted to the EPA for review and approval. Section 303(c)(2)(b) of the CWA requires states to update the
TMDLs every 3 years (SWRCB 2019).
Section 319 of the CWA mandates specific actions for the control of pollution from nonpoint sources. The EPA
has delegated responsibility for implementation of portions of the CWA, including water quality control planning
and programs such as the National Pollutant Discharge Elimination System (NPDES) program, to the SWRCB and
the RWQCBs.
National Pollutant Discharge Elimination System Permit
The NPDES permit system was established by the CWA to regulate both point-source discharges and nonpoint-
source discharges. Nonpoint pollution often enters receiving waters in the form of surface runoff and is not
conveyed by way of pipelines or discrete conveyances. Each NPDES permit contains limits on allowable
concentrations and mass emissions of pollutants contained in the discharge. Sections 401 and 402 of the CWA
contain general requirements regarding NPDES permits. Section 307 of the CWA describes the factors that the EPA
must consider in setting effluent limits for priority pollutants.
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A detailed discussion of the NPDES program is provided under the discussion of state regulations in this section,
since the authority to implement the NPDES program has been delegated to the SWRCB and RWQCBs.
Federal Antidegradation Policy
The federal Antidegradation Policy (40 CFR 131.12) requires states to develop statewide antidegradation policies
and identify methods for implementing them. Pursuant to this policy, state antidegradation policies and
implementation methods will, at a minimum, protect and maintain (1) existing in -stream water uses; (2) existing
water quality where the quality of the waters exceeds levels necessary to support existing beneficial uses, unless
the state finds that allowing lower water quality is necessary to accommodate economic and social development in
the area; and (3) water quality in waters considered an outstanding national resource. State permitting actions
must be consistent with the federal Antidegradation Policy.
National and State Safe Drinking Water Acts
The federal Safe Drinking Water Act, established in 1974, is administered by the EPA and sets drinking water
standards throughout the country. The drinking water standards established in the act, as set forth in the Code
of Federal Regulations (CFR), are referred to as the National Primary Drinking Water Regulations (Primary
Standards; 40 CFR 141), and the National Secondary Drinking Water Regulations (Secondary Standards; 40 CFR
143). According to the EPA, the Primary Standards are legally enforceable standards that apply to public water
systems. The Secondary Standards are non -enforceable guidelines regulating contaminants that may cause
cosmetic or aesthetic effects in drinking water. The EPA recommends the Secondary Standards for water systems
but does not require systems to comply. California passed its own Safe Drinking Water Act in 19 86 that authorizes
the state’s Department of Health Services to protect the public from contaminants in drinking water by
establishing maximum contaminant levels (as set forth in the California Code of Regulations (CCR), Title 22,
Division 4, Chapter 15) that are at least as stringent as those developed by the EPA, as required by the federal
Safe Drinking Water Act.
State
Responsibility for the protection of water quality in California rests with the SWRCB and nine RWQCBs. The SWRCB
establishes statewide policies and regulations for the implementation of water quality control programs mandated
by federal and state water quality statutes and regulations. The RWQCBs develop and implement water quality
control plans that consider regional beneficial uses, water quality characteristics, and water quality problems. The
project site is located within the jurisdiction of the San Diego RWQCB.
All projects resulting in discharges, whether to land or water, are subject to Section 13263 of the California Water
Code and are required to obtain approval of waste discharge requirements (WDRs) by the RWQCBs. WDRs related
to land and groundwater (i.e., non-NPDES WDRs) regulate discharges of privately or publicly treated domestic
wastewater and process/wash-down wastewater. WDRs for discharges to surface water also serve as NPDES
permits, which are further described in this section.
Porter-Cologne Water Quality Control Act
The Porter-Cologne Water Quality Control Act authorizes the SWRCB to adopt, review, and revise policies for all
waters of the state (including surface water and groundwater) and directs the RWQCBs to develop regional water
quality control plans. Section 13170 of the California Water Code authorizes the SWRCB to adopt water quality
control plans on its own initiative.
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Waste Discharge Requirements
All dischargers of waste to waters of the state are subject to regulation under the Porter -Cologne Water Quality
Control Act, and the requirements for WDRs are incorporated into the California Water Code. This includes point-
source and nonpoint-source dischargers. All current and proposed nonpoint-source discharges to land must be
regulated under WDRs, waivers of WDRs, a water quality control plan prohibition, or some combination of these
administrative tools. Discharges of waste directly to state waters are subject to an individual or general NPDES
permit, which also serves as WDRs. The RWQCBs have primary responsibility for issuing WDRs to cover a category
of discharges. WDRs may include effluent limitations or other requirements that are designed to implement
applicable water quality control plans, including designated beneficial uses and the water quality objectives
established to protect those uses and prevent the creation of nuisance conditions. Violations of WDRs may be
addressed by issuing Cleanup and Abatement Orders or Cease and Desist Orders, assessing administrative civil
liability, or seeking imposition of judicial civil liability or judicial injunctive relief.
National Pollutant Discharge Elimination System Permits
The NPDES permit system was established by the CWA to regulate both point-source discharges and nonpoint-
source discharges. Nonpoint pollution often enters receiving waters in the form of surface runoff and is not
conveyed by way of pipelines or discrete conveyances. Each NPDES permit contains limits on allowable
concentrations and mass emissions of pollutants contained in the discharge. Sections 401 and 402 of the CWA
contain general requirements regarding NPDES permits. Section 307 of the CWA describes the factors that the EPA
must consider in setting effluent limits for priority pollutants.
A detailed discussion of the NPDES program is provided under the discussion of state regulations in this section,
since the authority to implement the NPDES program has been delegated to the SWRCB and RWQCBs.
Construction General Permit
The SWRCB permits all regulated construction activities under Order No. 2009 -009-DWQ, as amended by 2010-
0014-DWQ and 2012-0006-DWQ. The order requires that, prior to beginning any construction activity, the permit
applicant obtain coverage under the Construction General Permit by preparing and submitting to the SWRCB a
Permit Registration Document that includes a Notice of Intent and appropriate fee. The SWRCB may issue a
Construction General Permit or an Individual Construction Permit that would contain more specific permit
provisions. Individual Construction Permits replace Construction General Permit regulations and provisions, if
issued. Additionally, coverage would not occur until an adequate stormwater pollution prevention plan (SWPPP) has
been prepared. A separate Notice of Intent is submitted to the SWRCB for each construction site.
SWRCB adopted the Construction General Permit on September 2, 2009, and it became effective on July 1, 2011.
In addition, 2010-0014-DWQ was adopted on November 16, 2010, and became effective on February 14, 2011.
The amendment provided text changes to the fact sheet, Conditions for Permit Coverage, Special Provisions,
Electronic Signature, and Certification Requirements of Order No. 2009-009-DWQ. Similarly, 2012-0006-DWQ was
adopted on July 17, 2012. The amendment provided updated text changes to the Fact Sheet, primarily with respect
to replacing numeric effluent limitations with narrative effluent limitations for Risk Level 3 and Linear
Underground/Overhead Project Type 3 construction sites (with the exception of Active Treatment Systems).
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Construction activities subject to the NPDES Construction General Permit include clearing, grading, and
disturbances to the ground (e.g., stockpiling or excavating), which result in soil disturbances of at least 1 acre of
total land area. Because construction of the project would cumulatively disturb more than 1 acre, all improvements
and development activities would be subject to these permit requirements, and the project would be required to
prepare a SWPPP. The SWPPP has two main objectives: to help identify the sources of sediment and other pollutants
that affect the quality of stormwater discharges, and to describe and ensure the implementation of best
management practices (BMPs) to reduce or eliminate sediment and other pollutants in stormwater and non -
stormwater discharges.
Sustainable Groundwater Management Act
On September 16, 2014, Governor Jerry Brown signed into law a three-bill legislative package—Assembly Bill 1739
(Dickinson), Senate Bill 1168 (Pavley), and Senate Bill 1319 (Pavley)—collectively known as the Sustainable
Groundwater Management Act (SGMA). SGMA requires governments and water agencies of high- and medium-priority
basins to halt overdraft and bring groundwater basins into balanced levels of pumping and recharge. Under SGMA,
these basins should reach sustainability within 20 years of implementing their sustainability plans. For critically
overdrafted basins, sustainability should be achieved by 2040. For the remaining high- and medium-priority basins,
2042 is the deadline. Through SGMA, the California Department of Water Resources provides ongoing support to local
agencies through guidance, financial assistance, and technical assistance. SGMA empowers local agencies to form
Groundwater Sustainability Agencies to manage basins sustainably and requires those Groundwater Sustainability
Agencies to adopt Groundwater Sustainability Plans for crucial groundwater basins in California.
California Water Code, Section 12924
The California Department of Water Resources, in conjunction with other public agencies, conducts investigations
of the state’s groundwater basins. The Department of Water Resources identifies the state’s groundwater basins
on the basis of geological and hydrologic conditions and with consideration of political boundary lines whenever
practical. The Department of Water Resources also investigates existing general patterns of groun dwater extraction
and groundwater recharge within those basins to the extent necessary to identify basins that are subject to critical
conditions of overdraft (DWR 2016).
Local
San Diego Basin Plan
The Water Quality Control Plan for the San Diego Basin (Basin Plan) is designed to preserve and enhance water
quality and protect the beneficial uses of all regional waters. Specifically, the Basin Plan: (1) designates beneficial
uses for surface and ground waters; (2) sets narrative and numerical objectives that must be attained or maintained
to protect the designated beneficial uses and conform to the state's antidegradation policy; (3) describes
implementation programs to protect the beneficial uses of all waters in the Region; and (4) descri bes surveillance
and monitoring activities to evaluate the effectiveness of the Basin Plan (California Water Code Sections 13240–
13244 and Section 13050[j]) (SDRWQCB 2018).
Chula Vista BMP Design Manual
In May 2013, the California Regional Water Quality Control Board for the San Diego Region reissued a municipal
stormwater NPDES permit (Municipal Separate Storm Sewer Systems [MS4] Permit; SDRWQCB 2013) that covered
its region. The San Diego Region is composed of San Diego, Orange, and Riverside County Copermittees. The MS4
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Permit reissuance to the San Diego County Copermittees went into effect in 2013 (Order No. R9 - 2013-0001 and
as amended by Order Nos. R9-2015-0001 and R9-2015-0100) (City of Chula Vista 2015).
The reissued MS4 Permit updates and expands storm water requirements for new developments and
redevelopments. In February 2015, the MS4 Permit was amended by Order R9-2015-0001, and again in November
2015 by Order R9-2015-0100. As required by the reissued MS4 Permit, the Copermittees have prepared the Model
Best Management Practices (BMP) Design Manual to replace the current Countywide Model Standard Urban
Stormwater Mitigation Plan (SUSMP), dated March 25, 2011, which was based on the requirements of the 2007
MS4 Permit (City of Chula Vista 2015).
The BMP Design Manual addresses updated on-site post-construction stormwater requirements for Standard Projects
and Priority Development Projects (PDPs), and provides updated procedures for planning, preliminary design,
selection, and design of permanent storm water BMPs based on the performance standards presented in the MS4
Permit (City of Chula Vista 2015).
Chula Vista Municipal Code Section 14.20, Storm Water Management and Discharge Control
The purpose of this ordinance is to promote the health, safety, and general welfare of the citizens of Chula Vista by
prohibiting non-stormwater discharges to the stormwater conveyance system, preventing discharges to the
stormwater conveyance system from disposal of materials other than stormwater, reducing pollutants in
stormwater discharges to the maximum extent practicable, and reducing pollutants in stormwater discharges to
achieve applicable water quality objectives for surface waters in San Diego County (Chula Vista Municipal Code
Section 14.20, Storm Water Management and Discharge Control). This ordinance states that it is unlawful for any
person to cause either individually or jointly, any discharge into or from the stormwater conveyance system that
results in or contributes to a violation of any NPDES permit. Any person engaged in activities that may result in
pollutants entering the stormwater conveyance system shall, to the maximum extent practical, undertake all
measures to reduce the risk of illegal discharges. The following requirements apply (CVMC Section 14.20):
• Best Management Practices Implementation. It is unlawful for any person not to comply with the BMPs and
pollution control requirements established by the city or other responsible agency to eliminate or reduce
pollutants entering the City stormwater conveyance system. BMPs shall be complied with throughout the
life of the activity.
• Stormwater Pollution Prevention Plan. When the enforcement official determines that a business or
business-related activity causes or may cause an illegal discharge to the stormwater conveyance system
then the enforcement official may require the business to develop and implement a SWPPP. Businesses
which may be required to prepare and implement a SWPPP include, but are not limited to, those which
perform maintenance, storage, manufacturing, assembly, equipment operations, vehicle loading and/or
cleanup activities partially or wholly out of doors.
• Coordination with Hazardous Materials Response Plans and Inventory. Any activity subject to the hazardous
materials inventory and response program, pursuant to Chapter 6.95 of the California Health and Safety
Code, shall include provisions for compliance with this chapter in its hazardous materials response plan,
including prohibitions of unlawful non-stormwater discharges and illegal discharges and provisions
requiring the use of BMPs to reduce the discharge of pollutants in stormwater.
• Impervious Surfaces. Persons owning or operating a parking lot or an impervious surface (including, but
not limited to, service station pavements or paved private streets and roads) used for automobile-related
or similar purposes shall clean those surfaces as frequently and as thoroughly as is necessary, in
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accordance with BMPs, to prevent the discharge of pollutants to the city stormwater conveyance system.
Sweepings or cleaning residue from parking lots or impervious surfaces shall not be swept or otherwise
made or allowed to go into any stormwater conveyance, gutter or roadway, but must be disposed of in
accordance with regional solid waste procedures and practices.
• Compliance with NPDES Permit for Storm Water Discharges. Each discharger subject to any NPDES permit
for stormwater discharges shall comply with all requirements of such permit.
The BMP Design Manual is incorporated into this ordinance by reference. The ordinance states that no landowner
or development project proponent in Chula Vista shall receive any City permit or approval for land development
activity or significant redevelopment activity unless the project meets or would me et the requirements of the
Development Storm Water Manual (CVMC Section 14.20).
City of Chula Vista General Plan
The Public Facilities and Services and Environmental Elements of the City of Chula Vista General Plan address
reliable drainage facilities and the protection of water quality. The Public Facilities and Services Element includes
objectives to increase efficiencies in handling stormwater runoff through use of alternative technologies (Objective
PFS 2). Objective E 2 in the Environmental Element is to protect and improve water quality within surface water
bodies and groundwater resources within and downstream of Chula Vista (City of Chula Vista 2005).
Zoning Code and Growth Management Ordinance
In accordance with Chula Vista Municipal Code Section 19.80.030, development is not permitted in the City of
Chula Vista that would degrade stormwater collection systems below acceptable standards. Similarly, Section
19.09, Growth Management, provides policies and programs that tie the pace of development to the provision of
public facilities and improvements. Section 19.09(F) specifically requires that (1) stormwater flows and volumes
shall not exceed City engineering standards as set forth in the subdivision manual and (2) the Growth Management
Oversight Commission shall annually review the performance of the City’s storm drain system to determine its ability
to meet the goals and objectives for drainage. Section 19.09 also requires a Public Facilities Financing Plan (PFFP)
and the demonstration that public services, such as police services, meet the Growth Management Oversight
Commission quality of life threshold standards. The analysis of storm drain systems provided in this section, along
with the PFFP to ensure funding for any needed expansion of services, would ensure that storm drain systems are
provided commensurate with development and demand.
5.9.1.2 Existing Setting
Under existing conditions, the project site is undeveloped and consists of natural grades and hills covered by native
vegetation and shrubs. The highest point of the project site is located on the southern boundary adjacent to the
Otay Landfill and makes the overall on-site surface flow pattern run from south to north. The Poggi Canyon Creek is
located downstream of the project site to the north and receives storm runoff from the surrounding area including
the project site.
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5.9.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to hydrology and water quality is based on the
recommendations provided in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). A significant impact
would occur if the project would:
A. Violate any water quality standards or waste discharge requirements, or otherwise substantially degrade
surface or ground water quality.
B. Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that
the project may impeded 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 though the addition of impervious surfaces, in a manner, which would result in
i. substantial erosion or siltation on- or off-site;
ii. Substantially increase the rate or amount of surface runoff in a manner which would result in flooding
on- or off-site;
iii. Create or contribute runoff water which would exceed the capacity of existing or planned stormwater
drainage systems or provide substantial additional sources of polluted runoff; or
iv. Impede or redirect flood flows.
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.
5.9.3 Impacts
A. Violate any water quality standards or waste discharge requirements, or otherwise substantially degrade
surface or ground water quality.
Construction activities associated with the proposed project could result in wind and water erosion of the disturbed
area leading to sediment discharges. Additionally, construction would involve the use of oil, lubricants, and other
chemicals that could be discharged from leaks or accidental spills. These potential sediment and chemical
discharges during construction would have the potential to impact water quality in receiving water bodies.
Construction of the project would result in more than 1 acre of land disturbance; therefore, the project would be
required to prepare and implement a SWPPP in accordance with the Statewide Construction General Permit. This
requires implementation of construction BMPs such as silt fences, inlet protection, and site stabilization techniques
to ensure that stormwater runoff from the construction work areas does not cause degradation of water quality in
receiving water bodies.
During operation, the project would introduce a 67.5-acre development area consisting of 44.2 acres of residential
uses, a 0.9-acre Community Purpose Facility (CPF), 5.9 acres of public streets, and 16.5 acres of manufactured
slopes and drainage basins, resulting in more impervious area to the site. The increase in impervious area would
result in reduced percolation and groundwater recharge as well as more surface runoff. An increase in surface
runoff would increase the potential for violation of water quality standards or waste discharge requirements. As
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discussed in Section 5.9.1, Existing Conditions, the project is located within the San Diego RWQCB jurisdiction that
oversees water quality in the San Diego region. The RWQCB has adopted the Water Quality Control Plan (WQCP) for
the San Diego Basin Plan that designates beneficial uses of the region’s surface water and groundwater, identifies
water quality objectives for the reasonable protection of those uses, and establishes an implementation plan to
achieve the objectives. The RWQCB also regulates discharges from municipal separate storm sewer systems in the
San Diego region under an NPDES MS4 Permit, which expired on June 27, 2018, but remains in effect under an
administrative extension until it is reissued by the RWQCB. The permit requires the development and
implementation of BMPs in planning and con struction of private and public development projects. Development
projects are also required to include BMPs to reduce pollutant discharges from the project site in the permanent
design. As discussed in the SWQMP prepared for the project, the project would incorporate source control and site
design BMPs to reduce water quality impacts (Appendix I1). Source control BMPs include prevention of illicit
discharges into the MS4; storm drain stenciling or signage; protecting trash storage areas from rainfall, run -on,
runoff, and wind dispersal; on-site storm drain inlets; interior floor drains and sump pumps; interior parking garages;
refuse area; and other miscellaneous drains. Site design BMPs include conserving natural areas, soils, and
vegetation; minimizing impervious areas; minimizing soil compaction; runoff collection; and landscaping with native
or drought-tolerant species. The structural BMPs would involve the installation of two biofiltration basins.
Biofiltration basin 1 would be located in the northeastern area of the project site and biofiltration basin 2 would be
located in the northwestern area of the project site. Both biofiltration basins would work for combined pollutant
control by collecting and treating runoff through a pre-treatment and biofiltration chamber filtering system.
Additionally, the structural BMPs would include three compact proprietary (CP) biofiltration units (i.e. Modular
Wetland Unit). These CP biofiltration units would be located along the proposed streets that would connect to
Olympic Parkway, one on the proposed street to the west and two on the proposed street to the east. These CP
biofiltration units would provide additional aide in pollutant control for the project site.
Therefore, with implementation of the SWPPP and SWQMP, impacts to water quality or waste discharge
requirements would be less than significant.
B. Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the
project may impeded sustainable groundwater management of the basin.
As stated in the Geotechnical Investigation Report (Appendix G to this EIR), it is expected that groundwater is
approximately 20 feet or greater below the existing grade. While the project would introduce new impervious area
by developing approximately 67.5 acres of land on a 135.7-acre site, approximately 50% of the project would be
open space and remain undeveloped. Thus, the undeveloped portion of the project site would allow for potential
groundwater recharge and infiltration. While the development area of the project would result in more impervious
area and reduce percolation and groundwater recharge, the general drainage pattern of the site that ultimately
flows into the Poggi Canyon Creek would remain the same (Appendix I2). Further, the proposed project would not
use groundwater during construction and would not have components that would withdraw groundwater during
operation. The Otay Water District (OWD) would serve the project’s water needs. The OWD is one of 23 member
water agencies and districts that make up the San Diego County California Water Authority (CWA). The CWA generally
imports 75% to 95% of its water from the Metropolitan Water District of Southern California. Water imported to the
region comes from two primary sources: the Colorado River, through the Colorado River Aqueduct; and the State
Water Project from Northern California, through the Sacramento–San Joaquin River Delta and the California
Aqueduct. As such, the proposed project would not rely on groundwater supplies.
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Therefore, because the project would not withdraw groundwater during construction or operation activities, the
majority of the project site would remain undeveloped, and the general drainage pattern would remain the same,
impacts associated with depletion of groundwater supplies would be less than significant.
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 though the addition of impervious surfaces, in a manner, which would result in
i. Substantial erosion or siltation on- or off-site.
Project construction would involve earth-disturbing activities, including grading, that could expose on-site soils to
erosion and surface water runoff. Additionally, construction would involve the use of oil, lubricants, and other
chemicals that could be discharged from leaks or accidental spills. These potential sediment and chemical
discharges during construction would have the potential to impact water quality in receiving water bodies such as
the Poggi Canyon Creek. Construction of the project would result in more than 1 acre of land disturbance;
therefore, the project would be required to prepare and implement a SWPPP in accordance with the Statewide
Construction General Permit. This requires implementation of BMPs to ensure that water quality standards are
met and that stormwater runoff from the construction work areas does not cause degradation of water quality in
receiving water bodies. Specific BMPs that address erosion impacts include erosion control blankets, watering of
site, and sediment filters.
During operation, the project would introduce 67.5-acre development area composed of 44.2 acres of residential
uses, a 0.9-acre Community Purpose Facility (CPF), 5.9 acres of public streets, and 16.5 acres of manufactured
slopes and drainage basins. As such, the proposed area to be developed would be graded and paved, greatly
reducing the possibility for soil erosion and siltation compared to current conditions. However, introducing more
impervious area would result in more surface runoff, which could lead to more soil erosion and siltation. As such,
a SWQMP has been prepared for the project. The SWQMP has been prepared consistent with the requirements
of the City’s BMP Design Manual and with the requirements of San Diego RWQCB Order No. R9-2013-0001
(Regional MS4 Permit). The SWQMP specifies site design BMPs that would be implemented to minimize soil
erosion. Site design BMPs include conserving natural areas, soils, and vegetation; minimizing impervious areas;
and minimizing soil compaction (Appendix I1). Therefore, with implementation of the SWPPP and incorporation of
the BMPs described in the SWQMP, impacts associated with substantial erosion or siltation on- or off-site would
be less than significant.
ii. Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on-
or off-site.
The project would introduce a 67.5-acre development area composed of 44.2 acres of residential uses, a 0.9-
acre Community Purpose Facility (CPF), 5.9 acres of public streets, and 16.5 acres of manufactured slopes and
drainage basins, resulting in more impervious area to the site, which would result in an increase of surface
runoff. The increase in surface runoff would present a potential increase to flooding on - or off-site in the event
of heavy rainfall.
To analyze whether the project would create adverse impacts related to flooding, the Drainage Report prepared for
the project (Appendix I2) evaluates the existing and proposed peak flows from the project site, assuming the
proposed project incorporates the aforementioned attenuation measures. The findings determined that the runoff
generated by the project would not exceed pre-project peak flow rates, and runoff velocities would be dissipated by
rock riprap at storm drain outfalls. Refer to Appendix I2 for further details. Additionally, the project site is located in
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Zone X, an area of minimal flood hazard per FEMA FIRM panel 06073C1914G effective May 16, 2012 (FEMA 2020).
This area is higher in elevation than the 0.2% annual chance flood (i.e., 500-year flood). Furthermore, the SWQMP
prepared for the project evaluated the existing and peak flows from the project site in the event of a 100-year flow
event (Appendix I1). Because the project would increase impervious area that could generate significantly more
surface runoff, the development of the project site would include adding storm drains, curb inlets, cleanouts along
the proposed on-site private roads and parking spaces to collect stormwater runoff (refer to Appendix I2). Stormwater
would be conveyed to the two proposed detention and water quality control basins located at northeast and
northwest part of the development area (see Figure 4-15, Proposed Storm Drain System). With incorporation of the
drainage improvements, the project would not exceed pre-project flow rates and would be designed to meet
projected 100-year flows (refer to Appendix I2 for further details). After the majority of the on-site runoff is treated
and detained by the biofiltration basin, the outflow will confluence with the bypass storm drain and discharge into
the Poggi Canyon Creek. Therefore, through improvements of stormwater infrastructure on site, impacts associated
with the project substantially increasing the rate or amount of surface runoff in a manner which would result in
flooding on- or off-site would be less than significant.
iii. Create or contribute runoff water which would exceed the capacity of existing or planned stormwater
drainage system or provide substantial additional sources of polluted runoff.
The project would introduce a 67.5-acre development area composed of 44.2 acres of residential uses, a 0.9-
acre Community Purpose Facility (CPF), 5.9 acres of public streets, and 16.5 acres of manufactured slopes and
drainage basins, resulting in more impervious area to the site, which would result in an increase of surface
runoff. An increase in surface runoff could potentially exceed the capacity of the existing or planned stormwater
drainage system or provide substantial additional sources of polluted runoff.
The proposed storm drain system and layout (see Figure 4-11, Streets ‘A’ and ‘B’ – Typical Street Sections) would
be designed to address peak flows and to integrate water quality features needed to comply with the City’s Standard
Urban Stormwater Mitigation Plan requirements for water quality. Development of the project site would include
adding storm drains, curb inlets, cleanouts along the proposed on-site private roads and parking spaces to
collect storm runoff (refer to Appendix I2). Stormwater would be conveyed to the two proposed detention and
water quality control basins located at the northeast and northwest part of the development area (see Figure
4-15). After the majority of the on-site runoff is treated and detained by the biofiltration basin, the outflow will
confluence with the bypass storm drain and discharge into the Poggi Canyon Creek. For small amount of runoff
generated from the north portion of proposed public roads which would be connecting with Olympic Parkway,
only the water quality control measurements are proposed, i.e., multiple Modular Wetland structures would be
installed to control the water quality. The outflow from Modular Wetlands then discharges into Poggi Canyon
Creek without detention. With incorporation of the drainage improvements, the project would not exceed pre-
project flow rates and would be designed to meet projected 100-year flows (refer to Appendix I2 for further
details). Therefore, impacts associated with the creation or contribution of water runoff which would exceed the
capacity of existing or planned stormwater drainage system or provide substantial additional sources of polluted
runoff would be less than significant.
iv. Impede or redirect flood flows.
As discussed previously, the project site is located in Zone X, an area of minimal flood hazard per FEMA FIRM panel
06073C1914G effective May 16, 2012 (FEMA 2020). This area is higher in elevation than the 0.2% annual chance
flood (i.e., 500-year flood). As previously discussed, the project would introduce impervious area to the project site,
which would increase surface runoff that could result in increased on- or off-site flooding. The evaluation of the
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existing and proposed flow rates showed that with incorporation of drainage improvements (adding storm drains,
curb inlets, cleanouts along the proposed on-site private roads and parking spaces to collect storm runoff) the project
site would maintain adequate stormwater conveyance as to not result in significant flooding on- or off-site associated
with the 100-year, 24-hour storm event (refer to Appendix I2 for further details). Therefore, impacts associated with
impeding or redirecting flood flows would be less than significant.
D. In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation.
Seiche is generally associated with oscillation of enclosed bodies of water typically caused by ground shaking
associated with a seismic event; however, the project site is not located near an enclosed body of water. The closest
body of water to the project site is the San Diego Bay, located approximately 4.4 miles west of the project site. Thus,
the probability of inundation by seiche or tsunamis is considered negligible. Additionally, flooding from tsunami
conditions is not expected because the project site is located approximately 6.3 miles inland from the Pacific Ocean.
As discussed under Threshold C(ii), the project site is located in Zone X, an area of minimal flood hazard per FEMA
FIRM panel 06073C1914G effective May 16, 2012 (FEMA 2020). This area is higher in elevation than the 0.2%
annual chance flood (i.e., 500-year flood). As previously discussed, although internal drainage patterns would be
somewhat altered as a result of project development, the project would maintain adequate stormwater conveyance
and therefore not result in an increase of surface runoff that would result in flooding on- or off-site associated with the
100-year, 24-hour storm event. Furthermore, as discussed in the SWQMP prepared for the project, the project would
incorporate source control and site design BMPs to reduce water quality impacts (Appendix I1). In the event of a flood,
appropriate source control BMPs that would reduce the risk of releasing pollutants would include protecting trash
storage areas from rainfall, run-on, runoff, and wind dispersal; on-site storm drain inlets; interior floor drains and sump
pumps; interior parking garages; refuse area; and other miscellaneous drains. The structural BMPs would involve the
installation of two biofiltration basins. Both biofiltration basins would work for combined pollutant control by collecting
and treating runoff through a pre-treatment and biofiltration chamber filtering system. Additionally, the structural
BMPs would include three CP biofiltration units (i.e., Modular Wetland Unit). These CP biofiltration units would be
located along the proposed streets that would connect to Olympic Parkway, one on Street A and two on Street B. These
CP biofiltration units would provide augment pollutant control for the project site.
Therefore, impacts associated with flood hazard, tsunami, or seiche zones, and risk release of pollutants due to
project inundation would be less than significant.
E. Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater
management plan.
The San Diego Basin underlies a small western portion of the project site; however, the majority of the project site
would not be located within the San Diego Basin (DWR 2020). As discussed in Section 5.9.1, the San Diego RWQCB
jurisdiction oversees water quality in the San Diego region. The RWQCB has adopted the WQCP for the San Diego
Basin Plan that designates beneficial uses of the region’s surface water and groundwater, identifies water quality
objectives for the reasonable protection of those uses, and establishes an implementation plan to achieve the
objectives (SDRWQCB. 2018). The project would be required to comply with applicable regulations and permit
requirements intended to support the objectives and policies of the WQCP regarding water quality and erosion and
sediment control. Implementation of measures identified in the SWQMP would include source control and site
design BMPs to reduce water quality impacts (Appendix I1). Source control BMPs include prevention of illicit
discharges into the MS4; storm drain stenciling or signage; protecting trash storage areas from rainfall, run-on, runoff,
and wind dispersal; on-site storm drain inlets; interior floor drains and sump pumps; interior parking garages; refuse
area; and other miscellaneous drains. Site design BMPs include conserving natural areas, soils, and vegetation;
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minimizing impervious areas; minimizing soil compaction; runoff collection; and landscaping with native or drought
tolerant species. The structural BMPs would involve the installation of two biofiltration basins. Biofiltration basin 1
would be located in the northeastern area of the project site and biofiltration basin 2 would be located in the
northwestern area of the project site. Both biofiltration basins would work for combined pollutant control by collecting
and treating runoff through a pre-treatment and biofiltration chamber filtering system. Additionally, the structural
BMPs would include three CP biofiltration units (i.e., Modular Wetland Unit). These CP biofiltration units would be
located along the proposed streets that would connect to Olympic Parkway, one on Street A and two on Street B. These
CP biofiltration units would provide additional aide in pollutant control for the project site. Thus, the BMPs would
reduce project impacts associated with water quality and soil erosion and would allow for the project to be
consistent with objectives and policies identified in the WQCP. Projects that are consistent with the objectives and
policies of the WQCP would not conflict with the WQCP. However, while the project site partially overlies the San
Diego Basin, the area overlying the San Diego Basin is proposed for open space and would remain undeveloped.
Furthermore, the project site is not located within a Sustainable Groundwater Management Act (SGMA) mandated
basin (County of San Diego 2020). SGMA requires that basins with medium and high-level priority to develop
sustainable groundwater sustainability plans and manage groundwater for long-term sustainability. The western
portion of the project site is located in the Coastal Plain of the San Diego Groundwater Basin; however, it is not
designated as medium or high priority and thus does not require a groundwater management plan (County of San
Diego 2020). Therefore, the project would not obstruct implementation of a water quality plan or sustainable
groundwater management plan; thus, impacts would be less than significant.
5.9.4 Level of Significance Prior to Mitigation
The proposed project would have a less-than-significant impact on hydrology and water quality.
5.9.5 Mitigation Measures
No mitigation measures would be required.
5.9.6 Level of Significance After Mitigation
No mitigation measures would be required. Impacts to hydrology and water quality would be less than significant.
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5.10 Land Use and Planning
This section of the environmental impact report (EIR) provides an overview of the land uses within the proposed
Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II, Phase 3 Project (proposed project) site
and surrounding region, the regulatory framework, and an analysis of potential conflicts with existing land use plans
that would result from implementation of the proposed project.
According to the California Environmental Quality Act (CEQA), a proposed project’s land use effects fall into two
main categories: (1) conflicts with any applicable land use plan, policy, or regulation adopted for the purpose of
avoiding or mitigating an environmental effect; and (2) physically dividing an established community. This section
of the EIR addresses potential environmental impacts associated with land use conflicts resulting from the
proposed project. Other environmental issues associated with land use decisions include aesthetics, noise, and
resource conservation. These issues are separately addressed in their respective sections of this EIR.
5.10.1 Existing Conditions
5.10.1.1 Regulatory Framework
Local
2050 Regional Transportation Plan/Sustainable Communities Strategy
SANDAG adopted the 2050 Regional Transportation Plan (RTP) in October 2011. The 2050 RTP provides a vision
of the San Diego region’s transportation system over the next 40 years. The document contains a robust
transportation network, with a diversity of projects that will provide residents and visitors with a variety of travel
choices (SANDAG 2011). As part of the 2050 RTP, SANDAG adopted the Sustainable Communities Strategy (SCS),
which details how the region will reduce greenhouse gas (GHG) emissions to state-mandated levels as required by
Senate Bill 375. The goal of the SCS is to establish a development plan for the region, which, after considering
transportation measures and policies, will achieve, if feasible, the GHG reduction targets. The GHG reduction targets
to be achieved through the adoption of SANDAG’s SCS are a 7% reduction in emissions per capita by 2020 and a
13% reduction by 2035. The 2050 RTP and SCS seek to guide the San Diego region toward a more sustainable
future by integrating land use, housing, and transportation planning to create communities that are more
sustainable, walkable, transit-oriented, and compact (SANDAG 2011). On October 9, 2015, SANDAG adopted “San
Diego Forward” a Regional Plan that merged its Regional Comprehensive Plan (RCP) with the 2050 RTP/SCS
(Regional Plan). The RCP served as the long-term planning framework for the San Diego region prior to adoption
of the Regional Plan. It provided a broad context within which local and regional land use decisions could be
made with respect to anticipated regional growth, and its effect on housing, economics, transportation,
environmental planning, and overall quality of life needs. Now, the Regional Plan serves as the blueprint for how
the San Diego region will grow and how SANDAG will invest in transportation infrastructure to provide more choices,
strengthen the economy, promote a healthy environment, and support thriving communities. The Regional Plan sets
forth the following six general objectives: Habitat and Open Space Prese rvation, Regional Economic Prosperity,
Environmental Stewardship, Providing Mobility Choices, Partnerships/Collaboration with neighboring entities and
creating Healthy and Complete Communities (SANDAG 2015).
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At the core of the Regional Plan is an SCS that charts a course toward lowering GHG emissions and includes the
following five building blocks (SANDAG 2015):
• A land use pattern that accommodates our region’s future employment and housing needs, and protects
sensitive habitats, cultural resources, and resource areas.
• A transportation network of public transit, Managed Lanes and highways, local streets, bikeways, and
walkways built and maintained with reasonably expected funding.
• Managing demands on our transportation system (also known as Transportation Demand Management, or
TDM) in ways that reduce or eliminate traffic congestion during peak periods of demand.
• Managing our transportation system (also known as Transportation System Management, or TSM) through
measures that maximize the overall efficiency of the transportation network.
• Innovative pricing policies and other measures designed to reduce the number of miles people travel in
their vehicles, as well as traffic congestion during peak periods of demand.
The Regional Plan includes the following set of principles that will guide the development of the region’s future
transportation network (SANDAG 2015):
• The SANDAG investment plan will be built with financial resources that are reasonably expected to be
available between now and 2050.
• A more efficient transportation network will be achieved through two key strategies: effectively managing
the overall system (TSM) and effectively managing demands on the system (TDM) with innovative
technologies integrated into both. The result will be maximized efficiency in the transportation network,
which ultimately can lower greenhouse gas emissions.
• Managing parts of the network, such as adding Managed Lanes and transit only lanes on freeways, which
encourage people to carpool and use public transit to bypass bottlenecks.
• The road toward a more sustainable San Diego region should include vehicles that use cleaner, alternative
sources of energy with SANDAG playing an important role in promoting this transition.
SANDAG also prepared a 2019 Federal Regional Transportation Plan (2019 Federal RTP), which was adopted on
October 25, 2019. The 2019 Federal RTP builds on the 2015 Regional Plan with updated project costs and
revenues and a new regional growth forecast. The 2019 Federal RTP is consistent with the Final EIR approved in
conjunction with the 2015 Regional Plan on October 9, 2015. State legislation (Assembly Bill 1730), was signed
into law on October 8, 2019, which ensures the 2015 Regional Plan remains valid for state funding eligibility and
other consistency purposes until the 2021 Regional Plan is adopted in late 2021. Preparation of the 2021 Regional
Plan is currently underway. In fall 2020, key policies and programs to be considered as part of the vision will be
presented to SANDAG policymakers. The draft 2021 Regional Plan and its draft Environmental Impact Report are
expected to be released for public and policymaker review in spring 2021 (SANDAG 2020).
City of Chula Vista General Plan
The City of Chula Vista General Plan was updated by the City on December 13, 2005, and most recently amended
in 2020. The General Plan provides a long -term strategy to address planning issues for the growth and
development of the City, and is composed of the following six ele ments: land use and transportation, economic
development, public facilities and services, growth management, environmental, and housing (City of Chula Vista
2005). A large portion of the project site’s existing General Plan land use designation is Open Space Preserve
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with small sections designated as Open Space. The southeast portion of the project site is designated as Limited
Industrial in the General Plan (see Figure 3-1, Existing General Plan Land Use). The proposed project is located in
the Sunbow subarea of the General Plan. Sunbow is identified as a master planned community in the General
Plan (City of Chula Vista 2005).
Land Use and Transportation Element
The Land Use and Transportation Element establishes the land use categories, roadway classifications, and
generalized land use patterns for City development and focuses on themes that (1) support strong community
character and image, (2) support strong and safe neighborhoods, and (3) improve mobility. This element establishes
plans and policies to identify the general distribution of housing, businesses, industry, open space (including parks),
education facilities, and public buildings. Standards for population density and building intensity in each land use
classification are also provided (City of Chula Vista 2005).
Economic Development Element
The Economic Development Element establishes policies to ensure the long -term vitality of the local economy
and to help develop, guide, and encourage appropr iate employment and business ownership in the City. It
promotes a sustainable local economy to benefit present and future generations without detrimentally affecting
resources. Employment land, or land designated for commercial, industrial and other non -residential, or open
space use, is concentrated in three principal areas: the tideland area, the Montgomery area, and the Otay Ranch
area (City of Chula Vista 2005).
Public Facilities and Services Element
The Public Facilities and Services Element establishe s the plan to provide and maintain infrastructure and public
services for future growth, without diminishing services to existing development within the City. The overall goal
of this element is to provide and maintain public facilities and services within the City through abundant public
infrastructure and community services that support and enhance the well -being of the City and its residents (City
of Chula Vista 2005).
Growth Management Element
The purpose of the Growth Management Element is to guide future development in the City based on the principles
that (1) rapid population growth and development have the potential to cause a variety of problems and impact the
well-being of a city and its residents, and (2) impacts can be mitigated by balancing competing demands for growth
and development through the adoption of comprehensive objectives and policies. This element serves as the
assurance that the vision described within the General Plan is achieved without sacrificing the quality of life enjoyed
in the community, and establishes a framework for directing new development, redevelopment, and community
enhancement, and provides the guidance to realize the vision for the City (City of Chula Vista 2005).
Environmental Element
The Environmental Element establishes the policy framework for improving sustainability through the City’s
stewardship of natural and cultural resources, promotion of environmental health, and protection of persons and
property from environmental hazards and noise. Sustainable development is identified as a means of balancing
current growth and economic progress with protection of future resources (City of Chula Vista 2005).
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Housing Element
The Housing Element details a 5-year strategy for enhancement and preservation of the City character, identifies
strategies for expanding housing opportunities for the various economic segments of the City, and provides policy
guidance for local decision-making related to housing. The focus of this element is to (1) maintain and enhance the
quality of housing and residential neighborhoods in the City, (2) support housing opportunities to meet the City’s
diverse needs, and (3) fund and implement services that provide vital community resources for lower-income
residents. The City of Chula Vista adopted a Balanced Communities Policy (Policy), commonly referred to as
Inclusionary Housing, in 1981 as part of its Housing Element of the General Plan. The City Council’s purpose of the
Policy is to increase the diversity of housing prices/rents throughout the community and ensure that the range of
prices/rents continues over time. Inclusionary policies of this element require 10% affordable (inclusionary)
housing, including 5% low-income and 5% moderate-income units, for projects consisting of 50 or more dwelling
units (City of Chula Vista 2005). The Guidelines to the Balanced Communities Policy, were established to
supplement and support the Inclusionary Housing Policy of Chula Vista which are read in conjunction with the Policy.
Pursuant to the Guidelines, the City may approve alternatives to the construction of new inclusionary units where
the proposed alternative provides a more effective and feasible means of satisfying this requirement or provides a
greater public benefit. Guidelines to the Balanced Communities Policy (2015). Currently, the City is updating the
General Plan Housing Element to account for housing needs and establish clear goals and objectives to inform
future housing decisions for the 2021 to 2029 housing cycle.
City of Chula Vista Multiple Species Conservation Program Subarea Plan
The City’s Multiple Species Conservation Program (MSCP) is a subregional plan under the California Natural
Community Conservation Planning Act (California Fish and Game Code Sections 2800–2835). The MSCP covers an
area encompassing 12 jurisdictions and 582,243 acres. The MSCP addresses the potential impacts of urban
growth, loss of natural habitat, and species endangerment, and creates a plan to mitigate for the potential loss of
covered species and their habitat due to the direct, indirect, and cumulative impacts of future development of both
public and private lands within the MSCP area. The MSCP Subregional Plan is a comprehensive, long-term habitat
conservation plan that addresses the needs of multiple sensitive plant and animal species and the preservation of
natural vegetation communities in southern San Diego County. The MSCP Subregional Plan is implemented through
local subarea plans prepared by participating jurisdictions (City of Chula Vista 2003). The City of Chula Vista MSCP
Subarea Plan was approved in 2003, and it provides for conservation of covered species and their associated
habitats by establishing a Preserve of interconnected conservation lands. The combination of the MSCP
Subregional Plan and subarea plans, including the City’s MSCP Subarea Plan, serves as a Multiple -Species
Habitat Conservation Plan pursuant to Section 10(a)(1)(B) of the federal Endangered Species Act and as Natural
Community Conservation Plan and associated permit under the Natural Co mmunity Conservation Planning Act.
The MSCP Subregional Plan is being implemented in phases as participating jurisdictions and special districts
submit their subarea plans for approval to the U.S. Fish and Wildlife service (USFWS) and the California
Department of Fish and Wildlife (CDFW). Upon approval, USFWS and CDFW authorize the take of listed species
and other species of concern, subject to the terms of the MSCP Subarea Plan and the MSCP Subregional Plan.
Conservation and management responsibilities and implementation guarantees for each subarea plan are set
forth in implementing agreements between the entity responsible for each subarea plan and USFWS and CDFW
(City of Chula Vista 2003).
The City’s MSCP Subarea Plan was approved in 2003, the City’s Implementation Agreement with USFWS and CDFW
was entered into in February 2003. The City’s MSCP Subarea Plan was prepared pursuant to a general outline
developed by USFWS and CDFW to meet the requirements of the Natural Community Conservation Planning Act.
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The City’s MSCP Subarea Plan is consistent with the MSCP Subregional Plan and contributes to its implementation.
In addition, the City’s MSCP Subarea Plan is a stand-alone document for purposes of implementing portions of the
MSCP Preserve (City of Chula Vista 2003).
The City’s MSCP Preserve was created in cooperation with USFWS and CDFW, property owners, developers, and
environmental groups. The majority of the City’s Preserve consists of hardline areas designated for 100%
conservation, and these areas are either already in public ownership or will be dedicated into the Preserve as part
of the City’s development approval process for covered projects. Preserve boundaries for covered projects were
established on a project-by-project basis after evaluation of habitat and species data and/or surveys conducted as
part of project entitlement processing, evaluation by USFWS and CDFW, and consideration of how such mitigation
could best contribute to the overall MSCP Subregional Plan (City of Chula Vista 2003).
Although the proposed project is not considered a “Covered Project” under the Chula Vista MSCP Subarea Plan, a
large portion of the project site (47%) is designated as Open Space Preserve. Land uses designated as Open Space
Preserve are areas within the City’s MSCP Subarea Plan that provide for the permanent conservation of biological
resources (City of Chula Vista 2005).
Sunbow General Development Plan
The Sunbow General Development Plan (GDP), which originally included 604.8 acres in the eastern portion of the
City, was adopted on December 5 , 1989, with the primary objective to create an efficient, self -contained village
with a mix of residential, commercial, community recreation, industrial par k, and open space/trails land uses.
The principal objective of the GDP was to develop an efficient self -contained village (City of Chula Vista 1989).
The GDP is implemented through the adoption of a more detailed SPA Plan, tentative tract maps, and potenti al
annexation and development agreements. The GDP is designed to function as a policy bridge between the
General Plan and the SPA Plan, which provides more detailed plans for development of the Sunbow Master
Planned Community . The project site is designated as Industrial Park and Open Space within the GDP (City of
Chula Vista 1989).
Sunbow Sectional Planning Area Plan
The SPA Plan was approved by the City Council on February 20, 1990. According to the City, GDPs are
implemented through the adoption of SPA Plans, which are more detailed in its zoning, design regulations, and
development parameters. The purpose of the SPA Plan is to assure high quality development, create an
economically viable plan, provide a plan for long -range development, facilitate provisions for community facilities,
preserve open space, and establish a planning and development framework. Regulations within the SPA Plan
supersede other regulations where there is potential conflict between the GDP and the General Plan . The project
site is designated as Industrial Park and Open Space within the SPA Plan (City of Chula Vista 1990).
City of Chula Vista Municipal Code
Zoning Ordinance
Title 19 of the City of Chula Vista Municipal Code (CVMC) is the City’s Zoning Code, which is intended to implement
the General Plan. The Sunbow Master Planned Community, which includes the project site, is designated as a
Planned Community (P-C) zone. Per the City’s Municipal Code Section 19.48.090, all P-C zones shall be divided into
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sectional planning areas, such is the case with the SPA Plan area. Specific land use districts are designated by the
SPA Plan. As defined in Chapter 19.48 of the CVMC, the purposes of the P-C zone are as follows:
• Provide for the orderly preplanning and long-term development of large tracts of land. These tracts may
contain a variety of land uses, but are under unified ownership or development control, so that the entire
tract will provide an environment of stable and desirable character.
• Give the developer reasonable assurance that sectional development plans in accordance with the
approved general development plan will be acceptable to the City. Sectional development plans may
include subdivision plans and/or planned unit development plans as provided in this title.
• Enable the City to adopt measures for the development of the surrounding area compatible with the
planned community zone.
According to Section 19.48.020 of the Zoning Code, P-C zoning may be established on lands that are suitable and
of sufficient size for planning and development in a manner consistent with the purpose of the zone. P -C zoning
does not include any area of less than 50 acres of contiguous land. Section 19.48.025 establishes a requirement
for Community-Purpose Facility (CPF) sites to be provided within the P-C zone at the rate of 1.39 acres per 1,000
persons. Section 19.48.090 establishes requirements for sectional planning areas.
Growth Management Ordinance
The purpose and intent of the City’s Growth Management Ordinance (GMO) (CVMC Section 19.09) is to provide
quality housing opportunities for all economic sections of the community; to balance the community with a dequate
commercial, industrial, recreational, and open space areas to support the residential areas of the City; to provide
that public facilities, services, and improvements meeting City standards exist or become available concurrent with
the need created by new development; to control the timing and location of development by tying the pace of
development to the provision of public facilities and improvements to conform to the City’s Threshold Standards;
and to meet the goals and objectives of the Growth Management Program and other programs associated with
quality of life. The GMO prohibits new development unless adequate public facilities are provided in advance of or
concurrently with the demands created by new development.
The GMO created the Growth Management Oversight Commission and established “quality of life” threshold
standards. These include police, fire, and emergency response times; anticipated demand for schools and evaluation
of school funding; establishment of a library service ratio; a service ratio for neighborhood and community park land;
water service availability; compliance with City engineering sewage flow and related standards (subdivision manual);
compliance with City engineering stormwater drainage standards (subdivision manual); maintenance of acceptable
City-wide traffic flows; and air quality and pollution overview and evaluation to foster air quality improvement pursuant
to relevant regional and local air quality improvement strategies. The GMO also requires public facilities finance plans
(PFFPs), air quality improvement plans, and water conservation plans for every SPA Plan, or, if a SPA Plan is not
required, for every tentative map (TM) application. The PFFP provides a complete description of all public facilities
included within the boundaries of the plan as defined by the development services director, including phasing and
financing of infrastructure. The plan must contain an analysis of the individual and cumulative impacts of the proposed
development on the community as it relates to the Growth Management Program, the specific facility master plans,
and the threshold standards. Proposed development must also prepare a fiscal impact report and provide funding for
periods when City expenditures for the development would exceed projected revenues.
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Park Land Dedication Ordinance
Chapter 17.10 of the CVMC establishes requirements for parklands and public facilities, including regulations for
the dedication of land and development of improvements for park and recreational purposes (Section 17.10.010);
determination of park and recreational requirements (Section 17.10.020); calculation of area to be dedicated
(Section 17.10.040); specifications for park improvements (Section 17.10.050); criteria for area to be dedicated
(Section 17.10.060); procedures for in-lieu fees for land dedication and/or park development improvements
(Section 17.10.070); and other regulations regarding park development and collection and distribution of fees.
Payment of a Park Benefit Fee, as described in Section 4.4.1.1 of the EIR, addresses the project’s Park Land
Dedication Ordinance requirements.
Tentative Map
Title 18 of the CVMC requires the adoption of a TM for division and development of land into five or more parcels.
A TM is made for the purpose of showing the design of a project, including the locations and layouts of streets and
parcels. Under CVMC Section 18.04.050, provisions shall be made in a TM to assure adequate access, light, air,
and privacy on all parcels of property, regardless of the land use. CVMC Section 18.05.060 provides for necessary
land for community facilities, including schools, parks, open space, playgrounds, and other required public facilities.
The TM must be reviewed by the Director of Public Works to ensure compliance with regulations applicable to public
and private utilities, streets, and respective rights-of-way and easements. The TM also must be reviewed by the
Development Services Director with regard to the number, size, and configuration of lots to be created, and the
alignment and width of streets and easements. TMs may be adopted at the time of project approval and shall expire
in 36 months in accordance with the Subdivision Map Act, although extensions may be requested.
Parks and Recreation Master Plan
The City of Chula Vista Parks and Recreation Master Plan (PRMP) was adopted in 2002 and the most recent Draft
Update was completed in 2018. The PRMP is the blueprint for the City’s park system through the year 2030. The
PRMP identifies existing park and recreation facilities and provides guidance for future park sites, including
locations for specific types of additional recreational facilities. The PRMP envisions a comprehensive and
interrelated package of community and neighborhood parks and presents each park within the context of the whole
park system to ensure that it provides a balance of recreational opportunities. The PRMP states that the year 2030
Citywide park system will contain community, neighborhood, mini, urban, and special-purpose parks and recreation
facility and community center sites (City of Chula Vista 2018).
The PRMP includes a set of goals and policies for the City’s parks and recreation aspirations. Each goal is
accompanied by a set of specific policies, rationales, and action plans, as appropriate. The goals are as follows (City
of Chula Vista 2018):
• Create a comprehensive parks and recreation system that meets the needs of the general public of Chula
Vista by effectively distributing park types and their associated recreation facilities and programs and by
using quasi-public resources.
• Establish priorities for allocation of existing and future public parkland resources that balance public
priorities and needs with quality of parks and facilities.
• Provide a program for implementation of the City’s Goals and Policies contained herein to ensure the
continued development of a comprehensive parks and recreation system providing citywide resources for
recreation services and programs that meet the needs of its citizens.
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Airport Land Use Compatibility Plan–Brown Field
The San Diego County Regional Airport Authority, designated as the Airport Land Use Commission for all public
airports in the County of San Diego, adopted the Brown Field Airport Land Use Compatibility Plan (ALUCP) in
September 1981 (last updated in December 2010). The ALUCP assists in achieving compatible land use
development in the area surrounding Brown Field airport located in Otay Mesa on Heritage Road, east of Interstate
(I) 805. Brown Field is a general aviation airport accommodating both propeller- and jet-powered aircraft and serves
as a port of entry for private aircraft coming into the United States from Mexico. Brown Field is also heavily used by
military and law enforcement agencies and is classified as a “reliever airport” by the Federal Aviation Administration
(SDCRAA 2010). The ALUCP designates the airport influence area and contains projected noise contours, flight
activity zones, a land use compatibility matrix, and plan recommendations for areas surrounding Brown Field. The
airport influence area is delineated by using the projected 60-decibel (dB) community noise equivalency level
(CNEL) contour and is generally the area in which current and future airport-related noise, overflight, safety, and/or
airspace protection factors may affect land uses or necessitate restrictions on uses. The airport influence area is
divided into Review Area 1 and Review Area 2.
The composition of each area is determined as follows (SDCRAA 2010):
• Review Area 1 consists of locations where noise or safety concerns may necessitate limitations on the types
of land use actions. Specifically, Review Area 1 encompasses locations exposed to aircraft noise levels of
60 dB CNEL or greater together with all of the safety zones identified in the ALUCP.
• Review Area 2 consists of locations beyond Review Area 1 but within the airspace protection and/or
overflight notification areas. Limits on the heights of structures, particularly in areas of high terrain, are the
only restrictions on land uses within Review Area 2.
A portion of the project site is within Review Area 2 of the Brown Field Airport Influence Area and the entire project
site is within the FAA Height Notification Boundary (SDCRAA 2010).
5.10.1.2 On-Site Conditions
The project site is centrally located in the City, east of I-805, west of SR-125, and north of SR-905. Specifically, the
project site is located south of Olympic Parkway and adjacent to the northern boundary of the Otay Landfill. Regional
access to the project would be provided primarily by Olympic Parkway. The project site is currently accessible from
Olympic Parkway through two existing unpaved culverts crossing Poggi Canyon Creek in the northern portion of the
site. The site is currently vacant and undeveloped with no public access. Vegetation communities on the project
site primarily consist of coastal and valley freshwater marsh, Diegan Coastal Sage Scrub, Native Grassland, and
Non-native Grassland.
5.10.1.3 Surrounding Land Uses
The project site is surrounded by existing development including residential land uses to the north, west, and
southwest. Approximately 300-500 feet of open space hillsides also exists north of the project site between Olympic
Parkway and the residential land uses. South of the project site is the Otay Landfill and directly southeast of the
project site is vacant and undeveloped land planned for residential and industrial development within Otay Ranch
Village Two. Valle Lindo Elementary School is located approximately 0.25 miles west of the project site and Fire
Station 3 is located 0.2 miles northwest of the project site.
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5.10.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to land use and planning is based on the
recommendations provided in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). A significant impact
would occur if the project would:
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.
5.10.3 Impacts
A. Physically divide an established community.
The proposed project is located on a currently vacant and undeveloped site surroun ded by existing and planned
development, as discussed in Section 5.10.1.2, On-Site Conditions. There is currently no public access to the project
site. Access to the proposed project would be provided from the existing Olympic Parkway and the project does not
propose components that would impede or present barriers to existing circulation networks within the Sunbow and
Otay Ranch communities. Rather, the proposed project would result in the development of residential uses on a site
that has historically been planned for development. Implementation of the proposed project would not physically divide
an established community. Therefore, impacts would be less than significant.
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.
The proposed project would include multiple discretionary actions and/or approvals, as discussed in Section 4.5,
Discretionary Actions/Approvals, of this EIR. These would include amendments to the General Plan, GDP, and SPA
Plan as well as a Rezone, a Development Agreement, MSCP Subarea Plan Boundary Line Adjustment, MSCP Minor
Amendment, and Tentative Map approval. Currently, the southeast portion of the project site is designated as
Limited Industrial in the General Plan and Industrial Park in the GDP and SPA Plan (see Figure 3-1, Existing General
Plan Land Use; Figure 3-3, Existing General Development Plan Land Use Designation; and Figure 3-4, Existing SPA
Plan Land Use). The General Plan, GDP, and SPA Plan amendments would primarily change these land use
designations to allow for the development of residential uses and the proposed community purpose facility (see
Figure 4-2, Proposed General Plan Land Use; Figure 4-3, Proposed General Development Plan Land Use
Designation; and Figure 4-4, Proposed SPA Plan Land Use). The remainder of the project would generally remain
unchanged as Open Space Preserve or Open Space., The proposed project also includes a MSCP Boundary Line
Adjustment to correct an inadvertent error in the MSCP that placed a 100% Preserve overlay on the project site
even though the project was not identified as a Covered Project. The proposed Boundary Line Adjustment would
result in a net increase of 0.09 acres of Preserve land. The proposed project also includes a Rezone. The project
site would remain designated as SPA under the existing P-C zoning. However, the specific zoning districts identified
within the GDP and SPA Plan for the Sunbow II, Phase 3 area would be amended to allow for the proposed
residential, community purpose facility, and open space project components (see Figure 4-5, Proposed Zoning).
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Chula Vista General Plan
Land Use and Transportation Element
The Land Use and Transportation Element establishes the land use categories, roadway classifications, and
generalized land use patterns for City development, while focusing on themes that (1) support strong community
character and image, (2) support strong and safe neighborhoods, and (3) improve mobility. This element establishes
plans and policies to identify the general distribution of housing, businesses, industry, open space (including parks),
education facilities, and public buildings. Standards for population density and building intensity in each land use
classification are also provided. General Plan Land Use and Transportation Element objectives relevant to the
proposed project include the following (City of Chula Vista 2005):
• 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.
• Objective LUT 2: Limit locations for the highest development intensities and densities, and the tallest
building forms, to key urban activity centers that are also well-served by transit.
• Objective LUT 3: Direct the urban design and form of new development and redevelopment in a manner
that blends with and enhances Chula Vista’s character and qualities, both physical and social.
• Objective LUT 6: Ensure adjacent land uses are compatible with one another.
• Objective LUT 7: Appropriate transitions should be provided between land uses.
• Objective LUT 13: Preserve scenic resources in Chula Vista, maintain the City’s open space network, and
promote beautification of the City.
• Objective LUT 29: Allow for the clustering of residential development to respond to site constraints, and
improve amenities for project residents.
• Objective LUT 71: Sustain the stable, well-maintained neighborhoods with adequate public facilities and
services that are in accordance with adopted policies and regulations intended to maintain desirable
community character.
• Objective LUT 79: Establish appropriate land uses adjacent to the Otay Landfill and Wolf Canyon that reflect
the unique land use and landform characteristics of these areas.
• Policy LUT 79.5: Limit land uses adjacent to the Otay Landfill to open space and limited industrial uses or
business park.
The proposed project would amend the General Plan to change the land use designation on the project site from
Research & Limited Industrial to Residential Medium-High and Residential High, as described above. The existing
General Plan land use designations are shown on Figure 3-1. Although residential development was not anticipated
for the project site by the General Plan, the site has historically been planned for development and the proposed
uses are currently encouraged by state law and regional planning documents due to the need for more housing within
the State. Consistent with General Plan Objective LUT 2, the proposed project would also locate higher density housing
near existing urban activity centers within the City and would be well-served by the existing transportation network
including Olympic Parkway and I-805.
The surrounding area is already substantially developed with housing to the north, west, and southwest, and the Otay
Landfill is located to the southeast. Consistent with General Plan Objective LUT 71, there is significant existing
infrastructure surrounding the project site to accommodate the proposed project including existing transportation and
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utility infrastructure (including water and sewer) adjacent to the project site within Olympic Parkway. The GMO also
requires PFFPs for every SPA Plan. A PFFP is required in conjunction with the preparation of a SPA Plan Amendment to
ensure that development of the proposed project is consistent with the overall goals and policies of the General Plan and
would not degrade public services. The Supplemental PFFP prepared for the proposed project (see Appendix B Sunbow
II, Phase 3 SPA Amendment Supplemental PFFP) provides a complete description of all public facilities included within
the boundaries of the SPA Plan area, including phasing and financing of infrastructure. The PFFP ensures that
development of project would not adversely impact the City’s quality of life standards by requiring public facilities and
services be provided concurrent with demand. Moreover, as discussed in Section 5.13, Public Services, and Section
5.16, Utilities and Service Systems, adequate public facilities and services currently exist to serve the proposed project
and the proposed project would result in less than significant impacts to public facilities and services.
Consistent with General Plan Objectives LUT 1 and LUT 3, the proposed project would develop new, higher density
housing on a site in a central location within the City that is already near existing commercial and employment centers.
Additionally, consistent with General Plan Objective LUT 29, the proposed project would cluster the residential uses
in the southeast corner of the project site and maintain the open space areas throughout the remainder of the site.
The proposed project would satisfy its affordable housing obligations via a Balanced Communities Affordable Housing
Agreement between the project applicant and the City. This Balanced Communities Affordable Housing Agreement will
document satisfaction with affordable housing requirements which would help the City fulfill both deficits from past 5th
Cycle RHNA allocations and projections for current 6th Cycle RHNA allocations for low income housing, as shown in
Tables 5.12-2 and 5.12-3 and discussed in Section 5.12, Population and Housing.
The project site is currently vacant and undeveloped, which provides scenic views for motorists traveling along
Olympic Parkway. The native habitat on site is identified in the General Plan as part of the City’s open space
network. Implementation of the proposed project would preserve approximately 63.6 acres of MSCP Open
Space Preserve, 3.9 acres of Poggi Creek Conservation easements, and 16.8 acres of Manufactured
Slopes/Basins/Wetland Resources, consistent General Plan Objective LUT 13 to maintain the City’s open
space network. As discussed in more detail in Secti on 5.1, Aesthetics, the proposed project would not conflict
with General Plan policies governing scenic quality.
Finally, the proposed project would include construction of residential land uses adjacent to the Otay Landfill.
General Plan Goal LUT 79 and Policy LUT 79.5 aims to limit land uses adjacent to the Otay Landfill to open space
and limited industrial uses or business park (City of Chula Vista 2005). While the proposed project would place
residential land uses in the vicinity of Otay Landfill, the proposed project would include open space setbacks
between the Otay Landfill and the closest proposed residences ranging from approximately 50 feet to 150 feet, as
shown in Figure 4-6, Illustrative Concept Plan. The Otay Landfill is also restricted from locating composting activities
within 1000 feet of residential uses. County of San Diego Major Use Permit Minor Deviation, MUP 76 -046WM
(September 12, 2019 MUP). This would ensure the proposed project is consistent with General Plan Objective LUT
7 to provide appropriate transitions between land uses. Moreover, the site has historically been planned for
development and as discussed in the Health Risk Assessment prepared for the proposed project (see Appendix C,
Air Quality and Greenhouse Gas Emissions Analysis), the landfill would cease operation in 2030, approximately 2
years after full buildout of the proposed project. As such, the proposed project would be compatible with
surrounding development and would not conflict with General Plan Objectives LUT 6, LUT 79, and Policy LUT 79.5.
The proposed project would not conflict with the Land Use and Transportation Element of the General Plan.
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Housing Element
The Housing Element details the City’s seven-year strategy for the enhancement and preservation of the
community’s character, identifies strategies for expanding housing opportunities for the City’s various economic
segments and provides the official policy guidance for local decision -making related to housing. The Housing
Element of the General Plan provides the implementation mechanisms for effectively addressing housing needs in
Chula Vista throughout the 2013-2020 planning period (City of Chula Vista 2013). Currently, the City is updating
the General Plan Housing Element to account for housing needs and esta blish clear goals and objectives to inform
future housing decisions for the 2021 to 2029 housing cycle. General Plan Housing Element objectives relevant to
the proposed project include the following (City of Chula Vista 2013):
• Objective H2: Promote efficient use of water and energy through sustainable design, adopted standards,
and incentives to conserve limited resources and reduce long-term operational costs of housing, consistent
with the California Long-Term Energy Efficiency Strategic Plan, the most recent Energy Code including City-
specific amendments, Green Building Standards, and other related City ordinances.
• Objective H5: Encourage the provision of a wide range of housing choices and equitable distribution by
location, type of unit, and price level, in particular the establishment of permanent affordable housing for
low-and moderate-income households.
• Objective H6: Promote the development of a variety of housing choices, coupled with appropriate services,
to meet the needs of special population groups, including the homeless, those “at-risk” of becoming
homeless, persons with disabilities, and seniors.
• Objective H7: Facilitate the creation, maintenance, preservation and conservation of affordable housing for
lower and moderate-income households through comprehensive planning documents and processes, and
the provision of financial assistance and other incentives.
Consistent with the General Plan Housing Element Objective H5 and H7, and the Guidelines to the Balanced
Communities Policy the proposed project would be consistent with the City’s Inclusionary Housing Policy by entering
into a Balanced Community Affordable Housing Agreement, that will increase the diversity of housing prices and
rent in the community. Per the City’s Balanced Com munity Affordable Housing Agreement, the project’s affordable
housing obligation of 72 affordable housing units, including 36 low-income and 36 moderate-income affordable
units will be met. The project will also contribute to the City’s Regional Housing Allocation requirements, and
consistent with General Plan Objectives H5, will offer a wide range of housing choices. This Balanced Communities
Affordable Housing Agreement will document satisfaction with affordable housing requirements. Proposed
residential uses would feature four unique multi-family attached residential product types with 15 unique
floorplans, ranging in square footage from approximately 1,100 to 2,050 and in two- and three-story homes,
consistent with General Plan Objective H6. The proposed project is required to meet all State of California
accessibility requirements for people with disabilities, and fair housing practices would be employed in the sale,
rental, and advertising of all units.
Consistent with General Plan Objective H2, the proposed project would comply with the Green Building Standards,
Energy Code, and California Long-Term Energy Efficiency Strategic Plan. Included in the Green Building Standards
is also a mandate for 20% less water use than currently required by the state plumbing code. Finally, as discussed
in Section 5.5, Energy, the proposed project would not result in the wasteful, inefficient, or unnecessary
consumption of energy resources; and, as discussed in Section 5.16, Utilities and Service Systems, there would be
sufficient water to serve the proposed project.
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As identified in the General Plan, the project site is designated Research & Limited Industrial, Open Space Preserve,
and Open Space. As such, the proposed project would conflict with the current General Plan land use designations
as described above. However, the proposed project involves an amendment to the General Plan, changing the land
use designations of the Research & Limited Industrial parcel to Residential Medium-High and High, to be processed
concurrently with the development of the proposed project. This amendment to the General Plan would allow the
proposed land uses to be developed on the project site. As such, the proposed project would not conflict with the
Housing Element of the General Plan.
Economic Development Element
The Economic Development Element establishes policies to ensure the long-term vitality of the local economy. The
purpose of the element is to help develop and guide employment and business ownership opportunities in Chula
Vista, and encourage appropriate economic and business development in the City (City of Chula Vista 2005). While
these are not adopted for the purposes of avoiding or mitigating an environmental effect, relevant policies of the
Economic Development Element included below are discussed:
• Policy ED 1.2: Provide sufficient tracts of land at a variety of sizes available for industrial and commercial
uses in order to provide a stable economic base.
• Policy ED 1.3: Encourage the preservation and expansion of existing industrial uses in areas
designated as industrial.
• Policy ED 1.5: Consider fiscal implications of General Plan amendments that propose changes to industrial
and commercial lands.
• Policy ED 2.3: Pursue a diverse supply of housing types and costs, as well as a diverse supply of jobs with
varying income potential, to balance local job and housing opportunities.
After marketing the project for over 30 years as an industrial park, the applicant entered into a Community Benefits
Agreement (CBA) with the City which provides an opportunity to facilitate economic growth funding for office uses within
the SR-125 corridor or the construction of facilities for academic, institutional, and innovation -related businesses within
the University Innovation District. The University Innovation District/Regional Technology Park SPA Plan provides for
development of approximately 10.1 million square feet of university and regional technologies uses, while the Eastern
Urban Center SPA Plan provides for development of approximately 3.8 million square feet of commercial/mixed use
development on 75.9 acres. This would facilitate the creation of high-quality jobs and economic growth within the City by
providing opportunities that target and attract industries and businesses that contribute to diversi fication and
stabilization of the local economy. Therefore, the project is consistent with Policies ED 1.2, 1.3, and 1.5. As discussed
above under the General Plan Housing Element, the project would include a range of housing types and opportunities.
The applicant will also enter into a Balanced Community Affordable Housing Agreement, that will increase the
diversity of housing prices and rent in the community, satisfying the project’s affordable housing obligation.
Therefore, the project is consistent with Policy ED 2.3. The project would not conflict with the Economic
Development Element of the General Plan.
Public Facilities & Services Element
The Public Facilities and Services Element establishes the City's plan to provide and maintain infrastructure and public
services for future growth, without diminishing services to existing development. Public facilities collectively refer to
utilities, such as: water; sewer; drainage; power; and telecommunications services. Public services collectively refer to
schools; libraries; law enforcement; and fire protection. This element also includes public facilities and services that
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support and enrich the community, such as: parks and recreation centers; art and cultural facilities and programs;
childcare opportunities; and health and human services. General Plan Public Facilities & Services Element objectives
relevant to the proposed project include the following (City of Chula Vista 2005):
• Objective PFS 1: Ensure adequate and reliable water, sewer, and drainage service and facilities.
• Objective PFS 2: Increase efficiencies in water use, wastewater generation and its re-use, and handling of
storm water runoff throughout the City through use of alternative technologies.
• Objective PFS 3: Ensure a long-term water supply to meet the needs of existing and future uses in Chula Vista.
• Objective PFS 4: Provide long-term wastewater treatment capacity to meet the needs of existing and new
development in Chula Vista.
• Objective PFS 5: Maintain sufficient levels of fire protection, emergency medical service and police services
to protect public safety and property.
• Objective PFS 6: Provide adequate fire and police protection services to newly developing and redeveloping
areas of the City.
• Objective PFS 24: Promote state-of-the-art telecommunication services throughout Chula Vista.
• Objective PFS 25: Efficiently handle solid waste disposal throughout the City.
Potential impacts to public facilities and services, including schools, libraries, law enforcement, and fire protection,
are discussed in Section 5.13. As discussed therein, the proposed project would pay Public Facilities Development
Impact Fees in accordance with the City’s fee schedule to ensure sufficient levels of fire protection and police
services, consistent with General Plan Objective PFS 5 and PFS 6. The proposed project is within the boundaries of
existing Community Facility Districts (CFDs) for both Chula Vista Elementary School and Sweetwater Union High
School Districts. Implementation of the CFD would ensure sufficient service by existing schools that would serve
the project site. Additionally, the proposed project would pay Park Benefit Fees, equal to the City’s Park Acquisition
and Development Fee Update, to fulfill parkland obligation requirements for population induced by the proposed
project. As such, it was determined that with payment of applicable development fees and the Park Benefit Fees,
the proposed project would result in less than significant impacts on schools, law enforcement, fire protection, and
parks and recreation. The proposed project also includes a Supplemental PFFP as required by the City’s GMO to
ensure that development of the project would not adversely impact the City’s quality of life standards by requiring
public facilities and services be provided concurrent with demand. Refer to Section 5.13 for additional information
on public services and Section 5.14, Recreation, for additional information on parks and recreation.
Potential impacts to public utilities and service systems, including water, sewer, drainage, power, and
telecommunications services are discussed in Section 5.16. As discussed therein, the proposed project would
result in less than significant impacts to water, wastewater treatment, stormwater drainage, electric power, natural
gas, and telecommunications facilities, consistent with General Plan Objectives PFS 1, 2, 4, and 24. Additionally, a
Water Supply Assessment was prepared for the proposed project, included as Appendix L2 to this EIR, and
consistent with General Plan Objective PFS 3, there would be sufficient water supply to serve the proposed project.
Finally, consistent with General Plan Objective PFS 25, there would be sufficient landfill capacity to accommodate
solid waste generated by the proposed project.
The proposed project would not conflict with the Public Facilities & Services Element of the General Plan.
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Environmental Element
The Environmental Element establishes the policy framework for improving sustainability through the responsible
stewardship of Chula Vista’s natural and cultural resources, promotion of both physical and environmental health,
and protection of persons and property from environmental hazards and noise. It contains policies that reconcile
conflicting demands created when population growth and development consumes natural resources--both
renewable and non-renewable, finite resources and environmental justice policies to help achieve a healthy
sustainable community for everyone. General Plan Environment Element objectives relevant to the proposed project
include the following (City of Chula Vista 2005):
• Objective E1: Conserve Chula Vista’s sensitive biological resources.
• Objective E3: Minimize the impacts of growth and development on water supply resources through the
efficient use and conservation of water by residents, businesses, and city government.
• Objective E6: Improve local air quality and reduce greenhouse gas emissions by minimizing the release of
air pollutants and toxic air contaminants and limiting the exposure of people to such pollutants.
• Objective E7: Promote energy conservation through the efficient use of energy and through the
development of local, non-fossil fuel-based renewable sources of energy.
• Objective E8: Minimize the amount of solid waste generated within the General Plan area that requires
landfill disposal.
• Objective E9: Protect Chula Vista’s important cultural resources and support and encourage their
accessibility to the public.
• Objective E10: Protect important paleontological resources and support and encourage public education
and awareness of such resources.
• Objective E14: Minimize the risk of injury, loss of life, and property damage associated with geologic hazards.
• Objective E16: Minimize the risk of injury and property damage associated with wildland fire hazards.
• Objective E21: Protect people from excessive noise through careful land use planning and the incorporation
of appropriate mitigation techniques.
Consistent with General Plan Objective E1, the proposed project would maintain 63.6 acres as MSCP Preserve
Open Space. Additionally, impacts to biological resources are analyzed in Section 5.3, Biological Resources. As
discussed therein, all impacts to biological resources would be mitigated to a less than significant level.
Consistent with General Plan Objective E3, a Water Supply Assessment was prepared for the proposed project, included
as Appendix L2, and impacts related to water supply resources are analyzed in Section 5.16. As discussed therein, there
would be sufficient water supply to serve the proposed project, consistent with General Plan Objective E3.
Consistent with General Plan Objective E6, impacts related to air quality are analyzed in Section 5.2, Air Quality. As
discussed therein, the proposed project would have a less-than-significant impacts on air quality.
Impacts related to greenhouse gas emissions (GHG) are analyzed in Section 5.7, Greenhouse Gas Emissions. As
discussed therein, the proposed project would result in significant and unavoidable impacts associated with
project’s efficiency metric and the state’s ability to meet future GHG emission reductions. However, the proposed
project would still implement Mitigation Measure (MM) GHG-1 (see Section 5.7.5, Mitigation Measures) to reduce
GHG emissions to the extent feasible. As such, because the proposed project would result in less-than-significant
air quality impacts and would mitigate GHG emissions to the extent feasible, the proposed project would not conflict
with General Plan Objective E6.
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Consistent with General Plan Objective E7, impacts related to energy usage are analyzed in Section 5.5, Energy. As
discussed therein, the proposed project would not result in the wasteful, inefficient, or unnecessary consumption
of energy resources.
Consistent with General Plan Objective E8, impacts related to solid waste are analyzed in Section 5.16. As discussed
therein, there would be sufficient landfill capacity to accommodate solid waste generated by the proposed project.
Consistent with General Plan Objective E9, impacts to cultural resources are analyzed in Section 5.4, Cultural and
Tribal Cultural Resources. As discussed therein, the proposed project would have potentially significant impacts
associated with the potential disturbance of previously unrecorded archaeological resources, human remains, and
tribal cultural resources. However, the proposed project would implement MM-CUL-1 (see Section 5.4.5) to reduce
potentially significant impacts related to cultural and tribal cultural resources to less-than-significant levels.
Therefore, the proposed project would not conflict with General Plan Objective E9.
Consistent with General Plan Objective E10, impacts to paleontological resources are analyzed in Section 5.6,
Geology and Soils. As discussed therein, the proposed project would have potentially significant impacts to
previously unrecorded paleontological resources. However, the proposed project would implement MM-GEO-1 (see
Section 5.6.5) to reduce potentially significant impacts to paleontological resources to a less-than-significant level.
Therefore, the proposed project would not conflict with General Plan Objective E10.
Consistent with General Plan Objective E14, impacts related to geologic hazards are analyzed in Section 5.6. As
discussed therein, the proposed project would result in less-than-significant impacts related to geologic hazards.
Consistent with General Plan Objective E16, impacts related to wildfire hazards are analyzed in Section 5.17,
Wildfire. A Fire Protection Plan (FPP) has been prepared for the proposed project and incorporated into the project
as applicable (Appendix H3). As discussed therein, the proposed project would have a potentially significant impact
associated with the project facilitating wildfire spread or exacerbating wildfire risk. However, the proposed project
would implement MM-WF-1 (see Section 5.17.5) to reduce potentially significant wildfire impacts to a less-than-
significant level. Therefore, the proposed project would not conflict with General Plan Objective E16.
Consistent with General Plan Objective E21, impacts related to noise are analyzed in Section 5.11, Noise. As
discussed therein, the proposed project would result in less-than-significant impacts related to noise.
The proposed project would not conflict with the Environmental Element of the General Plan.
Growth Management Element
Growth management refers to the conscious decision to direct the pattern and rate of development through a set
of comprehensive goals, objectives, and planning policies. The purpose of this Growth Management Element is to
describe the various components that, together, create the overall Growth Management Program that guides future
development in the City. General Plan Growth Management Element objectives relevant to the proposed project
include the following (City of Chula Vista 2005):
• Objective GM 1: Concurrent public facilities and services.
As discussed above, the proposed project would not conflict with the Public Facilities and Services Element of the
General Plan. The proposed project would pay applicable development fees for, police and fire service, and the Park
Benefit Fee for park and recreation. Additionally, the proposed project would result in less than significant impacts
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to water, wastewater treatment, stormwater drainage, electric power, natural gas, and telecommunications
facilities; and there would be sufficient landfill capacity to accommodate solid waste generated by the proposed
project. As such, adequate public services and facilities would exist to serve the proposed project and the proposed
project would result in less-than-significant impacts related to public services and facilities. Therefore, the project
would be consistent with General Plan Objective GM 1.
The proposed project would not conflict with the Growth Management Element of the General Plan.
General Plan Conclusion
As discussed above, the proposed project would not result in conflicts with any element of the General Plan. Therefore, the
proposed project would be consistent with the General Plan and no significant environmental impact would occur.
Sunbow General Development Plan and Section Planning Area Plan
The GDP contains several land use goals and objectives, as listed below, followed by consistency analysis (City of
Chula Vista 1989):
• Goal 3: It is the goal of the city to accommodate a full diversity of housing types, while maintaining an
orientation to detached single-family living.
o Objective 10: Encourage the development of a diversity of housing types and prices.
o Objective 11: Assure that new development meets or exceeds a standard of high quality planning and design.
o Objective 12: Provide for the development of multiple-family housing in appropriate areas convenient
to public services, facilities and circulation.
o Objective 13: Encourage planned developments, with a coordinated mix of urban uses, open spaces,
and amenities.
• Goal 5: Open Space, Recreation, and Visual Quality
o Objective 20: Preserve to the extent feasible natural open space areas and corridors, particularly the
major canyons and valleys, as integral and functional parts of the urban pattern. Particular emphasis
is placed on the canyons, stream valleys, and other corridors that connect to the greenbelt system and
can help to extend the greenbelt and trail system into the community.
• Goal 9: Growth Management
o Objective 27: Establish a growth management system to assure that private development is
coordinated with the provision of adequate public facilities and services.
The SPA Plan contains more specific objectives that pertain to the individual land use districts identified within the
GDP and SPA Plan. With regard to the project site, these objectives specifically pertain to development of an
Industrial Use. Similar to the General Plan, the GDP and SPA Plan identify the project site as Industrial Park and
Open Space. The existing GDP and SPA Plan designations for the project site are shown on Figures 3-3 and 3-4,
respectively. As such, the proposed project would conflict with the current GDP and SPA Plan land use designations
as described above. However, the proposed project involves amendments to the GDP and SPA Plan, changing the
land use designations from Industrial Park to Residential Multi-Family and Residential Condominium, to be
processed concurrently. These amendments to the GDP and SPA Plan would allow the proposed land uses to be
developed on the project site. As such, SPA Plan objectives for the Industrial Park District are not included herein
as they would no longer apply if the proposed project proposed amendments are approved. The City conducted a
market analysis for the site relative to its existing industrial use; this analysis determined that industrial
development of the site is unlikely to be financially feasible (HR&A 2020).
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Consistent with GDP Goal 3 and Objectives 10, 11, and 13, the proposed project would provide a variety of
housing types, recreational facilities, and open space. The proposed project would satisfy its affordable housing
obligations via a Balanced Communities Affordable Housing Agreement between the project applicant and the City. This
Balanced Communities Affordable Housing Agreement will document satisfaction with affordable housing requirements.
Consistent with GDP Goal 9 and Objectives 12 and 27, the proposed project would develop multiple-family housing
that would be sufficiently served by exiting public services, facilities, and circulation, as also previously discussed
under the General Plan consistency analysis, above. Additionally, it was determined that the proposed project would
not conflict with the General Plan, including the Public Facilities and Services Element and the Growth Management
Element. Please refer to the General Plan consistency analysis above as well as Sections 5.13 and 5.16 for
additional information.
The remaining project site acreage would be composed of open space consistent with the GDP and the SPA Plan.
Specifically, approximately 63.6 acres would be MSCP Open Space Preserve, 3.9 acres of Poggi Creek Conservation
easements, and 16.8 acres of Manufactured Slopes/Basins/Wetland Resources. Development of the proposed
project would maintain the open space designation for the remainder of the project site, consistent with GDP Goal 5
and Objective 20.
The proposed project would not conflict with the goals and objectives of the GDP. Further, upon approval, the proposed
project would not conflict with the land use designations of the GDP and SPA Plan because these plans would be
amended concurrently with development of the proposed project, to allow for the proposed land uses.
Growth Management Ordinance
The purpose and intent of the City’s GMO (CVMC Section 19.09) is to provide quality housing opportunities for all
economic sections of the community; to balance the community with adequate commercial, industrial, recreational, and
open space areas to support the residential areas of the City; to provide that public facilities, services, and improvements
meeting City standards exist or become available concurrent with the need created by new development; to control the
timing and location of development by tying the pace of development to the provision of public facilities and
improvements to conform to the City’s Threshold Standards; and to meet the goals and objectives of the Growth
Management Program and other programs associated with quality of life. The GMO prohibits new development unless
adequate public facilities are provided in advance of or concurrently with the demands created by new development. The
City’s GMO requires the provision of a PFFP, air quality implementation plan, and water conservation plan for every SPA
Plan to ensure that existing public services or financing for new public facilities would be provided for new development,
that adequate water supply would be available to serve the development, and that the project would meet air quality
standards. The proposed project includes a Supplemental PFFP as required by the City’s GMO to ensure that
development of the proposed project would not adversely impact the City’s quality of life standards by requiring
public facilities and services be provided concurrent with demand (see Appendix H3, Fire Protection Plan).
Additionally, as discussed above and in Sections 5.13 and 5.16, the payment of Public Facilities Development Impact
Fees (PFDIFs) would ensure the proposed project would not significantly impact public services and facilities. As
discussed in Section 5.2, the proposed project would have a less-than-significant impact on air quality. As discussed
in Section 5.16, there would be adequate water supply to serve the project and impacts associated with water
supply would be less than significant. Therefore, the proposed project would not conflict with the City’s GMO.
Parkland Dedication Ordinance
Chapter 17.10 of the CVMC establishes requirements for parklands and public facilities, including regulations for
the dedication of land and development of improvements for park and recreational purposes (Section 17.10.010);
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determination of park and recreational requirements (Section 17.10.020); calculation of area to be dedicated
(Section 17.10.040); specifications for park improvements (Section 17.10.050); criteria for area to be dedicated
(Section 17.10.060); procedures for in-lieu fees for land dedication and/or park development improvements
(Section 17.10.070); and other regulations regarding park development and collection and distribution of fees. The
Parkland Dedication Ordinance requires the dedication of 3 acres of parkland per 1,000 residents. The proposed
project would pay Park Benefit Fees, equal to the City’s Park Acquisition and Development Fee Update, to fulfill
parkland obligation requirements for population induced by the proposed project. As such, it was determined that
with payment of all applicable development fees, the proposed project would result in less than significant impacts
on parks and recreation facilities. Therefore, the proposed project would not conflict with the City’s Parkland
Dedication Ordinance.
Parks and Recreation Master Plan
The City’s PRMP was adopted in 2002 and a Draft Update was completed in 2018. The PRMP is the blueprint for
the City’s park system through the year 2030. The PRMP identifies existing park and recreation facilities and
provides guidance for future park sites, including locations for specific types of additional recreational facilities. The
PRMP envisions a comprehensive and interrelated package of community and neighborhood parks and presents
each park within the context of the whole park system to ensure that it provides a balance of rec reational
opportunities. The PRMP states that the year 2030 citywide park system will contain community, neighborhood,
mini, urban, and special-purpose parks and recreation facility and community center sites. The City PRMP includes
a set of goals and policies for the City’s parks and recreation aspirations. These goals and policies are as follows
(City of Chula Vista 2018):
• Goal #1: Fulfilling the Comprehensive Park System Need
Create a comprehensive parks and recreation system that meets the needs of the general public of Chula
Vista by effectively distributing park types and their associated recreation facilities and programs and by
using quasi-public resources.
o Policy 1.1: Continue to require new development to comply with the Parklands and Public Facilities
Ordinances, Chapter 17.10 of the Chula Vista Municipal Code (CVMC17.10), requiring a level of service
standard of a minimum ratio of three acres of public parkland per 1,000 population so that new
development will meet the demands created by these projects.
o Policy 1.3: The City will only allow the developer to receive credit towards their public parkland
obligation for new development when the parkland they provide to the City meets the criteria
established in the Master Plan for Community, Neighborhood, Mini, Urban, and Town Square parks.
• Goal #2: Priorities for Allocation of Resources
Establish priorities for allocation of existing and future public parkland resources that balance public
priorities and needs with quality of parks and facilities.
• Goal #3: Implementation Program
Provide a program for implementation of the City’s Goals and Policies contained herein to ensure the
continued development of a comprehensive parks and recreation system providing citywide resources for
recreation services and programs that meet the needs of its citizens.
As discussed above, the proposed project would comply with the City’s Parkland Dedication Ordinance. The
proposed project would pay Park Benefit Fees, equal to the City’s Park Acquisition and Development Fee Update,
to fulfill parkland obligation requirements for population induced by the proposed project. As such, it was
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determined that with payment of Park Benefit Fee, the proposed project would result in less than significant impacts
on parks and recreation facilities, consistent with the goals and policies of the Parks and Recreation Master Plan
listed above. Therefore, the proposed project would not conflict with the Parks and Recreation Master Plan.
Airport Land Use Compatibility Plan–Brown Field
The San Diego County Regional Airport Authority, designated as the Airport Land Use Commission for all public
airports in the County of San Diego, adopted the Brown Field ALUCP in September 1981 and it was last updated in
December 2010. The ALUCP assists in achieving compatible land use development in the area surrounding Brown
Field airport located in Otay Mesa on Heritage Road, east of I -805. The airport is a general aviation airport
accommodating both propeller- and jet-powered aircraft and serves as a port of entry for private aircraft coming
into the United States from Mexico. Brown Field is also heavily used by military and law enforcement agencies and
is classified as a “reliever airport” by the Federal Aviation Administration (SDCRAA 2010). The A LUCP designates
the airport influence area and contains projected noise contours, flight activity zones, a land use compatibility matrix
and plan recommendations for areas surrounding the Brown Field airport. A portion of the project site is located in
Review Area 2 of the Brown Field Airport Influence Area, but the entire project site is located outside of safety and
noise zones for Brown Field Airport. The entire project site is also located within the FAA Height Notification
Boundary. The project applicant would be required to notify the FAA of the proposed project. However, no conflicts
with the Brown Field ALUCP would occur.
City’s Multiple Species Conservation Program Subarea Plan
The proposed project includes an MSCP Boundary Line Adjustment to correct an inadvertent error in the MSCP
that placed a 100% Preserve overlay on the project site even though the project was not identified as a Covered
Project. As a part of the proposed MSCP Boundary Line Adjustment, the proposed project is required to propose
a potentially suitable area currently located outside of the MSCP Preserve to incorporate into the MSCP Preserve
at a 1:1 acreage ratio. The proposed MSCP Boundary Line Adjustment would be required to result in equal or
higher biological value as compared to the existing MSCP Preserve. The determination of biological value of the
proposed MSCP Preserve Boundary Line Adjustment shall be made by the City, as the local jurisdiction, in
concurrence with USFWS and CDFW. A functional equivalency and Boundary Line Adjustment analysis has been
prepared for the project and is included in Appendix D. The proposed MSCP Boundary Adjustment would meet
the MSCP Boundary Line Adjustment functional equivalency criteria and would result in a 0.09-acre increase to
the MSCP Preserve Area. As discussed in Section 5.3, the proposed project would not result in conflicts with the
City’s MSCP Subarea Plan through compliance with the MSCP Boundary Line Adjustment functional equivalency
criteria. Moreover, all impacts to biological resources would be mitigated to a less than significant level. As such,
no conflicts with the City’s MSCP Subarea Plan would occur.
Conclusion
As demonstrated throughout the analysis for Threshold B, the proposed project would not result in 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. Impacts would be less than significant.
5.10.4 Level of Significance Prior to Mitigation
Impacts related to land use and planning would be less than significant
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5.10.5 Mitigation Measures
No mitigation measures would be required.
5.10.6 Level of Significance After Mitigation
No mitigation measures would be required. Impacts related to land use and planning would be less than significant.
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INTENTIONALLY LEFT BLANK
5.11– Noise
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5.11 Noise
This section of the environmental impact report (EIR) addresses the potential noise impacts resulting from the
implementation of the proposed Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II, Phase
3 Project (project or proposed project). The discussion found in this section is based on the Noise Assessment
Technical Report for the proposed project that was prepared by Dudek. The complete report is contained in
Appendix J of this EIR.
5.11.1 Existing Conditions
5.11.1.1 Regulatory Framework
Federal
Federal Transit Administration
In its Transit Noise and Vibration Impact Assessment guidance manual, the Federal Transit Administration (FTA)
recommends a daytime construction noise level threshold of 80 dBA Leq over an 8-hour period (FTA 2018) when
detailed construction noise assessments are performed to evaluate potential impacts to community residences
surrounding a project. Although this FTA guidance is not a regulation, it can serve as a quantified standard in the
absence of such noise limits at the state and local jurisdictional levels.
State
California Code of Regulations, Title 24
Title 24 of the California Code of Regulations sets standards that new development in California must meet.
According to Title 24, interior noise levels are not to exceed 45 A-weighted decibel Community Noise Equivalent Level
(dBA CNEL) in any habitable room (ICC 2019).
California Department of Health Services Guidelines
The California Department of Health Services has developed guidelines of community noise acceptability for use by
local agencies (OPR 2017). Selected relevant levels are listed here:
• Below 60 dBA CNEL: normally acceptable for low-density residential use
• 50 to 70 dBA: conditionally acceptable for low-density residential use
• Below 65 dBA CNEL: normally acceptable for high-density residential use and transient lodging
• 60 to 70 dBA CNEL: conditionally acceptable for high-density residential, transient lodging, churches,
educational, and medical facilities
The normally acceptable exterior noise level for high-density residential use is up to 65 dBA CNEL. Additionally, this
exterior noise level limit is consistent with the City of Chula Vista (City) General Plan Noise Element (City of Chula Vista
2005), which considers multi- family units noise-sensitive land uses.
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California Department of Transportation
In its Transportation and Construction Vibration Guidance Manual (Caltrans 2013 a), the California Department of
Transportation (Caltrans) recommends 0.5 inches per second (ips) peak particle velocity (PPV) as a threshold for
the avoidance of structural damage to typical newer residential buildings exposed to continuous or frequent
intermittent sources of groundborne vibration. For transient vibration events, such as blasting, the damage risk
threshold would be 1.0 ips PPV (Caltrans 2013a) at the same type of newer residential structures. For older
structures, these guidance thresholds would be more stringent: 0.3 ips PPV for continuous/intermittent vibration
sources, and 0.5 ips PPV for transient vibration events. With respect to human annoyance, Caltrans guidance
indicates that building occupants exposed to continuous groundborne vibration in the range of 0.2 -0.6 ips PPV
would find it “unpleasant or “annoying” and therefore a likely significant impact. Although these Caltrans guidance
thresholds are not regulations, they can serve as quantified standards in the absence of such limits at the local
jurisdictional level.
Local
City of Chula Vista Municipal Code 19.68 (Noise Ordinance)
The City of Chula Vista Noise Ordinance (Chula Vista Municipal Code [CVMC] Section 19.68) (City of Chula Vista
2020) contains regulations restricting land use related noise-generating activities and operations, so as to avoid
noise nuisance in the community. Section 19.68.030 of the CVMC establishes the maximum allowable exterior
noise limits, based upon the classification of the receiving land use. These standards typically apply to stationary
sources such as noise from mechanical equipment (including mechanical ventilation and air condition noise, pool
pump noise, etc.) or event noise, as opposed to traffic noise. For instance, a school, commercial enterprise, or
industrial operation must not generate noise that exceeds a certain specified noise level at a ny property boundary
where an adjacent residential use exists. The property-line noise standards are presented in Table 5.11-1.
Table 5.11-1. City of Chula Vista Exterior Property-Line Noise Limits
Receiving Land Use Category
Noise Level (dBA)
10 p.m. to 7 a.m. (Weekdays) 7 a.m. to 10 p.m. (Weekdays)
10 p.m. to 8 a.m. (Weekends) 8 a.m. to 10 p.m. (Weekends)
All residential (except multiple dwelling) 45 55
Multiple-dwelling residential 50 60
Commercial 60 65
Light industry – I-R and I-L zone 70 70
Heavy industry – I zone 80 80
Source: Appendix J.
Note: dBA = A-weighted decibels
Title 17 of the CVMC (Environmental Quality), Chapter 24, addresses managing noisy and disorderly conduct. Section
17.24.040.C.8 specifically addresses restrictions against generation of construction noise in overnight periods. The
use of any tools, power machinery, or equipment, or the conduct of construction and building work in residential zones
so as to cause noises disturbing to the peace, comfort, and quiet enjoyment of property of any person residing or
working in the vicinity, shall be prohibited between the hours of 10:00 p.m. and 7:00 a.m., Monday–Friday, and
between the hours of 10:00 p.m. and 8:00 a.m., Saturday and Sunday, except when the work is necessary for
emergency repairs required for the health and safety of any member of the community (City of Chula Vista 2020).
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Although the City does not set specific numerical limits for noise associated with temporary construction
activities, it can be perceived as a nuisance; therefore, the City restricts the times of day when construction may
occur (7:00 a.m.–10:00 p.m., Monday–Friday, and 8:00 a.m.–10:00 p.m., Saturday and Sunday).
5.11.1.2 Existing Setting
The project site is located within the East Planning Area of the City, as identified in the General Plan (City of Chula
Vista 2005). More specifically, the approximately 135.7-acre project site is located south of Olympic Parkway, and
generally between Brandywine Avenue and Heritage Road. The Otay Landfill is located to the south and southeast of
the site and undeveloped land approved for industrial and residential land uses is located to the east. Existing
Olympic Parkway, a six-lane prime arterial roadway, forms the northern boundary of the project site. The project site
currently consists of vacant and undeveloped land.
5.11.1.3 Noise Characteristics
Sound is mechanical energy transmitted by pressure waves in a compressible medium, such as air. Noise is defined
as sound that is loud, unpleasant, unexpected, or undesired. The sound pressure level (SPL) has become the most
common descriptor used to characterize the loudness of an ambient sound level. The unit of measurement of sound
pressure is a decibel (dB). Under controlled conditions in an acoustics laboratory, the trained, healthy human ear
is able to discern changes in sound levels of 1 dB when exposed to steady, single-frequency signals in the mid-
frequency range. Outside such controlled conditions, the trained ear can detect changes of 2 dB in normal
environmental noise. However, it is widely accepted that the average healthy ear can barely perceive noise level
changes of 3 dB. A change of 5 dB is readily perceptible, and a change of 10 dB is perceived as twice or half as loud
(Caltrans 2013b). A doubling of sound energy results in a 3 dB increase in sound, which means that a doubling of
sound energy (e.g., doubling the number of daily trips along a given road) would result in a barely perceptible change
in sound level.
Sound may be described in terms of level or amplitude (measured in dB), frequency or pitch (measured in hertz or
cycles per second), and duration (measured in seconds or minutes). Because the human ear is not equally sensitive
to sound at all frequencies, a special frequency-dependent rating scale is used to relate noise to human sensitivity.
The A-weighted decibel (dBA) scale performs this compensation by discriminating against low and very high
frequencies in a manner approximating the sensitivity of the human ear.
Several descriptors of noise (a.k.a., noise metrics) exist to help predict average community reactions to the adverse
effects of environmental noise, including traffic-generated noise. These descriptors include the equivalent noise
level over a given period (Leq), the day–night average noise level (Ldn), and the community noise equivalent level
(CNEL). Each of these descriptors uses units of dBA.
Leq is a decibel quantity that represents the constant or energy-averaged value equivalent to the amount of variable
sound energy received by a receptor during a time interval. For example, a 1-hour Leq measurement of 60 dBA would
represent the average amount of energy contained in all the noise that occurred in that hour. L eq is an effective
noise descriptor because of its ability to assess the total time-varying effects of noise on sensitive receptors, which
can then be compared to an established Leq standard or threshold of the same duration. Another descriptor is
maximum sound level (Lmax), which is the greatest sound level measured during a designated time interval or event.
The minimum sound level (Lmin) is often called the floor of a measurement period.
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Unlike the Leq, Lmax, and Lmin metrics, Ldn and CNEL descriptors always represent 24-hour periods and differ from a
24-hour Leq value because they apply a time-weighted factor designed to emphasize noise events that occur during
the non-daytime hours (when speech and sleep disturbance is of more concern). Time weighted refers to the fact
that Ldn and CNEL penalize noise that occurs during certain sensitive periods. In the case of CNEL, noise occurring
during the daytime (7:00 a.m. to 7:00 p.m.) receives no penalty. Noise during the evening (7:00 p.m. to 10:00 p.m.)
is penalized by adding 5 dB to the actual levels, and nighttime (10:00 p.m. to 7:00 a.m.) noise is penalized by
adding 10 dB to the actual levels. Ldn differs from CNEL in that the daytime period is longer (defined instead as 7:00
a.m. to 10:00 p.m.), thus eliminating the dB adjustment for the evening period. L dn and CNEL are the predominant
criteria used to measure roadway noise affecting residential receptors. These two metrics generally differ from one
another by no more than 0.5–1 dB and are often considered or actually defined as being essentially equivalent by
many jurisdictions.
5.11.1.4 Vibration Fundamentals
Vibration is oscillatory movement of mass (typically a solid) over time. It is described in terms of frequency and
amplitude and, unlike sound, can be expressed as displacement, velocity, or acceleration. For environmental
studies, vibration is often studied as a velocity that, akin to the discussion of sound pressure levels, can also be
expressed in dB as a way to cast a large range of quantities into a more convenient scale and with respect to a
reference quantity. Vibration impacts to buildings are generally discussed in terms of in ips PPV, which will be used
herein to discuss vibration levels for ease of reading and comparison with relevant standards. Vibration can also be
annoying and thereby impact occupants of structures, and vibration of sufficient amplitude can disrupt sensitive
equipment and processes (Caltrans 2013a), such as those involving the use of electron microscopes and
lithography equipment. Common sources of vibration within communities include construction activities and
railroads. Groundborne vibration generated by construction projects is usually highest during pile driving, rock
blasting, soil compacting, jack hammering, and demolition-related activities where sudden releases of subterranean
energy or powerful impacts of tools on hard materials occur. Depending on their distances to a sensitive receptor,
operation of large bulldozers, graders, loaded dump trucks, or other heavy construction equipment and vehicles on
a construction site also have the potential to cause high vibration amplitudes.
5.11.1.5 Ambient Noise Monitoring
SPL measurements were conducted near the proposed project site on April 2, 2020, to quantify and characterize
the existing outdoor ambient sound levels. Table 5.11-2 provides the location, date, and time period at which these
baseline noise level measurements were performed by a Dudek field investigator using a Rion-branded Model NL-
52 sound level meter (SLM) equipped with a 0.5-inch, pre-polarized condenser microphone with pre- amplifier. The
SLM meets the current American National Standards Institute standard for a Type 1 (Precision Grade) sound level
meter. The accuracy of the SLM was verified using a field calibrator before and after the measurements, and the
measurements were conducted with the microphone positioned approximately 5 feet above the ground.
Four short-term (ST) noise level measurement locations (ST1–ST4) that represent existing noise-sensitive receivers
were selected on and near the proposed project site. ST1 and S2 two are associated with existing residences
located to the north and southwest of the site, respectively. ST3 was used as traffic calibration along Olympic
Parkway. ST 4 was chosen as an acoustically equivalent site to represent where the future buildings would be
located, as access to the development site was not granted at the time. These locations are depicted as receivers
ST1–ST4 on Figure 5.11-1, Noise Measurement and Modeling Locations. The measured Leq and Lmax noise levels
are provided in Table 5.11-2. The primary noise sources at the sites identified in Table 5.11-2 consisted of traffic
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along adjacent roadways, the sounds of leaves rustling, and birdsong. As shown in Table 5.11-2, the measured SPL
ranged from approximately 67.2 dBA Leq at ST3 to 45.6 dBA Leq at ST2. Beyond the summarized information
presented in Table 5.11-2, detailed noise measurement data is included in Appendix A, Baseline Noise
Measurement Field Data of Appendix J.
Table 5.11-2. Measured Baseline Outdoor Ambient Noise Levels
Site Location/Address Date/Time Leq (dBA) Lmax (dBA)
ST1 East of 760 De La Toba Rd
Chula Vista, California 91911
2020-04-02, 11:50 AM
to 12:00 PM
55.1 59.8
ST2 East of 651 Point Buchon Court,
Chula Vista, California 91911
2020-04-02, 10:50 AM
to 11:00 AM
45.6 52.9
ST3 East 1501 Brandywine Ave
Chula Vista, California 91911
2020-04-02, 11:05 AM
to 11:15 AM
67.2 81.2
ST4 Western boundary of proposed project 2020-04-02, 11:20 AM
to 11:30 AM
56.3 68.5
Source: Appendix A of Appendix J.
Notes: Leq = equivalent continuous sound level (time-averaged sound level); Lmax = maximum sound level during the measurement
interval; dBA = A-weighted decibels; ST = short-term noise measurement locations.
Generally, the measured samples of daytime Leq agree with expectations: ST3 is above 67 dBA due largely to its
proximity to Olympic Parkway, a major roadway; ST4 is farther up the bluff at the western boundary of the proposed
project; and ST1 and ST2 are well within the residential neighborhoods and much more distant from these sources
of roadway traffic noise.
5.11.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to noise is based on the recommendations provided
in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). A significant impact would occur if the project would:
A. Generate of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the
project in excess standards established in the local general plan or noise ordinance, or applicable
standards of other agencies.
B. Generate excessive groundborne vibration or groundborne noise levels.
C. 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.
In light of these above significance criteria, this analysis uses the following standards to evaluate potential noise
and vibration impacts.
• Construction noise – The City regulates construction noise by restricting the allowable hours of construction.
Section 9.40.110 of the CVMC exempts construction noise from the stationary noise standards, provided that
construction occurs between 7:00 a.m. and 10:00 p.m., Monday through Friday, and 8:00 a.m. to 10:00 p.m.,
Saturday and Sunday. Through adherence to the limitation of allowable construction times provided in the CVMC,
the construction-related noise levels would not exceed any standards. The existing residential receptors to the
southwest of the proposed project site suggest that source-to-receiver distances are greater than 900 feet.
Additionally, most construction equipment and vehicles on a project site do not operate continuously. To verify
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noise levels during construction would not be significant, consistent with the FTA guidance mentioned in Section
5.11.1.1, Regulatory Setting, this analysis will use 80 dBA Leq over an 8-hour period as the construction noise
impact criterion during daytime hours 7:00 a.m. and 10:00 p.m. Monday through Friday, and 8:00 a.m. to 10:00
p.m., Saturday and Sunday.
• Off-site project-attributed transportation noise – For purposes for this analysis, a direct roadway noise
impact would be considered significant if increases in roadway traffic noise levels attributed to the
proposed project were greater than 3 dBA CNEL at an existing noise-sensitive land use.
• Off-site project-attributed stationary noise – For purposes for this analysis, a noise impact would be
considered significant if noise from typical operation of heating, ventilation, and air conditioning and other
electro-mechanical systems associated with the proposed project exceeded 50 dBA hourly Leq at the
property line from 7:00 a.m. to 9:59 p.m., and 45 dBA hourly Leq from 10:00 p.m. to 6:59 a.m.
• Construction vibration – Guidance from Caltrans indicates that a vibration velocity level of 0.2 ips PPV
received at a structure would be considered annoying by occupants within (Caltrans 2013a). As for the
receiving structure itself, aforementioned Caltrans guidance from Section 2 recommends that a vibration
level of 0.3 ips PPV would represent the threshold for building damage risk.
For purposes of disclosure, since current CEQA noise criteria listed above do not consider it, this analysis also
evaluates compatibility of on-site noise levels with the City’s exterior and interior noise standards of 65 dBA CNEL
and 45 dBA CNEL, respectively.
5.11.3 Impacts
A. Generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the
project in excess standards established in the local general plan or noise ordinance, or applicable
standards of other agencies.
Construction
Construction noise and vibration are temporary phenomena. Construction noise and vibration levels vary from
hour to hour and day to day, depending on the equipment in use, the operations performed, and the distance
between the source and receptor.
Equipment that would be in use during construction would include, in part, graders, backhoes, excavators, dump
trucks, loaders, cranes, dozers, gradalls, scrapers, cement mixers, pavers, rollers, welders, and air compressors.
The typical maximum noise levels for various pieces of construction equipment at a distance of 50 feet are
presented in Table 5.11-3. Usually, construction equipment operates in alternating cycles of full power and low
power, producing average noise levels over time that are less than the listed maximum noise level. The average
sound level of construction activity also depends on the amount of time that the equipment operates and the
intensity of construction activities during that time.
Table 5.11-3. Typical Construction Equipment Maximum Noise Levels
Equipment Type Typical Equipment (Lmax, dBA at 50 Feet)
Air compressor 78
Backhoe 78
Concrete pump truck 81
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Table 5.11-3. Typical Construction Equipment Maximum Noise Levels
Equipment Type Typical Equipment (Lmax, dBA at 50 Feet)
Dozer 85
Grader 85
Crane 81
Gradall 85
Scraper 85
Dump truck 76
Roller 80
Generator 72
Front-end loader 79
Paver 77
Welder 74
Source: Appendix J.
Note: dBA = A-weighted decibels
Aggregate noise emission from proposed project construction activities, broken down by sequential phase, was
predicted at three distances to the nearest existing noise-sensitive receptor: (1) from the nearest position of the
construction site boundary to the closest northern receptor, (2) from the nearest position of the construction site
boundary to the closest western receptor, and (3) from the nearest position of the proposed new road boundary
to the closest northern receptor. The intent of these distances is to help evaluate anticipated construction noise
from a limited quantity of typical equipment or vehicle activity expected to be at the boundary for some period of
time, which would be most appropriate for phases such as site preparation, grading, and paving. Table 5.11 -
4 summarizes these three distances to the apparent closest noise-sensitive receptor for each of the five
sequential construction phases. This analysis conservatively assumes a “worst-case” condition that places all
pieces of construction equipment of each listed type per phase at the site boundary for the entire 8-hour period.
In reality, at any given time some equipment may be further away from the site boundary.
Table 5.11-4. Estimated Distances between Construction Activities and the Nearest Noise-
Sensitive Receptors
Construction Phase
(and Equipment Types Involved)
Distance from Nearest
Noise Sensitive
Receptor to North of
Construction Site
Boundary (Feet)
Distance from
Nearest Noise
Sensitive Receptor
to West of
Construction Site
Boundary (Feet)
Distance from
Nearest Noise
Sensitive Receptor to
North of Proposed
New Road Boundary
(Feet)
Architectural Coating (air compressor) 895 940 N/A
Site Preparation (dozer, front-end loader) 895 940 580
Grading (excavator, grader, dozer,
scraper, backhoe)
895 940 580
Building Construction (crane, gradall,
generator, backhoe, welder)
895 940 N/A
Paving (paver, dump truck, roller) 895 940 580
Source: Appendix J.
Note: N/A = not applicable.
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A Microsoft Excel–based noise prediction model emulating and using reference data from the Federal Highway
Administration Roadway Construction Noise Model (RCNM) (FHWA 2008) was used to estimate construction noise
levels at the nearest occupied noise-sensitive land use.1 Input variables for the predictive modeling consist of the
equipment type and number of each (e.g., two graders, a loader, a tractor), the duty cycle for each piece of equipment
(e.g., percentage of time within a specific time period, such as an hour, when the equipment is expected to operate at
full power or capacity and therefore make noise at a level comparable to what is presented in Table 5.11-3, and the
distance from the noise-sensitive receiver. The predictive model also considers how many hours that equipment may
be on site and operating (or idling) within an established work shift. Conservatively, no intervening topographical or
structural shielding was assumed in the modeling. The RCNM has default duty-cycle values for the various pieces of
equipment, which were derived from an extensive study of typical construction activity patterns. Those default duty-
cycle values were used for this noise analysis, which is detailed in Appendix B, Construction Noise Modeling Input and
Output, of Appendix J, and produce the predicted results displayed in Table 5.11-5.
Table 5.11-5. Predicted Construction Noise Levels per Activity Phase
Construction Phase
(and Equipment Types Involved)
8-Hour Leq at Nearest
Noise Sensitive
Receptor to North of
Construction Site
Boundary (dBA)
8-Hour Leq at Nearest
Noise Sensitive
Receptor to West of
Construction Site
Boundary (dBA)
8-Hour Leq at Nearest
Noise Sensitive
Receptor to North of
Proposed New Road
Boundary (dBA)
Architectural Coating (air compressor) 48.6 48.2 N/A
Site Preparation (dozer, front-end loader) 59.8 59.4 63.6
Grading (excavator, grader, dozer,
scraper, backhoe)
62.0 61.6 65.8
Building Construction (crane, gradall,
generator, backhoe, welder)
61.1 60.7 N/A
Paving (paver, dump truck, roller) 56.0 55.6 59.8
Source: Appendix J.
As presented in Table 5.11-5, the estimated construction noise levels are predicted to be less than 66 dBA Leq over
an 8- hour period at the nearest existing residences (as close as 580 feet away) when site preparation activities take
place near the northern project boundaries. Note that these estimated noise levels at a source-to-receiver distance of
580 feet would occur when noted pieces of heavy equipment would each operate for a cumulative period for 8 hours
a day. The predicted operation of construction equipment and processes do not exceed noise levels of 80 dBA Leq,
which the FTA recommends as a daytime threshold for construction noise exposure over an 8-hour period at a
residential receptor. Consistent with Section 9.40.110 of the CVMC, construction activities associated with the
proposed project would only take place within the hours of 7:00 a.m. and 10:00 p.m., Monday through Friday, and
8 a.m. to 10 p.m., Saturday and Sunday. In summary, typical construction noise during allowable daytime
hours would not exceed the FTA guidance -based standard. Thus, temporary construction -related noise
impacts would be less than significant.
1 Although the RCNM was funded and promulgated by the Federal Highway Administration, it is often used for non-roadway projects,
because the same types of construction equipment used for roadway projects are often used for other types of construction.
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Operational
Roadway Traffic Noise
The proposed project would result in the creation of additional vehicle trips on local roadways (i.e., Olympic
Parkway), which could result in increased traffic noise levels at adjacent noise -sensitive land uses. Appendix C,
Traffic Noise Modeling Input and Output, of Appendix J, contains a spreadsheet with average daily traffic converted
to peak hour traffic for Olympic Parkway and surrounding arterial roadways. These peak hour volumes were
calculated by taking 10% of the average daily traffic and using a vehicle distribution of 97% autos, 2% medium
trucks, and 1% heavy trucks. Consistent with the worked example in the Caltrans Technical Noise Supplement
(“TeNS”) that is considered “fairly typical,” peak hour volume is assumed to be 10% of average daily traffic (Caltrans
2013b). In particular, the proposed project would create additional traffic along Olympic Parkway, which according
to the Traffic Impact Assessment prepared for the proposed project (Appendix K) would add 5,760 average daily
trips to the segment of Olympic Parkway and adjacent roadways surrounding the project site.
Potential noise effects from vehicular traffic were assessed using the Federal Highway Administration’s Traffic
Noise Model version 2.5 (FHWA 2004). Information used in the model included the roadway geometry, posted
traffic speeds, and traffic volumes for the following scenarios: existing (year 2019), existing plus project, near -
term (2024), and near-term plus project. Noise levels were modeled at representative noise-sensitive receivers
ST1 through ST4, as shown in Figure 5.11-1.
The General Plan Noise Element establishes a policy for exterior sensitive areas to be protected from high noise
levels. The Noise Element sets 65 dBA CNEL for the outdoor areas and 45 dBA CNEL for interior areas as the
normally acceptable levels. However, existing levels from traffic already exceed this threshold in the vicinity of
ST3. For the purposes of this noise analysis, such impacts are considered significant when they cause an increase
of 3 dB from existing noise levels. An increase or decrease in noise level of at least 3 dB is required before any
noticeable change in community response would be expected (Caltrans 2013 b). The receivers were modeled to
be 5 feet above the local ground elevation. The noise model results are summarized in Table 5.11-6.
Table 5.11-6. Roadway Traffic Noise Modeling Results
Modeled
Receiver Tag
(Location
Description)
Existing (2019)
Noise Level
(dBA CNEL)
Existing (2019)
Plus Project
Noise Level
(dBA CNEL)
Near-term
(2024) Noise
Level (dBA
CNEL)
Near-term
(2024) Plus
Project Noise
Level (dBA
CNEL)
Maximum
Project-Related
Noise Level
Increase (dB)
ST1 59.1 61.1 61.8 62.1 2.0
ST2 48.9 48.5 49.2 49.2 0.0
ST3 71.1 70.8 71.4 72.1 0.7
ST4 63.9 62.9 63.5 63.8 0.3
Source: Appendix J.
Notes: dBA = A-weighted decibel; CNEL = Community Noise Equivalent Level; dB = decibel.
Table 5.11-6 shows that at all four listed representative receivers, the addition of proposed project traffic to the
roadway network would result in a CNEL increase of less than 3 dB, which is below the discernible level of change
for the average healthy human ear. At some modeled locations, expected traffic noise levels are predicted to
decrease due to introduction of the proposed new buildings as sound path occlusion between them and the
roadway noise source. Thus, a project–related impact to off-site traffic noise increases affecting existing
residences in the vicinity would be less than significant.
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Traffic Noise Exposure to Future Project Occupants
Aside from exposure to aviation traffic noise, current CEQA noise-related guidelines do not require an assessment
of exterior-to-interior noise intrusion, environmental noise exposure to occupants of newly-created project
residences, or environmental noise exposure to exterior non-residential uses attributed to the development of
the proposed project. Nevertheless, the California Building Code requires that interior background noise levels
not exceed a CNEL of 45 dB within habitable rooms. Hence, the following predictive analysis of traffic noise
exposure at the exteriors of occupied residences and outdoor living areas is provided for informational purposes.
In addition to the prediction results presented in Table 5.11-6, the Federal Highway Administration Traffic Noise
Model software was also used to predict the Near-Term Plus Project scenario traffic noise levels at multiple on-
site exterior areas, as listed in Table 5.11-7. Modeled receptor locations, which appear in Figure 5.11-1, include
representative positions for the exteriors of the northern facades.
Table 5.11-7. On-Site Roadway Traffic Noise Modeling Results
Location Modeled Receiver Description
Predicted Traffic Noise Exposure at Modeled
Receiver (dBA CNEL)
Product B M1-1 Patio 59.2
M1-2 2nd floor 64.1
M2-1 Patio 59.2
M2-2 2nd floor 64.2
M3-1 Patio 57.6
M3-2 2nd floor 63.1
M4-1 Patio 58.1
M4-2 2nd floor 63.4
Product C M5-1 Patio 58.6
M5-2 2nd floor 64.0
M5-3 3rd floor 64.9
M6-1 Patio 58.6
M6-2 2nd floor 64.1
M6-3 3rd floor 64.9
Source: Appendix J.
Notes: dBA = A-weighted decibel; CNEL = Community Noise Equivalent Level.
Table 5.11-7 shows that at the modeled northern facade positions representing exterior walls of occupied living
rooms or bedrooms that are closest to and face Olympic Parkway, predicted on -site CNEL values are all less than
65 dBA and all other modeled locations are consistent with the City’s guidance for exterior noise levels.
Typically, when they feature open windows, building shells provide an average of 12 –18 dB (OPR 2017) of exterior-
to-interior noise reduction. Such building facades typical of residential construction with windows closed generally
provide a minimum of 25 dB exterior-to-interior noise attenuation (FHWA 2011). An analysis of composite sound
transmission class (STC) of sample project exterior wall assemblies, including fenestration, supports these general
assertions as shown in Table 5.11-8 and are based on the following parameters:
• The exterior wall assembly includes (or is acoustically comparable to): one layer of 5/8” gypsum wallboard
on the interior-facing side, 2”×4” wood studs, glass fiber batt insulation in the stud cavities, and a thin
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stucco/plaster coating on one layer of 5/8” gypsum wallboard (or what may instead be underlying wooden
structural panels or sheeting having comparable mass).
• Windows are assumed to be single hung operable windows, featuring dual pane assembly composed of
two 1/8”-thick glass panes separated by a 3/8” wide air-gap.
• For purposes of this analysis, doors are sliding-type and assumed to feature a dual-pane glazing system
similar to the window assembly (i.e., two 1/8”-thick glass panes separated by a 3/8” wide air-gap) in narrow-
perimeter frames. The analysis also assumes that these door products—akin to the windows—feature good
seals and related hardware, so that when closed, the effective sound insulating performance is represented
by the gap-separated glass panes.
Table 5.11-8. Predicted Net Sound Transmission Class of Sample Occupied Room Facade
Building &
Sample
Occupied
Unit
Occupied
Room Facade
Predicted Net STC for Scenario
Closed
Window(s)
and Door(s)
Open
Window
Open
Window,
Closed Door
Open Door,
Closed
Window
Open Door,
Open
Window
B 2nd-floor
bedroom
36 11 11 11 11
C 2nd-floor living
room
35 N/A N/A N/A N/A
C 3rd-floor
bedroom
36 12 12 12 12
Source: Appendix J.
Notes: STC = sound transmission class; N/A = not applicable.
Table 5.11-8 illustrates that an open window or an open sliding door to an adjoining patio or balcony greatly
compromises the sound insulation performance of the studied wall assemblies. However, when such windows
and doors are closed, all studied sample facades are anticipated to exhibit a predicted STC rating of at least 35
and therefore would provide sufficient exterior-to-interior sound insulation from outdoor traffic noise to yield
interior background sound levels that are less than 45 dBA CNEL and thus compliant with the City and state
standards. Recall that none of the predicted exterior traffic noise levels at the studied receptor locations
exceeded 65 dBA CNEL; therefore, the STC rating value (for closed windows and doors) subtracted from these
exterior noise values must result in interior noise levels of less than 45 dBA CNEL (e.g., 65 – 35 = 30 dBA CNEL,
which is less than 45). The apparent requirement for closed windows and doors means that the design of these
habitable rooms should feature mechanical ventilation or an air-conditioning system to provide interior comfort
of the occupants. Thus, implementation of Project Design Feature (PDF) NOI-1, Exterior-to-Interior Noise Analysis
(see Section 4.4.8, Project Design Features, for details) would help demonstrate that the expected resultant
interior background noise level for inhabited rooms in the proposed project would meet the state and City interior
noise standard of 45 dBA CNEL.
Stationary Operations Noise
The incorporation of new multifamily homes and a mix of open space uses attributed to development of the
proposed project will add a variety of noise-producing mechanical equipment that include those presented and
discussed in the following paragraphs. Most of these noise-producing equipment or sound sources would be
considered stationary or limited in mobility to a defined area. Using a Microsoft Excel-based outdoor sound
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propagation prediction model, project- attributed operational noise at nearby community receptors was predicted
using several assumptions:
• Treatment of exposed patio air-cooled condensing units as point-type sound emission sources; and,
• Point-source sound propagation (i.e., 6 dB per doubling of distance) that conservatively ignores acoustical
absorption from atmospheric and ground surface effects.
• These condenser units would generally be installed near building exterior walls in private area “backyards”
or external areas.
• While the condenser units are expected to be at-grade, the prediction model conservatively ignores
potential noise path occlusion due to intervening building locations. Hence, should the proposed project
design develop further and position these condenser units above grade level (e.g., on rooftops or balconies),
the predictive analysis would still be considered accurate.
Please see Appendix D of Appendix J for quantitative details of the below predictions.
Residential Unit Heating, Ventilation, and Air Conditioning Noise
For purposes of this analysis, each of the new occupied residential units would be expected to feature a split-
system type air-conditioning unit, with an air-cooled refrigeration (2-ton capacity) condenser unit at grade level.
Assuming each condenser unit has an SPL of 68 dBA at 3 feet based on available data from a likely manufacturer
(Carrier 2012), the closest existing noise-sensitive residential receptor to the south of the proposed project’s
southernmost unit would be over 900 horizontal feet to the nearest of these condenser units. The predicted
sound emission level from the combination of all 718 operating condenser units at off-site single-family receptors
would be lower than 45 dBA Leq and therefore be compliant with the City’s nighttime threshold of 50 dBA hourly
Leq. Therefore, under such conditions, the project’s noise impacts associated with operation of residential air-
conditioning units would be less than significant.
B. Generate excessive groundborne vibration or groundborne noise levels.
Construction
Construction activities may expose persons to excessive groundborne vibration or groundborne noise. Caltrans has
collected groundborne vibration information related to construction activities (Caltrans 2013a). Information from
Caltrans indicates that continuous vibrations with a PPV of approximately 0.2 ips is considered annoying. For
context, heavier pieces of construction equipment, such as a bulldozer that may be expected on the project site,
have peak particle velocities of approximately 0.089 ips or less at a reference distance of 25 feet (DOT 2006).
Groundborne vibration attenuates rapidly, even over short distances. The attenuation of groundborne vibration as
it propagates from source to receptor through intervening soils and rock strata can be estimated with expressions
found in FTA and Caltrans guidance. By way of example, for a bulldozer operating on site and as close as the northern
project boundary (i.e., 580 feet from the nearest receiving sensitive land use) the estimated vibration velocity level
would be 0.001 ips per the equation as follows (FTA 2006):
PPVrcvr = PPVref * (25/D)^1.5 = 0.19 = 0.089 * (25/580)^1.5;
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where PPVrcvr is the predicted vibration velocity at the receiver position, PPVref is the reference value at 25 feet
from the vibration source (the bulldozer), and D is the actual horizontal distance to the receiver. Therefore, at
this predicted PPV, the impact of vibration-induced annoyance to occupants of nearby existing homes would be
less than significant.
Construction vibration, at sufficiently high levels, can also present a building damage risk. However, the predicted
0.001 ips PPV at the nearest residential receiver 580 feet away from on-site operation of the bulldozer during grading
would not surpass the guidance limit of 0.3 to 0.5 ips PPV for preventing damage to residential structures (Caltrans
2013a). Because the predicted vibration level at 580 feet is less than both the annoyance and building damage risk
thresholds, vibration from project conventional construction activities is considered less than significant.
Operation
Once operational, the proposed project would not be expected to feature major on-site producers of groundborne
vibration. Anticipated mechanical systems like pumps are designed and manufactured to feature rotating components
(e.g., impellers) that are well-balanced with isolated vibration within or external to the equipment casings. On this
basis, potential vibration impacts due to proposed project operation would be less than significant.
C. For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has
not been adopted, within two miles of a public airport or public use airport, would the project expose people
residing or working in the project area to excessive noise levels.
There are no private airstrips within the vicinity of the project site. The closest airport to the project site is the
Brown Field Municipal Airport approximately 2.5 miles southeast of the site. However, the project site is located
approximately 1.3 miles north of the closest nois e exposure boundary (60 to 65 dB CNEL), as outlined in the
Brown Field Municipal Airport Land Use Compatibility Plan (San Diego County Airport Land Use Commission
2010). Airport-generated noise attenuates with distance beyond this boundary and therefore wo uld
substantially less than 60 to 65 dB CNEL at the project site. Therefore, people within the project site would
not be exposed to substantial noise from operations at Brown Field Municipal Airport. Impacts from aviation
overflight noise exposure would be considered less than significant.
5.11.4 Level of Significance Prior to Mitigation
As discussed in Section 5.11.3, the proposed project’s noise impacts would be less than significant.
5.11.5 Mitigation Measures
No mitigation measures would be required.
5.11.6 Level of Significance After Mitigation
As no mitigation measures are required, impacts to noise associated with the proposed project would remain less
than significant.
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M5
M6
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ST2
ST3 ST4
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FIGURE 5.11-1
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5.12 – Population and Housing
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5.12 Population and Housing
This section of the environmental impact report (EIR) discusses the existing population and housing conditions in
the City of Chula Vista (City), and addresses the proposed Sunbow Sectional Planning Area (SPA) Plan Amendment
for the Sunbow II, Phase 3 Project (project or proposed project) impacts on housing and population growth. Changes
in population, employment, and housing demand are social and economic effects, not environmental effects.
According to the California Environmental Quality Act (CEQA), these effects should be considered in an EIR only to
the extent that they would create adverse impacts on the physical environment. According to Section 15382 of the
CEQA Guidelines, “[a]n economic or social change by itself shall not be considered a significant effect on the
environment” (14 CCR 15000 et seq.).
5.12.1 Existing Conditions
5.12.1.1 Regulatory Framework
Federal
No federal regulations or guidelines relating to population and housing apply to the proposed project.
State
No state regulations or guidelines relating to population and housing apply to the proposed project.
Local
San Diego Forward: The Regional Plan
The San Diego Forward: Regional Plan, combines the region’s two most important existing planning documents: the
Regional Comprehensive Plan (RCP), and the Regional Transportation Plan (SANDAG 2011a) and its Sustainable
Communities Strategy (RTP/SCS). The RCP, adopted in 2004, laid out key principles for managing the region ’s
growth while preserving natural resources and limiting urban sprawl. The plan covers policy areas including urban
form, transportation, housing, healthy environment, economic prosperity, public facilities, our borders, and social
equity (SANDAG 2004). These policy areas were addressed in the 2050 Regional Transportation Plan and its
Sustainable Communities Strategy (2050 RTP/SCS) and are now fully integrated into San Diego Forward: The
Regional Plan (SANDAG 2015a).
The San Diego Association of Governments (SANDAG) estimates future population, housing, land use, and economic
growth throughout San Diego County and in individual cities, including the City. On October 15, 2013, the Series
13: 2050 Regional Growth Forecast was accepted by the SANDAG Board of Directors for planning purposes. This
forecast serves as the foundation for San Diego Forward: The Regional Plan and other planning documents across
the region. SANDAG projects the region’s population will grow by nearly 1 million people by 2050. This forecast is
consistent with previous expectations although future growth rates have been reduced due to increased domestic
migration out of the region. The growth in population will drive job growth and housing demand within the region ,
adding nearly 500,000 jobs and more than 330,000 housing units by 2050 (SANDAG 2013).
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SANDAG prepared a 2019 Federal Regional Transportation Plan (2019 Federal RTP), which was adopted on October
25, 2019. The 2019 Federal RTP builds on the 2015 Regional Plan with updated project costs and revenues and
a new regional growth forecast. The 2019 Federal RTP is consistent with the Final EIR approved in conjunction with
the 2015 Regional Plan on October 9, 2015. State legislation (Assembly Bill 1730), was signed into law on October
8, 2019, which ensures the 2015 Regional Plan remains valid for state funding eligibility and other consistency
purposes until the 2021 Regional Plan is adopted in late 2021. Preparation of the 2021 Regional Plan is currently
underway. In fall 2020, key policies and programs to be considered as part of the vision will be presented to SANDAG
policymakers. The draft 2021 Regional Plan and its draft Environmental Impact Report are expected to be released
for public and policymaker review in spring 2021 (SANDAG 2020).
As shown in Table 5.12-1, the SANDAG Series 13 Regional Growth Forecast for 2050 predicts population, housing,
and employment for the San Diego Region, as well as for the City of Chula Vista, for 2012 through 2050.
Table 5.12-1. San Diego Region vs. City of Chula Vista Population, Housing,
and Employment Forecast
Planning Area Year 2012 Year 2020 Year 2035 Year 2050 Increase Percent Change
Population
City of Chula
Vista
249,382 287,173 326,625 345,586 96,204 38.6%
San Diego
Region*
3,143,429 3,435,713 3,853,698 4,068,759 973,446 31.4%
Housing
City of Chula
Vista
79,225 89,176 101,188 108,273 29,048 36.7%
San Diego
Region
1,165,818 1,249,684 1,394,783 1,491,935 326,117 28%
Employment
City of Chula
Vista
65,340 82,953 93,552 114,550 49,210 75.3%
San Diego
Region
1,450,913 1,624,124 1,769,938 1,911,405 287,281 19.8%
Sources: SANDAG 2013, 2015b.
* The San Diego Region includes both incorporated and unincorporated areas of the region.
Regional Housing Needs Assessment
According to SANDAG’s 2050 Cities/Counties Forecast, the City is expected to gain 92,454 new residents and
28,755 new households (SANDAG 2015b). Furthermore, SANDAG, through its Regional Housing Needs Allocation,
estimated that , the City would experience a demand for 12,125 new housing units from January 1, 2010 through
December 31, 2020, of which 6,303 new housing units for affordable to low and very low income households and
2,220 new housing units for moderate income households. The City of Chula Vista an ticipates that much of the new
construction will result from building out the master-planned communities in the East Planning Area, such as Otay
Ranch, infill development, and mixed-use development (SANDAG 2011b).
To encourage the development of adequate housing to meet the needs of low and moderate-income households
and to further geographic and community balance, the City’s adopted Housing Element provides for a Balanced
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Communities Policy, requiring 10% affordable housing for low- and moderate-income households1,2 within
developments of 50 or more residential units. This inclusionary housing program will serve as only one component
of the City’s overall housing strategy and will complement other affordable housing efforts, including preservation
of existing assisted housing, development of new assisted housing with public subsidies, first-time homebuyer
assistance, and rehabilitation loans for low income homeowners. The City does find that such an inclusionary
housing policy is beneficial to increasing the supply of housing affordable to households of lower and moderate
incomes and to meet the City’s regional share of housing needs given the demographics of the community and its
needs, past housing production performance, and the existing opportunities and constraints as detailed in its
Housing Element (SANDAG 2011b).
Currently, the City is updating the General Plan Housing Element to account for housing needs and establish clear
goals and objectives to inform future housing decisions for the 2021 to 2029 housing cycle. As part of the Housing
Element update, the City must demonstrate there is sufficient capacity to accommodate the number of housing
units identified in the RHNA. As such, the RHNA allocation was released by SANDAG in November 2019 and is
helping inform preparation of the 2021 Housing Element (City of Chula Vista 2020a). Tables 5.12-2 and 5.12.3
show the past performance RHNA from the 5th Cycle (2013–2020) and the current RHNA allocation for the 6th
Cycle (2021–2029), respectively (City of Chula Vista 2020a, 2020b).
Table 5.12-2. Past Performance RHNA 5th Cycle (2013–2020)
Income Level RHNA Allocation by Level
Total Units to Date
(all years)
Total Remaining RHNA
(2019–2021)
Very Low 3,209 91 3,118
Low 2,439 557 1,882
Moderate 2,257 328 1,929
Above Moderate 4,956 7,614 2,658
Total 12,861 8,590 4,271
Source: City of Chula Vista 2020b.
Table 5.12-3. RHNA Allocation for the 6th Cycle (2021–2029)
Income Category RHNA Allocation by Level Percentage of Total Units
Extremely Low and Very Low 1,777 16%
Other Lower 2,750 25%
Moderate 1,911 17%
Above Moderate 4,667 42%
Total 11,105 100%
Source: City of Chula Vista 2020a.
1 Low-income households are households of persons who claim primary residency at the same unit with combined incomes that
are greater than 50%, but not more than 80% of the Area Median Income (AMI) for the San Diego area based on household size
as determined annually by the U.S. Department of Housing and Urban Development (HUD). Household size is calculated by the
number of persons residing at the same unit as their primary residency.
2 Moderate-income households are households of persons who claim primary residency at the same unit with combined incomes
between 80% to 120% of the AMI for the San Diego area based on household size as determined annually by HUD. Household
size is calculated by the number of persons residing at the same unit as their primary residency.
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Chula Vista General Plan
The City of Chula Vista General Plan (General Plan) divides the City into four planning areas: (1) the Southwest
Planning Area, (2) the Northwest Planning Area, (3) the East Planning Area, and (4) the Bayfront Planning Area (City
of Chula Vista 2005).
Under the General Plan’s Land Use and Transportation Element, population for the City is projected to increase by
101,600 persons, from 222,300 in 2004 to 323,900 in 2030 (City of Chula Vista 2005). Projected growth in the
City is summarized in Table 5.12-4. The General Plan’s projected population exceeds the SANDAG 2050 Regional
Forecast for 2030 by 34,922 persons. As shown in Table 5.12-4, the General Plan anticipates the population in the
incorporated portion of the East Planning Area to increase by 58,990 persons, from 98,710 in 2004 to 157,700 in
2030. The project site is within the East (incorporated area) planning area.
Table 5.12-4. Chula Vista Projected Population in 2030
Planning Area Year 2004 Year 2030 Increase
Bayfront 0 4,860 4,860
Southwest 53,560 72,401 18,841
Northwest 56,930 89,090 32,160
East (incorporated area) 98,710 209,256 110,546
East (unincorporated area) 13,100 25,937 12,837
Total 222,300 401,544 179,244
Source: City of Chula Vista 2005.
The General Plan incorporates a Housing Element (adopted April 23, 2013) that identifies strategies to expand
housing opportunities for the City’s various economic segments. Under the Housing Element, the provision of
new housing opportunities within mixed use areas and at higher density levels, particularly transit focus areas,
is encouraged. A primary issue of the Housing Element is the shortfall of housing, particularly affordable housing,
in the City and the region. Of the City’s previous 5 th Cycle RHNA allocation, the City has only met 8,590 out of
12,861 units; only 648 very -low and low units have been developed out of the 5,648 allocated . To address this
issue, the Housing Element requires residential developments with 50 or more dwelling units provid e 10% of
total units for low- and moderate-income households, with at least half of those (5%) designated for low -income
households (City of Chula Vista 2013). As discussed above, preparation of the 2021 Housing Element is currently
underway. The City Planning and the Housing Divisions are working together on the 2021–2029 Housing Element,
a multi-year update that will help address the growing housing challenges faced by the City. The State Department
of Housing and Community Development (HCD) deadline for adoption of local government housing elements is April
15, 2021 (City of Chula Vista 2020b).
Goals and policies listed in the General Plan encourage the provision of a wide range of housing choices by location,
type of unit, and price level, in particular the establishment of permanent affordable housing for low and m oderate-
income households. General Plan goals and polices ensure the availability of housing opportunities to persons
regardless of race, color, ancestry, national origin, religion, sex, disability, marital status, and familial status, source
of income or sexual orientation and support efforts to increase homeownership rates to build individual wealth (City
of Chula Vista 2013).
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Sunbow General Development Plan
The Sunbow General Development Plan (GDP), which originally included 604.8 acres in eastern Chula Vista, was
adopted on December 5, 1989, with the primary objective to create an efficient, self -contained village (City of
Chula Vista 1989).
The GDP is implemented through the adoption of the more detailed SPA Plan, tentative tract maps, and
potential ann exation and development agreements. The GDP is designed to function as a policy bridge between
the General Plan and the SPA Plan, which provides more detailed plans for development of the Sunbow Master
Planned Community (City of Chula Vista 1989).
Sunbow Sectional Planning Area Plan
The SPA Plan was approved by the City Council in 1990. According to the City, GDPs are implemented through
the adoption of SPA Plans, which are more detailed in its zoning, design regulations, and development
parameters. The purpose of the SPA Plan is to assure high quality development, create an economically viable
plan, provide a plan for long-range development, facilitate provisions for community facilities, preserve open
space, and establish a planning and development framework. Regulations within the SPA Plan supersede other
regulations where there is potential conflict between the GDP and the General Plan (City of Chula Vista 1990).
City of Chula Vista Municipal Code
Growth Management Ordinance
The purpose and intent of the City’s Growth Management Ordinance (GMO) (CVMC Section 19.09) is to provide
quality housing opportunities for all economic sections of the community; to balance the community with adequate
commercial, industrial, recreational, and open space areas to support the residential areas of the City; to provide
that public facilities, services, and improvements meeting City standards exist or become available concurrent with
the need created by new development; to control the timing and location of development by tying the pace of
development to the provision of public facilities and improvements to conform to the City’s Threshold Standards;
and to meet the goals and objectives of the Growth Management Program and other programs associated with
quality of life. The GMO prohibits new development unless adequate public facilities are provided in advance of or
concurrently with the demands created by new development.
The GMO created the Growth Management Oversight Commission (GMOC) and established “quality of life” threshold
standards. These include police, fire, and emergency response times; anticipated demand for schools and evaluation
of school funding; establishment of a library service ratio; a service ratio for neighborhood and community park land;
water service availability; compliance with City engineering sewage flow and related standards (subdivision manual);
compliance with City engineering stormwater drainage standards (subdivision manual); maintenance of acceptable
City-wide traffic flows; and air quality and pollution overview and evaluation to foster air quality improvement pursuant
to relevant regional and local air quality improvement strategies. The GMO also requires public facilities finance plans
(PFFPs), air quality improvement plans, and water conservation plans for every SPA Plan, or, if a SPA Plan is not
required, for every tentative map (TM) application. The PFFP provides a complete description of all public facilities
included within the boundaries of the plan as defined by the development services director, including phasing and
financing of infrastructure. The plan must contain an analysis of the individual and cumulative impacts of the proposed
development on the community as it relates to the Growth Management Program, the specific facility master plans,
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and the threshold standards. Proposed development must also prepare a fiscal impact report and provide funding for
periods when City expenditures for the development would exceed projected revenues.
5.12.1.2 Existing Setting
The project site lies within the East Planning Area of the City, as identified in the General Plan (City of Chula
Vista 2005). The East Planning Area is divided into six su bareas: East Main Street subarea, unincorporated
Sweetwater Subarea, Otay Ranch Subarea, Master Plan Community Subarea, unincorporated East Otay Ranch
Subarea, and other miscellaneous areas subareas (City of Chula Vista 2005). The project is located within the
Master Planned Communities Subarea, which is further broken down into six subareas: Sunbow, Rancho del Rey,
Eastlake, Rolling Hills Ranch, San Miguel Ranch, and portions of Otay Ranch. The proposed project is a component
of the GDP, which is implemented through the SPA Plan .
The eastern portion of the project site (formerly referred to as Planning Area 23 in the GDP and SPA Plan) was
originally identified to be developed as Industrial Park, while the rest of the project site was designated as
Open Space in the GDP and SPA Plan. The Industrial Park is currently designated to include an approximately
54.7-acre research/development and light industrial uses, with approximately 700,000 square feet of leasable
area generating approximately 2,800 employment o pportunities.
The approximately 135.7-acre project site currently consists of vacant and undeveloped land. There is currently no
public access; however, a number of dirt roads traverse the site. No former or current residential uses are located
within the project site.
5.12.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to Population and Housing is based on the
recommendations provided in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). A significant impact
would occur if the project would:
A. Induce substantial unplanned population growth in an area, either directly (i.e., by proposing new homes and
businesses) or indirectly (i.e., through extension of roads or other infrastructure).
B. Displace substantial numbers of existing housing or people, necessitating the construction of replacement
housing elsewhere.
5.12.3 Impacts
A. Induce substantial unplanned population growth in an area, either directly (i.e., by proposing new homes and
businesses) or indirectly (i.e., through extension of roads or other infrastructure).
As described above, the General Plan has planned for the population of the entire City to grow by 101,600 persons
from 2004 to 2030, growing from 222,300 people in 2004 to 323,900 people in 2030. A majority of this growth
(58,990 persons) is planned in the East Planning Area, where the project site is located (City of Chula Vista 2005).
Alternatively, SANDAG Series 13 estimates the population in the City would grow from 287,173 in 2020 to 326,625
in 2035 and that housing would increase from 89,176 units in 2020 to 101,188 units in 2035 (Appendix F). According
to the General Plan Housing Element, projected population exceeds the SANDAG 2050 Regional Forecast for the year
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2030 by 34,922 persons (City of Chula Vista 2013). As such, SANDAG Series 13 forecasts are used herein to provide
a conservative analysis of the proposed project’s population inducement.
The proposed residential development area was originally identified to be developed as Industrial Park in the
GDP and SPA Plan . As such, the change in land use from Industrial Park to Medium-High and High Residential
would be considered unplanned population growth in excess of the original estimates in the GDP and SPA Plan.
The project proposes the development of 718 multi-family residential units in phases with partial occupancy
beginning in 2024 and full occupancy anticipated in 2028. Based on SANDAG’s Series 13 forecast, the interpolated
persons per household ratio in 2028 is 3.224. Thus, the proposed project would result in approximately 2,314.83
persons (rounded to 2,315) (Appendix F).
Although this population growth would be considered unplanned, the proposed project would only represent 5.9% of
forecasted population growth and 6% of forecasted housing growth between 2020 and 2035, based on SANDAG’s
Series 13 forecast. Additionally, development of an Industrial Park would directly result in some amount of population
growth within the City due to new employment in the area. Based on the SANDAG Series 13 growth forecast,
employment density3 in the City in 2035 is anticipated to be 17.5 jobs per developed employment acre (SANDAG 2013).
At this rate, a project consistent with the existing Industrial Park land use would result in approximately 957 employees
in 2035, some percentage of which would move to the area resulting in population growth. Although the proposed
project would result in greater population inducement, development under the existing Industrial Park land use was
already anticipated to generate some population under the City’s growth projections, associated with employees that
would move to the area as a result of development of the Industrial Park.
Furthermore, as shown in Table 5.12-2, the City was 4,271 units under the RHNA allocation for the 5th Cycle (2013–
2020) and specifically for Very Low to Moderate income levels. As shown in Table 5.12-3, the City also has a current
RHNA allocation of 11,105 units for the 6th Cycle (2021–2029), including 6,438 units for Extremely Low to
Moderate income levels. The proposed project’s entitlements would include execution of an Affordable Housing
Agreement with the City to satisfy the requirement that the project foster the provision of 72 (10% of project units)
affordable housing units. Therefore, the generation of 2,315 persons through the addition of 718 units between 2024
and 2028 would provide balanced and diverse housing to the City and would provide housing to accommodate the
City’s future growth projections.
Improvements to transportation, utilities, and public service infrastructure as part of the proposed project would
accommodate the direct growth induced by the proposed project. These improvements would not open up new
areas to development because they would connect the project site to existing transportation and utility
infrastructure (including water and sewer) adjacent to the project site on and within Olympic Parkway. The project
site has been planned for development for decades and the surrounding area is already substantially developed
with housing to the north, west, and southwest and the Otay Landfill to the southeast. Consequently, there is already
significant existing infrastructure surrounding the project and these improvements would provide access and utility
service solely to the proposed project.
Furthermore, the City of Chula Vista Growth Management Program, outlined in the Chula Vista Municipal Code Chapter
19.09, Growth Management, calls for directing growth in and around the City in an orderly fashion, to avoid “leapfrog”
development, to protect and preserve the City’s amenities, and to guide growth in a general west to east direction. The
proposed project fosters a development pattern that promotes orderly growth and prevents urban sprawl by developing
on a site surrounded by existing development and planned for development for several decades. The proposed project
3 Civilian jobs per developed employment acre (industrial, retail, office, schools, and half of mixed-use acres).
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will comply with the City’s GMO and established “quality of life” threshold standards (Chula Vista Municipal Code
Section 19.09, Growth Management ).
While the proposed project would directly contribute to population growth in the area as compared to existing
conditions, the population inducement resulting from the proposed project would not be considered substantial.
Impacts would be less than significant.
B. Displace substantial numbers of existing housing or people, necessitating the construction of replacement
housing elsewhere.
No existing or former residential uses occupy the project site as the site is currently vacant and undeveloped land.
As such, the proposed project would not displace any existing households or people, or necessitate the construction
of replacement housing elsewhere. No impact would occur.
5.12.4 Level of Significance Prior to Mitigation
Impacts to housing and population would be less than significant; therefore, no mitigation is required.
5.12.5 Mitigation Measures
Impacts to housing and population would be less than significant; therefore, no mitigation is required.
5.12.6 Level of Significance After Mitigation
Impacts to housing and population would be less than significant; therefore, no mitigation is required.
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5.13 Public Services
This section of the environmental impact report (EIR) describes the existing setting related to public services and
facilities that would serve the proposed Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II,
Phase 3 Project (project or proposed project) and evaluates potential impacts to public services due to the
implementation of the proposed project.
5.13.1 Existing Conditions
5.13.1.1 Regulatory Framework
Federal
Fire Protection Services
National Fire Protection Association
The National Fire Protection Association recommends that fire departments respond to fire calls within six minutes
of receiving the request for assistance 90% of the time. These time recommendations are based on the demands
created by a structural fire. It is crucial to attempt to arrive and intervene at a fire scene prior to the fire spreading
beyond the room of origin. Total structural destruction typically starts within eight to ten minutes after ignition.
Response time is generally defined as one minute to receive and dispatch the call, one minute to prepare to respond
to the fire station or field and four minutes (or less) travel time.
State
Fire Protection
2019 California Fire Code
The California Fire Code (Title 24, Part 9 of the California Code of Regulations) was published on July 1, 2019, and
effective January 1, 2020. The California Fire Code establishes regulations to safeguard life and property against
hazards of fire, explosion, or dangerous conditions in new and existing buildings, structures, and premises. The Fire
Code also establishes requirements intended to provide safety and assistance to firefighters and emergency
responders during emergency operations. The provisions of the Fire Code apply to the construction, alteration,
movement, enlargement, replacement, repair, equipment, use and occupancy, location, maintenance, removal,
and demolition of every building or structure throughout the State of California. The Fire Code includes regulations
regarding fire-resistance-rate construction, fire protection systems such as alarm and sprinkler systems, fire service
features such as fire apparatus access roads, means of egress fire safety during construction and demolition, and
wildland–urban interface areas.
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Schools
Mello-Roos Community Facilities Act of 1982
The Mello-Roos Community Facilities Act of 1982 permits the establishment of Community Facilities Districts
(CFDs), commonly referred to as “Mello-Roos.” CFDs are special districts established by local governments as a
means of financing public facilities, including schools, through a special tax imposed on the property within the
CFD. The project site is located within existing CFDs for both Chula Vista Elementary School and Sweetwater Union
High School Districts.
California Senate Bill 50
Two public school districts provide primary and secondary school facilities and services within the City of Chula
Vista: The Chula Vista Elementary School District (CVESD) (kindergarten through sixth grade) and the Sweetwater
Union High School District (SUHSD) (seventh through 12th gra de). Senate Bill 50, enacted in 1998, allows school
districts to levy a fee, charge, dedication, or other requirement against any development project within its
boundaries for the purpose of funding the construction or reconstruction of school facilities. Pursuant to
Government Code Section 65996, the payment of these fees by a developer serves to fully mitigate all potential
project impacts on school facilities to less than significant levels.
Proposition 1A
On November 3, 1998, California voters approved Proposition 1A, the Class Size Reduction Kindergarten-University
Public Education Facilities Bond Act of 1998. Prior to the passage of Proposition 1A, school districts relied on statutory
school fees established by Assembly Bill 2926 (“School Fee Legislation”), which was adopted in 1986, as well as judicial
authority (i.e., Mira-Hart-Murrieta court decisions) to mitigate the impacts of new residential development. In a post
Proposition 1A environment, the statutory fees provided for in the School Fee Legislation remains in effect and any
mitigation requirements or conditions of approval not memorialized in a mitigation agreement, after January 1, 2000
have been replaced by Alternative Fees – sometimes referred to as Level II and Level III Fees.
Leroy F. Green School Facilities Act
California Government Code Section 65995 (The Leroy F. Green School Facilities Act of 1998) set base limits and
additional provisions for school districts to levy development impact fees and to help fund expanded facilities to
house new pupils that may be generated by the development project. Sections 65996(a) and (b) state that such
fees collected by school districts provide full and complete school facilities mitigation under the California
Environmental Quality Act (CEQA). These fees may be adjusted by the District over time as conditions change
Parks and Open Space
Quimby Act
The Quimby Act, enacted in 1975, creates a framework that allows cities and counties to provide parks for growing
communities. The Quimby Act authorizes jurisdictions to adopt ordinances that require parkland dedication or
payment of in-lieu fees as a condition of approval of residential subdivisions, The Quimby Act also specifies
acceptable uses and expenditures of such funds, such as allowing developers to set aside land, donate
conservation easements, or pay direct fees for park improvements.
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Proposition 40 Park Bond Act
Proposition 40, also known as the Park Bond Act allows for the maintenance for preservation of parks of the state’s
growing population by borrowing money through general obligation bonds for the development, restoration, and
acquisition of state and local parks, recreation areas and historical resources, and for land, air, and water
conservation programs.
Local
City of Chula Vista General Plan
The City of Chula Vista (City) General Plan (General Plan) was adopted on December 13, 2005 and amended on
March 17, 2020. The Public Facilities and Services Element establishes the City’s plan to provide and maintain
infrastructure and public services for future growth (City of Chula Vista 2005a).
Fire Protection Services
The General Plan (amended in 2020) recognizes that fire protection and emergency services will need to expand
as the population in the City of Chula Vista grows. The Public Facilities and Services Element includes objectives to
maintain sufficient levels of fire protection and emergency medical service to protect public safety and property
(Objective PFS 5) and provide adequate fire protection services to newly developing and redeveloping areas of the
City (Objective PFS 6). Additionally, GM 1 and Policy GM 1.11 provide for withholding discretionary approvals and
subsequent building permits from projects demonstrated to be out of compliance with applicable threshold
standards for fire and emergency medical services (City of Chula Vista 2005a).
Police Protection Services
The Public Facilities and Services Element of the General Plan includes objectives to maintain sufficient levels of
police service to protect public safety and property (Objective PFS 5) and to provide adequate police protection
services to newly developing and redeveloping areas of the City (Objective PFS 6). Additionally, Growth Management
Objective GM 1 and Policy GM 1.11 provide for withholding discretionary approvals and subsequent building
permits from projects demonstrated to be out of compliance with applicable threshold standards for police services
(City of Chula Vista 2005a).
Libraries
The General Plan recognizes that demand for library facilities will continue to increase as the City’s population grows
in the eastern areas of the City through new development, and that location is the most important reason residents
choose to utilize a particular public library. The General Plan Public Facilities and Services Element includes
objectives for the City to provide a library system of facilities and programs that meets the needs of Chula Vista
residents of all ages (Objective PFS 11) and to efficiently locate and design library facilities (Objective PFS 12).
Additionally, Growth Management Objective GM 1 and Policy GM 1.11 provide for withholding discretionary
approvals and subsequent building permits from projects demonstrated to be out of compliance with applicable
threshold standards for library services (City of Chula Vista 2005a).
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Schools
The General Plan recognizes that demand for school facilities will continue to increase as the City’s population grows and
states that it is the intent of the City to facilitate the efforts of the districts to provide school services. The Public Facilities
and Services Element includes objectives to efficiently locate and design school facilities (Objective PFS 10) (City of Chula
Vista 2005a).
Parks
The City’s open space and trail network abuts other regional open space areas and trails, including: the Bayshore
Bikeway; California Riding and Hiking Trail; Sweetwater Valley trail system; the future Otay Valley Regional Park trail
system; and the open space preserve in the eastern portion of Otay Ranch. The aforementioned open spaces and trail
networks are regional facilities that enter the City of Chula Vista jurisdiction. The goals of the General Plan to provide and
maintain infrastructure and public services and improve sustainability of the City’s natural resources are established in
the Public Facilities and Services and Environmental Elements of the General Plan. The Public Facilities and Services
Element contains objectives to provide new park and recreation facilities for residents of new development (Objective
PFS 15 and PFS 16) (City of Chula Vista 2020a). The Environmental Element of the General Plan establishes the policy
framework for improving sustainability through the responsible stewardship of the City’s natural and cultural resources
(Objective E.11), including the preservation of open space and development of connecting trails (City of Chula Vista
2005a). The City is committed to providing an integrated network of open space areas throughout the City to serve
residents, as well as to serve as a regional asset and attractor of visitors. The City of Chula Vista has significant open
space areas with a variety of natural resources. The City has taken a multi-track approach to the conservation and
management of its open space resources. Additionally, Growth Management Objective GM 1 and Policy GM 1.11
provides for withholding discretionary approvals and subsequent building permits from projects demonstrated to be out
of compliance with applicable park threshold standards (City of Chula Vista 2005a).
Chula Vista Public Facilities Development Impact Fee
In August 1989, the Chula Vista City Council adopted Ordinance No. 2320 establishing a Public Facilities
Development Impact Fee (PFDIF), which helps cover the cost of new or expanding public facilities within the City
(City of Chula Vista 2005b). The facilities are required to support future development within the City, and the fee
schedule has been adopted in accordance with California Government Code Section 66000. The proposed project
would be subject to the payment of the fee at the rate in effect at the time building permits are issued. The PFDIF
amount is determined through evaluation of the need for new facilities as it relates to the level of service demanded
by new development, which varies in proportion to the equivalent dwelling unit generated by a specific land use.
The PFDIF addresses the project’s proportional impact on capital facilities, such as structures and equipment. It
does not address the impact associated with operations and maintenance for those facilities. Public funds such as
property taxes, sales taxes, and fees generated by the project would be used to cover the incremental costs
associated with providing services. The project would be required to pay the PFDIF, which would be used exclusively
for future facility improvements necessary to ensure that the development contributes its fair share of the cost of
facilities and equipment determined to be necessary to adequately accomm odate new development in the City.
Chula Vista Municipal Code
CVMC Section 19.80.030, Controlled Residential Growth, is intended to ensure that new development would not
degrade existing public services and facilities below acceptable standards. Similarly, Section 19.09, Growth
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Management, of the CVMC provides policies and programs that tie the pace of development to the provision of
public facilities and improvements. Section 19.09 requires that a Public Finance Plan (PFFP) be implemented and
demonstrate that public services meet the Growth Management Ordinance’s quality of life standard. Other relevant
CVMC sections are discussed below.
Fire Protection Services
Ch. 15.36 Fire Code. Chula Vista Municipal Code (CVMC) Section 15.36.010, California Fire Code, 2019 Edition, adopted
by reference, sets the California Code of Regulations, Title 24, Part 9, as the fire code of the City of Chula Vista.
CVMC Section 18.40.080. CVMC Section 18.40.080, Access for fire protection, dictates that in any areas where
there are fire hazards would require unobstructed easements not less than 15 feet wide from the public street to
the subdivision boundary.
Police Protection
CVMC Section 3.50.030 and 3.50.060. CVMC Section 3.50.030, Public facilities to be financed by the Fee,
indicates that a PFDIF would fund six public facilities, including police department facilities and equipment. The
service demand generated for police department facilities and equipment would be 0.747 for multi-family dwelling
units and 0.031 per industrial acre (CVMC Section 3.50.060, Determination of Fees by land use category).
Libraries
CVMC Section 3.50.030 and 3.50.060. CVMC Section 3.50.030, Public facilities to be financed by the Fee,
indicates that a PFDIF would fund six public facilities, including the library system expansion. The service demand
generated for the library system expansion by a multi-family dwelling unit would be 0.822 (CVMC Section 3.50.060,
Determination of Fees by land use category).
Section 19.09.040D specifically requires “500 square feet (gross) of adequately equipped and staffed library
facility per 1,000 population. The City of Chula Vista shall construct 60,000 gross square feet of additional library
space, over the June 30, 2000 gross square feet total, in the area east of I-805 by buildout.” The analysis of library
services provided in this section, along with the PFFPs are intended to ensure funding for any needed expansion of
services, while also ensuring that library services will be provided commensurate with development and demand.
Schools
CVMC Section 17.11.020 and 17.11.130. CVMC Section 17.11.020 states that any property to be developed shall
dedicate a portion of the land or, in lieu thereof, pay a fee for each dwelling unit in the subdivision or development.
CVMC Section 17.11.130, School district schedule, dictates that the governing body of the school district shall
submit a schedule specifying how it will use the land or fees, or both.
Parks
CVMC Section 17.10, Park Lands Dedication Ordinance, establishes requirements for parklands and public
facilities, including regulations for the dedication of land and development improvements for park and recreation
purposes (CVMC Section 17.10.010); determination of park and recreation requirements (CVMC Section
17.10.020); area to be dedicated (CVMC Section 17.10.040); specifications for park improvements (CVMC Section
17.10,050); criteria for area to be dedicated (CVMC Section 17.10.060); procedures for in lieu fees for land
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dedication and/or park development improvements (CVMC Section 17.10.070); and other regulations regarding
park development and collection and distribution of fees. The Park Lands Dedication Ordinance requires the
dedication of three acres of parkland per 1,000 people or a combination of land dedication, in -lieu fees, or park
development improvements to be offered at the time of Final Map or in the case of a residential development that
is not required to submit a Final Map, at the time of the first building permit application. As previously discussed,
CVMC Section 19.09, Growth Management, requires a PFFP and demonstration that public services, such as parks,
meet the Growth Management Ordinance’s quality of life threshold standard for parks and recreation. Furthermore,
CVMC Section 19.09.040E requires “three acres of neighborhood and community park land with appropriate
facilities per 1,000 residents east of I-805.”
City of Chula Vista Public Library Strategic Facilities Plan
The Chula Vista Public Library (CVPL) Strategic Facilities Plan is intended as a foundation for the City and the library
in planning the future of library facilities in Chula Vista. The CVPL Strategic Facilities Plan includes goals and
objectives for implementing the library’s vision and mission. These goals include maintaining an excellent and
responsive materials collection, ensuring high quality of public library services through appropriate planning
processes, ensuring that library programs and services are accessible to the broadest range of potential users, and
increasing the visibility and community awareness of the library, its services, programs, and funding needs (City of
Chula Vista 2011).
City of Chula Vista Public Library Strategic Vision Plan
The CVPL Strategic Vision Plan is a companion volume to the CVPL’s 2011 Strategic Facilities Plan (City of Chula
Vista 2014). The 2014 CVPL Strategic Vision Plan would guide the CVPL’s service directions for the next decade,
and summarizes the community’s vision for the CVPL, strategic discussions for library services and facilities, and
associated updates to the Strategic Facilities Plan.
City of Chula Vista Greenbelt Master Plan
The City of Chula Vista Greenbelt Master Plan provides guidance and continuity for planning open space and
constructing and maintaining the Greenbelt Trail (City of Chula Vista 2003). The Greenbelt Master Plan addresses
existing and potential trail locations, trail and staging area development standards, maintenance responsibilities
and a system of trails and open space that serve as a unifying element in linking other trails within the central areas
of the City. The future Otay Valley Regional Park trail, running parallel to the Otay River, is located approximately
1 mile south of the proposed project site (City of Chula Vista 2003).
City of Chula Parks and Recreation Master Plan
The City of Chula Vista Parks and Recreation Master Plan, updated and adopted by City Council on August 7, 2018,
describes a comprehensive parks and recreation system that serves the community at large through the delivery of
a variety of park sites containing a variety of recreational experiences. The Master Plan contains goals and policies
that serve as a blueprint for creating a quality park system. The document establishes goals for the creation of a
comprehensive parks and recreation system that meet the needs of the public by effectively distributing park types
and associated recreation facilities and programs throughout the City (City of Chula Vista 2018).
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City of Chula Vista Active Transportation Plan
The Chula Vista Active Transportation Plan is an update to the 2010 Pedestrian Master Plan and the 2011 Bikeway
Master Plan. The Active Transportation Plan combines the two aforementioned documents and focuses mainly on
non-motorized users (City of Chula Vista 2020b). The plan supports the integration of land use planning with
transportation planning to take into account future land use and population projections and as a means to provide
bicycle facilities to help decrease auto dependence. The plan also supports integrated planning efforts as a means
of promoting opportunities for exercise and recreation, highlighting the interconnection of bikeways with area parks.
5.13.1.2 Existing Conditions
The existing fire stations, police stations, parks, schools, and libraries surrounding the project site are discussed
below and shown on Figure 5.13-1, Facility Locations.
Fire Protection Services
Fire protection for the City of Chula Vista is provided by the Chula Vista Fire Department (CVFD). The CVFD offers
the following services: fire operations and suppression, emergency medical services (EMS), hazardous materials
response, community emergency response team, rescue services, fire protection, fire inspections, public education,
plan checking, and disaster preparedness (City of Chula Vista 2020c). The CVFD serves a population of 287,173
over a 52-square-mile service area (City of Chula Vista 2020d). Each day, there are 49 firefighters on duty with an
additional two firefighters per Strategic Quick Unit Apparatus Delivery (SQUAD) unit (City of Chula Vista 2020d).
As seen in Table 5.13-1, CVFD’s total fire department staff, as of 2019, is 161 people, including firefighters and
administrative staff (CVFD 2019a). Of the 161 CVFD employees, 150 are sworn staff, and 11 are civilian staff. As
described in the 2019 CVFD Annual Report and shown on Table 5.13-1, the CVFD’s sworn staff includes 1 fire chief, 2
deputy fire chiefs, 2 division chiefs, 6 suppression battalion chiefs, 1 administrative battalion chief, 35 suppression fire
captains, 4 administrative fire captains, 33 suppression fire engineers, 1 administrative fire engineer, 35
firefighters/paramedics, 21 firefighters/EMTs, 2 senior fire inspectors/investigators, 4 fire inspectors/investigators II,
and 3 fire inspectors/investigators I. The CVFD’s civilian staff includes 1 administrative secretary, 1 emergency services
coordinator, 1 public safety analyst, 1 training program specialist, 1 senior office specialist, 1 facility supply specialist, 1
multimedia production specialist, 1 fire prevention aid, 0.5 fire inspector II/investigator I, 0.5 intern, 1 medical director,
and 1 senior fiscal office specialist. Additionally, CVFD has 105 volunteers.
Table 5.13-1. Chula Vista Fire Department Staffing
Position Number of Employees
Sworn Staff
Fire Chief 1
Deputy Fire Chief 2
Division Chief 2
Battalion Chief – Suppression 6
Fire Captain – Suppression 35
Fire Captain – Administrative 4
Fire Engineer – Suppression 33
Fire Engineer – Administrative 1
Firefighter/Paramedic 35
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Table 5.13-1. Chula Vista Fire Department Staffing
Position Number of Employees
Firefighter/EMT 21
Senior Fire Inspector/Investigator 2
Fire Inspector/Investigator II 4
Fire Inspector/Investigator I 3
Total Sworn Staff 150
Civilian Staff
Administrative Secretary 1
Emergency Services Coordinator 1
Public Safety Analyst 1
Training Program Specialist 1
Senior Office Specialist 1
Facility Supply Specialist 1
Multimedia Production Specialist 1
Fire Prevention Aide 1
Fire Inspector II/Investigator 1 0.5
Intern 0.5
Medical Director 1
Senior Fiscal Office Specialist 1
Total Civilian Staff 11
Total 161
Source: CVFD 2019.
There are currently 10 fire stations in the City of Chula Vista, serving a population of approximately 287,173 people
and an area covering over 52 square miles. During a typical 24-hour shift, there are 34 line firefighters and two
battalion chiefs on constant duty spread among the City’s 10 fire stations. Each station has a captain, engineer and
one firefighter. Table 5.13-2 lists the locations and service areas of the 10 fire stations serving the City of Chula Vista.
Fire Station 3, located at 1401 Brandywine Avenue, Chula Vista, California 91911, is the closest existing station to
the proposed project site. This fire station is located approximately 1,000 feet north of the proposed project site. Fire
Station No. 3‘s service area includes Interstate 805, East Main Street, and South/East Chula Vista. Every day the Fire
Department has two Battalion Chiefs on-duty, each covering one half of the City. These Chiefs serve as supervisors for
a number of fire stations and their respective crews and take command of major emergency incidents. Fire Station
No. 3 is equipped with one tender/trailer and Urban Search and Rescue 53 (Type I Heavy Rescue).
Table 5.13-2. City of Chula Vista Fire Station Facilities
Location Service Area Apparatus
Fire Station 1
447 F Street
Chula Vista, California 91910
Downtown, Bayfront, Northwest City, Interstates 5,
54 & 805/North
Truck 51
Engine 51
Battalion 51
Fire Station 2
80 East J Street
Chula Vista, California 91910
Central City, Interstate 805/Central, Hilltop, Country
Club
Engine 52
OES 420
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Table 5.13-2. City of Chula Vista Fire Station Facilities
Location Service Area Apparatus
Fire Station 3
1410 Brandywine Avenue
Chula Vista, California 91911
Interstate 805, East Main Street,
South/East Chula Vista
US&R 53
Tender/Trailer
Fire Station 4
850 Paseo Ranchero
Chula Vista, California 91910
Rancho Del Rey, Bonita Long Canyon, Southwestern
College
Engine 54
Fire Station 51
391 Oxford Street
Chula Vista, California 91911
Montgomery, Harborside, Otay, Interstate 5/South
Southwest City, West/Main Street
Engine 55
Fire Station 6
605 Mt. Miguel Road
Chula Vista, California 91914
Eastlake, Rolling Hills Ranch, San Miguel Ranch Engine 56
Brush 56
Fire Station 7
1640 Santa Venetia
Chula Vista, California 91913
Otay Ranch, Village of Heritage, Heritage Hills, Village
of Countryside
Engine 57
Truck 57
Battalion 52
Fire Station 8
1180 Woods Drive
Chula Vista, California 91914
Eastlake Greens, Rolling Hills Ranch, The Woods Engine 58
Fire Station 91
266 E Oneida
Chula Vista, California 91911
Sunbow, Woodlawn Park Engine 59
Fire Station 10
1715 Millenia Avenue
Chula Vista, California 91915
Southeast Otay Ranch, Winding Walk, Millenia Engine 60
Source: City of Chula Vista 2020b.
1 It should be noted that CVFD Fire Station 5 and Fire Station 9 are being newly constructed and are anticipated to be completed by the
middle of 2021; CVFD Fire Station 5 and 9 are being newly constructed at 341 Orange Avenue (adjacent to the South Branch Chula Vista
Library) and 100 Moss Street (the southeast corner of Naples Street and Alpine Avenue), respectively.
The proposed project would be required to pay the PFDIF which would fund the City’s Fire Suppression System
expansion. Payment of the PFDIF would aid in maintaining the following City Growth Management Oversight
Commission (GMOC) Threshold Standard for the Fire Suppression System Expansion: “property equipped and
staffed fire and medical units shall respond to 80 percent of calls throughout the City within seven (7) minutes”
(City of Chula Vista 2005b). The purpose of the GMOC’s threshold and related PFDIF is to maintain the pre -
development level of fire protection and EMS in the City.
According to the 2019 GMOC Annual Report, the CVFD received approximately 20,367 calls for service in Fiscal
Year (FY) 2019 (City of Chula Vista 2020a). Of these calls, 82%, were responded to within a response time of 7
minutes during FY 2019. The current GMOC threshold standard for emergency fire response is 7 minutes or less in
80% of calls. The CVFD meets the GMOC threshold standard in FY 2019.
Emergency Medical Services
In March of 2008, CVFD contracted fire and emergency medical dispatch services with the City of San Diego Fire Rescue
Department. With this contract came upgraded response capabilities including Automatic Vehicle Location and
enhanced mutual aid capabilities. CVFD has completed its transition to a new level of EMS which provides a Paramedic
or Advanced Life Support (ALS) on all responses from the department (City of Chula Vista 2020d). The CVFD’s paramedics
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provide ALS services to those who need assistance including the capacity to start an intravenous drip (IV), defibrillation
of the heart, decompression of a collapsed lung and various other advanced aid procedures.
The CVFD’s EMS system is a combination of 911 dispatchers, CVFD first responders, and contracted American
Medical Response (AMR) transport units (CVFD 2019a). In July 2013, CVFD began providing this level of care via
five engines located at Fire Stations 5, 6, 7, 8, and 9. By June of 2015, the CVFD began providing ALS level of care
via the remaining engines located at Fire Stations 1, 2, 3, and 4. Recently, Truck 51 and 57 have been added as
ALS providers making CVFD fully ALS capable – years ahead of schedule (City of Chula Vista 2020d). In the event
of any large-scale emergency in the City, the CVFD would activate their Emergency Operations Center. The
Emergency Operations Center is staffed by emergency personnel and trained City staff members with the purpose
of supporting residents during disaster by focusing on life safety, evacuation needs, as well as public utilities and
infrastructure maintenance (CVFD 2019a).
According to the CVFD’s 2019 Annual Report, the average response time for CVFD EMS’s first unit is 5 minutes and
8 seconds, and 9 minutes and 32 seconds for AMR’s EMS first unit. The average response time for CVFD’s EMS all
units is 5 minutes and 47 seconds, and 9 minutes and 44 seconds for AMR’s EMS all units (CVFD 2019b).
Police Protection Services
Police protection services for the proposed project would be provided by the Chula Vista Police Department (CVPD)
from its existing police facility located at 315 Fourth Avenue in downtown Chula Vista (City of Chula Vista 2005a). As
of August 28, 2020, the CVPD had 270 sworn employees and 108.5 civilian employees, totaling 355.5 employees. Of
the 270 sworn employees, there is 1 Police Chief, 3 Captains, 10 Lieutenants, 31 Sergeants, 54 Agents, and 171
Officers (CVPD 2020a). At least one patrol car serves each beat in the City 24 hours a day. As the City continues to
grow and the demand for police services increases, the CVPD regularly evaluates beat structure. Patrol officers
respond to calls Citywide, and the beat strength does not include traffic units, school resource officers, roving patrol
officers, and patrol sergeants who would service the project as needed. In addition, the CVPD participates in regional
mutual aid agreements which allows supporting agencies to aid in emergency situations. The CVPD opened a
community storefront facility located at 2015 Birch Road of the Otay Ranch Town Center in Chula Vista in early 2011,
which provides limited police services to the community (CVPD 2020a).
The GMOC’s Threshold Standards for the CVPD for FY 2021 includes Priority 1 Goals (Goal 1: maintain an average
response time of 6 minutes or less, and Goal 2) respond to at least 81% of calls within 7 minutes and 30 seconds)
and a Priority 2 Goal (maintain an average response time of 12 minutes or less) (CVPD 2020b). Priority One calls are
defined as emergency calls, which include: life threatening calls, felony in progress, probability of injury (crime or
accident), robbery or panic alarms, and/or urgent cover calls from officers (City of Chula Vista 2020a). Priority One
calls may require a response such as an immediate response by 2 officers from any source or assignment and/or
immediate response by paramedics/fire if injuries are believed to have occurred. Priority Two calls are defined as
urgent calls, which include: misdemeanor in progress, possibility of severe injury, serious non-routine calls (domestic
violence or other disturbances with potential for violence), and/or burglar alarms (City of Chula Vista 2020a). Priority
Two calls may require a response such as an immediate response by one or two officers, from clear units or those on
interruptible activities (traffic, field interviews, etc.).
According to the CVPD’s GMOC report, for Priority One calls, the CVPD has an average actual response time of 6
minutes and 1 second and responds to 73.23% calls within 7 minutes and 30 sections (CVPD 2020b). For Priority
Two calls, the average actual response time is 13 minute and 14 seconds. As of October 1, 2020, the CVPD does not
meet the threshold standards for Priority One threshold standards (for both Goal 1 and Goal 2) or the Priority Two
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threshold standards as stipulated by the GMOC (CVPD 2020b). However, beginning on October 22, 2018, the CVPD
began deploying drones from the rooftop of the Police Department Headquarters to 911 calls and other reports of
emergency incidents such as crimes in progress, fires, traffic accidents, and reports of dangerous subjects. This
unique concept of operations is called Drone as First Responder (DFR) and it is a transformational metho d of
policing that has demonstrated the ability to increase officer and community safety and reduce overall police
response times (City of Chula Vista 2021).
The proposed project would be required to pay the PFDIF which would fund the City’s Police Facilities and Equipment
projects (City of Chula Vista 2005b). Payment of the PFDIF would aide in enhancing the City’s GMOC Threshold
Standard for police facilities responses to emergency calls (Priority One) and urgent calls (Priority Two), which
currently do not meet the GMOC’s threshold standards.
Libraries
The City of Chula Vista operates three library facilities: the South Chula Vista Branch Library, Otay Ranch Branch
Library, and the Civic Center Branch Library (City of Chula Vista 2005a). The South Chula Vista Branch Library is the
closest library to the project site, located at 389 Orange Avenue, approximately 2.5 miles west of the proposed
project site and consists of approximately 38,000 square feet. This branch has two conference rooms seating
approximately 25 and 50 each, three small study rooms for groups of two or more that may be reserved on site and
the Rosemary Lane Galleria which acts as an exhibition space for local artists. This library is already a community
destination for social and recreational activities, particularly for teens, as well as for literacy and learning. It provides
a variety of spaces for library and community programs, cultural events, and recreational activities, as well as gallery
space for display of community art and exhibits (City of Chula Vista 2011; CVMC Section 19.09, Growth
Management). The Otay Ranch Branch Library is located at 2015 Birch Road in the Otay Ranch Town Center,
approximately 3.5 miles northeast of the proposed project site and consists of approximately 3,500 square feet
and provides a bit of everything: collection materials, computers, seating, and even a group study room.
The Civic Center Branch Library is located at 365 F Street, approximately 5 miles northwest of the proposed project
site and is the largest library facility within the City, consisting of a two -story, 55,000-square-foot building (City of
Chula Vista 2011). It also has a 152-seat auditorium and a 26-seat conference room and serves as a multi-use
facility including storage for the Heritage Museum and limited exhibition space. The Civic Center Branch site also
offers opportunities for expansion. The Strategic Facilities Plan recommends an additional 60,000 square fee t of
library space to serve Chula Vista’s buildout population.
In addition to the existing libraries described above, the current Library Facilities Master Plan (City of Chula Vista 2011)
calls for construction of the approximately 30,000 square foot Rancho del Rey library located at the intersection of East
H Street and Paseo Ranchero, approximately 2.5 miles northeast of the proposed project site. However, the Rancho del
Rey Library has been delayed indefinitely due to budget constraints (City of Chula Vista 2014).
The GMOC threshold standard for libraries is 500 gross square feet of library space, adequately equipped and
staffed, per 1,000 residents (City of Chula Vista 2020a). According to the 2019 GMOC Annual Report, the current
service ratio for FY 2019 was 350 square feet for every 1,000 residents. Therefore, the City does not current meet
the GMOC threshold for libraries.
The proposed project would be required to pay the PFDIF which would fund the City’s Library System Expansion
(City of Chula Vista 2005b). Payment of PFDIFs would aide in enhancing the City’s GMOC Threshold Standard for
the library square footage per resident ratio, which currently do not meet the GMOC’s threshold standards, and by
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funding potential future library projects. According to the Chula Vista Public Library Strategic Vision Plan (2014), an
additional approximately 60,000 square feet of library space in the City would meet the needs of the buildout
population (City of Chula Vista 2014).
Schools
Existing and Planned Educational Facilities
The CVESD (elementary schools) and the Sweetwater Union High School District (SUHSD) (middle and high schools)
would serve the proposed project site. Specifically, the project site is served by Valle Lindo Elementary School
(CVESD), Rancho Del Rey Middle School (SUHSD), Castle Park Middle School (SUHSD), Otay Ranch High School
(SUHSD), and Castle Park High School (SUHSD) (CVESD 2020a; SUHSD 2020a).
According to the CVESD webpage, the CVESD was established in 1892, is located over 103 square miles in southern
San Diego County and has 49 schools (CVESD 2020b). The CVESD serves approximately 29,600 students, primarily
grade K-6. The CVESD employs 1,703 certified employees and 1,648 classified employees. SUHSD was founded in
1920 and is located in the Cities of Chula Vista, Imperial Beach, National City, and San Diego (including the
communities of Bonita, Eastlake, Otay Mesa, San Ysidro, and South San Diego) (SUHSD 2020b). The SUHSD has
approximately 40,000 students in grades 7-12, and 22,000 adult learners.
As stated earlier, the proposed project site would be served by Valle Lindo Elementary School. Valle Lindo
Elementary School is located within the CVESD and is located at 1515 Oleander Avenue, Chula Vista, California
91911, approximately 0.25 miles west of the proposed project site. Valle Lindo Elementary School serves pre -
kindergarten to 6th grade and, as of 2019, enrolls approximately 440 students (SARC 2019a).
The Sweetwater Union High School District (SUHSD) serves the project site. Founded in 1920, SUHSD has grown to
more than 42,000 students in grades 7 through 12 and more than 32,000 adult learners. The district’s 32
campuses are located in the cities of Chula Vista, Imperial Beach, National City and San Diego, includin g the
communities of Bonita, Eastlake, Otay Mesa, San Ysidro and South San Diego. Several middle and high schools are
planned or have been recently opened in the area. The majority of the project site is within the attendance boundary
of Rancho Del Rey Middle School, while the southwestern portion of the project site is served by Castle Park Middle
School. Similarly, the majority of the project site is served by Otay Ranch High School, while the southwestern portion
of the site is served by Castle Park High School (SUHSD 2020b). All middle schools (grades 7-12) and high schools
(grades 9-12) are located approximately 1 mile from the project site.
The following schools are located within the SUHSD. Rancho Del Rey Middle School is located at 1174 East J Street,
Chula Vista, CA 91910, approximately 2 miles northeast of the proposed project site. The school serves 897
students in 7th grade and 860 students in 8th grade, totaling 1,757 students (SARC 2019b). Castle Park Middle
School is located at 160 Quintard Street, Chula Vista, California 91911, approximately 2 miles west of the proposed
project site. The school serves 408 students in 7th grade and 395 students in 8th grade, totaling 803 students
(SARC 2019c). Otay Ranch High School is located at 1250 Olympic Parkway, Chula Vista, California 91913,
approximately 2.5 miles northeast of the proposed project site. The school serves 576 students in 9th grade, 592
students in 10th grade, 578 students in 11th grade, and 626 students in 12th grade, totaling 2,372 students
(SARC 2019d). Castle Park High School is located at 1395 Hilltop Drive, Chula Vista, CA 91911, approximately 1.5
miles west of the proposed project site. The school serves 399 students in 9th grade, 424 students in 10th grade,
405 students in 11th grade, and 447 students in 12th grade, totaling 1,675 students (SARC 2019e).
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Parks
Per CVMC 17.10.040, the City’s parkland standard or parkland threshold is currently three park acres per 1,000
people (City of Chula Vista 2018). More specifically, the area to be dedicated for multiple-family dwelling units
require one acre per 128 units.
According to San Diego Association of Governments Series 13, the City’s population as of 2020 is 287,173 (see Section
5.12, Population and Housing, of this EIR). The total developed park acreage available to the public within the City is 718
acres (City of Chula Vista 2018). Currently, the ratio of parkland to population is approximately 2.64 acres of parkland
per 1,000 residents in Chula Vista, which does not currently meet the City’s parkland ratio standards as defined by CVMC
17.10.040 (City of Chula Vista 2020a). However, eastern Chula Vista, where the project is located, currently exceeds the
threshold standard for parks (City of Chula Vista 2020a). The City’s Parks and Recreation Master Plan indicates that the
City would develop an additional 363 acres of parkland by 2030, for a total of 1,081 parkland acres.
Table 5.14-3, in Section 5.14, outlines existing parks within the vicinity of the project site. As shown on this figure,
there are 8 existing parks located within 2 miles to the proposed project site, which future tenants of the proposed
project would potentially use (City of Chula Vista 2005a). These parks include Valle Lindo Park, Veteran’s Park,
Horizon Park, Greg Rogers Park, Sunbow Park, Sunridge Park, Paseo Del Rey Park, and Palomar Park. Table 5-14-3
provides detailed park information such as the street address, distance from the proposed project site, park
resource type, and total acres. As discussed earlier, public parks in the City are open to all area citizens.
Neighborhood parks generally serve a local adjacent or nearby residential neighborhood, while community parks
serve the broader community and provide a greater range of services.
Regional and County Parks
Regional and County of San Diego parks are located within or adjacent to the City of Chula Vista in eastern Chula
Vista and adjacent San Diego County. This includes the Otay Valley Regional Park and the Otay Lakes County Park
(see Section 5.14.2, Existing Conditions, for details).
5.13.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to public services is based on the recommendations
provided in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). A significant impact would occur if the
project would:
A. 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:
i. Fire protection
ii. Police protection
iii. Schools
iv. Parks
v. Other public facilities
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5.13.3 Impact Analysis
A. 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:
i. Fire protection.
Based on current Fire Station distribution, Fire Stations 3, 7, and 9 are most likely to provide initial response.
However, all stations within the CVFD are available to service the project site, if necessary. As depicted in Table
5.13-2, CVFD Fire Station No. 3, located at 1410 Brandywine Avenue is the closest station that services the
project site. Station 3 is located 1.2 miles from the most remote portion of the development. This Station is
staffed with 4 firefighters on a Type 1 Heavy Rescue apparatus, which responds to fires, technical rescues, and
medical emergencies. Fire Stations 7 and 9, which are located at 1640 Santa Venetia and 266 East Oneida,
respectively, are the next two closest stations that could respond to the site. Station 7 is located 2.9 miles away
and is staffed with 8 firefighters on a Type 1 Fire Engine, a Ladder Truck, and a Battalion Chief vehicle. Station
91 is currently located 2.7 miles from the most southern boundary of the site but is being relocated to a point
that is 4 miles from the site. The station is equipped with a Type 1 Fire Engine and 3 firefighters.
Emergency travel time for first arriving engines from each station to the project site are derived from Google
road data while travel times are calculated using response speeds of 35 mph, consistent with nationally
recognized National Fire Protection Association (NFPA) 1710 and Insurance Services Office (ISO) Public
Protection Classification Program’s Response Time Standard formula (Time=0.65 + 1.7(Distance). The ISO
response travel time formula discounts speed for intersections, vehicle deceleration and acceleration, and does
not include turnout time. Automatic and/or Mutual Aid agreements with surrounding fire departments are in
place and would potentially result in additional resources that were not analyzed within this section or the
project’s FPP (Appendix H3). The first arriving engine from Station 3 with four firefighters onboard achieves an
approximately 2-minute 05-second travel time to the southeastern portion of the project site. This first arriving
response substantially conforms with the approved response goal of 5 minutes 90% of the time, and it satisfies the
OSHA two-in and two-out standard. As mentioned above, CVFD Station 9 is being newly constructed at the southeast
corner of Naples Street and Alpine Avenue and is proposed to be completed by the middle of 2021. With that said,
once construction of the new CVFD Station 9 is completed, the current second arriving engine from Station 9 would
instead be from Station 7, which archives an approximately 4-minute 58- second travel time to the southeastern
portion of the project site.
The Effective Fighting Force (EFF) or first 3 engines, 1 truck and battalion chief for a total of 14 firefighters could be
on-scene within roughly 7 minutes travel time from three fire stations (including travel time from the new CVFD
Station 9). In this case, the emergency responses from Stations 3, 7, and 9 are substantially within 5 minutes and
under the 8-minute travel time goal for EFF. Table 5.13-3 summarizes these response times.
1 It should be noted that CVFD Fire Station 9 is being newly constructed at the southeast corner of Naples Street and Alpine Avenue
and is proposed to be completed by the middle of 2021. The new CVFD Fire Station 9 when constructed, will be approximately 4
miles from the most remote portion of the development.
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Table 5.13-3. CVFD Emergency Response Analysis for the Proposed Project Site
Chula Vista Fire
Department Station No.
Total Mileage to Furthest Extent
on Proposed Project Site
Estimated Response
Travel Time2 Firefighting Resources3
3 1.2 miles 2 min. 05 sec. USAR 53
(4 personnel/shift)
7 2.9 miles 4 min. 58 sec. Engine 57; Truck 57;
Battalion 52
8 personnel/shift)
9 2.7 miles 4 min. 40 sec. Engine 59
(3 personnel/shift)
9 (relocated site) 4.0 miles1 6 min. 50 secs. N/A
Notes:
1 It should be noted that CVFD Fire Station 9 is being newly constructed at the southeast corner of Naples Street and Alpine Avenue
and is proposed to be completed by the middle of 2021.
2 Presents results of response travel time utilized travel distances derived from Google road data while travel times are calculated
using response speeds at an average of 35 mph, consistent with nationally recognized National Fire Protection Association (NFPA)
1710 and does not include turnout times. Response times are to the furthest extent of the project site.
3 The Effective Firefighting Force could include responses from all three stations with a best-case assembly travel time of just under
6 minutes to the furthest extent of the project site.
Based on CVFD call volume estimates, the proposed project is conservative calculated to generate
approximately 191 calls per year, or about 0.52 calls per day, with roughly 69% of which (131 calls per year)
expected to be medical emergencies (Appendix H3).
For purposes of this analysis, Fire Stations 3 (USAR 53), 7 (Engine 57 and Truck 57), and 9 (Engine 59) were
evaluated as it provides perspective for the potential impacts from build out of the proposed project. Heavy
Rescue (USAR) 53 responded to 2,195 calls; Engine 57 responded to 1,793 calls; Truck 57 responded to 548
calls; and Engine 59 responded to 2,638 during 2018 (City of Chula Vista 2020a). This calculates as 6 calls
per day for USAR 53; 5 calls per day for Engine 57 (E57); 7 calls per day for Engine 59; and 1.5 calls per day
for Truck 57 (T57). See Appendix H3 for additional details.
As previously mentioned, the proposed project is estimated to generate approximately 191 calls per year. The
addition of less than 1 call per day to Fire Station 7 that currently has fire apparatus that responds to
approximately 1.5 (T57) and 4.9 (E57), calls per day, respectively is considered average for typical urban fire
stations. Six or seven calls per day for Stations 3 and 9, respectively, would be considered already busy stations.
For perspective, a typical station averages five calls per day and a busy station responds to about ten calls per
day. With the additional 1 call per day, as described herein, and the currently low call volume at Station 7 and
slightly above average calls at other stations, the additional calls associated with build out can be absorbed
and still result in acceptable emergency response coverage. Table 5.13-4 presents estimated call volume
increases based on the demand from the proposed project
Table 5.13-4. Fire Station Call Volumes
Chula Vista
Fire Station
Current Daily Call
Volume
Estimated Daily Call
Volume Increase
Estimated Total Daily Call Volumes
with Proposed Project1
3 6.0 (USAR 53) Less than 1.0 Approx. 6.5
7 4.9 (Engine 57) + 1.5
(Truck 57)
Less than 1.0 Less than 6.9
9 7.2 (Engine 59) Less than 1.0 Less than 7.7
Source: Appendix H3.
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Notes:
1 Estimated total daily call volume is based on existing volume in addition to the conservatively calculated 0.52 calls per day from
the Proposed Project.
The available firefighting and emergency medical resources in the vicinity of the project site include an
assortment of fire apparatus and equipment considered capable of responding to the type of fires and
emergency medical services potentially occurring within the proposed project. The proposed project is projected
to slightly increase the nearest station’s (Fire Station 3) current call volume, but not at significant levels,
because the current call volume is considered slightly above average compared to other urban fire stations and
the capacity would not be considered impacted to the point of resulting in a busy or stressed condition.
Furthermore, the proposed project does not include the construction of any fire stations. However, in the event
that the new fire stations are constructed after implementation of the proposed project, the new fire stations
would be supported on a fair share basis by future development (including the proposed project), through
payment of the City’s PFDIF. The PFDIF addresses a project’s proportional impact on capital facilities, such as
structures and equipment, associated with fire protection. It does not address the impacts associated with
operations and maintenance for those facilities, and it is the City’s policy to use public funds such as property
taxes, sales taxes, and fees generated by the proposed project to cover the incremental costs associated with
providing fire services. This impact would be potentially significant if these mechanisms are not enforced.
Therefore, impacts would be potentially significant and mitigation is required (Mitigation Measure [MM] PS-1;
see Section 5.13.5, Mitigation Measures).
ii. Police protection.
The Chula Vista Police Department (CVPD) would provide law enforcement services to the project site. The CVPD
currently provides police service to the project site from its existing police facility in downtown Chula Vista. The
current ratio of police officers required to adequately serve the residents of the City is 1.16 sworn police officers
per 1,000 residents. The project would generate approximately 2,315 residents. Thus, rounding the number of
residents to 2,500 for adequate police coverage would result in approximately 3 sworn police officers (2.5
multiplied by 1.16) required to support the population generated from the project. The City’s PFDIF, described
previously, would help cover the cost of new or expanding public facilities within the City, incl uding police
facilities. The proposed project would be subject to the payment of the PFDIF at the rate in effect at the
time building permits are issued. Although additional law enforcement staff may be required to adequately
support the proposed project at buildout, the project would be required to pay the PFDIF, which would be used
exclusively for future facility improvements necessary to ensure that the development contributes its fair share
of the cost of police facilities and equipment determined to be necessary to adequately accommodate new
development in the City. This impact would be potentially significant if these PFDIF mechanisms are not
enforced. Therefore, impacts would be potentially significant and mitigation is required (MM-PS-1).
iii. Schools.
The proposed project would increase the number of dwelling units and population within the City, thereby generating
a number of students (see Section 5.12). Students from the proposed project would be served by CVESD’s Valle
Lindo Elementary School and SUHSD’s Rancho Del Rey Middle School, Castle Park Middle School, Otay Ranch High
School, and/or Castle Park High School (CVESD 2020b; SUHSD 2020b).
The additional population generated by the proposed project could potentially overcrowd schools and result in
the need for additional schools. Schools are funded through the payment of Development Impact Fees (DIFs)
pursuant to SB 50/Government Code Section 65995. CVESD collects Level I Schedule fees for new residential
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and commercial/industrial developments (CVESD 2010). SUHSD currently collects Level I Schedule fees for
residential and commercial developments based on the square footage of the new developments (SUHSD
2020c). Fees paid by the developer would be used to offset the impact of the number of new students
generated by the development of the proposed project. These fees are required to be paid by future
development prior to issuance of building permits.
As stated previously, the project site is located within existing CFDs for CVESD and SUHSD, which impose a
special tax on property owners to finance both school districts. Any development of new school facilities
resulting from these CFDs would be undertaken by the school district and an environmental document would
be prepared at such time. Pursuant to Education Code Section 17620(a)(1), the governing board can authorize
the levy of a fee, charge, dedication, or other requirements against any construction within school district
boundaries, and with the school district’s collection of Statutory and Alternative fees developers could fully
mitigate their impact. However, in the event that these taxes are not implemented, impacts to schools would
be potentially significant. Therefore, impacts would be potentially significant and mitigation is required (MM-
PS-2; see Section 5.13.5).
iv. Parks.
As discussed above, the City’s existing parkland to resident ratio conditions do not meet the standards defined
in CVMC 17.10.040. However, according to the City’s Parks and Recreation Master Plan, in 2030, the City’s
forecasted population would be 340,215 and 1,237 acres of developed parkland would be within the City. With
the projected population and the anticipated additional 363 acres of parkland development, the City would have a
parkland ratio of 3.64 acres of parkland per 1,000 residents. The proposed project is aligned with the City’s
forecasted population growth for 2030 (see Section 5.12). The proposed project would not disrupt the City’s existing
conditions and existing plans that would create an adequate parkland per resident ratio.
The Applicant would comply with CVMC Section 19.80, Controlled Residential Development, which would
ensure that development would not degrade existing public services and facilities below acceptable standards
for parks and other public services. Payment of appropriate fees (further discussed below) would allow existing
public services and facilities to remain at acceptable standards while the usage potentially increases due to
the population increase resulting from the proposed project. The applicant would comply with CVMC Section
19.09, Growth Management, which provides policies and programs that tie the pace of development to the
provision of public facilities and improvements. CVMC Section 19.09.040E, specifically, requires three acres of
neighborhood and community park land with appropriate facilities per 1,000 residents east of I-805.
Additionally, the proposed project would pay the appropriate land acquisition and park development fees to
offset potential impacts to recreational facilities and parkland. A Community Benefit Agreement between the
City and the Applicant stipulates that the Applicant shall pay the City a Park Benefit Fee, equal to the Park
Acquisition and Development (PAD) fee that would have been due pursuant to CVMC Section 17.10, of
approximately $11.03 million based on 2019 PAD fees, which may be revised by the City from time to time.
The Public Benefit Fee would be used by the City to acquire or develop parkland, pursuant to the City’s Parks
and Recreation Master Plan. Without payment of the Park Benefit Fees, impacts associated with parks would
be potentially significant. Therefore, impacts would be potentially significant and mitigation is required (MM-PS-
3; see Section 5.13.5).
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v. Libraries.
The proposed project would result in increased demand for libraries and may have the potential to require the
construction of new or expanded library facilities. The Chula Vista Library Strategic Vision Plan establishes a
standard of 500 square feet of adequately equipped and staffed library facilities per 1,000 residents (City of
Chula Vista 2014). The proposed project development would result in approximately 2,315 persons (see
Section 5.12 of this EIR). Thus, the proposed project would generate demand for approximately 1,158 square
feet of additional library facilities within the City. Although the proposed project does not specifically include the
development of a library, this demand would be satisfied through payment of PFDIF as stated in CVMC Section
3.50.030 and 3.50.060, which would go toward the City’s library system expansion program. Thus, impacts
would be potentially significant if these PFDIF mechanisms are not enforced. Therefore, impacts would be
potentially significant and mitigation is required (MM-PS-1).
5.13.4 Level of Significance Prior to Mitigation
Prior to mitigation, the proposed project would have potentially significant impacts associated with fire protection,
police protection, libraries, and schools.
5.13.5 Mitigation Measures
Implementation of the following mitigation measures would reduce identified potentially significant impacts
associated with fire protection, police protection, libraries, and schools to a less-than-significant level:
MM-PS-1 Prior to the issuance of each building permit for any residential dwelling units, the applicant shall
pay a Public Facilities Development Impact Fee (PFDIF) in accordance with the fees in effect at the
time of building permit issuance and phasing approved in the Supplemental Public Facilities
Finance Plan, unless stated otherwise in a separate development agreement.
MM-PS-2 Prior to the issuance of a building permit, the applicant shall provide evidence or certification by
the Chula Vista Elementary School District (CVESD) and the Sweetwater Union High School District
(SUHSD) that any fee charge, dedication or other requirement levied by the school district (s) has
been complied with or that the district(s) has determined the fee, charge, dedication or other
requirements do not apply to the construction or that the applicant has entered into a school
mitigation agreement. School facility mitigation fees shall be in accordance with the fees in effect
at the time of building permit issuance.
MM-PS-3 No earlier than issuance of certificate of occupancyPrior to the issuance of each building permit for
any residential dwelling units, the applicant shall pay the Park Benefit Fee, as outlined in the
project’s Development Agreement, equal to the City’s Park Acquisition and Development (PAD) Fee
Update pursuant to Chula Vista Municipal Code Section 17.10. The final Park Benefit Fee amount
shall be determined based on the number and type of residential units constructed and the PAD
fee rates in effect as of the effective date of paymentthe project’s Development Agreement. To
create this Park Benefit Fee, the City will waive the parkland dedication and development
requirements set in Chapter 17.10 of the Chula Vista Municipal Code, including the Parkland
Acquisition and Public Facilities Development fees, and Quimby Act fees. The Park Benefit Fee shall
satisfy the project’s park obligations and may be utilized by the City to acquire or develop parkland,
as the City determines appropriate and in the best interest of the City.
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5.13.6 Level of Significance After Mitigation
Implementation of MM-PS-1 through MM-PS-3 would reduce potentially significant impacts associated with fire
protection, police protection, libraries, and schools to a less-than-significant level.
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Project Boundary
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Facility
Fire Station
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Park
School
FIGURE 5.13
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5.15 – Transportation
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5.15 Transportation
This section of the environmental impact report (EIR) addresses potential impacts to transportation resulting from
the proposed Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II, Phase 3 Project (project
or proposed project). The discussion in this section is based on the Transportation Impact Analysis (TIA) prepared
for the project by Linscott, Law, and Greenspan (LLG). The complete report is provided in Appendix K of this EIR.
5.15.1 Existing Conditions
5.15.1.1 Regulatory Framework
Federal
No federal regulations or guidelines relating to transportation apply to the proposed project.
State
Senate Bill 743
In September 2013, the Governor’s Office signed SB 743 into law, starting a process that fundamentally changes
the way transportation impact analysis is conducted under the California Environmental Quality Act (CEQA). Within
the State’s CEQA Guidelines, these changes include the elimination of auto delay, level of service (LOS), and similar
measurements of vehicular roadway capacity and tra ffic congestion as the basis for determining significant
impacts. The guidance identifies vehicle miles traveled (VMT) as the most appropriate CEQA transportation metric,
along with the elimination of auto delay/LOS for CEQA purposes statewide. The justification for this paradigm shift
is that auto delay/level of service (LOS) impacts lead to improvements that increase roadway capacity and therefore
induce more traffic and greenhouse gas (GHG) emissions. The legislation was also intended to incentivize
development in and around Transit Priority Areas (TPAs) and High-Quality Transit Corridors (HQTCs), and to
encourage high density infill and mixed-use projects. In January 2016, the Governor’s Office of Planning and
Research (OPR) issued Draft Guidance, which provided recommendations for updating the State’s CEQA Guidelines
in response to SB 743 and recommended practice for VMT analysis in an accompanying Technical Advisory on
Evaluating Transportation Impacts in CEQA (Technical Advisory). OPR’s most recent Technical Advisory is dated
December 2018.
Statewide Transportation Improvement Program
The Statewide Transportation Improvement Program (STIP), run by the California Transportation Commission, is a
multi-year, statewide, intermodal program of transportation projects that is consistent with the statewide
transportation plan and planning processes, metropolitan plans, and Title 23 of the CFR. The latest version of the
STIP was adopted on March 25, 2020 (California Transportation Commission 2020). The STIP is prepared in
cooperation with the California Department of Transportation (Caltrans), the metropolitan planning organizations,
and the regional transportation planning agencies. In the County of San Diego, the regional transportation planning
agency is the San Diego Association of Governments (SANDAG). The STIP contains all capital and non -capital
transportation projects or identified phases of transportation projects for funding under the Federal Transit Act and
Title 23 of the CFR, including federally funded projects.
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Interregional Transportation Improvement Program
The 2015 Interregional Transportation Improvement Program (ITIP) was approved by Caltrans in December 2015.
California Government Code Section 14526 specifies that the purpose of the ITIP is to fund projects that improve
interregional movement for people and goods across California on the State Highway System and develop Intercity
Passenger Rail corridors of strategic importance. The ITIP is one of many state funding programs that collectively
invest in transportation infrastructure, maintenance and operations and is prepared by Caltrans for submittal to the
California Transportation Commission to assist with recommendations for projects in the STIP.
Congestion Management Program
The Congestion Management Program was enacted by the state legislature in 1989 to improve traffic congestion in
urbanized areas. The program became effective with the passage of state Proposition 111 in June 1990, which increased
the state gas tax. The funds generated by the gas tax increase are advanced to cities and counties for constructing road
improvements, provided that a Congestion Management Program is in place. If a city does not comply with the Congestion
Management Program, it could lose funding under Proposition 111. Under the program, regional agencies within each
county are designated to prepare and administer the Congestion Management Program.
Local
San Diego Association of Governments
SANDAG serves as the forum for decision making on regional issues such as growth, transportation, land use,
economy, environment, and criminal justice. SANDAG builds consensus, prepares strategic plans, obtains, and
allocates resources, and provides information on a broad range of topics pertinent to the region’s quality of life.
SANDAG is governed by a Board of Directors composed of mayors, council members, and supervisors from each of
the San Diego region’s 19 local governments. As the metropolitan planning organization and regional transportation
planning agency for the San Diego region, SANDAG has produced the following documents that identify
transportation plans and policies in the San Diego area.
San Diego Forward – The Regional Plan
San Diego Forward: The Regional Plan (The Regional Plan) was adopted by SANDAG on October 9, 2015. The
Regional Plan combines and updates two regional planning documents, the 2004 Regional Comprehensive Plan
and the 2011 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), into a unified document
to guide regional growth between 2015 and 2050. The Regional Plan unites land use and transportation planning
by incorporating local planning efforts with regional transportation planning and also identifies investments in public
transportation, bike paths, and pedestrian improvements in the region. The Regional Plan includes a number of
elements, one of which is the SCS. Required by state law (SB 375), the primary purpose of the SCS is to show how
development patterns and our transportation system will work together to reduce GHG emissions for cars and light
trucks, providing a more sustainable future for our region.
2014 Regional Transportation Improvement Plan
The Regional Transportation Improvement Program (RTIP) is a multi-year program of proposed major highway,
arterial, transit, and bikeway projects. The 2014 RTIP is a prioritized program designed to implement the region’s
overall strategy for providing mobility and improving the efficiency and safety of efforts to attain federal and state
air quality standards for the region. The 2014 RTIP also incrementally implements the 2011 Regional
Transportation Plan. The 2014 RTIP covers fiscal years 2014/2015 to 2018/2019. The 2014 RTIP was adopted
on September 26, 2014.
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City of Chula Vista General Plan
The City of Chula Vista General Plan (General Plan), known as Vision 2020, was adopted by the City on December
13, 2005 (Chula Vista 2005). The General Plan contains objectives and policies in the Land Use and Transportation
Element that support transit (Objective LUT 17), encourage alternative transportation measures (Objectives LUT 18
and LUT 23), encourage regional transportation coordination (Objective LUT 19), develop transit-friendly roads
(Objective LUT 20), support parking management policies (Objectives LUT 30 through LUT 33), and ensure
pedestrian-oriented environments (Objective LUT 63).
Chula Vista Municipal Code
Chula Vista Municipal Code (CVMC) Chapter 3.54 establishes a Transportation Development Impact Fee (TDIF) to
fund transportation improvements and facilities within the Eastern Territories of the City and requires payment prior
to the issuance of building permits for development. Section 3.54.030 lists the transportation facilities to be
financed by the fees collected and includes a total of 72 roadways within the City. In addition, CVMC Chapter 12.24,
Dedications, imposes reasonable requirements upon developers of traffic-generating developments within the City
to mitigate potential dangers associated with the (1) lack of sidewalks; (2) moving, high, and stagnant waters during
the rainy season; (3) streets of inadequate widths; (4) poor drainage due to the lack of curbs, storm drain facilities
and improved alleys; and (5) inadequate street lighting, to the extent reasonably possible.
City of Chula Vista Transportation Study Guidelines
The City of Chula Vista adopted their Traffic Study Guidelines (TSG) in June of 2020 to comply with SB 743. The
TSG provides criteria to evaluate projects for consistency related to the City’s transportation goals, policies, and
plans, and through procedures established under CEQA. The TSG establishes the content requirements and
procedures for preparing a Transportation Study in Chula Vista. At the time the project’s VMT analysis was prepared,
the City was still in the process of developing their guidelines for VMT evaluation. Therefore, LLG coordinated with
City Staff to develop an interim approach and methodology, and to obtain the latest draft screening map which
identifies residential VMT per capita for locations regionwide. The interim approach and methodology are consistent
with the approved TSG for the purposes of evaluating the project’s potential vehicular impacts.
Sunbow General Development Plan
The Sunbow General Development Plan (GDP; City of Chula Vista 1989) proposes development of a 604.8-acre
planned community in eastern Chula Vista. The principal objective of the GDP is the creation of an efficient, self-
contained village. One of the primary objectives of the GDP is to provide a safe, convenient, and efficient local
circulation system which maximizes access between residential areas and community facilities while minimizing
travel distance and reliance on the automobile.
5.15.1.2 Existing Setting
Existing Transportation Network
The following is a description of the major roadways, bicycle network, pedestrian facilities, and transit located within
the immediate vicinity of the project site.
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Roadways
Olympic Parkway
Olympic Parkway is classified as a Prime Arterial in the City of Chula Vista Circulation Plan (Circulation Plan). It is built as
a 6-lane divided road with three lanes westbound and three lanes eastbound and a raised median. The posted speed
limit is 45 mph from I-805 to Brandywine Avenue. and 50 mph east of Brandywine Avenue.
Oleander Avenue
Oleander Avenue is classified as a two-lane collector street in the Circulation Plan. It is built as a 2-lane undivided
road with one lane northbound and one lane southbound. The posted speed limit is 25 mph.
Brandywine Avenue
Brandywine Avenue is classified as a Class I collector in the Circulation Plan. It is built as a 4-lane undivided road
with two lanes northbound and 2 lanes southbound, north of Olympic Parkway and a 2-lane undivided road with
one lane northbound and 1 lane southbound, south of Olympic Parkway. The posted speed limit is 40 mph north of
Olympic Parkway and 35 mph south of Olympic Parkway.
Heritage Road
Heritage Road is classified as a Prime Arterial in the Circulation Plan. It is built as a 6-lane divided road with 3 lanes
northbound and 3 lanes southbound. The posted speed limit is 40 mph.
Santa Venetia Street
Santa Venetia Street is classified as a two-lane collector in the Circulation Plan. It is built as a 2-lane undivided road with
one lane northbound and one lane southbound, south of Olympic Parkway. The assumed speed limit is 25 mph.
La Media Road
La Media Road is classified as a Prime Arterial in the Circulation Plan. It is built as a 6-lane divided road with 3
lanes northbound and 3 lanes southbound. The posted speed limit is 45 mph.
Bicycle Network
There is a Class 2 bike lane on Olympic Parkway between Oleander Avenue and Lake Crest Drive. There is a Class
2 bike lane on Brandywine Avenue beginning at Telegraph Canyon Road and ending at Main Street. There is a Class
2 bike lane on Heritage Road beginning at Telegraph Canyon Road and ending at Main Street. Class 2 bike lanes
are provided on both sides of La Media Road beginning at Telegraph Canyon Road and ending at Santa Luna Street.
Pedestrian Facilities
Sidewalks are provided along both sides of Olympic Parkway, Oleander Avenue, Brandywine Avenue, Santa Venetia
Street, and La Media Road. Sidewalks are also provided on both sides of Heritage Road, north of Olympic Parkway,
and on the east side of Heritage Road, south of Olympic Parkway. The Chula Vista Regional Trail is located along
the west side of Heritage Road south of Olympic Parkway. Four signalized crosswalks with ramps on each corner
are located adjacent to the project site at the intersection of Olympic Parkway and Brandywine Avenue.
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Transit
The project area is served by transit provided by the San Diego Metropolitan Transit System (MTS). There are no
bus routes that travel directly along Olympic Parkway adjacent to the project site.
The five MTS bus routes summarized in the following paragraphs serve the general study area.
Route 225. Route 225 runs from the Otay Mesa Transit Center to the Santa Fe Depot Transit Center via Broadway,
I-805, and SR-125, as well as other streets that are not near the project study area. There are 11 stops along this
route with destinations to the East Palomar Transit Station, City College Transit Center, and the Santa Fe Depot.
Route 225 currently operates Monday through Friday from 4:49 AM through 10:13 PM departing from the Otay
Mesa Transit Center and from 6:08 AM through 11:39 PM departing from the Santa Fe Depot Transit Center.
Saturday and Sunday route schedule begins at 4:49 AM through 10:11 AM departing from the Otay Mesa Transit
Center and begins at 6:08 AM to 11:37 PM departing from the Santa Fe Depot Transit Center. Route 225 operates
on observed holidays with a Saturday or Sunday schedule. Weekday schedules include 30-minute headways.
Weekend schedules include 30-minute headways.
Route 704. Route 704 runs from the East Street Transit Center to the Palomar Street Transit Center via East Orange
Avenue, Brandywine Avenue, and East Palomar Street, as well as other streets that are not near the project study
area. There are 48 stops along this route with destinations to the Chula Vista Public Library, Civic Center, Memorial
Park, Sharp CV Medical Center, South County Regional Center, and the Veterans Home. Route 704 currently
operates Monday through Friday from 6:03 AM through 8:20 PM departing from the E Street Transit Center and
from 5:28 AM through 9:00 PM departing from The Palomar Street Transit Center. Saturday route schedule begins
at 6:26 AM through 8:25 AM departing from the E Street Transit Center and begins at 6:28 AM to 8:29 PM departing
from the Palomar Street Transit Center. Sunday schedule begins at 7:22 AM through 6:22 PM departing from Sharp
Medical Center and begins at 7:30 AM through 6:30 PM departing from the Palomar Street Transit Center. Route
704 operates on observed holidays with a Saturday or Sunday schedule. Weekday schedules include 30 -minute
headways. Weekend schedules include 1-hour headways.
Route 707. Route 707 runs from Eastlake Parkway and Olympic Parkway to Southwestern College via East H Street
and Eastlake Parkway. There are 26 stops along this route with destinations to Bonita Vista High School, Eastlake
High School, Eastlake Village Center, Otay Ranch Town Center, and Southwestern College. Route 707 currently
operates Monday through Friday from 5:02 AM through 7:14 PM departing from Eastlake Parkway & Olympic
Parkway and from 6:31 AM through 7:23 PM departing from Southwestern College. Weekday schedules include
30-minute headways. Route 707 does not operate on weekends or observed holidays.
Route 709. Route 709 runs from the H Street Transit Center to Eastlake Parkway & Olympic Parkway via East H
Street, East Palomar Street, and La Media Road, as well as other streets that are not near the project study area.
There are 22 stops along this route with destinations to Bonita Vista High School, Hilltop High School, Otay Ranch
Town Center, Scripps Hospital and Southwestern College. Route 709 currently operates Monday through Friday
from 5:49 AM through 10:22 PM departing from the H Street Transit Center and f rom 4:52 AM through 10:06 PM
departing from Eastlake Parkway & Olympic Parkway. Saturday route schedule begins at 6:22 AM through 9:55 AM
departing from the H Street Transit Center and begins at 5:37 AM to 9:37 PM departing from Eastlake Parkway &
Olympic Parkway. Sunday schedule begins at 6:51 AM through 8:07 PM departing from the H Street Transit Center
and begins at 6:37 AM through 7:50 PM departing from Eastlake Parkway & Olympic Parkway. Route 709 operates
on observed holidays with a Saturday or Sunday schedule. Weekday schedules include 30-minute headways.
Weekend schedules include 1-hour headways.
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Route 712. Route 712 runs from the Palomar Street Transit Center to Southwestern College via Palomar Street and
East Palomar Street. There are 26 stops along this route with destinations to Castle Park Middle School, Castle
Park High School, Heritage Park, Palomar High School, Sharp Medical Center, and Veterans Park. Route 712
currently operates Monday through Friday from 5:45 AM through 9:26 PM departing fro m the Palomar Street Transit
Center and from 6:19 AM through 10:09 PM departing from Southwestern College. Saturday route schedule begins
at 6:30 AM through 8:30 PM departing from the Palomar Street Transit Center and begins at 6:19 AM to 8:19 PM
departing from Southwestern College. Sunday schedule begins at 8:00 AM through 7:00 PM departing from the
Palomar Street Transit Center and begins at 6:49 AM through 6:48 PM departing from Southwestern College. Route
712 operates on observed holidays with a Saturday or Sunday schedule. Weekday schedules include 30-minute
headways. Weekend schedules include 1-hour headways.
5.15.1.3 Methodology
In compliance with SB 743, the TIA evaluates the project’s potential vehicular impacts using a vehicle miles traveled
(VMT) metric, pursuant to direction from the Governor’s Office of Planning and Research (OPR) in December 2018
and specifically addresses Threshold B of the Transportation thresholds of significance per the CEQA guidelines
(see Section 5.15.2 and 5.15.3 below).
Vehicle Miles Traveled
The City of Chula Vista adopted their TSG in June of 2020. However, at the time the project’s VMT analysis was
prepared, the City was still in the process of developing their guidelines for VMT evaluation. Therefore, LLG
coordinated with City Staff to develop an interim approach and methodology, and to obtain the latest draft screening
map which identifies residential VMT per capita for locations regionwide. The interim approach and methodology
are consistent with the approved TSG for the purposes of evaluating the project’s potential vehicular impacts.
VMT is defined as a measurement of miles traveled by vehicles within a specified region and for a specified time period.
VMT is a measure of the use and efficiency of the transportation network. VMTs are calculated based on individual vehicle
trips generated and their associated trip lengths. VMT accounts for two-way (round trip) travel and is estimated for a
typical weekday for the purposes of measuring transportation impacts. For residential projects, “VMT per capita” is the
efficiency metric used for evaluation. In general, the analysis presents the project VMT per capita, and compares it to a
regional VMT per capita to determine if the former is higher, equal to, or lower than the latter.
Proposed Technical Guidance
The following information is sourced from OPR’s latest Technical Advisory (2018). This represents a non-regulatory
advisory document on the evaluation of transportation impacts using VMT.
General Recommendations Regarding Methodology
The following is a discussion of the general methodology recommendations to evaluate VMT for various technical
areas and project types. The project would fall within the “Residential Projects” category, and the SANDAG Series
13 Year 2020 Travel Demand Model (TDM) was used in the analysis presented in this report. The Series 13 Year
2020 TDM generated a land use-specific average trip length (residential) as well as an average daily volume to
calculate the total residential VMT per capita.
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Using Models to Estimate VMT
Travel demand models, sketch models, spreadsheet models, research, and data can all be used to calculate and
estimate VMT. To the extent possible, lead agencies should choose models that have sensitivity to features of the
project that affect VMT. Those tools and resources can also assist in establishing thresholds of significance and
estimating VMT reduction attributable to mitigation measures and project alternatives.
Vehicle Types
Vehicle Miles Traveled refers to on-road passenger vehicles, specifically cars and light trucks. Heavy-duty truck VMT
could be included for modeling convenience and ease of calculation.
Residential Projects
Residential project VMT is evaluated in terms of VMT per capita, with project results compared to established VMT
thresholds to determine significance of project impacts.
Transit Priority Areas
Any project that includes in its geographic bounds a portion of an existing or planned Transit Priority Area (TPA) (i.e.,
the project is within 0.5 miles of an existing or planned major transit stop or an existing stop along a high -quality
transit corridor) may employ VMT as its primary metric of transportation impact for the entire project. A high-quality
transit corridor is defined as a corridor with fixed route bus service with service intervals no longer than 15 minutes
during peak commute hours.
Recommendations Regarding Significance Thresholds
Lead agencies have the discretion to set or apply their own thresholds of significance. However, the cr iteria for
determining the significance of transportation impacts should promote:
• Reduction of GHG emissions
• Development of multimodal transportation networks
• A diversity of land uses
Given that the City had not yet adopted VMT thresholds at the time the project’s VMT analysis was prepared, the
OPR Technical Advisory was used for the project’s VMT analysis:
• Residential Projects: A project exceeding a level of 15% 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% or less of the Regional VMT per capita. Any project whose VMT per capita is 15% or more below the
Regional mean is presumed to be less than significant. This approach is consistent with the approved TSG.
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VMT Analysis
Local Agency Transition to SB743
In June 2020, the City of Chula Vista adopted their TSG to comply with Senate Bill 743, which replaced LOS with
VMT as the metric for determining the significance of a project’s transportation impacts under CEQA.
Since the VMT analysis for the project was prepared prior to formal adoption of the City’s TSG, LLG consulted with
City staff and was instructed to utilize OPR guidance from the Technical Advisory and San Diego ITE Regional
Guidelines to develop significance thresholds and technical methodologies for the project.
Significance Criteria
Guidance from OPR’s Technical Advisory is used to establish a significance threshold of a minimum 15% reduction
or more from the Regional average VMT per capita for this residential evaluation. That means that if the project’s
VMT per capita is more than 15% below the regional average, no significant transportation impact would result.
This approach is consistent with the approved TSG.
Map-Based Screening
Prior to any detailed project-specific VMT analysis, OPR allows for the use of a “map-based screening” (screening
map) to identify if a project would result in a less-than-significant impact. The City’s screening map which has been
developed for their VMT guidelines was utilized for the project. This map provides VMT per capita evaluation for
locations throughout the City, and accounts for surrounding land uses, populat ion density, and transportation
infrastructure in accordance with OPR guidelines. These elements collectively shape mobility behavior and provide
a strong indication of expected project VMT. In general, higher density and mix of land uses with access to mobility
options are expected to generate lower VMT.
Screening Map Results
The City’s VMT Screening Tool allows for a search by address of properties within the City. The data presented in
the screening map include the following:
• Census tract
• VMT per capita
• Percent of regional mean
• Residents
• Description of VMT results
The VMT Screening Tool shows the project location, the City boundaries, and the TPAs and HQTCs identified within
the City. The data represented on the VMT Screening Tool follows the OPR guidance and displays VMT efficient
areas that are 85% or less of the SANDAG regional average. The da ta shown is based on the SANDAG Series 13
Activity Based Model #1 (ABM1) for the base year of the model 2012. As shown in the results of the VMT Screening
Tool provided in the TIA, the project site is not fully located within a HQTC or TPA. A small portion of the project site
is within 0.5 miles of a High-Quality Transit Corridor. The City has determined the project not to be eligible for map-
based screening given that the site is only partially enclosed by a transit buffer.
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5.15.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to transportation is based on the recommendations
provided in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). A significant impact would occur if the
project would:
A. Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit,
roadway, bicycle and pedestrian facilities.
B. 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.
5.15.3 Impacts
A. Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway,
bicycle and pedestrian facilities?
The General Plan Land Use and Transportation Element contains objectives and policies that support transit
(Objective LUT 17), encourage alternative transportation measures (Objectives LUT 18 and LUT 23), encourage
regional transportation coordination (Objective LUT 19), develop transit-friendly roads (Objective LUT 20), support
parking management policies (Objectives LUT 30 through LUT 33), and ensure pedestrian -oriented environments
(Objective LUT 63).
The project would propose a high density residential use located in close proximity to major streets such as Olympic
Parkway, Brandywine Avenue, Heritage Road and the I-805 freeway. Future residents of the project would have
access to a Class 2 bike lane and sidewalks and the Chula Vista Regional Trail adjacent to the project site along
Olympic Parkway. As discussed in Section 5.15.1, Existing Conditions, there are also nearby Class 2 bike lanes
along Brandywine Avenue (beginning at Telegraph Canyon Road and ending at Main Street) and Heritage Road
(beginning at Telegraph Canyon Road and ending at Main Street). Residents would have access to sidewalks/Chula
Vista Regional Trails along Olympic Parkway as well as Heritage Road. Located adjacent to the project site at the
intersection of Olympic Parkway and Brandywine Avenue are four signalized crosswalks with ramps on each corner.
The surrounding area is served by transit provided by the San Diego MTS. While there are no bus routes that travel
directly along Olympic Parkway adjacent to the project site, transit connection for route 704 is provided at the transit
stop on Brandywine Avenue located approximately 250-feet east of the project site. Thus, the future residents of
the project would have access to major roadways, freeways, transit, and bicycle and pedestrian facilities. As such,
the project would be consistent with the City’s Land Use and Transportation Element.
Additionally, the project would be consistent with the GDP, which has a principle objective to create an efficient,
self-contained village. One of the primary objectives of the GDP is to provide a safe, convenient, and efficient local
circulation system which maximizes access between residential areas and community facilities while minimizing
travel distance and reliance on the automobile.
As part of the TIA, a project -specific Local Mobility Analysis (LMA) was prepared that focuses on automobile
delay/LOS. The LOS analysis was conducted to identify roadway deficiencies in the project study area (refer to
Appendix K for further details) and recommend project improvements to address such deficiency. The LMA was
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prepared for existing plus project conditions, near -term without project conditions, near -term with project
conditions, and year 2035 conditions. The City’s goal for acceptable levels of service is generall y LOS D or better
at signalized and unsignalized intersections and LOS C along roadway segments (City of Chula Vista 2005). The
LMA is a City requirement for transportation analysis that is not tied to CEQA; therefore implementation of
measures to address LOS-related effects does not constitute CEQA mitigation.
The TIA determined that the project would result in effects associated with unacceptable LOS under the General Plan
LOS standards. While Olympic Parkway is built-out and the provision of additional lanes is considered physically
infeasible, it is recommended that payment of the City’s Transportation Development Impact Fee (TDIF) should be
applied towards other planned network enhancements included in the Eastern TDIF program that would reduce traffic
on Olympic Parkway and be implemented as a condition of approval for the project outside of this EIR. In addition, it is
recommended that the project provide a fair share contribution toward the provision of Adaptive Traffic Signal Control
(ATSC) modules to each signalized intersection along the Olympic Parkway corridor between the I-805 Ramps and La
Media Road (refer to Appendix K for further details). These TDIF and other requirements associated with LOS deficiencies
would be included as part of the project’s conditions of approval, outside of this EIR.
Therefore, impacts associated with the project conflicting with a program, plan, ordinance, or policy addressing the
circulation system, including transit, roadway, bicycle and pedestrian facilities, would be less than significant.
B. Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b).
As discussed in Section 5.15.1 the City was still in the process of developing their guidelines for VMT evaluation at
the time the project’s VMT analysis was prepared. Therefore, an interim approach and methodology was developed
in coordination with City staff. Thus, for this analysis, the minimum threshold of significance for determination of
the project’s transportation impact is 15% or less of the City VMT per capita. Any project whose VMT per capita is
15% or more below the regional mean is presumed to be less than significant. As shown in Table 5.15-1, the results
of the project VMT comparison indicate that the project would exceed the significance threshold by 1.4%. This would
require a reduction of 1.4% or more to reduce the VMT impact to less than significant. This approach is consistent
with the City’s TSG, which is now approved.
To calculate the VMT per capita for the baseline and the project, the SANDAG Series 13 Year 2020 TDM was used.
The model generates a land use-specific average trip length (residential) as well as an average daily volume, which
ultimately calculates the total residential VMT per capita, region-wide and for the project. The SANDAG Series 13
Year 2020 TDM results are included in Appendix K. Table 5.15-1 summarizes the Regional average baseline VMT
results provided by SANDAG using the Series 13 model. As seen in Table 5.15-1, the Regional average baseline
VMT per capita is 16.4 miles per resident. For the purpose of determining the significance of VMT impacts, the
project VMT per capita would need to be 85% below the Regional average, which equates to 13.9 VMT pe r capita.
Similar to the Regional average baseline calculations, the project VMT per capita was determined. However, since
the project site is currently zoned for industrial use, is coded as such in the SANDAG model, and it is difficult to
accurately override the zoned land uses, a proxy site located just a few hundred feet north of the project site with
similar residential land use characteristics (i.e. single family residential dwelling units) was used to determine the
expected VMT per resident. The proxy site contains single family residential units and does not have direct access
to Olympic Parkway. In addition, per the SANDAG Trip Generation Brief Guide, single-family and multi-family
residential units have the same trip lengths, therefore, the difference in unit type between the proxy site and the
project site is not relevant to the VMT analysis. The proxy site does not have direct access to Olympic Parkway ,
which results in longer trip lengths (and therefore greater VMT) as compared to the project site. Lastly, the Office of
Planning and Research (OPR) and SANDAG do not differentiate VMT between multi-family and single-family land
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uses. Therefore, the VMT analysis using this proxy site is a conservative approach. The proxy site is Traffic Analysis
Zone (TAZ) 4728, which is located immediately north of the project site on Olympic Parkway. As shown in Table
5.15-1, the project average VMT per capita for TAZ 4728 is calculated at 14.1 VMT per resident.
Table 5.15-1. Project VMT Analysis
VMT per Resident
Geography Residents Total Trips
Person Miles of
Travel
Vehicle Miles
of Travel
VMT per
Resident
San Diego Region 3,435,715 12,302,411 77,559,665 56,353,219 16.4
Significance threshold (85% of regional average VMT) 13.9
Proxy for Project Site a 2,053 7,173 41,393 28,780 14.1
Exceeds Threshold? Yes
Source: SANDAG 2020.
Note: VMT = vehicle miles traveled.
a Since the project site is currently zoned for industrial use, and is coded as such in the SANDAG model, a proxy site in the vicinity
with similar characteristics was used to determine the expected VMT per resident. The proxy site is Traffic Analysis Zone (TAZ)
4728), and is located immediately north of the project site on Olympic Parkway.
The results of the project VMT comparison indicate that the project (i.e. proxy site) would exceed the significance
threshold by 1.4%. This would require a reduction of 1.4% or more to reduce the VMT to below the significance
threshold. Several quantifiable transportation demand management strategies can be used to reduce a project’s
VMT impacts. Transportation demand management strategies can be quantified using methodologies described in
Quantifying Greenhouse Gas Mitigation Measures published by the California Air Pollution Control Officers’
Association (CAPCOA) (2010). The transportation demand management measures identified in the CAPCOA
document that would potentially lessen residential project impacts are grouped into five categories:
• Land Use and Location
• Neighborhood and Site Enhancement
• Parking Policy and Pricing
• Commute Trip Reduction Programs
• Transit System Improvements
While many of the CAPCOA measures were considered applicable to the project, the following Land Use and
Location series measure, was selected to reduce the project’s VMT impact:
LUT-1: Increase Density. Designing the project with increased densities, where allowed by the General Plan and/or
Zoning Ordinance reduce GHG emissions associated with traffic in several ways. Density is usually measured in
terms of persons, jobs, or dwelling units per unit area. Increased densities affect the distance people travel and
provide greater options for the mode of travel they choose.
This measure is applicable to the project because the project proposes development of 718 multi-family residential
dwelling units with a density of 16.3 units per acre, whereas the calculated VMT per resident of 14.1 as shown in
Table 5.15-1, is based on a proxy site where the residential dwelling units are exclusively single family. Thus, the
project proposes a high-density residential use which in turn provides greater options for mode of travel and could
reduce VMT. Table 5.15-2 summarizes the results of the project’s VMT generation within the incorporation of the
LUT-1: Increase Density measure.
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Table 5.15-2. Project VMT Results with Implementation of Series Measures
Series Measure
Range of
Effectiveness DU/Acre Trip
Resulting VMT
Reduction
Project VMT to
be Reduced
Impact
Avoided?
LUT-1 0.8 – 30.0 % 16.3 8.0% 1.4% Yes
Source: Appendix K
Notes: Results are based on methodology from Quantifying Green House Gas Mitigation Measures (CAPCOA 2010)
PDF = project design feature; DU = dwelling unit; VMT = vehicle miles traveled
As shown in Table 5.15-2, based on the project’s density of 16.3 units per acre, the VMT reduction would be 8%,
when compared to the proxy site. Therefore, implementation of series measure LUT-1, as part of project design,
would avoid the project’s 1.4% VMT impact.
In addition, the following trip strategies identified within the TIA would be implemented as Project Design Features
(PDF) TRA-1 (see Section 4.4.8, Project Design Features, for full text of this PDF) and as conditions of approval, with
implementation required once the project is at 50% occupancy.
These strategies, outlined below, would further reduce the number of automobile trips generated by residents of
the project and the distance that the residents drive.
• Provide ride share coordination services through the project’s homeowner’s association to match residents
interested in carpooling.
• Coordinate with nearby schools and/or the project’s homeowner’s association to match residents
interested in carpooling to/from schools.
• Provide on-site transit opportunities information.
• Encourage bicycling by providing on-site bicycle infrastructure such as bike racks.
Therefore, with implementation of the aforementioned CAPCOA measure and PDF-TRA-1, impacts would be less
than significant.
C. Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm equipment).
As discussed in the TIA (Appendix K), two signalized points of access to the site are planned from Olympic
Parkway , in the locations designated in the SPA Plan . Peak Hour signal warrant analy ses based on the warrants
contained in Chapter 4C, “Traffi c Control Signal Needs Studies,” of the 2014 California Manual on Uniform
Traffic Control Devices, Revision 5 , were conducted for the project’s proposed driveways to ensure
signalization is warranted (Caltrans 2014). The TIA determined that both driveways meet the Peak Hour signal
warrant and are calculated to operate acceptably at LOS C or better . The TIA includes recommended and the
proposed design includes lane configurations that ensure intersections operate efficiently . Additionally, the
project includes a circulation network that would serve the project site and surrounding uses. Direct access to the
project site would be provided by two proposed public streets, Street “A” and Street “B” (Streets A and B).
Street A would extend south from Olympic Parkway, through the project site, and curve to the east to connect
with Street B. Street B would also extend south from the eastern portion of Olympic Parkway, adjacent to the
project site (see Figure 4 -6, Illustrative Concept Plan , and Figure 4-9, Vehicular Circulation Plan). In addition to
the proposed Streets A and B, various private streets and drives are proposed throughout the proposed
development area of the project site. Two types of private streets are proposed throughout the project site and
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would be composed of two 12-foot-wide travel lanes, 5-foot-wide sidewalks, and 5.5-foot-wide landscaped parkways
on both sides. Private residential streets with parking would also be planned throughout the project site and would
be designed to include two 12-foot-wide travel lanes, 8-foot-wide parallel or 18-foot-wide perpendicular parking
lanes, a contiguous sidewalk on one side, and a 5-foot-wide landscaped parkway on the opposite side. The design
of both these street sections, shown on Figure 4-12, Private Residential Street Sections, will be implemented on
the site plan, may be refined during final engineering and shall be subject to City approval.
Therefore, the project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves
or dangerous intersections) or incompatible uses (e.g., farm equipment) and impacts would be less than significant.
D. Result in inadequate emergency access.
The project may result in a temporary increase in traffic on roadways surrounding the project site due to increased
truck loads or the transport of construction equipment to and from the project site during the constru ction period.
All construction activities including staging would occur in accordance with City requirements (such as CVMC
Chapter 12.12, which prohibits street obstructions), which would ensure that adequate emergency access be
provided during construction of the project (CVMC 2020). Additionally, because the project site is included in the
GDP as a planned community, it is incorporated into the City’s existing emergency disaster programs, including all
fire and emergency services and mutual aid agreements. Emergency response to the project site would be serviced
by the City of Chula Vista Fire Department, Police Department, and other responsible agencies. Furthermore, the
City is part of the San Diego County Emergency Operations Plan (SDCEOP; County of San Diego 2018), which
includes a detailed evacuation response plan in the event of an emergency. As stated in the SDCEOP, major ground
transportation corridors shall be used as primary evacuation routes in the event of an emergency. As such, Olympic
Parkway would be the closest evacuation route to the project site. As previously stated, all construction activities
including staging would occur in accordance with City requirements, which would ensure that adequate emergency
access would be provided during construction of the project. Thus, construction of the project is not anticipated to
interfere with an adopted emergency response plan or evacuation plan, nor would it substantially impede public
access or roadway circulation.
Upon completion of construction, direct access to the project site would be provided by two proposed public streets,
Street A and Street B. Street A would extend south from Olympic Parkway, through the project site, and curve to the
east to connect with Street B. Street B would also extend south from the eastern portion of Olympic Parkway,
adjacent to the project site (see Figures 4-6 and 4-9). As previously mentioned, Olympic Parkway, located adjacent
to the project site, would be the closest evacuation route to the project site in the event of an emergency.
Additionally, the proposed driveways and roadways providing access to the project site would comply with the
requirements of the Chula Vista Fire Code (including 2019 Fire Code and 2018 Urban–Wildland Interface Code),
and would be reviewed and approved by the Chula Vista Fire Department. Furthermore, all on-site roads would be
constructed to current Fire Codes and City of Chula Vista or County of San Diego Standards for public and private
roads, including minimum 24-foot-wide, unobstructed road widths.
Therefore, the project would not result in inadequate emergency access; impacts would be less than significant.
5.15.4 Level of Significance Prior to Mitigation
Impacts related to transportation would be less than significant.
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5.15.5 Mitigation Measures
No mitigation measures would be required.
5.15.6 Level of Significance After Mitigation
No mitigation measures would be required. Impacts related to transportation would be less than significant.
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Using Models to Estimate VMT
Travel demand models, sketch models, spreadsheet models, research, and data can all be used to calculate and
estimate VMT. To the extent possible, lead agencies should choose models that have sensitivity to features of the
project that affect VMT. Those tools and resources can also assist in establishing thresholds of significance and
estimating VMT reduction attributable to mitigation measures and project alternatives.
Vehicle Types
Vehicle Miles Traveled refers to on-road passenger vehicles, specifically cars and light trucks. Heavy-duty truck VMT
could be included for modeling convenience and ease of calculation.
Residential Projects
Residential project VMT is evaluated in terms of VMT per capita, with project results compared to established VMT
thresholds to determine significance of project impacts.
Transit Priority Areas
Any project that includes in its geographic bounds a portion of an existing or planned Transit Priority Area (TPA) (i.e.,
the project is within 0.5 miles of an existing or planned major transit stop or an existing stop along a high -quality
transit corridor) may employ VMT as its primary metric of transportation impact for the entire project. A high-quality
transit corridor is defined as a corridor with fixed route bus service with service intervals no longer than 15 minutes
during peak commute hours.
Recommendations Regarding Significance Thresholds
Lead agencies have the discretion to set or apply their own thresholds of significance. However, the cr iteria for
determining the significance of transportation impacts should promote:
• Reduction of GHG emissions
• Development of multimodal transportation networks
• A diversity of land uses
Given that the City had not yet adopted VMT thresholds at the time the project’s VMT analysis was prepared, the
OPR Technical Advisory was used for the project’s VMT analysis:
• Residential Projects: A project exceeding a level of 15% 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% or less of the Regional VMT per capita. Any project whose VMT per capita is 15% or more below the
Regional mean is presumed to be less than significant. This approach is consistent with the approved TSG.
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VMT Analysis
Local Agency Transition to SB743
In June 2020, the City of Chula Vista adopted their TSG to comply with Senate Bill 743, which replaced LOS with
VMT as the metric for determining the significance of a project’s transportation impacts under CEQA.
Since the VMT analysis for the project was prepared prior to formal adoption of the City’s TSG, LLG consulted with
City staff and was instructed to utilize OPR guidance from the Technical Advisory and San Diego ITE Regional
Guidelines to develop significance thresholds and technical methodologies for the project.
Significance Criteria
Guidance from OPR’s Technical Advisory is used to establish a significance threshold of a minimum 15% reduction
or more from the Regional average VMT per capita for this residential evaluation. That means that if the project’s
VMT per capita is more than 15% below the regional average, no significant transportation impact would result.
This approach is consistent with the approved TSG.
Map-Based Screening
Prior to any detailed project-specific VMT analysis, OPR allows for the use of a “map-based screening” (screening
map) to identify if a project would result in a less-than-significant impact. The City’s screening map which has been
developed for their VMT guidelines was utilized for the project. This map provides VMT per capita evaluation for
locations throughout the City, and accounts for surrounding land uses, populat ion density, and transportation
infrastructure in accordance with OPR guidelines. These elements collectively shape mobility behavior and provide
a strong indication of expected project VMT. In general, higher density and mix of land uses with access to mobility
options are expected to generate lower VMT.
Screening Map Results
The City’s VMT Screening Tool allows for a search by address of properties within the City. The data presented in
the screening map include the following:
• Census tract
• VMT per capita
• Percent of regional mean
• Residents
• Description of VMT results
The VMT Screening Tool shows the project location, the City boundaries, and the TPAs and HQTCs identified within
the City. The data represented on the VMT Screening Tool follows the OPR guidance and displays VMT efficient
areas that are 85% or less of the SANDAG regional average. The da ta shown is based on the SANDAG Series 13
Activity Based Model #1 (ABM1) for the base year of the model 2012. As shown in the results of the VMT Screening
Tool provided in the TIA, the project site is not fully located within a HQTC or TPA. A small portion of the project site
is within 0.5 miles of a High-Quality Transit Corridor. The City has determined the project not to be eligible for map-
based screening given that the site is only partially enclosed by a transit buffer.
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5.15.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to transportation is based on the recommendations
provided in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). A significant impact would occur if the
project would:
A. Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit,
roadway, bicycle and pedestrian facilities.
B. 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.
5.15.3 Impacts
A. Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway,
bicycle and pedestrian facilities?
The General Plan Land Use and Transportation Element contains objectives and policies that support transit
(Objective LUT 17), encourage alternative transportation measures (Objectives LUT 18 and LUT 23), encourage
regional transportation coordination (Objective LUT 19), develop transit-friendly roads (Objective LUT 20), support
parking management policies (Objectives LUT 30 through LUT 33), and ensure pedestrian -oriented environments
(Objective LUT 63).
The project would propose a high density residential use located in close proximity to major streets such as Olympic
Parkway, Brandywine Avenue, Heritage Road and the I-805 freeway. Future residents of the project would have
access to a Class 2 bike lane and sidewalks and the Chula Vista Regional Trail adjacent to the project site along
Olympic Parkway. As discussed in Section 5.15.1, Existing Conditions, there are also nearby Class 2 bike lanes
along Brandywine Avenue (beginning at Telegraph Canyon Road and ending at Main Street) and Heritage Road
(beginning at Telegraph Canyon Road and ending at Main Street). Residents would have access to sidewalks/Chula
Vista Regional Trails along Olympic Parkway as well as Heritage Road. Located adjacent to the project site at the
intersection of Olympic Parkway and Brandywine Avenue are four signalized crosswalks with ramps on each corner.
The surrounding area is served by transit provided by the San Diego MTS. While there are no bus routes that travel
directly along Olympic Parkway adjacent to the project site, transit connection for route 704 is provided at the transit
stop on Brandywine Avenue located approximately 250-feet east of the project site. Thus, the future residents of
the project would have access to major roadways, freeways, transit, and bicycle and pedestrian facilities. As such,
the project would be consistent with the City’s Land Use and Transportation Element.
Additionally, the project would be consistent with the GDP, which has a principle objective to create an efficient,
self-contained village. One of the primary objectives of the GDP is to provide a safe, convenient, and efficient local
circulation system which maximizes access between residential areas and community facilities while minimizing
travel distance and reliance on the automobile.
As part of the TIA, a project -specific Local Mobility Analysis (LMA) was prepared that focuses on automobile
delay/LOS. The LOS analysis was conducted to identify roadway deficiencies in the project study area (refer to
Appendix K for further details) and recommend project improvements to address such deficiency. The LMA was
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prepared for existing plus project conditions, near -term without project conditions, near -term with project
conditions, and year 2035 conditions. The City’s goal for acceptable levels of service is generall y LOS D or better
at signalized and unsignalized intersections and LOS C along roadway segments (City of Chula Vista 2005). The
LMA is a City requirement for transportation analysis that is not tied to CEQA; therefore implementation of
measures to address LOS-related effects does not constitute CEQA mitigation.
The TIA determined that the project would result in effects associated with unacceptable LOS under the General Plan
LOS standards. While Olympic Parkway is built-out and the provision of additional lanes is considered physically
infeasible, it is recommended that payment of the City’s Transportation Development Impact Fee (TDIF) should be
applied towards other planned network enhancements included in the Eastern TDIF program that would reduce traffic
on Olympic Parkway and be implemented as a condition of approval for the project outside of this EIR. In addition, it is
recommended that the project provide a fair share contribution toward the provision of Adaptive Traffic Signal Control
(ATSC) modules to each signalized intersection along the Olympic Parkway corridor between the I-805 Ramps and La
Media Road (refer to Appendix K for further details). These TDIF and other requirements associated with LOS deficiencies
would be included as part of the project’s conditions of approval, outside of this EIR.
Therefore, impacts associated with the project conflicting with a program, plan, ordinance, or policy addressing the
circulation system, including transit, roadway, bicycle and pedestrian facilities, would be less than significant.
B. Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b).
As discussed in Section 5.15.1 the City was still in the process of developing their guidelines for VMT evaluation at
the time the project’s VMT analysis was prepared. Therefore, an interim approach and methodology was developed
in coordination with City staff. Thus, for this analysis, the minimum threshold of significance for determination of
the project’s transportation impact is 15% or less of the City VMT per capita. Any project whose VMT per capita is
15% or more below the regional mean is presumed to be less than significant. As shown in Table 5.15-1, the results
of the project VMT comparison indicate that the project would exceed the significance threshold by 1.4%. This would
require a reduction of 1.4% or more to reduce the VMT impact to less than significant. This approach is consistent
with the City’s TSG, which is now approved.
To calculate the VMT per capita for the baseline and the project, the SANDAG Series 13 Year 2020 TDM was used.
The model generates a land use-specific average trip length (residential) as well as an average daily volume, which
ultimately calculates the total residential VMT per capita, region-wide and for the project. The SANDAG Series 13
Year 2020 TDM results are included in Appendix K. Table 5.15-1 summarizes the Regional average baseline VMT
results provided by SANDAG using the Series 13 model. As seen in Table 5.15-1, the Regional average baseline
VMT per capita is 16.4 miles per resident. For the purpose of determining the significance of VMT impacts, the
project VMT per capita would need to be 85% below the Regional average, which equates to 13.9 VMT pe r capita.
Similar to the Regional average baseline calculations, the project VMT per capita was determined. However, since
the project site is currently zoned for industrial use, is coded as such in the SANDAG model, and it is difficult to
accurately override the zoned land uses, a proxy site located just a few hundred feet north of the project site with
similar residential land use characteristics (i.e. single family residential dwelling units) was used to determine the
expected VMT per resident. The proxy site contains single family residential units and does not have direct access
to Olympic Parkway. In addition, per the SANDAG Trip Generation Brief Guide, single-family and multi-family
residential units have the same trip lengths, therefore, the difference in unit type between the proxy site and the
project site is not relevant to the VMT analysis. The proxy site does not have direct access to Olympic Parkway ,
which results in longer trip lengths (and therefore greater VMT) as compared to the project site. Lastly, the Office of
Planning and Research (OPR) and SANDAG do not differentiate VMT between multi-family and single-family land
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uses. Therefore, the VMT analysis using this proxy site is a conservative approach. The proxy site is Traffic Analysis
Zone (TAZ) 4728, which is located immediately north of the project site on Olympic Parkway. As shown in Table
5.15-1, the project average VMT per capita for TAZ 4728 is calculated at 14.1 VMT per resident.
Table 5.15-1. Project VMT Analysis
VMT per Resident
Geography Residents Total Trips
Person Miles of
Travel
Vehicle Miles
of Travel
VMT per
Resident
San Diego Region 3,435,715 12,302,411 77,559,665 56,353,219 16.4
Significance threshold (85% of regional average VMT) 13.9
Proxy for Project Site a 2,053 7,173 41,393 28,780 14.1
Exceeds Threshold? Yes
Source: SANDAG 2020.
Note: VMT = vehicle miles traveled.
a Since the project site is currently zoned for industrial use, and is coded as such in the SANDAG model, a proxy site in the vicinity
with similar characteristics was used to determine the expected VMT per resident. The proxy site is Traffic Analysis Zone (TAZ)
4728), and is located immediately north of the project site on Olympic Parkway.
The results of the project VMT comparison indicate that the project (i.e. proxy site) would exceed the significance
threshold by 1.4%. This would require a reduction of 1.4% or more to reduce the VMT to below the significance
threshold. Several quantifiable transportation demand management strategies can be used to reduce a project’s
VMT impacts. Transportation demand management strategies can be quantified using methodologies described in
Quantifying Greenhouse Gas Mitigation Measures published by the California Air Pollution Control Officers’
Association (CAPCOA) (2010). The transportation demand management measures identified in the CAPCOA
document that would potentially lessen residential project impacts are grouped into five categories:
• Land Use and Location
• Neighborhood and Site Enhancement
• Parking Policy and Pricing
• Commute Trip Reduction Programs
• Transit System Improvements
While many of the CAPCOA measures were considered applicable to the project, the following Land Use and
Location series measure, was selected to reduce the project’s VMT impact:
LUT-1: Increase Density. Designing the project with increased densities, where allowed by the General Plan and/or
Zoning Ordinance reduce GHG emissions associated with traffic in several ways. Density is usually measured in
terms of persons, jobs, or dwelling units per unit area. Increased densities affect the distance people travel and
provide greater options for the mode of travel they choose.
This measure is applicable to the project because the project proposes development of 718 multi-family residential
dwelling units with a density of 16.3 units per acre, whereas the calculated VMT per resident of 14.1 as shown in
Table 5.15-1, is based on a proxy site where the residential dwelling units are exclusively single family. Thus, the
project proposes a high-density residential use which in turn provides greater options for mode of travel and could
reduce VMT. Table 5.15-2 summarizes the results of the project’s VMT generation within the incorporation of the
LUT-1: Increase Density measure.
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Table 5.15-2. Project VMT Results with Implementation of Series Measures
Series Measure
Range of
Effectiveness DU/Acre Trip
Resulting VMT
Reduction
Project VMT to
be Reduced
Impact
Avoided?
LUT-1 0.8 – 30.0 % 16.3 8.0% 1.4% Yes
Source: Appendix K
Notes: Results are based on methodology from Quantifying Green House Gas Mitigation Measures (CAPCOA 2010)
PDF = project design feature; DU = dwelling unit; VMT = vehicle miles traveled
As shown in Table 5.15-2, based on the project’s density of 16.3 units per acre, the VMT reduction would be 8%,
when compared to the proxy site. Therefore, implementation of series measure LUT-1, as part of project design,
would avoid the project’s 1.4% VMT impact.
In addition, the following trip strategies identified within the TIA would be implemented as Project Design Features
(PDF) TRA-1 (see Section 4.4.8, Project Design Features, for full text of this PDF) and as conditions of approval, with
implementation required once the project is at 50% occupancy.
These strategies, outlined below, would further reduce the number of automobile trips generated by residents of
the project and the distance that the residents drive.
• Provide ride share coordination services through the project’s homeowner’s association to match residents
interested in carpooling.
• Coordinate with nearby schools and/or the project’s homeowner’s association to match residents
interested in carpooling to/from schools.
• Provide on-site transit opportunities information.
• Encourage bicycling by providing on-site bicycle infrastructure such as bike racks.
Therefore, with implementation of the aforementioned CAPCOA measure and PDF-TRA-1, impacts would be less
than significant.
C. Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm equipment).
As discussed in the TIA (Appendix K), two signalized points of access to the site are planned from Olympic
Parkway , in the locations designated in the SPA Plan . Peak Hour signal warrant analy ses based on the warrants
contained in Chapter 4C, “Traffi c Control Signal Needs Studies,” of the 2014 California Manual on Uniform
Traffic Control Devices, Revision 5 , were conducted for the project’s proposed driveways to ensure
signalization is warranted (Caltrans 2014). The TIA determined that both driveways meet the Peak Hour signal
warrant and are calculated to operate acceptably at LOS C or better . The TIA includes recommended and the
proposed design includes lane configurations that ensure intersections operate efficiently . Additionally, the
project includes a circulation network that would serve the project site and surrounding uses. Direct access to the
project site would be provided by two proposed public streets, Street “A” and Street “B” (Streets A and B).
Street A would extend south from Olympic Parkway, through the project site, and curve to the east to connect
with Street B. Street B would also extend south from the eastern portion of Olympic Parkway, adjacent to the
project site (see Figure 4 -6, Illustrative Concept Plan , and Figure 4-9, Vehicular Circulation Plan). In addition to
the proposed Streets A and B, various private streets and drives are proposed throughout the proposed
development area of the project site. Two types of private streets are proposed throughout the project site and
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would be composed of two 12-foot-wide travel lanes, 5-foot-wide sidewalks, and 5.5-foot-wide landscaped parkways
on both sides. Private residential streets with parking would also be planned throughout the project site and would
be designed to include two 12-foot-wide travel lanes, 8-foot-wide parallel or 18-foot-wide perpendicular parking
lanes, a contiguous sidewalk on one side, and a 5-foot-wide landscaped parkway on the opposite side. The design
of both these street sections, shown on Figure 4-12, Private Residential Street Sections, will be implemented on
the site plan, may be refined during final engineering and shall be subject to City approval.
Therefore, the project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves
or dangerous intersections) or incompatible uses (e.g., farm equipment) and impacts would be less than significant.
D. Result in inadequate emergency access.
The project may result in a temporary increase in traffic on roadways surrounding the project site due to increased
truck loads or the transport of construction equipment to and from the project site during the constru ction period.
All construction activities including staging would occur in accordance with City requirements (such as CVMC
Chapter 12.12, which prohibits street obstructions), which would ensure that adequate emergency access be
provided during construction of the project (CVMC 2020). Additionally, because the project site is included in the
GDP as a planned community, it is incorporated into the City’s existing emergency disaster programs, including all
fire and emergency services and mutual aid agreements. Emergency response to the project site would be serviced
by the City of Chula Vista Fire Department, Police Department, and other responsible agencies. Furthermore, the
City is part of the San Diego County Emergency Operations Plan (SDCEOP; County of San Diego 2018), which
includes a detailed evacuation response plan in the event of an emergency. As stated in the SDCEOP, major ground
transportation corridors shall be used as primary evacuation routes in the event of an emergency. As such, Olympic
Parkway would be the closest evacuation route to the project site. As previously stated, all construction activities
including staging would occur in accordance with City requirements, which would ensure that adequate emergency
access would be provided during construction of the project. Thus, construction of the project is not anticipated to
interfere with an adopted emergency response plan or evacuation plan, nor would it substantially impede public
access or roadway circulation.
Upon completion of construction, direct access to the project site would be provided by two proposed public streets,
Street A and Street B. Street A would extend south from Olympic Parkway, through the project site, and curve to the
east to connect with Street B. Street B would also extend south from the eastern portion of Olympic Parkway,
adjacent to the project site (see Figures 4-6 and 4-9). As previously mentioned, Olympic Parkway, located adjacent
to the project site, would be the closest evacuation route to the project site in the event of an emergency.
Additionally, the proposed driveways and roadways providing access to the project site would comply with the
requirements of the Chula Vista Fire Code (including 2019 Fire Code and 2018 Urban–Wildland Interface Code),
and would be reviewed and approved by the Chula Vista Fire Department. Furthermore, all on-site roads would be
constructed to current Fire Codes and City of Chula Vista or County of San Diego Standards for public and private
roads, including minimum 24-foot-wide, unobstructed road widths.
Therefore, the project would not result in inadequate emergency access; impacts would be less than significant.
5.15.4 Level of Significance Prior to Mitigation
Impacts related to transportation would be less than significant.
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5.15.5 Mitigation Measures
No mitigation measures would be required.
5.15.6 Level of Significance After Mitigation
No mitigation measures would be required. Impacts related to transportation would be less than significant.
5.16 – Utilities and Service Systems
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5.16 Utilities and Service Systems
This section of the environmental impact report (EIR) describes the existing setting related to utilities and service
systems that would serve the proposed Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow
II, Phase 3 Project (project or proposed project) and evaluates potential impacts to utilities and service systems
due to the implementation of the proposed project.
The discussion is below is based on the following studies:
• Appendix I1 - Priority Development Project (PDP) Storm Water Quality Management Plan (SWQMP),
prepared by Hunsaker & Associates.
• Appendix I2 - Drainage Study for Sunbow II, Phase 3 (TM), prepared by Hunsaker & Associates.
• Appendix L1 - Overview of Water Service for Sunbow II, Phase 3, prepared by Dexter Wilson Engineering.
• Appendix L2 – Water Supply Assessment, prepared by Otay Water District.
• Appendix L3 – Water Conservation Plan, prepared by Dexter Wilson.
• Appendix L4 Sewer System Evaluation for Sunbow II, Phase 3, prepared by Dexter Wilson Engineering.
5.16.1 Existing Conditions
5.16.1.1 Regulatory Framework
Federal
Integrated Waste Management Act of 1989 (AB 341)
The Integrated Waste Management Act of 1989 requires each city, county, and regional agency to develop a source
reduction and recycling element of an integrated waste management plan that includes source reduction, recycling,
and composting components. A minimum of a 50% diversion rate of all s olid waste from landfill disposal or
transformation by January 1, 2000 was required and met. The current policy goal of the state is no less than 75%
of solid waste generated be source reduced, recycled, or composted by the year 2020.
State
Urban Water Management Planning Act
In 1983, the Legislature enacted the Urban Water Management Planning Act (UWMP Act; California Water Code,
Sections 10610–10656), which requires specified urban water suppliers within the state to prepare an Urban Water
Management Plan (UWMP) and update it every 5 years. State and local agencies and the public frequently use UWMPs
to determine if agencies are planning adequately to reliably meet water demands in various service areas. As such,
UWMPs serve as an important element in documenting water supply availability and reliability for purposes of
compliance with state laws, Senate Bills 610 and 221, which link water supply sufficiency to large land-use
development project approvals. Urban water suppliers also must prepare UWMPs, pursuant to the UWMP Act, to be
eligible for state funding and drought assistance.
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The UWMP provides information on water usage, water supply sources, and water reliability planning within a specified
water agency service area. It also may provide implementation schedules to meet projected demands over the planning
horizon; a description of opportunities for new development of desalinated water; groundwater information (where
groundwater is identified as an existing or planned water source); description of water quality over the planning horizon; and
identification of water management tools that maximize local resources and minimize imported water supplies. Additionally,
the UWMP evaluates the reliability of water supplies within the specified service area. This includes a water supply reliability
assessment, water shortage contingency plan, and development of a plan in case of an interruption of water supplies.
The Metropolitan Water District (MWD), San Diego County Water Authority (SDCWA), and the Otay Water District
(OWD) all play a role in supplying water to the proposed project. All of these agencies have prepared and updated
UWMPs in accordance with the UWMP Act.
Senate Bills 610 and 221
On January 1, 2002, Senate Bill 610 took effect. Senate Bill 610, which was codified in the Water Code beginning
with Section 10910, requires the preparation of a water supply assessment for projects within cities and counties
that propose to construct 500 or more residential units or the equivalent. Senate Bill 610 stipulates that when
environmental review of certain development projects is required, the water agency that is to serve the development
must complete the water supply assessment to evaluate water supplies that are or will be available during normal,
single-dry, and multiple-dry years during a 20-year projection to meet existing and planned future demands,
including the demand associated with a proposed project.
Senate Bill 221, enacted in 2001 and codified in the Water Code, requires a city, county, or local agency to include
a condition to any tentative subdivision map that a sufficient water supply shall be available to serve the subdivision.
The term “sufficient water supply” is defined as the total water supplies available during normal, single -dry, and
multiple-dry years within a 20-year projection that would meet the proposed subdivision project’s projected water
demand, in addition to existing and planned future water uses, including agricultural and industrial uses, within the
specified service area. Senate Bill 221 further requires any verification of “projected” water supplies to be based
on entitlement contracts, capital outlay programs and regulatory permits and approvals.
Memorandum of Understanding Regarding Urban Water Conservation in California
The OWD is signatory to the Memorandum of Understanding (MOU) Regarding Urban Water Conservation in
California, which created the California Urban Water Conservation Council in 1991 in an effort to reduce California’s
long-term water demands. Water conservation programs are developed and implemented to reduce the demand
on available supply, which is vital to the optimal utilization of a region’s water supply resources.
As one of the first signatories to the MOU, OWD has made implementation of best management p ractices (BMPs)
for water conservation the cornerstone of its conservation programs and a key element in its water resource
management strategy. As a member of the SDCWA, OWD also benefits from regional programs performed on behalf
of its member agencies. The BMPs implemented by OWD and the regional BMPs implemented by SDCWA are
addressed in the OWD 2015 UWMP (OWD 2016).
As a signatory to the MOU, OWD is required to submit biannual reports that detail the implementation of current
water conservation practices. The OWD voluntarily agreed to implement the fourteen water conservation BMPs
beginning in 1992. The OWD submits its report to the California Urban Water Conservation Council every 2 years,
and the OWD BMP reports are included in the OWD 2015 UWMP (OWD 2016).
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Title 14: Natural Resources – Division 7
Title 14 of the California Code of Regulations regarding Natural Resources sets minimum standards for solid waste
handling and disposal, including specific regulations regarding waste tire storage and disposal, hazardous waste
disposal facilities, construction and demolition and inert debris transfer/processing, construction and demolition
waste and inert debris disposal, transfer/processing operations and facilities, siting and design, operation
standards, record keeping, and additional operating requirements for facilities. Additional guidance and
requirements for compostable materials handling operations and facilities, asbestos handling and disposal,
resource conservation programs, farm and ranch solid waste cleanup and abatement, used oil recycling program,
electronic waste recovery and recycling, solid waste cleanup among others are also addressed in Title 14.
Title 27: Environmental Protection – Division 2, Solid Waste
Title 27 of the California Code of Regulations regarding Environmental Protection and Solid Waste set the criteria
for all waste management units, facilities, and disposal sites including regulations of the California Integrated Waste
Management Board (CIWMB) and State Water Resources Control Board (SWRCB). Waste classification, siting,
construction standards, water quality monitoring and response programs , operating criteria, daily and immediate
cover, handling and equipment, controls, gas monitoring and control, closure and post -closure standards, and
financial assurances are all aspects covered in Title 27.
Assembly Bill 939 and Assembly Bill 341
In 1989, AB 939, known as the Integrated Waste Management Act (California Public Resources Code, Sections
40000 et seq.), was passed because of the increase in waste stream and the decrease in landfill capacity. The
statute established the California Integrated Waste Management Board, which oversees a disposal reporting
system. AB 939 mandated a reduction of waste being disposed where jurisdictions were required to meet diversion
goals of all solid waste through source reduction, recycling, and composting activities of 25% by 1995 and 50% by
the year 2000.
AB 341 (2011) amended the California Integrated Waste Management Act of 1989 to include a provision declaring
that it is the policy goal of the state that not less than 75% of solid waste generated be source-reduced, recycled,
or composted by the year 2020 and annually thereafter. In addition, AB 341 required the California Department of
Resources Recycling and Recovery (CalRecycle) to develop strategies to achieve the state’s policy goal. CalRecycle
has conducted multiple workshops and published documents that identify priority strategies that CalRecycle
believes would assist the state in reaching the 75% goal by 2020.
Executive Order B-29-15
In response to the ongoing drought in California, EO B-29-15 (April 2015) set a goal of achieving a statewide
reduction in potable urban water usage of 25% relative to water use in 2013. The term of the EO extended through
February 28, 2016, although many of the directives have since become permanent water-efficiency standards and
requirements. The EO includes specific directives that set strict limits on water usage in the state. In response to
EO B-29-15, the California Department of Water Resources has modified and adopted a revised version of the
Model Water Efficient Landscape Ordinance that, among other changes, significantly increases the requirements
for landscape water use efficiency and broadens its applicability to include new development projects with smaller
landscape areas.
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Local
Urban Water Management Plans
The UWMP Act requires that each urban water supplier providing water for municipal purposes, either to more than
3,000 customers, or more than 3,000 AF of water annually, must prepare, adopt, and update a UWMP at least once
every 5 years on or before December 31, in years ending in five and zero. This applies to MWD, SDCWA, and its
member agencies, including OWD, that serve unincorporated San Diego County. The intent of an UWMP is to present
information on water supply, water usage/demand, recycled water, and water use efficiency programs in a
respective water district’s service area. The UWMP also serves as a valuable resource for planners and policy
makers over a 25-year time frame.
The UWMP process ensures that water supplies are being planned to meet future growth. UWMPs are developed
to manage the uncertainties and variability of multiple supply sources and demands over the long term. Water
agencies and districts update their demand and supply estimates based on the most recent San Diego Association
of Governments (SANDAG) forecast approximately every 5 years to coincide with preparation of their UWMPs. The
most current supply and demand projections are contained in the 2015 UWMPs of MWD, SDCWA, and OWD (MWD
2016a; OWD 2016; SDCWA 2016). SDCWA member districts rely on the UWMPs and Integrated Resources Plans
(IRPs) of MWD (MWD 2016b) and the Regional Water Facilities Master Plan of SDCWA to document sup plies
available to meet projected demands.
Normal year, single-dry year, and multiple-dry year 2015 UWMP supply and demand assessments for MWD, SDCWA,
and OWD are intended to describe the water supply reliability and vulnerability to seasonal or climatic c onditions.
Normal water years are considered to be years that experience average rainfall for the respective district. Single -
dry water years are considered 1-year drought events. Multiple-dry water years refer to a series of below average
rainfall for particular areas (i.e., multiple drought year conditions). Projections for multiple-dry years are made in 5-
year increments.
In the 2015 UWMPs, MWD, SDCWA, and all SDCWA member agencies, including OWD, that serve unincorporated
San Diego County have determined that adequate water supplies would be available to serve existing service areas
under normal year, single dry year, and multiple dry year conditions through the year 2040.
City of Chula Vista General Plan
The Chula Vista General Plan recognizes that, in order to ensure adequate water service, water supplies and
facilities need to be maintained and expanded in response to the City’s projected population growth. The General
Plan includes objectives and policies in the Public Facilities and Services Elemen t that require development to plan
for careful use of natural and man-made resources and services, and maximize opportunities for conservation while
minimizing waste (Objective LUT 62); and increase efficiencies in water use through use of alternative technologies
(Objective PFS 2). Additionally, the Housing Element includes Objective H 2 to promote efficient use of water through
adopted standards and incentive-based policies to conserve limited resources and reduce long-term operational
costs of housing. Growth Management Objective GM 1 and Policy GM 1.11 provide for withholding discretionary
approvals and subsequent building permits from projects demonstrated to be out of compliance with applicable
threshold standards for water service (City of Chula Vista 2005).
In addition, the City of Chula Vista General Plan recognizes that to ensure adequate and reliable sewer service and
facilities, services need to be maintained and expanded to accommodate growth in the City’s population. The Chula
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Vista General Plan includes objectives and policies in the Public Facilities and Services Element that increase
efficiencies in wastewater generation and its reuse through use of alternative technologies (Objective PFS 2).
Additionally, Growth Management Objective GM 1 and Policy GM 1.11 provide for withholding discretionary
approvals and subsequent building permits from projects that are not in compliance with applicable threshold
standards for wastewater service (City of Chula Vista 2005).
In 2005, the City of Chula Vista updated its General Plan and certified the related EIR for the General Plan Update
(GPU). In 2013, the City certified a Supplemental EIR (City of Chula Vista 2012a), and approved a General Plan
Amendment/General Development Plan Amendment (GPA/GDPA). The GPA/GDPA Supplemental EIR (City of Chula
Vista 2012a) assessed, at the General Plan level, water demands and long-term water supply availability and
reliability. The City concluded that a long-term water supply could not be guaranteed; and, therefore, increases in
water demand projected in the General Plan and later Amendment would result in a significant unavoidable impact.
The result of the City’s findings is that large-scale proposed development projects within the City must conduct a
project-level water supply/demand analysis, accompanied by the required SB 610/SB 221 water supply
assessment/verification. Based on this project-level water supply/demand analysis and associated project EIR, the
City will then reassess its General Plan-level water supply findings and determinations based on the record before it.
The 2005 Chula Vista General Plan recognizes that the Otay Landfill is anticipated to reach capacity within the next
15 years (2020), requiring closure of the facility (refer to the analysis below regarding specific landfill capacity
information). The General Plan forecasts that the future solid waste disposal needs of the City may require the
creation of a regional transfer station, where solid waste from individual collection routes would be transferred into
large trucks for disposal (City of Chula Vista 2005). As such, the policies are regional in nature and do not specifically
address individual developments.
Chula Vista Landscape Water Conservation Ordinance
In response to the new State Water Conservation in Landscaping Act (Assembly Bill 1881), which required cities and
counties to adopt landscape water conservation ordinances by January 1, 2010, the City of Chula adopted the Landscape
Water Conservation Ordinance (CVMC, Section 20.12) in 2009 and was updated in 2015. This ordinance requires that
the majority of new or rehabilitated landscapes be designed using a water budget, to help encourage outdoor water
conservation. As a part of the City’s permitting process, some projects will be required to complete either a Landscape
Documentation Package or a WaterSmart Checklist. In general, the Landscape Documentation Package will be prepared
for larger projects that involve installing or changing an existing landscape, while the WaterSmart Checklist is designed
for smaller projects. The size of the “landscape area” will determine which of these documents will be required. The
landscape area is measured in square feet, and it is an area with outdoor plants, turf and other vegetation that uses
water, including any water features either in an area with vegetation or that stand alone (CVMC, Section 20.12).
Otay Water District Growth Management Oversight Commission
Both the Otay Water District and Sweetwater Authority reported that, despite the State of California’s water conservation
mandates between June 1, 2015 and February 13, 2016, Chula Vista’s water supply is in good shape because
customers have been exceeding water conservation goals for several years, in preparation for the drought. (Note: Water
Conservation Plans required by Chula Vista’s “Growth Management” ordinance for all SPA Plans, Tentative Maps, and
major development projects have also had a positive effect on water conservation in the City.)
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The OWD’s supply and storage capacity for both potable water and non-potable water exceeds current demands and the
demand projected by December 2020 and June 2024 (City of Chula Vista 2020). Similarly, the Sweetwater Authority
supply and storage capacity for potable water would exceed the current demand and the demand projected by December
2020 and June 2024 (City of Chula Vista 2020).
City of Chula Vista Growth Management Program
The Chula Vista Growth Management Program goal for water supply is to ensure that adequate supplies of quality
water (appropriate for intended uses) are available to Chula Vista. The Growth Management Program has two
objectives regarding water supply and distribution (City of Chula Vista 2020).
1. Adequate water supply must be available to serve new development. Therefore, developers shall provide
the City with a service availability letter form the appropriate water district for each project.
2. The City shall annually provide the San Diego County Water Authority, the Sweetwater Authority and the Otay
Municipal Water District with the City’s annual 5-year residential growth forecast and request that they provide
an evaluation of their ability to accommodate forecasted growth. Replies should address the following:
a. Water availability to the City, considering both short- and long-term perspectives.
b. Identify current and projected demand, and the amount of current capacity, including storage capacity,
now used or committed.
c. Ability of current and projected facilities to absorb forecasted growth.
d. Evaluation of funding and site availability for projected new facilities.
City of Chula Vista Wastewater Master Plan
The City of Chula Vista Wastewater Collection System Master Plan (City of Chula Vista 2014) provides a
comprehensive review and evaluation of the City of Chula Vista’s wastewater collection, conveyance, and treatment
capacity requirements under the existing (2012) and ultimate (2050) conditions. Based on findings of the
evaluation, the City’s Wastewater Collection System Master Plan recommends facility improvements and financing
alternatives to ensure that aging infrastructure remains serviceable and to allow for the continued build out of the
General Plan. Currently, wastewater generation within the City of Chula Vista is collected by City -owned facilities
and conveyed to connections to the City of San Diego’s Metropolitan Wastewater Department (METRO) conveyance
and treatment facilities for treatment and disposal. As of 2014, the City’s capacity at METRO is 20.864 mgd. Future
City flow projections based on current growth projections indicate that this capacity may be exceeded within the
next 10-15 years. As such, the wastewater generation analysis presented in the Wastewater Master Plan is intended
to be used by the City to establish a basis for acquiring future METRO treatment capacity to allow for implementation
of the Chula Vista General Plan, as adopted in 2005 and amended in 2012. The City’s sewage capacity was not
exceeded in 2015 and the 2019 GMOC Annual Report concluded the City would not exceed its sewage capacity
until 2027 (City of Chula Vista 2020).
Chula Vista Municipal Code
Chula Vista Municipal Code, Section 19.09.040G, requires “that sewage flows and volumes shall not exceed City
engineering standards as set forth in the subdivision manual.” In addition, the City must annually provide Metro
with a 12- to 18-month development forecast and request confirmation that the projection is within the City’s
purchased capacity rights and an evaluation of Metro’s ability to accommodate the forecast and continuing growth.
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Construction and Demolition Debris Recycling Ordinance
Effective July 1, 2008, construction and demolition projects are required to divert their debris from landfill disposal in the
City of Chula Vista; 100% of inert materials (i.e., concrete, rock, landscape debris) and a minimum of 50% of all other
materials (i.e., Cabinets, carpet, drywall, etc.) shall be recycled and or reused from certain ‘covered’ projects. Covered
projects are those with an approved Waste Management Report and submitted performance deposit. The Construction
and Demolition Debris (C&DD) Recycling Ordinance (CVMC Section 8.25.095) is designed as a means of achieving
compliance with California Green Building Standards Code (Title 24, Part II, Sections 4.408 and 5.408).
5.16.1.2 Existing Conditions
Water
Water service to the proposed project would be provided by Otay Water District (OWD) (City of Chula Vista 2005). OWD
purchases water from San Diego County Water Authority (SDCWA), which in turn imports water from the Metropolitan
Water District (MWD). According to Appendix L1, the OWD has existing and planned facilities in the vicinity of the project
site and water service can be provided by expanding the existing system. The proposed project water service would be
provided by the 624 Pressure Zone (624 Zone) within the Central Area System of the OWD. The 624 Zone is fed from
the SDCWA aqueduct connections that supply 624 Zone Reservoirs. The existing and projected water supply and demand
for each agency are described below and are based on approved planning documents.
Regional and Local Water Supply
Metropolitan Water District (MWD)
The MWD supplies water to approximately 18.7 million people to a 5,200 square mil eservice area that includes
portions of Ventura, Los Angeles, Orange, San Bernardino, Riverside, and San Diego countries. SDCWA is one of the
MWD’s 26 member agencies.
To supply the more than 300 cities and unincorporated areas in Southern California with reliable and safe water,
Metropolitan owns and operates an extensive water system, including the Colorado River Aqueduct, 16
hydroelectric facilities, nine reservoirs, 819 miles of large-scale pipes and five water treatment plants. It also helps
its member agencies develop water recycling, storage and other local resource programs to provide additio nal
supplies and conservation programs to reduce regional demands. Metropolitan currently delivers an average of 1.5
billion gallons of water per day to a 5,200-square-mile service area (MWD 2016a).
MWD gets its water from two sources. The first source is the Colorado River, which is connected to MWD’s six-
county service area through a 242 -mile aqueduct. The aqueduct system is known as the Central Valley Project
(CVP). The CVP is operated by the U.S. Bureau of Reclamation. The second source is water from northern California,
which supplies water through a series of dams, aqueducts, pipelines, and other facilities known as the State Water
Project (SWP). The SWP is operated by the California Department of Water Resources (DWR). From the Colorado
River Agreement (CRA), MWD is apportioned 550,000 acre-feet of water per year (AFY) from the Colorado River.
Despite this low apportionment, MWD was able to transport up to 1.2 million acre-feet (MAF) through the CRA in
past years by relying on unused apportionments from Arizona, Nevada, and California agricultural agencies.
However, because MWD’s firm water supply from CRA is only 550,00 AF that is the number planning agencies must
rely on for development. To supplement this supply, MWD also has several existing programs and additional
programs are being developed in cooperation with other agencies.
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From SWP, MWD is contractually entitled to receive 1,911,000 AF of water; however, the level of SWP supply
development, state and federal environmental regulations, and other factors have restricted and, in some cases, reduced
the actual amount of available SWP water. As a result of these and other limitations, MWD estimated that actual SWP
supplies will be 701,000 AF in a dry year and 566,000 AF during multiple dry years, with Delta improvements.
In May 2016, the MWD adopted its 2015 Regional UWMP, which is an update to its prior 2010 Regional UWMP. In
its 2015 UWMP, MWD evaluated water supply reliability, over a 20-year period, for average, single-dry, and multiple-
dry years. To complete its most recent water supply reliability assessment, MWD developed estimates of total retail
demands for the region factoring in the impacts of conservation. After estimating demands, the water reliability
analysis identified current supplies and supplies under development to meet projected demands. MWD’s reliability
assessment showed that MWD can maintain reliable water supplies to meet projected demands through the year
2040. MWD also identified buffer supplies, including other SWP groundwater storage and transfers, which could
serve to supply additional water needs.
Imported Supplies
Colorado River: The Colorado River was MWD’s original source of water after MWD’s establishment in 1928. MWD
has a legal entitlement to receive water from the Colorado River under a permanent service contract with the
Secretary of the Interior. The CRA, which has a capacity of 1.2 MAF a year, is owned and operated by MWD. It
transports water from Lake Havasu, at the border of the state of California and Arizona, approximately 242 miles
to its terminus at Lake Mathews in Riverside County. Over the years, Metropolitan increased reliable supply from
the CRA through programs that it helped fund and implement including: farm and irrigation district c onservation
programs, improved reservoir system operations, land management programs, and water transfers and exchanges
through arrangements with agricultural water districts in southern California, San Diego County Water Authority,
and entities in Arizona and Nevada that use Colorado River water, and the U.S. Department of the Interior, Bureau
of Reclamation (USBR) (MWD 2016a).
State Water Project (SWP): MWD imports water from the SWP, owned by the state of California and operated by the
California DWR. The SWP transports Feather River water stored in and released from Oroville Dam and conveyed
through the Bay-Delta, as well as unregulated flows diverted directly from the Bay-Delta south via the California
Aqueduct to four delivery points near the northern and eastern boundaries of MWD’s service area (MWD 2016a).
In 1960, MWD signed a contract with the California DWR for SWP water supplies. MWD is one of 29 agencies that
have long-term contracts for water service from the California DWR, and is the largest agency in terms of the number
of people it serves (nearly 19 million), the share of SWP water that it has contracted to receive (approximately 46%),
and the percentage of total annual payments made to DWR by agencies with State water contracts (approximately
53% in 2015) (MWD 2016a).
Local Supplies
Approximately 50% of the region’s water supplies come from resources controlled or operated by local water
agencies. These resources include water extracted from local groundwater basins, catchment of local surface water,
non-MWD imported water supplied through the Los Angeles Aqueduct, and Colorado River water exchanged for
MWD supplies (MWD 2016a).
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Groundwater
The groundwater basins that underlie the region provide nearly 35% of the water supply in Southern California. The
major groundwater basins provide an annual average supply of approximately 1.35 MAF. Natural recharge of the
groundwater basins is supplemented by active recharge of captured stormwater, recycled water, and imported
water to support this level of annual production (MWD 2016a).
Estimates indicate that available storage space in the region’s groundwater basins in mid-2015 is approximately 4.8
MAF. Successive dry years have resulted in groundwater depletions that will need to be replaced with natural recharge
during wet years and active spreading of captured stormwater, recycled water, and imported water. Groundwater basin
managers and water suppliers have taken steps to store water in advance of dry years to soften the potential impact
on groundwater aquifers and to maintain reliable local water supplies during dry years (MWD 2016a).
Recycling, Groundwater Recovery, and Seawater Desalination
Recycling and groundwater recovery are local resources that add balance to Southern California’s diverse water
portfolio. In addition to replenishing groundwater basins described above, water recycling provides extensive
treated wastewater for applicable municipal and industrial uses. Common uses of recycled water include landscape
irrigation, agricultural irrigation, and commercial and industrial applications. Groundwater recovery employs
additional treatment techniques to effectively use degraded groundwater supplies that were previously not
considered viable due to high salinity or other contamination (MWD 2016a).
While water recycling and groundwater recovery projects in the Southern California region are primarily developed
by local water agencies, many newer projects have been developed with financial incentives provided through
Metropolitan’s Local Resources Program (LRP). The LRP is a performance-based program that provides incentives
to expand water recycling and support recovery of degraded groundwater. In 2015, the regional water production
from water recycling and groundwater recovery totaled approximately 530 trillion acre feet (TAF), of which 244 TAF
was developed with MWD funding assistance (MWD 2016a).
Seawater desalination represents a significant opportunity to diversify the region’s water resource mix with a new, locally
controlled, reliable potable supply. MWD supports seawater desalination to its member agencies by providing technical
assistance, regional facilitation of research and information exchanges, and financial incentives through the LRP.
San Diego County Water Authority (SDCWA)
The SDCWA service area covers approximately 951,000 acres and encompasses the western third of San Diego
County. SDCWA has 24 member agencies, 15 of which provide water to unincorporated areas of San Diego County.
SDCWA is responsible for ensuring a safe and reliable water supply to support the region’s economy and quality of
life for over 3 million residents. SDCWA’s 24 member agencies purchase water from the SDCWA for retail
distribution within their service territories. A 36-member Board of Directors consisting of member agency
representatives governs the Water Authority. The member agencies’ 6 cities, 5 water districts, 8 municipal water
districts, 3 irrigation districts, a public utility district, and a federal military reservation have diverse and varying
water needs. In terms of land area, the City of San Diego is the largest member agency with 210,726 acres. The
smallest is the City of Del Mar, with 1,159 acres. Some member agencies, such as the cities of National City and
Del Mar, use water almost entirely for municipal and industrial purposes. Others, including Valley Center, Rainbow,
and Yuima Municipal Water Districts, deliver water that is used mostly for agricultural production (SDCWA 2016).
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The SDCWA is one of 26 member agencies of Metropolitan. The SDCWA is MWD’s largest member agency in terms
of purchases. Because of the County’s semi-arid climate and limited local water supplies, SDCWA has historically
imported between 70 and 95 % of the water used in the San Diego region from MWD. In 2008, MWD provided 71
% of the San Diego region’s water supply. Most of this water is obtained from the Colorado River and the SWP
through a system of pipes, aqueducts, and associated facilities. Through development of new local water supply
sources such as the Carlsbad Desalination Plant, SDCWA has become increasingly less reliant on MWD water
supplies in recent years. To reduce its dependency on MWD and diversify its supplies, the SDCWA in recent years
has undertaken several initiatives, including the following (SDCWA 2016):
• Carlsbad Seawater Desalination Water Purchase Agreement: To further help diversify regional supplies, the
SDCWA has entered into a Water Purchase Agreement under which it agrees to purchase up to 56,000
acre-feet/year (AFY) of desalinated water from the plant in the City of Carlsbad, operated by an affiliate of
Poseidon Resources Inc. The plant began operation in December 2015.
• Imperial Irrigation District Transfer: The SDCWA signed a Water Conservation and Transfer Agreement with the
Imperial Irrigation District in 1998. Through the transfer agreement, the SDCWA is purchasing water from the
Imperial Irrigation District at volumes that will gradually increase year to year, reaching 200,000 acre-feet/year
in 2021. The water is physically delivered to San Diego via Metropolitan’s Colorado River Aqueduct.
• All-American and Coachella Canal Lining Conserved Water: In 2003, as part of the execution of the
Quantification Settlement Agreement on the Colorado River, the SDCWA was assigned rights to 77,700 acre-
feet/year of conserved water from the All-American and Coachella Canals. As with the Imperial Irrigation
District transfer water, the water is physically delivered to San Diego via MWD’s Colorado River Aqueduct.
• Water Transfer and Banking Programs: The SDCWA has entered into water transfer and water banking
arrangements with Central Valley area agricultural agencies and groundwater storage interests. These projects
are designed to make additional water available to the SDCWA during dry-year supply shortages from MWD.
In June 2016, the SDCWA adopted its 2015 UWMP, updating the previously adopted 2010 UWMP. Sections 4, 5,
and 6 of SDCWA’s 2015 UMWP contain documentation of SDCWA’s existing and planned water supplies, including
MWD supplies (imported Colorado River water and SWP water), SDCWA supplies, and local member agency supplies
(surface water reservoirs, water recycling, groundwater, and groundwater recovery). SDCWA supplies include (1) IID
water transfer supplies, (2) Supplies from conservation projects to line the All-American Canal and the Coachella
Canal, located in Imperial and Coachella Valleys, and (3) development of a seawater desalination facility at Encina
Power Plant in Carlsbad, which is anticipated to produce 56,000 AFY of additional water supplies (see Table 5.16-1).
Table 5.16-1. Projected Normal Year Water Supplies (AFY)
Water Source 2020 2025 2030 2035 2040
Water Authority Supplies
IID Water Transfer 190,000 200,000 200,000 200,000 200,000
Supply from MWD 136,002 181,840 207,413 224,863 248,565
Coachella Canal and All American Canal Lining
Projects
80,200 80,200 80,200 80,200 80,200
Regional Seawater Desalination 50,000 50,000 50,000 50,000 50,000
Member Agency Supplies
Surface Water 51,580 51,480 51,380 51,280 51,180
Water Recycling 40,459 43,674 45,758 46,118 46,858
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Table 5.16-1. Projected Normal Year Water Supplies (AFY)
Water Source 2020 2025 2030 2035 2040
Groundwater 17,940 19,130 20,170 20,170 20,170
Seawater Desalination 6,000 6,000 6,000 6,000 6,000
Brackish Groundwater Recovery 12,100 12,500 12,500 12,500 12,500
Total Projected Supplies 587,581 648,124 676,721 676,721 718,778
Source: Appendix L1.
Section 9 of the SDCWA’s 2015 UMWP evaluates water supply reliability in average, single-dry and multiple-dry
years. Based on SDCWA’s water supply reliability assessment, SDCWA concluded that water supplies would be
sufficient through 2040 (see Table 5.16-2 and Table 5.16-3).
Based on the imported and member agency local water sources discussed above, SDCWA estimated that it, along
with member agency local sources will be able to supply 587,581 AF of water in 2020, as demonstrated in Table
5.16-2, Table 5.16-3, and Table 5.16-4. The reason that supplies exactly met demands in Table 5.16-2 is that
SDCWA only imports that amount of water necessary to meet demand. In Tables 5.16 -3 and Table 5.16-4, years
that show a deficit would require the use of water storage offsets and management actions to balance demand and
supplies. These tables indicate that SDCWA has adequate supply to meet projected demands.
Table 5.16-2. Average/Normal Water Year Supply and Demand Assessment (AFY)
Water Source 2020 2025 2030 2035 2040
Member Agency Supplies
Surface Water 51,580 51,480 51,380 51,280 51,180
Water Recycling 40,459 43,674 45,758 46,188 46,858
Groundwater 17,940 19,130 20,170 20,170 20,170
Brackish Groundwater Recovery 12,100 12,500 12,500 12,500 12,500
Seawater Desalination 6,000 6,000 6,000 6,000 6,000
Potable Reuse 3,300 3,300 3,300 3,300 3,300
Water Authority Supplies
IID Water Transfer 190,000 200,000 200,000 200,000 200,000
Supply from MWD 136,002 181,840 207,413 224,863 248,565
Coachella Canal and All American Canal Lining
Projects
80,200 80,200 80,200 80,200 80,200
Carlsbad Desalination Plant 50,000 50,000 50,000 50,000 50,000
Total Projected Supplies 587,581 648,124 676,721 694,431 718,773
Total Estimated Demands 587,581 648,124 676,721 694,431 718,773
Difference 0 0 0 0 0
Source: Appendix L4.
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Table 5.16-3. Single Dry Water Year Supply and Demand Assessment (AFY)
Water Source 2020 2025 2030 2035 2040
Member Agency Supplies
Surface Water 6,004 6,004 6,004 6,004 6,004
Water Recycling 40,459 43,674 45,758 46,188 46,858
Groundwater 15,281 15,281 15,281 15,281 15,281
Brackish Groundwater Recovery 12,100 12,500 12,500 12,500 12,500
Seawater Desalination 6,000 6,000 6,000 6,000 6,000
Potable Reuse 3,300 3,300 3,300 3,300 3,300
Water Authority Supplies
IID Water Transfer 190,000 200,000 200,000 200,000 200,000
Supply from MWD 263,340 264,740 263,340 260,680 258,720
Coachella Canal and All American Canal Lining Projects 80,200 80,200 80,200 80,200 80,200
Carlsbad Desalination Plant 50,000 50,000 50,000 50,000 50,000
Total Projected Supplies 666,684 681,699 682,383 680,083 678,863
Total Estimated Demands 629,198 694,147 725,006 743,990 770,765
Difference 37,486 (12,448) (42,623) (63,907) (91,902)
Source: Appendix L1.
Table 5.16-4. Multiple Dry Water Year Supply and Demand Assessment (AFY)
Scenario
Near Term Long Term
2017 2018 2019 2036 2037 2038
Multiple Dry Years
Demands 491,000 495,910 500,869 749,030 756,521 764,086
Supply 525,710 558,634 586,587 720,579 678,564 642,327
Potential Surplus or
(Shortage)1
34,710 62,724 85,718 (28,454) (77,957) (121,759)
Source: Appendix L1.
1 Potential shortages would be offset through carryover storage and management actions.
Otay Water District (OWD)
Otay Water District is located in the southern half of San Diego County and was created in 1956. The OWD joined
the SDCWA as a member agency in the same year. The SDCWA is the agency responsible for the supply of imported
water into the San Diego County through its membership in MWD (OWD 2016).
The OWD is a California special district authorized under the provisions of the Municipal Water District Law of 1911 and
is revenue neutral, i.e., each end user pays their fair share of costs for capital improvements, water acquisition, and the
operation and maintenance of facilities. Its elected Board of Directors sets the OWD ordinances, policies, taxes, and rates
for providing wastewater, potable water, and recycled water services. The OWD’s water service area is generally located
within the south central portion of San Diego County and includes approximately 126 square miles. The topography of
the service area is diverse, consisting of a variety of valleys, hills, mountains, mesas, lakes and rivers. The service area
includes both urban and rural development. The major transportation arteries serving the area include State Highway 94
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in the north, Interstate 805 in the southwest and the newly constructed State Route 125 to the east. Interstate 905 and
State Highway 11 are in the process of being constructed in the Otay Mesa area (OWD 2016).
Once water is made available by SDCWA, it is transferred across San Diego County in two aqueducts containing five
large-diameter pipelines. The first Aqueduct includes Pipelines 1 and 2, and the second Aqueduct includes Pipelines
3, 4 and 5. The OWD maintains several connections to Pipeline 4, which delivers filtered water from the MWD
filtration plant at Lake Skinner in Riverside County.
In San Diego County, OWD provides water services to southern El Cajon, La Mesa, Rancho San Diego, Jamul, Spring
Valley, Bonita, eastern Chula Vista, and Otay Mesa along the international border with Mexico. OWD covers approximately
80,000 acres and has approximately 47,000 connections. OWD has approximately 709 miles of pipelines, 24 pump
stations, and 40 reservoirs with a total storage capacity of 226 million gallons (MG). OWD provides approximately 90 %
of its water service to residential land uses, and 10 % to commercial and industrial land uses. Average annual
consumption for OWD is approximately 30,000 AF. OWD maintains five major systems to supply and deliver water, which
include Hillsdale, Regulatory, La Presa, Central, and Otay Mesa.
In addition, OWD’s Flow Control Facility No. 14 and the Jamacha Road Pipeline delivers filtered water from the R.M. Levy
Water Treatment Plant which is owned and operated by the Helix Water District. However, this connection currently
supplies water to the north portion of OWD only. Furthermore, OWD maintains a connection to the City of San Diego’s
water system in Telegraph Canyon Road and has an agreement which allows the District to receive water from the Lower
Otay Filtration Plant.
In June 2016, OWD’s Board of Directors adopted the updated OWD 2015 UWMP. Sections 2, 3 and 4 of the 2015 UWMP
provides an overview of OWD’s service area, its current water supply sources, supply reliability, water demands,
measures to reduce water demand, and planned water supply projects and programs. Section 5 of the 2015 UWMP
contains OWD’s water service reliability assessment. This section states that the level of reliability is based on the
documentation in the UWMP’s prepared by MWD and SDCWA and that these agencies have determined they will be able
to meet potable water demands through 2040, during normal and dry year conditions. According to the 2015 UMWP,
OWD currently relies on MWD and SDCWA for its potable supply, and OWD has worked with these agencies to prepare
consistent demand projections for OWD’s service area.
The OWD’s service area has experienced growth in the past five years, and the service area population is expected
to be approximately 285,340 people by 2040. The OWD serves a wide spectrum of communities including southern
El Cajon, La Mesa, Rancho San Diego, Jamul, Spring Valley, Bonita, eastern City of Chula Vista, East Lake, Otay
Ranch and Otay Mesa areas. The water purveyors that border the District include Padre Dam Municipal Water
District (Padre Dam MWD) on the north, Helix WD on the northwest, and the Sweetwater Authority, and the City of
San Diego on the west. The southern boundary of the OWD is the international border with Mexico (OWD 2016).
The projected supply and demand comparison for normal year, single dry year, and multiple dry year scenarios are
summarized in Table 5.16-5. OWD’s potable water supply is expected to be adequately supplied by SDCWA during
normal year scenarios and single dry year scenarios. Water demand is anticipated to increase in dry years. In the
multiple dry year scenario where shortages may take place, the SDCWA would utilize its carryover storage supply
capacity during dry years. In years where shortages may still occur, after utilization of the carryover storage,
additional regional shortage management measures, consistent with the SDCWA’s Water Storage and Drought
Response Plan, would be taken to fill the supply shortfall (OWD 2016). Additionally, implementation of conservation
measures, anticipated increase in potable water supplies, and anticipated increased recycled water supply would
help to alleviate potential shortages.
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Table 5.16-5. Otay Water District Projected Water Supply and Demand
Year-Type 2020 2025 2030 2035 2040
Water Supply1
Normal Year 45,748 51,883 54,540 55,455 62,792
Single Dry Year 45,748 56,213 61,125 63,932 75,087
Multiple Dry Year: 1st Year 46,346 52,239 54,832 56,138 n/a
Multiple Dry Year: 2nd Year 48,769 54,469 57,290 58,714 n/a
Multiple Dry Year
3rd Year
51,823 57,467 58,024 57,153 n/a
Water Demand3
Normal Year 45,748 51,883 54,540 55,455 62,792
Single Dry Year 45,748 56,213 61,125 63,932 75,087
Multiple Dry Year: 1st Year 46,346 52,239 54,832 56,138 n/a
Multiple Dry Year: 2nd Year 48,769 54,469 57,290 58,714 n/a
Multiple Dry Year
3rd Year
51,823 57,467 60,142 62,086 n/a
Difference
Normal Year 0 0 0 0 0
Single Dry Year 0 0 0 0 0
Multiple Dry Year: 1st Year 0 0 0 0 0
Multiple Dry Year: 2nd Year 0 0 0 0 0
Multiple Dry Year
3rd Year
0 0 (2,118) (4,933) n/a
Source: OWD 2016.
Notes: Units in acre-feet per year (AFY).
1 SDCWA UWMP analysis shows 100% supply reliability for these conditions so total supplies are set equal to OWD projected demands.
2 OWD demand totals with additional conservation and proportional adjustment for dry year per SDCWA CWA-MAIN model during
period of record.
3 Third dry year supply shortages will be addressed through drought management actions.
Additionally, 20 maintenance, replacement, and/or upgrade projects needed to serve the City of Chula Vista are included
in the Fiscal Year 2020 through 2015 OWD Capital Improvement Program document (City of Chula Vista 2020). The
OWD maintains a per capita demand of 118 gallons per capita per day (gpcd), or approximately 0.13 AFY (OWD 2016).
The OWD would supply water to Sunbow II, Phase 3 project from the 624 Zone of the District’s Central Area System.
The 624 Zone accesses water from the SDCWA aqueduct by Otay Flow Control Facilities Number 10 and 12, which
fill 624 Pressure Zone reservoirs. Water is then distributed within the 624 Zone and pumped to the 711 and 980
Zone storage and distribution systems.
To receive potable water service, the Sunbow II, Phase 3 project will need to expand the existing 624 Zone to include
the project’s water facilities, as discussed in Section 5.16.3 below. The following details the existing potable water
facilities located in the vicinity of the project.
There are three existing reservoirs in the 624 Zone, located along the SDCWA aqueduct east of the project. The
624-1 Zone reservoir is located near the SDCWA Otay No. 12 aqueduct connection and has capacity of 12.4 million
gallons (MG). The 624-2 Zone reservoir is located north of Otay Lakes Road near the SDCWA Otay No. 10 connection
and has a capacity of 8.1 MG. The 624-3 Zone reservoir is located just south of the 624-1 Zone reservoir and has
a capacity of 30 MG.
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There are major transmission lines from these reservoirs to convey water to the various 624 Zone use areas and
to supply 711 Zone and 980 Zone pump stations. In the vicinity of the Sunbow II, Phase 3 project, there are 16 -
inch transmission lines in Medical Center Drive, Paseo Ladera, and Olympic Parkway.
Recycled Water
The OWD operates and maintains over 93 miles of recycled water transmission and distribution pipelines, pump
stations and reservoirs, making it one of the largest recycled water systems in San Diego County. The District’s
mandatory reuse ordinance, land development conditions, and public outreach has resulted in a OWD’s acceptance
of recycled water as a viable local water supply for irrigation, especially during recent drought conditions. The OWD
continues to successfully serve recycled water to customers within its central service area, south of the Sweetwater
Reservoir and west of the Otay Lakes Reservoirs. The majority of the area represents the Otay Ranch GPD area
within the City of Chula Vista (OWD 2016).
In order to serve the OWD’s existing demand for recycled water, the OWD entered into an agreement to purchase
recycled water from the City of San Diego’s South Bay Water Reclamation Plant (SBWRP). The SBWRP has a rated
capacity of 15 mgd and is located at Monument and Dairy Mart Roads near the international border, adjacent to
the Tijuana River. The SBWRP receives wastewater flow from the Grove Avenue Pump Station that scalps flow from
the existing interceptor system that conveys flow northward to the Point Loma Treatment Plant for treatment and
ocean outfall disposal. The existing interceptor system flows are thereby reduced, freeing up additional capacity for
future growth in the South Bay region. The SBWRP in essence is a scalping plant and is designed for a relatively
constant flow rate depending upon recycled water demands and interceptor capacity limitations.
The OWD has two sources of recycled water supply: Recycled water produced locally at the OWD’s Ralph W. Chapman
Water Recycling Facility (RWCWRF) and a recycled water supply produced at the City of San Diego’s SBWRP. The
RWCWRF is located near the intersection of Campo Road/Highway 94 and Singer Lane within the Middle Sweetwater
River basin. The agencies that participate in recycled water planning for the OWD’s service area are as follows:
• Otay Water District (OWD) – Owns and operates RWCWRF and the recycled water distribution network.
• City of San Diego Metropolitan Wastewater Department (MWWD) – Owns and operates regional
interceptors, SBWRP, and Point Loma Wastewater Treatment Plant (WWTP).
The RWCWRF has the ability to produce approximately 1.3 mgd of recycled water meeting Title 22 requirements.
The RWCWRF is a scalping treatment facility: wastewater that is not treated by the facility for beneficial reuse
continues to flow in the Rancho San Diego Outfall Facilities to the City of San Diego Metropolitan Wastewater
System. Some of this wastewater is treated by MWWD at its SBWRP at the secondary level, and the remainder is
sent to the Point Loma WWTP for treatment at the advanced primary level and disposed through an ocean outfall.
At RWCWRF, tertiary treatment of the 1.3 mgd has the ability to reliably produce approximately 1,100 AFY of
recycled water. The RWCWRF provides tertiary treatment that meets the State of California’s Title 22 requirements
for reuse. Effluent from the plant is pumped to lined and covered reservoirs in the District’s property located north
of Proctor Valley Road adjacent to the Rolling Hills Ranch Development project.
Table 5.16-6 shows the projected recycled water demand up to 2040.
Table 5.16-6. Projected Recycled Water Demand
2020 2025 2030 2035 2040
Total (Acre-Feet) 5,670 5,900 6,000 6,200 6,500
Source: OWD 2016.
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Sewer/Wastewater
The City maintains and operates sewer facilities that feed into a larger regional system for treatment and disposal.
Chula Vista relies on the City of San Diego Metropolitan (Metro) Sewage System for treatment and disposal of the
wastewater generated within the project site (City of Chula Vista 2005). The Metro sewer system treats wastewater
from the City of San Diego and 15 other cities and districts, including Chula Vista. Flows are conveyed to the Point Loma
Wastewater Treatment plant, which has a maximum daily treatment capacity of 240 mgd and currently treats
approximately 175 mgd (Metro Wastewater n.d.a.).
The project proposes the development of 718 multi-family residential units and 0.9 acres of Community Purpose
Facility (Appendix L4). The sewer generation factor, based on analysis done within the Sewer System Evaluation for
Sunbow II, Phase (Appendix L4), was estimated to be 182 gpd/unit for multi-family residential units and 1,313
gpd/ac for Community Purpose Facilities (summarized in Table 5.16-7).
Table 5.16-7. Sewer Generation Factor
Land Use Generation Factor
Multi-Family Residential Units 182 gpd/unit
Community Purpose Facility 1,313 gpd/ac
Source: Appendix L4.
The City of Chula Vista operates and maintains its own sanitary collection system that connects to the Metro
sewerage system for treatment and disposal. The Metro sewerage system treats wastewater from the City of San
Diego and 15 other cities and districts, including Chula Vista. The San Diego Metropolitan Sewer Authority regulates
the three wastewater treatment plants: (1) Point Loma Wastewater Treatment Plan; (2) Southbay Water
Reclamation Plant; and (3) North City Water Reclamation Plant. Currently, the three combined treatment plants
have a maximum permitted treatment capacity of 285 mgd of wastewater for the City of San Diego and 15 other
participating agencies. All sewer flows from the project will be conveyed to the Poggi Canyon Interceptor Sewer
located in Olympic Parkway adjacent to the project site (Appendix L4).
The available capacity in the Poggi Canyon Interceptor was evaluated in the April 2009 Poggi Canyon Basin Gravity
Sewer Development Impact Fee (DIF) Update prepared by PMC (Appendix L4). Available capacity in the interceptor
has been updated several times in recent years by proposed developments within the Poggi Canyon Basin. All
previous studies have been based on industrial land use for the project site.
Since there are planned improvements to the proposed Poggi Canyon Interceptor prior to the full buildout of
development, it is necessary to establish the development thresholds at which these improvements will be required.
The improvements to critical sections of the Poggi Canyon Interceptor will be funded from the DIF that has been
collected from all units that convey flow to the Poggi Canyon Interceptor. The City shall perform flow metering of
critical reaches of the Poggi Canyon Interceptor to assist in determining the timing of the work to upsize these
critical pipe segments.
Solid Waste
The City of Chula Vista’s Public Works Department and Environmental Services Division oversees waste
management in the City for residences and businesses in accordance with the goals and polici es of the adopted
General Plan and State Statues (AB 341). Republic Services (formerly known as Allied Waste Management)
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currently serves the City of Chula Vista as the sole solid waste and recycling service provider for residential,
commercial and industrial customers. The City disposes of solid waste, yard waste, and C&DD at the Otay Landfill,
which is anticipated to close in 2028. The City is currently working on further waste diversion plans, in addition to
the C&DD Ordinance to help extend the lifespan of the Otay Landfill; the Sycamore Canyon Landfill will be utilized
as the City’s primary landfill once the Otay Landfill closes. The mixed debris that are required to be recycled per the
C&DD Ordinance are processed at one of two C&D facilities in San Diego: the Otay Landfill run by Republic Services
and EDCO’s C&D facility in Lemon Grove. Both of these C&D facilities are open to the public, as neighboring cities
have similar ordinances and solid waste requirements (City of Chula Vista 2014). In September 12, 2019, the
County of San Diego issued a Major Use Permit Minor Deviation, MUP 76 -046WM ("2019 MUP") that allowed for
the construction and operation of a composting operation, however, restricted such composting activities from
being located within 1,000 feet from residential development. The Otay Landfill has requested a CMHF Permit for
the composting operation within the active Otay landfill disposal area (230 acres) for processing up to 200 TPD of
green waste, food waste, and organic/agriculture waste using a mobile covered aerated composting system
(GORE® Covers technology).
In addition, the Environmental Services Division offers bulky item collection, composting, construction and
demolition debris, electronic waste, hazardous waste, reuse, sharps waste disposal, special services, universal
waste and yard waste programs and services. The City of Chula Vista runs its own household hazardous waste
(HHW) program and collection facility to help manage the hazardous waste disposal throughout the City. The
hazardous waste disposal facility is part of the City’s effort to divert household toxics and hazardous waste from
their landfill facilities. Residential composting is encouraged by the City through the availability of composting
education and subsidized compost bins. The City is currently working on a food waste pilot program, in efforts to
divert up to approximately 25% of the solid waste stream (organics) from their landfills (City of Chula Vista 2014).
Chula Vista’s CLEAN business program promotes businesses which implement solid waste reduction measures and
practices, as well as energy conservation, water conservation and pollution prevention measures. The City of Chula
Vista’s Environmental Services Division also manages special events solid waste disposal with the implementation
of the Special Events Recycling and Solid Waste Management Plan (City of Chula Vista 2014).
Stormwater Drainage
Existing site drainage patterns includes a 117.3-acre hydrologic catchment primarily consisting of natural grades
and hills all covered by native vegetations and shrubs. The site is accessible from Olympic Parkway through two
separate bridges crossing Poggi Canyon creek on the north side. The Poggi Canyon creek flows from northeast to
southwest and accepts a large amount of storm runoff from surrounding area. It is also downstream of the on-site
runoff from both the project site existing and proposed conditions. The local high points are in the southern
boundary of the site adjacent to the Otay landfill and make the overall on-site surface flow pattern south to north
(Appendix I1).
A small portion of the site in the southwest corner was occupied by a water tank that is serving the nearby residential areas.
Based on the site topography, the existing condition catchment was divided into seven sub catchments. All on-site
runoff from the project sub-catchment under design event will flow from south via natural valley to north into Poggi
Canyon creek and eventually confluence at the northwest corner of the projects catchment.
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Electric Power, Natural Gas. and Telecommunication Facilities
As discussed in Section 4.4.3.4, telephone, cable television, and internet service would be provided by companies
such as Cox Communications, Time Warner, and AT&T. Gas and electric services would be provided by San Diego
Gas & Electric Company.
5.16.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to utilities and service systems is based on the
recommendations provided in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). A significant impact
would occur if the project would:
A. Require or result in the relocation or construction of new or expanded water, wastewater treatment, or
storm water drainage, electric power, natural gas, or telecommunications facilities or expansion of existing
facilities, the construction or relocation of which could cause significant environmental effects.
B. Have insufficient 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. Not comply with federal, state, and local management and reduction statutes and regulations related to
solid waste.
5.16.3 Impacts
A. Require or result in the relocation or construction of new or expanded water, wastewater treatment, or storm
water drainage, electric power, natural gas, or telecommunications facilities or expansion of existing facilities,
the construction or relocation of which could cause significant environmental effects.
Proposed utility improvements are described in Section 4.4.3, Public Service and Utilities, of this EIR. These utility
improvements are included as a part of the project, and the associated impacts are addressed in this EIR.
Water
Water service will be provided by the Otay Water District (OWD). Water supply requirements specified in the
California Fire Code (Section 404 of the Wildland-Urban Interface Code and Appendix B – Fire Flow Requirements
for Buildings, Appendix C – Fire Hydrant Locations and Distribution {Chula Vista revisions – Sections 15.36.050
and 15.36.055}) including for hydrants and interior sprinklers will be provided for the proposed project. A water
system would be installed in accordance with the standards of the OWD and would be maintained and operated by
OWD. One existing OWD waterline and one existing OWD recycled water line are present along Olympic Parkway.
The proposed project would receive water by expanding the existing 624 Pressure Zone, located within the Central
Area System of OWD, through creating two domestic service connections and two fire service connections
transmission lines within Olympic Parkway, directly to the north of Streets A and Bpublic streets. In addition, an on-
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site loop would be constructed for domestic and fire protection systems and would include a proposed public 12-
inch OWD waterline , an 8-inch-diameter private domestic waterline, an 8-inch-diameter private fire protection
waterline, and an 68-inch-diameter public OWD recycled water line, to be constructed within Streets A and B, and
an 8-inch-diameter private domestic waterline and an 8-inch-diameter private fire protection waterline, to be
constructed outside of the public streets. The proposed water and recycled water systems are shown on Figure 4-
13. Details regarding the overview of the water service and supply are provided in Appendix L. The final fire flow
and duration will be determined during a future review of the water service overview would occur before final
approval by the Chula Vista Fire Department.
The development pads on the project will range in elevation from approximately 370 feet to 420 feet. With service
provided from the 624 Zone, this will result in maximum static pressure ranging from 88 to 110 psi. The proposed
water and recycled water systems are shown on Figure 4-13.
Table 5.16-8 provides the duty factors used in projecting the total average demand for the proposed project.
Table 5.16-8. Water Duty Factors
Land Use Designation Unit Domestic Demand Required Fire Flow (gpm)
Required Fire Flow
Duration (hours)
Multi-Family (>10 DU/AC) 170 gpd/unit 2,500 2
Park/CPF 1,900 gpd/ac --- ---
Source: Appendix L1.
Table 5.16-9 provides the projected potable water demand for Sunbow II, Phase 3 project. The total estimated
average potable water use is 0.12 mgd, or approximately 136.72 AFY. This demand would be supplied from the
OWD’s 624 Zone. As discussed above, there are three existing reservoirs in the 624 Zone, located along the SDCWA
aqueduct east of the project. The 624-1 Zone reservoir is located near the SDCWA Otay No. 12 aqueduct connection
and has capacity of 12.4 million gallons (MG). The 624-2 Zone reservoir is located north of Otay Lakes Road near
the SDCWA Otay No. 10 connection and has a capacity of 8.1 MG. The 624-3 Zone reservoir is located just south
of the 624-1 Zone reservoir and has a capacity of 30 MG. There are major transmission lines from these reservoirs
to convey water to the various 624 Zone use areas and to supply 711 Zone and 980 Zone pump stations. In the
vicinity of the project, there are 16-inch transmission lines in Medical Center Drive, Paseo Ladera, and Olympic
Parkway. This existing OWD water infrastructure has capacity to serve the project.
Table 5.16-9. Sunbow II, Phase 3 Projected Potable Water Demands
Neighborhood
Land Use
Designation Gross Acres Quantity, Units
Water Duty
Factor
Total Average
Water Demand,
GPD
R-1 MF Residential 8.5 131 170 gpd/unit 22,270
R-2 MF Residential 4.6 73 170 gpd/unit 12,410
R-3 MF Residential 8.1 108 170 gpd/unit 18,360
R-4 MF Residential 8.2 118 170 gpd/unit 20,060
R-5 MF Residential 7.1 104 170 gpd/unit 17,680
R-6 MF Residential 7.6 184 170 gpd/unit 31,280
Total 718 N/A 122,060
Source: Appendix L1.
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The proposed water infrastructure improvements shown on Figure 4-13 and existing OWD infrastructure would
serve the project needs and no additional water improvements that would result in environmental impacts would
be necessary to serve the project. OWD has a potable water storage capacity of 218.9 million gallons (OWD 2020).
As shown in Table 5.16-9, the project would have a potable water demand of 122,060 GPD. Additionally, while the
project would provide potable water to residents, recycled water is proposed to be used at all common landscaped
areas within the project as well as the irrigated areas of the private open space/CPF. Therefore, impacts would be
less than significant.
Recycled Water
Recycled water would be used for irrigation of manufactured slopes and common areas. Table 5.16-10 provides
the projected recycled water demands for the project. The project’s total average demand is 0.024 mgd, or
approximately 27.45 AFY. In Table 5.16-6, the City’s project recycled water demand increases by 230 AFY from
2020 to 2025, 100 AFY from 2025 to 2030, 200 AFY from 2030 to 2040. The 27.45 AFY projected recycled water
demand from the project would be adequately considered within the OWD’s projected recycled water demands.
Table 5.16-10. Sunbow II, Phase 3 Projected Recycled Water Demands
Land Use Designation Quantity Irrigation Factor Total Average Demand, GPD
Irrigated Slopes 12 ac 1,900 gpd/ac 22,800
Private Open Space/CPF 0.9 ac 1,900 gpd/ac 1,710
Total 24,510
Source: Appendix L1.
Recycled water is proposed to be used at all common landscaped areas within the project as well as the irrigated
areas of the private open space/CPF. There is a 680 Zone recycled water line in Olympic Parkway adjacent to the
project site. The project would connect to this line and set a meter(s) such that all on-site irrigation piping will be
private outside of public streets. Service from the 680 Zone will result in static pressures of 113 psi and 134 psi in
the development areas. Pressures at irrigated slopes will vary from this and the landscape architect will verify the
ability to serve all irrigated areas of the project from the 680 Zone.
These improvements would serve the project needs and no additional water improvements that would result in
environmental impacts would be necessary to serve the project. Therefore, impacts would be less than significant.
Sewer/Wastewater
The proposed on-site sewer system for the project consists of gravity sewer lines that will convey flow to the Poggi
Canyon Interceptor in Olympic Parkway. Based on the average flow presented in Table 5.16 -11 and a peak factor
of 2.33 from the City Subdivision Manual, the projected peak flow for the project is 0.31 mgd. An 8-inch gravity
sewer line with a minimum slope of 1.0 % is adequate to convey this total project flow. It is anticipated that an 8-
inch public sewer line will be constructed on site to convey flows to the point of connection with the Poggi Canyon
Interceptor. Private sewer lines will be connected to this 8-inch public sewer line and extended to the proposed
building sewer laterals. The proposed sewer plan is shown on Figure 4-14.
The proposed project would receive sewer service by construction of on-site 8-inch gravity sewer line(s) connecting
to the Poggi Canyon Interceptor in Olympic Parkway. The projected flows from the proposed project are slightly lower
than were projected in previous Poggi Canyon Basin Studies and, therefore, the proposed project does not require
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any new improvements to the Poggi Canyon Interceptor or accelerate any previously identified improvements.
Based on flow monitoring by the City, the timing for replacement of the critical reaches would be determined and
implemented by the City. The project would fund their fair share of Poggi Canyon Interceptor improvements through
the payment of the Poggi DIF (Appendix L4).
Table 5.16-11 provides a comparison between projected sewer flower from the Poggi Development Impact Fee
(DIF) study based on the current land use plan with updated sewer generation factors, as analyzed in Appendix L4.
The increased sewer flows would be 4,642 gpd, or approximately 5.2 AFY.
Table 5.16-11. Sunbow II, Phase 3 Sewer Flow Summary
Land Use Acres Building Units Generation Factor Average Flow (gpd)
2009 Poggi Canyon Basin DIF Sewer Flow
Industrial 54.61 --- 2,500 gpd/ac 136,500
Current Proposed Sewer Flow
Multi-family
Residential Units
--- 718 182 gpd/unit 130,676
Community Purpose 0.9 --- 1,313 gpd/ac 1,182
Subtotal 131,858
Increased Sewer Flow (4,642)
Increased Sewer EDUs2 (20)
Source: Appendix L4.
Notes:
1 From 2009 Poggi Basin DIF Study.
2 Based on 230 gpd/Equivalent Dwelling Units (EDUs).
As discussed earlier, wastewater flows are conveyed to the Point Loma Wastewater Treatment plant, which has a
maximum daily treatment capacity of 240 mgd and currently treats approximately 175 mgd (Metro Wastewater
n.d.a). The proposed project would result in an increased sewer flow of 4,642 gpd, or 0.0046 mgd, which can be
adequately accommodated by the Point Loma Wastewater Treatment plant.
These improvements would serve the project needs and no additional water improvements that would result in
environmental impacts would be necessary to serve the project. Therefore, impacts would be less than significant.
Stormwater Drainage
Hydrology is also discussed in detail in Section 5.9, Hydrology and Water Quality, of this EIR. The storm drain and
storm water quality control facilities are proposed to meet the city requirements. According to Appendix I1, the
proposed project would create 10,000 square feet or more of impervious surfaces. Specifically, the total impervious
area would be 1,599,328.2 square feet (Appendix I1).
The development of the site will include adding the storm drains, curb inlets, cleanouts along the proposed on -site
private roads and parking spaces to collect and convey the storm runoff to the two proposed detention and water
quality control basins located at the northeast and northwest part of the development area.
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The on-site runoff from the site will be collected by proposed curb inlets and storm drain systems which will convey
the stormwater through the on-site Biofiltration and Modular Wetland BMPs for water quality control. The outflow
of these BMPs discharges into Poggi Canyon Creek whose ultimate downstream destination is San Diego Bay.
Since the proposed development will increase runoff generated by the project site, the project will use on-site
detention facilities to mitigate for the increase in peak flow. As a result, the mitigated Q100 of proposed condition
demonstrates 25.07 cfs flow rate reduction compare to that of the existing condition (Appendix I2). Runoff
generated by the project will not exceed pre-project peak flow rates, and runoff velocities will be dissipated by rock
riprap at storm drain outfalls. Riprap design (per SDRSD D-40) will be provided with hydraulics during the final
engineering stage.
Due to the grading of the site, drainage pathways would be altered slightly such that some of the independent small
sub-catchments in the center portion of the project site were combined into bigger sub-catchments. However, the
designated flow would still be within the capacity of water quality facilities (Appendix I1). Therefore, impacts would
be less than significant.
Electric Power, Natural Gas and Telecommunication Facilities
Proposed power, natural gas, and telecommunications facilities improvements would include connections to
existing service lines located in the adjacent roadways. The project would connect to existing dry utilities. Refer also
to Section 5.5, Energy, for a discussion of energy consumption. Therefore, impacts would be less than significant.
B. Have insufficient water supplies available to serve the project and reasonably foreseeable future development
during normal, dry and multiple dry years.
A Water Supply Assessment (WSA) was prepared for the project by OWD at the request of the City and was approved
by the OWD Board of Directors on January 6, 2021. The WSA is included with this EIR as Appendix L2. The following
analysis is based on the WSA as well as the Otay Water District’s (OWD) Urban Water Management Plan (UWMP)
(OWD 2016).
The project would construct 718 dwelling units and have an anticipated water usage of 122,060 gallons per day, or
approximately 136.72 AFY (Table 5.16-9). This is 84.7 AFY higher than the projected demands in the OWD’s 2015
Facilities Master Plan which estimated 52 AFY for 54.7 acres of industrial use. However, the projected 84.7 AFY
increase in demand is accounted for through the Accelerated Forecasted Growth demand increment of the SDCWA’s
2015 UWMP. Additionally, the project would use recycled water for irrigation of manufactured slopes and common
areas. The projected recycled water demand for the project is 24,510 gpd, or about 27.5 AFY (Appendix L2).
As documented in the SDCWA’s 2015 UWMP, the SDCWA is planning to meet future and existing water demands
which include the demand increment associated with the accelerated forecasted growth. The SDCWA will assist its
member agencies in tracking the environmental documents provided by the agencies that include water supply
assessments and verifications reports that utilize the accelerated forecasted growth demand increment to
demonstrate supplies for the development. In addition, the next update of the demand forecast for the SDCWA’s 2020
UWMP will be based on SANDAG’s most recently updated forecast, which will include the project. Therefore, based on
the findings presented in the WSA, the project would result in no unanticipated water demands (Appendix L2).
As discussed in the WSA, the SDCWA and MWD have an established process that ensures water supplies are planned to
meet future growth. The SDCWA and MWD update their demand forecasts and supply needs based on the most recent
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SANDAG forecast approximately every five years to coincide with preparation of their urban water management plans. Prior
to the next forecast update, local jurisdictions may require water supply assessment for proposed land developments that
are not within the OWD, SDCWA, or MWD jurisdictions or that have revised land use plans with lower or higher land use
intensities than reflected in the existing growth forecasts. The OWD, SDCWA, and MWD next demand forecast and supply
requirements and associated planning documents would then capture any increase or decrease in demands and required
supplies as a result of annexations or revised land use planning decisions. This process would be utilized by the SDCWA
and MWD to document the water supplies necessary to serve the demands of the project, along with existing and other
projected future users, as well as the actions necessary to develop any required water supplies (Appendix L2).
Additionally, the OWD 2015 UWMP includes a water conservation component to comply with Senate Bill 7 of the
Seventh Extraordinary Session (SBX 7-7), which became effective February 3, 2010. This new law was the water
conservation component to the Delta legislation package and seeks to achieve a 20 percent statewide reduction
in urban per capita water use in California by December 31, 2020. Specifically, SBX 7-7 requires each urban retail
water supplier to develop urban water use targets to help meet the 20 percent reduction goal by 2020 (20x2020),
and an interim water reduction target by 2015. OWD adopted Method 1 to set its 2015 interim and 2020 water
use targets. Method 1 requires setting the 2020 water use target to 80 percent of baseline per capita water use
target as provided in the State’s 20x2020 Water Conservation Plan. The OWD 2015 target was 172 gallons per
capita per day (gpcd) which it met (2015 actual was 124 gpcd) and the 2020 gpcd target (80 percent of baseline)
is 153 gpcd. The OWD recent per capita water use has been declining and current water use meets the 2020 target
as calculated using Method 1. The decline in per capita water use was due to drought water use restrictions,
increased water costs, and economic conditions. OWD’s effective water use awareness campaign and enhanced
conservation mentality of its customers has resulted in long-term carryover of these reduced rates (Appendix L2).
The WSA findings show that based on a normal water supply year, the projected potable and recycled water supply
is being planned for and is intended to be acquired to meet the estimated water demand targets of the OWD per
the OWD 2015 UWMP. Table 5.16-12 presents the forecast balance of water demands and required supplies for
the OWD service area under average or normal year conditions.
Table 5.16-12. Projected Balance of Water Demands and Supplies Normal Year Conditions
(Acre Feet)
Description FY 2025 FY 2030 FY 2035 FY 2040
Demands
OWD Demands 54,771 57,965 59,279 65,913
Active Conservation Savings (1,844) (1,585) (1,538) (1,587)
Accelerated Forecast Growth (AFG) –
Planning Area 12
46 46 46 46
AFG – Otay Sunroad EOM SPA 836 836 836 836
AFG – University Innovation District 11.7 11.7 11.7 11.7
AFG – Sunbow II, Phase 3 84.7 84.7 84.7 84.7
Passive Conservation Savings (4,497) (5,489) (6,040) (6,744)
Total Demand 49,408.4 51,869.4 52,679.4 58,560.4
Supplies
Water Authority Supply 43,508.4 45,869.4 46,479.4 52,060.4
Recycled Water Supply 5,900 6,000 6,200 6,500
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Table 5.16-12. Projected Balance of Water Demands and Supplies Normal Year Conditions
(Acre Feet)
Description FY 2025 FY 2030 FY 2035 FY 2040
Total Supply 49,408.4 51,869.4 52,679.4 58,560.4
Supply Surplus 0 0 0 0
Source: Appendix L2
Further, based on dry year forecasts, the estimated water supply is also being planned for and is intended to be
acquired to meet the projected water demand, during single dry and multiple dry year scenarios. On average, the
dry-year demands are about 6.64 percent higher than the normal year demands. However, as shown in Table 5.16-
13, the OWD recycled water supply is assumed to be drought-proof and not subject to reduction during dry periods.
These findings from the WSA assess, demonstrate, and document that sufficient water supplies are planned for
and are intended to be acquired for the project’s proposed water demands. In addition, the actions necessary to
develop these supplies are and will be further documented, to serve the project and the existing and other
reasonably foreseeable planned development projects within the OWD in both normal and single and multiple dry
year forecasts for a 20-year horizon. Refer to Appendix L2 for further details.
Table 5.16-13. Projected Balance of Water Demands and Supplies Single Dry and Multiple Dry
Year Conditions (Acre Feet)
Normal Year Single Dry Year Multiple Dry Years
FY 2011 First Dry Year
First Dry
Year
Second
Dry Year
Third Dry
Year
Demands
OWD Demands 37,176 38,749 38,844 40,378 42,430
Total Demand 37,176 38,749 38,844 40,378 42,430
Supplies
Water Authority Supply 33,268 33,877 33,972 35,240 37,026
Recycled Water Supply 3,908 4,872 4,872 5,138 5,404
Total Supply 37,176 34,639 38,844 40,378 42,430
Supply Surplus 0 0 0 0 0
Source: Appendix L2
The findings above show that sufficient water supplies are planned for and are intended to be acquired for the
project. Additionally, the actions necessary to develop these supplies are and will be further documented, to serve
the project and the existing and other reasonably foreseeable planned development projects within the OWD in
both normal and single and multiple dry year forecasts for a 20-year planning horizon. Furthermore, in evaluating
the availability of sufficient water supplies, the project development proponents would be required to participate in
the development of alternative water supply project(s). This can be achieved through payment of the New Water
Supply Fee adopted by the OWD Board in May 2010. These water supply projects are in addition to those identified
as sustainable supplies in the current SDCWA and MWD UWMP, Integrated Resource Plans, Master Plans, and
other planning documents. Refer to Appendix L2 for further details. Thus, regional water suppliers along with OWD
fully intend to maintain sufficient reliable supplies through the 20-year planning horizon under normal, single, and
multiple dry year conditions to meet projected demand of the project, along with existing and other planned
development projects within the OWD service area. Therefore, impacts would be less than significant.
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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.
See discussion of Sewer/Wastewater under Threshold A. Impacts would be less than significant.
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.
Solid waste management services for the City of Chula Vista are provided by Republic Services. Solid waste is
collected curbside once a week and transported to the Otay Landfill in the City of Chula Vista. The Otay Landfill
currently has a projected life span of 15-years, and a maximum permitted throughput of 5,830 tons per day
(CalRecycle 2016a). However, the Otay Landfill is projected to close in 2030. Construction of the proposed project
would result in a temporary increase in solid waste generation, while operation would result in a long term,
permanent, incremental increase in solid waste generation.
Additionally, under the current franchise agreement between the City of Chula Vista and Republic Services, solid
waste would be disposed of at the Sycamore Landfill once the Otay Landfill meets its permitted capacity and
terminates solid waste services (City of Chula Vista 2012a). The Sycamore Landfill has a remaining capacity of
47,388,428 cubic yards and projected cease operation date of December 2031 (CalRecycle 2016b). As such, solid
waste service would continue following closure of the Otay Landfill and permitted capacity would be available to
accommodate the proposed project. Impacts would be less than significant.
E. Not comply with federal, state, and local management and reduction statutes and regulations related to solid waste.
The State of California has mandated the at least 50% of the solid waste generated by a City or County be diverted
from landfills. Additionally, the State has set per capita disposal rates of 5.3-pounds per person per day for the City
of Chula Vista (Atlantis Group 2017). To maintain these targets, the following programs must be implemented per
Chula Vista Municipal Code Sections 8.23, Solid Waste and Recycling Contract or Franchise; 8.24, Solid Waste and
Litter; 8.25, Recycling; and 19.58.340, Trash Enclosures:
1. All new construction and demolition projects in the City are required to divert from landfill disposal 100 -
percent of inert waste, to include asphalt, concrete, bricks, tile, trees, stumps, rocks, and associated
vegetation and soils resulting from land clearing, and not less than 50 -percent of the remaining waste
generated, via reuse or recycling, unless a partial or full diversion exemption has been granted pursuant to
CVMC 8.25.095, in which case the diversion requirement shall be the maximum feasible diversion rate
established by the Waste Management Report Compliance Official for the project (CVMC 8.25.020(O6)).
Contractors will be required to put up a performance deposit and prepare a Waste Management Report
Form to ensure that all materials are responsibly handled. Upon verification that the diversion goals have
been met the performance deposit will be refunded (CVMC 8.25.095).
2. The City of Chula Vista’s Recycling and Solid Waste Planning Manual, adopted by City Council, provides
information for adequate space allocated to recycling and solid waste within individual projects, based
upon the type of project and collection service needed. Republic Services is the City of Chula Vista
contracted service provider for all commercial, industrial, and residential services within the city limits.
3. Plans are subject to approval by the City Manager or designee, who is the Environmental Services Program
Manager in the Public Works Department.
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4. Additionally, the City of Chula Vista encourages the use of compost materials to be incorporated into the
soil of all new construction projects to improve soil health, water retention, less water run-off, and filtration
of water run-off prior to entering storm drains and creeks on the way to San Diego Bay. The yard trimmings
collected in Chula Vista are composted at the Otay Landfill and may be available for purchase.
The proposed project would be constructed and operated in compliance with all applicable federal, state, and local
statues and regulations relating to solid waste. Thus, impacts would be less than significant.
5.16.4 Level of Significance Prior to Mitigation
No significant impacts would occur as a result of the proposed project related to public utilities. Impacts would be
less than significant.
5.16.5 Mitigation Measures
Impacts were found to be less than significant.
5.16.6 Level of Significance After Mitigation
No significant impacts would occur as a result of the proposed project related to public utilities. Impacts would be
less than significant.
Existing Water Facilities
Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II, Phase 3 Project EIR
FIGURE 5.16-1SOURCE: Dexter Wilson Engineering 2020Path: Z:\Projects\j1261201\MAPDOC\DOCUMENT\EIR
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5.17 – Wildfire
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5.17 Wildfire
This section of the environmental impact report (EIR) describes the existing wildfire conditions within the vicinity of
the project site, identifies associated regulatory requirements, evaluates potential impacts associated with wildfire
and contribution to regional wildfire conditions, and identifies mitigation measures related to implementation of the
proposed Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II, Phase 3 Project (project or
proposed project). Potential wildfire impacts resulting from construction and operation of the proposed project
were evaluated based on a review of existing resources and applicable laws, regulations, guidelines, and standards.
This section focuses on the effect of the proposed project on wildfire risk. Fire protection services for the proposed
project are addressed in Section 5.13, Public Services, of this EIR. A Fire Protection Plan (FPP), which evaluated
and identified potential fire risks associated with the project, was prepared for the project by Dudek and has been
included as Appendix H3 of this EIR.
5.17.1 Existing Conditions
5.17.1.1 Regulatory Framework
Federal
National Fire Protection Association Codes, Standards, Practices, and Guides
National Fire Protection Association codes, standards, recommended practices, and guides are developed through
a consensus standards development process approved by the American National Standards Institute. This process
brings together professionals representing varied viewpoints and interests to achieve consensus on fire and other
safety issues. National Fire Protection Association standards are recommended guidelines and nationally accepted
good practices in fire protection, but are not laws or codes unless adopted as such or referenced as such by the
California Fire Code (CFC) or the local fire agency.
Federal Wildland Fire Management Policy
The Federal Wildland Fire Management Policy was developed in 1995, updated in 2001, and again in 2009, by the
National Wildfire Coordinating Group, a federal multiagency group that establishes consistent and coordinated fire
management policy across multiple federal jurisdictions. An important component of the Federal Wildland Fire
Management Policy is the acknowledgement of the essential role of fire in maintaining natural ecosystems. The
Federal Wildland Fire Management Policy and its implementation are founded on the foll owing guiding principles,
found in the Guidance for Implementation of Federal Wildland Fire Management Policy (National Wildfire
Coordinating Group 2009):
• Firefighter and public safety is the first priority in every fire management activity.
• The role of wildland fire as an essential ecological process and natural change agent will be incorporated
into the planning process.
• Fire management plans, programs, and activities support land and resource management plans and
their implementation.
• Sound risk management is a foundation for all fire management activities.
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• Fire management programs and activities are economically viable, based upon values to be protected,
costs, and land and resource management objectives.
• Fire management plans and activities are based upon the best available science.
• Fire management plans and activities incorporate public health and environmental quality considerations.
• Federal, state, tribal, local, interagency, and international coordination and cooperation are essential.
• Standardization of policies and procedures among federal agencies is an ongoing objective.
National Fire Plan
The National Fire Plan, officially titled Managing the Impacts of Wildfire on Communities and the Environment: A
Report to the President In Response to the Wildfires of 2000, was a presidential directive in 2000 as a response
to severe wildland fires that had burned throughout the United States. The National Fire Plan focuses on reducing
fire impacts on rural communities and providing assurance for sufficient firefighting capacity in the future. The plan
addresses the following five key points: firefighting, rehabilitation, hazardous fuels reduction, community
assistance, and accountability. The plan provides technical, financial, and resource guidance an d support for
wildland fire management across the United States. The U.S. Forest Service and the Department of the Interior are
working to successfully implement the key points outlined in the plan (DOI and USDA 2000).
International Fire Code
Created by the International Code Council, the International Fire Code addresses a wide array of conditions
hazardous to life and property, including fire, explosions, and hazardous materials handling or usage (although not
a federal regulation, but rather the product of the International Code Council). The International Fire Code places
an emphasis on prescriptive and performance-based approaches to fire prevention and fire protection systems.
Updated every 3 years, the International Fire Code uses a hazards classific ation system to determine the
appropriate measures to be incorporated to protect life and property (often times these measures include
construction standards and specialized equipment). The International Fire Code uses a permit system (based on
hazard classification) to ensure that required measures are instituted (ICC 2017).
International Wildland–Urban Interface Code
The International Wildland–Urban Interface Code is published by the International Code Council and is a model
code addressing wildfire issues (ICC 2014).
State
California Government Code
Sections 51175–51189 of the California Government Code provide guidance for classifying lands in California as
fire hazard areas and requirements for management of property within those lands. The California Department of
Forestry and Fire Protection (CAL FIRE) is responsible for classifying Fire Hazard Severity Zones (FHSZs) based on
statewide criteria, and makes the information available for public review. Further, local agencies must designate,
by ordinance, Very High FHSZs within their jurisdiction based on the recommendations of CAL FIRE.
Section 51182 of the California Government Code sets forth requirements for maintaining property within fire
hazard areas, such as defensible space, vegetative fuels ma nagement, and building materials and standards.
Defensible space around structures in fire hazard areas must consist of 100 feet of fuel modification on each side
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of a structure, but not beyond the property line unless findings conclude that the clearing is necessary to
significantly reduce the risk of structure ignition in the event of a wildfire. Clearance on adjacent property shall only
be conducted following written consent by the adjacent owner. Further, trees must be trimmed from within 10 feet
of the outlet of a chimney or stovepipe, vegetation near buildings must be maintained, and roofs of structures must
be cleared of vegetative materials. Exemptions may apply for buildings with an exterior constructed entirely of
nonflammable materials.
California Code of Regulations
Title 14 Natural Resources
Title 14, Division 1.5, Chapter 7, Subchapter 3, Fire Hazard, also sets forth requirements for defensible space if the
distances specified in Section 51182 of the California Government Code (outlined above) cannot be met. For
example, options that have similar practical effects include noncombustible block walls or fences, 5 feet of
noncombustible material horizontally around the structure, installing hardscape landscaping or reducing exposed
windows on the side of the structure with a less-than-30-foot setback, or additional structure hardening such as
those required in the California Building Code, California Code of Regulations Title 24, Part 2, Chapter 7A.
Title 24 California Building Standards Code
California Building Code
Part 2 of Title 24 of the California Building Standards Code contains the California Building Code (CBC). Chapter 7A
of the California Building Code regulates building materials, systems, and/or assemblies used in the exterior design
and construction of new buildings located within a fire hazard area. Fire hazard areas as defined by the California
Building Code include areas identified as a FHSZ within a State Responsibility Area or a wildland–urban interface
fire area. The purpose of Chapter 7A is to establish minimum standards for the protection of life and property by
increasing the ability of structures located in a fire hazard area to resist the intrusion of flames or burning embers
projected by a wildfire, and to contribute to a systematic reduction in structural losses from a wildfire. New buildings
located in such areas must comply with the ignition-resistant construction standards outlined in Chapter 7A.
California Fire Code
Part 9 of Title 24 of the California Building Standards Code contains the CFC, which incorporates by adoption the
International Fire Code with necessary California amendments. The purpose of the CFC is to establish the minimum
requirements to safeguard the public health, safety, and general welfare from the hazards of fire, explosion, or
dangerous conditions in new and existing buildings, structures, and premises, and to provide safety and assistance
to firefighters and emergency responders during emergency operations. Chapter 49 of the CFC contains minimum
standards for development in the wildland–urban interface and fire hazard areas.
The CFC and Office of the State Fire Marshal provide regulations and guidance for local agencies in the development
and enforcement of fire safety standards. The CFC is updated and published every 3 years by the California Building
Standards Commission. The 2016 CFC took effect on January 1, 2017, and the 2019 CFC took effect on January
1, 2020. The City adopted the 2016 CFC with local amendments in August 2018.
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California Public Resources Code
California Public Resources Code Section 4290 requires minimum fire safety standards related to defensible space
that are applicable to residential, commercial, and industrial building construction in State Responsibility Area lands
and lands classified and designated as Very High FHSZs. These regulations include road standards for fire
apparatus access, standards for signs identifying roads and buildings, fuel breaks and green belts, and minimum
water supply requirements. It should be noted that these regulations do not supersede local regulations, which are
equal to or exceed minimum regulations required by the state.
California Public Resources Code Section 4291 requires a reduction of fire hazards around buildings located
adjacent to a mountainous area, forest-covered lands, brush-covered lands, grass-covered lands, or land that is
covered in flammable material. It is required to maintain 100 feet of defensible space around all sides of a
structure, but not beyond the property line unless required by state law, local ordinance, rule, or regulations. Further,
California Public Resources Code Section 4291 requires the removal of dead or dying vegetative materials from the
roof of a structure, and trees and shrubs must be trimmed from within 10 feet of the outlet of a chimney or
stovepipe. Exemptions may apply for buildings with an exterior constructed entirely of nonflammable materials.
Fire Hazard Severity Zones
CAL FIRE maps FHSZs based on fuel loading, slope, fire history, weather, and other relevant factors as directed by
California Public Resources Code, Sections 4201–4204, and California Government Code, Sections 51175–
51189. FHSZs are ranked from Moderate to Very High, and are categorized for fire protection within a Federal
Responsibility Area, State Responsibility Area, or Local Responsibility Area under the jurisdiction of a federal agency,
CAL FIRE, or local agency, respectively. The project site is within a wildland-urban interface (WUI) location that is in
an area statutorily designated a Local Responsibility Area (LRA) Non-Fire Hazard Severity Zone (FHSZ) by the City
and CAL FIRE (CAL FIRE 2009).
California Strategic Fire Plan
The 2018 Strategic Fire Plan for California reflects CAL FIRE’s focus on fire prevention and suppression activities
to protect lives, property, and ecosystem services, as well as natural resource management to maintain the state’s
forests as a resilient carbon sink to meet California’s climate change goals and to serve as important habitat for
adaptation and mitigation. The Strategic Fire Plan for California provides a vision for a natural environment that is
more fire resilient, buildings and infrastructure that are more fire resistant, and a society that is more aware of and
responsive to the benefits and threats of wildland fire, all achieved through local, state, federal, tribal, and private
partnerships (CAL FIRE 2018). Plan goals include the following:
• Identify and evaluate wildland fire hazards and recognize life, property, and natural resource assets at risk,
including watershed, habitat, social, and other values of functioning ecosystems. Facilitate the collaborative
development and sharing of all analyses and data collection across all ownerships for consistency in type and kind.
• Promote and support local land use planning processes as they relate to (a) protection of life, property, and natural
resources from risks associated with wildland fire; and (b) individual landowner objectives and responsibilities.
• Support and participate in the collaborative development and implementation of local, cou nty, and regional
plans that address fire protection and landowner objectives.
• Increase fire prevention awareness, knowledge, and actions implemented by individuals and communities
to reduce human loss, property damage, and impacts to natural resources from wildland fires.
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• Integrate fire and fuels management practices with landowner/land manager priorities across jurisdictions.
• Determine the level of resources necessary to effectively identify, plan, and implement fire prevention using
adaptive management strategies.
• Determine the level of fire suppression resources necessary to protect the values and assets at risk
identified during planning processes.
• Implement post-fire assessments and programs for the protection of life, property, and natural resource recovery.
Mutual Aid Agreements
The California Disaster and Civil Defense Master Mutual Aid Agreement, as provided by the California Emergency
Services Act, provides statewide mutual aid between and among local jurisdictions and the state. The statewide
mutual aid system exists to ensure that adequate resources, facilities, and other supports are provided to
jurisdictions whenever resources prove to be inadequate for a given situation. Each jurisdiction controls its own
personnel and facilities, but can give and receive help whenever needed.
Local
San Diego County Emergency Operations Plan
The San Diego County Emergency Operations Plan (EOP) is a comprehensive emergency management system that
provides for a planned response to disaster situations associated with natural disasters, technological incidents,
and nuclear defense operations. The EOP is for use by the County and all cities, including the City of Chula Vista,
within the county to respond to major emergencies. The EOP includes operational concepts relating to various
emergency situations, identifies components of the Emergency Management Organization and describes the overall
responsibilities for protecting life and property and assuring the overall well-being of the population. The plan also
identifies the sources of outside support that might be provided (through mutual aid and specific statutory
authorities) by other jurisdictions, state and federal agencies, and the private sector (County of San Diego 2018).
San Diego County Multi-Jurisdictional Hazard Mitigation Plan
The San Diego County Multi-Jurisdictional Hazard Mitigation Plan was originally prepared in July 2010 and updated
in October 2017 to meet federal and state requirements for disaster preparedness to make the county eligible for
funding and technical assistance from state and federal hazard mitigation programs. The plan includes a risk
assessment to enable local jurisdictions to identify and prioritize appropriate mitigation actions to reduce losses
from potential hazards, including flooding, earthquakes, fires, and man-made hazards. To address potential
hazards, the plan then incorporates mitigation goals and objectives, mitigation actions and priorities, an
implementation plan, and documentation of the mitigation planning process for each of the 22 participating
jurisdictions, including Chula Vista (County of San Diego 2017).
City of Chula Vista Multiple Species Conservation Program Subarea Plan
The Multiple Species Conservation Program (MSCP) is a comprehensive, long-term habitat conservation plan which
addresses the needs of multiple species and the preservation of natural vegetation communities in San Diego
County. Because fire is a natural feature of the Chula Vista Subarea, under normal circumstances natural re -growth
of habitat is expected. However, the Wildlife Agencies have indicated that certain Repetitive Fires within the same
location of the Chula Vista MSCP Preserve may adversely affect the Covered Species conserved by the Subarea
Plan as a result of habitat type conversion from existing habitat(s) to invasive or non-native weeds. In order to
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further reduce the risk of fire, the City has instituted a special weed abatement and brush management program
focused particularly on the edges between urban areas and open space Preserv e lands. Brush management is
required to be undertaken in the City in areas where urban development interfaces with open space, in order to
reduce fire fuel loads and reduce potential fire hazard (City of Chula Vista 2003).
Chula Vista General Plan
The following objectives and policies from the City of Chula Vista General Plan (General Plan) are relevant to the
proposed project (City of Chula Vista 2005):
• Objective E 16: Minimize the risk of injury and property damage associated with wildland fire hazards.
• Policy E 16-1: Implement brush management programs which are consistent with the Chula Vista MSCP
Subarea Plan and the City’s Urban-Wildland Interface Code, within urban development and open space
interface areas in order to reduce potential wildland fire hazards. Brush management guidelines within the
MSCP Subarea Plan and the Urban-Wildland Interface Code shall include limits and measures to prevent
increased risk of erosion.
City of Chula Vista Municipal Code
Title 15, Chapter 15.36 of the City of Chula Vista’s Municipal Code (CVMC) (City of Chula Vista 2020) contains the
California Fire Code, 2019 Edition, with local amendments. A city, county, or city and county may establish more
restrictive building standards reasonably necessary because of local climatic, geological, or topographical
conditions. The code contains provisions for fire prevention and safety, reflecting regulations set forth by the CFC,
such as requirements for emergency planning and preparedness (Section 15.36.045), fire protection systems
(Section 15.36.055 and 15.36.060), and vegetation management and clearance (Section 15.36.065).
Chapter 15.34, Section 15.34.010 of the CVMC (City of Chula Vista 2020) defines that the City Council of the City
of Chula Vista (City) designates very high fire hazard severity zones as recommended by the Director of CAL FIRE
and as designated on a map titled “Very High Fire Hazard Severity Zones (VHFHSZ) – Local Responsibility Areas
(LRA),” dated April 3, 2008, and filed with the office of the City Clerk. (Ord. 3113 § 1, 2008).
Fire Protection Plan
A Fire Protection Plan (FPP) was prepared for the proposed project in September 2020. The FPP evaluates and
identifies the potential fire risk associated with the project’s land uses and identifies requirements for water supply,
fuel modification and defensible space, emergency access, building ignition and fire resistance, fire protection
systems, and wildfire emergency pre-planning, among other pertinent fire protection criteria. The purpose of the
FPP is to generate and memorialize the fire safety requirements of the City along with project-specific measures
based on the site, its intended use, and its fire environment.
5.17.1.2 Existing Setting
Wildfire is a continuous threat in Southern California, and is particularly concerning in the WUI, the geographic area
where urban development either abuts or intermingles with wildland or vegetative fuels. Since the City receives
limited precipitation, the potential for wildland fires represents a significant hazard within areas of the City (City of
Chula Vista 2005). As discussed in Section 5.17.1.1, Regulatory Framework, the project site is within a WUI location
that is in an area statutorily designated an LRA Non-FHSZ by the City and CAL FIRE (CALFIRE 2009). While the
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project site is not designated as a FHSV by CALFIRE, the General Plan has determined its own fire hazard zones
(FHZ) to acknowledge areas that are potentially susceptible to wildfire. As such, the General Plan designates the
project site as a High Hazard area which suggests the area may contain substantial forest fire risk and hazards (City
of Chula Vista 2005). Fire Station 3 is located 0.2 miles northwest of the project site.
Surrounding Area
The project site is located in a predominantly residential area of the City. It is bounded to the north by an open
space preserve, which runs along the southern side of Olympic Parkway. Further north of Olympic Parkway is a
single-family residential community. The future Otay Ranch Village 2 development is immediately to the east of the
project site; however, the land is currently undeveloped and will be developed in the future. The Otay Landfill and
City open space/future community park are located to the south-southeast. Both the City and the County of San
Diego own undeveloped land to the south of the project site. Brandywine Avenue and existing residential
communities border the western and southwestern edges, respectively, of the project site.
Topography
Approximately 19.2 acres of open space, located in the northern portion of the project site , would consist of the
Poggi Canyon Creek, parallel to Olympic Parkway (see Figure 4-8, Proposed Poggi Creek Conservation Easement
and MSCP Boundary). The general topography of the project site is moderately hilly and slopes downward to the
north toward Poggi Canyon Creek and the south side of Olympic Parkway. Elevations range from approximately 455
feet above mean sea level (amsl) at the southeast property boundary to 228 feet amsl in the northwestern end of
the project site. Topographic features that may present a fire spread facilitator are the narrow sub -drainages that
trend south to north which may serve to funnel winds. From a regional perspective, the northeast to southwest
alignment of Poggi Canyon is conducive to channeling and funneling wind towards the project site.
Climate
Throughout Southern California, including at the project site, climate has a large influence on fire risk. Local climate is
typical of a Mediterranean area, with warm, dry summers and wetter winters. Precipitation typically occurs between
December and March. The prevailing wind is an on-shore flow from the Pacific Ocean, which is approximately 6.6 miles
to the west, Santa Ana winds, which typically occur in the fall, from the northeast can gust to 50 miles per hour (mph) or
higher. Drying vegetation (fuel moisture of less than 5% for 1-hour fuels is possible) during the summer months becomes
fuel available to advancing flames should an ignition occur. Extreme conditions, used in fire modeling for this site, include
92°F temperatures in summer and winds of up to 50 mph during the fall. Relative humidity of 12% or less is possible
during fire season. The site is within the coastal influence area and would be expected to, on average, include higher
humidity and resulting plant moisture, than more inland areas.
Vegetation Communities
The project site is currently undeveloped land with four native or naturalized vegetation communities and one land
cover type that were mapped on the site. The acreage of each on-site vegetation community or land cover type is
provided in Table 5.17-1. There are three pre-dominant vegetation types mapped on the project site, including
Diegan coastal sage scrub, native grasslands, and non-native grasslands which encompass approximately 22%,
25%, and 46% of the property, respectively. Smaller areas of wetlands/non-wetlands waters, disturbed habitat, and
the Poggi Creek Maintenance area are also present on the project site.
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Table 5.17-1. Proposed Project Vegetation Communities and Land Cover Types
Vegetation Community or Land Cover Type Total Acres Inside Preserve (Acres) Outside Preserve (Acres)
Diegan coastal sage scrub 29.8 22.6 7.2
Native grassland 33.6 27.4 6.2
Non-native grassland 62.2 4.4 57.8
Non-native vegetation 0.4 0.3 0.1
Southern willow scrub (including seep) 1.3 0.4 0.9
Mulefat scrub <0.1 <0.1 0.0
Coastal and valley freshwater marsh 8.4 7.0 1.4
Total 135.7 62.1 73.6
Source: Appendix H3.
Vegetation Dynamics
Variations in vegetative cover type and species composition have a direct effect on fire behavior. Some plant
communities and their associated plant species have increased flammability based on plant physiology (resin
content), biological function (flowering, retention of dead plant material), physical structure (bark thickness, leaf
size, branching patterns), and overall fuel loading. For example, the native shrub species that compose the
chaparral plant communities on site are considered to exhibit higher potential hazard (higher intensity heat and
flame length) than grass dominated plant communities (fast moving, but lower intensity) if ignition occurred . The
corresponding fuel models for each of these vegetation types are designed to capture these differ ences.
Additionally, vegetative cover influences fire suppression efforts through its effect on fire behavior. For example,
while fires burning in grasslands may exhibit lower flame lengths and heat outputs than those burning in native
shrub habitats, fire spread rates in grasslands are often more rapid.
A critical factor to consider is the dynamic nature of vegetation communities. Fire presence and absence at varying
cycles or regimes disrupts plant succession, setting plant communities to an earlier state where less fuel is present
for a period of time as the plant community begins its succession again. In summary, high -frequency fires tend to
convert shrublands to grasslands or maintain grasslands, and fire exclusion tends to convert grasslands to
shrublands over time as shrubs sprout back or establish and are not disturbed by repeated fires.
In general, biomass and associated fuel loading will increase over time, assuming that disturbance (e.g., fire,
grazing, or farming) or fuel reduction efforts are not diligently implemented, which would not occur on this site due
to the funded maintenance entity. It is possible to alter successional pathways for varying plant communities
through manual alteration. This concept is a key component in the overall estab lishment and maintenance of the
proposed FMZs for the project site. The FMZs will consist of irrigated and maintained landscapes that will be subject
to regular “disturbance” in the form of maintenance and will not be allowed to accumulate excessive biomass over
time, which results in reduced fire ignition, spread rates, and intensity. In contrast, conditions outside the FMZs,
where the wildfire threat will exist post-development, are classified as medium to heavy fuel loads due to the
maturity of the vegetation, which haven’t burned for many decades.
Fire History
The project site has been subject to one wildfire during the recorded fire history period. The Maxwell Fire in 1984
burned along the southern portion of the project site. In addition to the one fire burning on the project site, the
majority of other large wildfires historically start east of the proposed project site area and are typically contained
east of Lower Otay Lake.
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The lack of recent fire history does not indicate that a fire cannot occur in the vegetation that would be adjacent to
the proposed site. It is expected that fires have not consistently spread into the proposed project site area due to
three factors: the position of the surrounding urban developments which are newer, ignition resistant construction;
the position of lower Otay Lake to the east, which presents a very wide firebreak; and the effective wildland fire
fighting capabilities of Chula Vista Fire Department (CVFD).
5.17.2 Thresholds of Significance
The significance criteria used to evaluate the project impacts to wildfire is based on the recommendations provided
in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). As mentioned previously, the project site is within a
WUI location that is in an area statutorily designated an LRA Non-FHSZ by the City and CAL FIRE (CALFIRE 2009).
However, the project site is within a City designated FHZ and is considered a High Hazard area (City of Chula Vista
2005). Thus, a significant impact associated with wildfire would occur if the project would:
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.
5.17.3 Impacts
A. Substantially impair an adopted emergency response plan or emergency evacuation plan.
The project site is located within a City designated FHZ. As seen in Figure 9-9, Wildland Fire Hazards Map, of the
General Plan, the project site is designated as a High Hazard area (City of Chula Vista 2005). In the event of an
emergency, response to the project site would be serviced by the City of Chula Vista Fire Department, Police
Department, and other responsible agencies. Additionally, the City is part of the San Diego County Emergency
Operations Plan (SDCEOP) which includes a detailed evacuation response plan in the event that evacuation is
required. As stated in the SDCEOP, major ground transportation corridors shall be used as primary evacuation
routes in the event of an emergency. As such, Olympic Parkway, which provides access to the project site, would be
the closest evacuation route. During construction of the project, a temporary increase in traffic on roadways
surrounding the project site may occur due to increased truck loads or the transport of construction equipment to
and from the project site during the construction period. However, all construction activities including staging would
occur in accordance with City requirements (such as CVMC Chapter 12.12, which prohibits street obstructions),
which would ensure that adequate emergency access to the project site in the event of an emergency or evacuation
order would be provided during construction of the project (City of Chula Vista 2020). Furthermore, because the
project site is included in the General Development Plan as a planned community (City of Chula Vista 1989), it is
incorporated into the City’s existing emergency disaster programs, including all fire and emergency services and
mutual aid agreements.
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Upon completion of construction, direct access to the project site would be provided by two proposed public streets,
Street “A” and Street “B” (Streets A and B). Street A would extend south from Olympic Parkway, through the project
site, and curve to the east to connect with Street B. Street B would also extend south from the eastern portion of
Olympic Parkway, adjacent to the project site (see Figure 4.6, Illustrative Concept Plan, and Figure 4.9, Vehicular
Circulation Plan). The proposed driveways and roadways providing access to the project site would comply with the
requirements of the Chula Vista Fire Code (including 2019 Fire Code and 2018 Urban–Wildland Interface Code),
and would be reviewed and approved by Chula Vista Fire Department (CVFD). Additionally, all on-site roads would
be constructed to current Fire Codes and City of Chula Vista or County of San Diego Standards for public and private
roads, including minimum 24-foot-wide, unobstructed road widths.
As discussed in the FPP, early evacuation for any type of wildfire emergency near the project site is the preferred method of
providing for resident safety, consistent with the City’s current approach. As such, each property owner would be individually
responsible to adopt, practice, and implement a “Ready, Set, Go!” (International Fire Chiefs Association 2013) approach to
site evacuation. The “Ready, Set, Go!” concept is widely known and encouraged by the state of California and most fire
agencies. Pre-planning for emergencies, including wildfire emergencies, focuses on being prepared, having a well-defined
plan, minimizing potential for errors, maintaining the site’s fire protection systems, and implementing a conservative
(evacuate as early as possible) approach to evacuation and site uses during periods of fire weather extremes.
Therefore, through compliance with existing regulations and recommendations of the FPP, the proposed project would not
interfere with an adopted emergency response or emergency evacuation plan; impacts would be less than significant.
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.
As stated in Section 5.17.1, Existing Conditions, the project site is within a WUI location that is in an area statutorily
designated an LRA Non-FHSZ by the City and CAL FIRE (CALFIRE 2009). However, the project site is within a City
designated FHZ and is considered a High Hazard area (City of Chula Vista 2005). As such, the project could result in an
impact related to exacerbating wildfire risk that exposes project occupants to pollutant concentrations from a wildfire or
the uncontrollable spread of a wildfire if it would increase the risk of a wildfire occurring and the climatic, topographic,
vegetation, weather conditions, and other factors that aid in increasing the severity of such an occurrence.
Construction
Construction of the project would introduce potential ignition sources to the project site, including the use of heavy
machinery and the potential for sparks during welding activities or other hot work. However, the project would be
required to comply with City and state requirements for activities in hazardous fire areas, including fire safety
practices, to reduce the possibility of fires during construction activities. As discussed in the FPP prepared for the
project, pre-construction requirements would be adhered to in order to reduce the potential of fire caused by
construction-related activities. These requirements include establishing perimeter fuel modification areas that are
approved by the CVFD prior to combustible materials being brought on site; reducing existing flammable vegetation
by 50% on vacant lots upon commencement of construction; removing dead fuel, ladder fuel (fuel which can spread
fire from ground to trees), and downed fuel; and ensuring that on-site trees/shrubs shall be properly limbed, pruned,
and spaced. While vegetation management would not be required on vacant lots until constriction begins, perimeter
Fuel Management Zones (FMZ) must be implemented prior to commencement of construction utilizing combustible
materials. In addition, vacant lots adjacent to active construction areas/lots would be required to implement
vegetation management if they are within 50 feet of the active construction area. Prior to issuance of a permit for
any construction, grading, digging, installation of fences, etc., on a vacant lot, the 50 feet at the perimeter of the lot
shall be maintained as a vegetation management zone.
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In the event of a fire, existing vegetation located on the project site (areas proposed for open space) and in the
surrounding area would be susceptible to burning and releasing pollutant concentrations. However, with adherence
of the aforementioned pre-construction establishing fuel modification areas, risk associated with exposure of
pollutant concentrations would be reduced greatly. Additionally, construction activities that would potentially
introduce potential ignition sources would be temporary. Therefore, impacts to pollutant concentrations from a
wildfire or the uncontrolled spread of a wildfire would be less than significant during construction.
Operational
As mentioned previously, the project site is located in an area statutorily designated as an LRA Non-FHSZ (CAlFIRE
2009). However, the project site is located within a City designated FHZ and is considered a High Hazard area (City
of Chula Vista 2005). Thus, the project includes fire resistance-related measures that shall lessen the potential
impact of the project exacerbating wildfire risk.
All new structures within the project site would be constructed to at least the California Fire Code standard. Each
of the proposed buildings would comply with the enhanced ignition-resistant construction standards of the 2019
CBC (Chapter 7A) and Chapter 5 of the Urban–Wildland Interface code, except where buildings require enhanced
ignition resistance as part of an alternative material and method proposal. These requirements address roofs,
eaves, exterior walls, vents, appendages, windows, and doors and result in hardened structures that have been
proven to perform at high levels (resist ignition) during the typically short duration of exposure to burning vegetation
from wildfires. Buildings that include higher occupancies shall meet all California Fire and Building requirements
for higher occupancy structures. Included in the high occupancy category are multi -family residences over three
units, attached condominiums, and attached townhomes up to three stories, but less than 30 feet overall height.
In addition, the project would include fire protection systems including fire hydrants, automatic fire sprinkler system,
and fire alarm systems and residential hazard detectors (See Appendix H3 for further details).
Per Chapter 15.36 of the CVMC, the City shall incorporate vegetation management and clearance standards set by
the California Fire Code (City of Chula Vista 2020). As such, all non-maintained combustible vegetation, and or other
such accumulations of combustible vegetation materials in open space areas, as determined by the Fire Code
Official, shall not be located within one hundred feet of any building or structure designated or intended for
occupancy by humans or animals. As described in the FPP, FMZs shall be implemented to provide vegetation buffers
that gradually reduce fire intensity and flame lengths from advancing fire by strategically placing thinning zones,
restricted vegetation zones, and irrigated zones adjacent to each other. Thus, with implementation of FMZs, the
spread of wildfire as well as exposure of pollutant concentrations resulting from vegetation and other materials
burning would be reduced. FMZs would be located on the perimeter of all structures and along both ingress/egress
roadways to and from Olympic Parkway. Roadway-adjacent fuel modification does not preclude the planting of street
trees in these fuel modification zones, as long as they are not found on the Prohibited Plant List (Appendix D of the
FPP) and are included in the Approved Plant Palette (Appendix C of the FPP). Typical fuel modification includes
establishment of a minimum 50-foot wide irrigated zone (Zone 1) and a 50-foot wide thinned zone (Zone 2) on the
periphery of the project site, beginning from the rear or side yard lot line (For further details regarding Zone 1 and
Zone 2 criteria refer to Appendix H3). As discussed in the FPP, FMZ areas experience a significant reduction in
flame length and intensity. Reduction of flame lengths and intensities are assumed to occur within the full 100 feet
of fuel modification (a combination of Zones 1 and 2). However, due to site constraints, it is not feasible to achieve
a 100-foot FMZ width on the south side of the project site. As such, it is possible that the project would exacerbate
wildfire risk and impacts would be potentially significant. Thus, implementation of Mitigation Measure (MM) WF-1
is required (see Section 5.17.5, Mitigation Measures).
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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.
The proposed project is primarily a residential project, with associated infrastructure and open space areas. As such,
the project would include installation and maintenance of associated infrastructure including driveways and
roadways, connections to service utilities (e.g., water, wastewater, electric power, natural gas, and
telecommunications services), water drainage and water quality improvements (e.g., biofiltration basins), and fuel
breaks (e.g., fuel modification).
Vegetation Management
As previously discussed, the General Plan designates the project site and surrounding area as a High Fire Hazard
area, and implementation of FMZs and defensible space is required. FMZs are designed to provide vegetation
buffers that gradually reduce fire intensity and flame lengths from advancing fire, and would reduce, rather than
exacerbate, wildfire risk. Refer to the discussion in threshold b of this section for further details.
Roads
The proposed project would include construction of two on-site public streets, Street “A” and Street “B.” Street “A”
would extend south from Olympic Parkway, through the project site, and curve to the east to connect with Street
“B.” Street “B” would also extend south from the eastern portion of Olympic Parkway, adjacent to the project site
(see Figures 4.6 and 4.9). The presence of increased human activity and vehicles along newly installed roads would
introduce new potential ignition sources to the project area. However, vegetation management would be required
along roadways within the High Fire Hazard area for roads internal and external to the project site. As stated in the
FPP, combustible vegetation would be modified within 30 feet from each side of Streets “A” and “B.” Roadway-
adjacent fuel modification does not preclude the planting of street trees in these fuel modification zones, as long
as they are not found on the Prohibited Plant List (Appendix D of the FPP) and are included in the Approved Plant
Palette (Appendix C of the FPP). Additionally, construction of project roadways and connections to existing roadways
would provide increased accessibility for the Chula Vista Fire Department to the project area. Therefore, vegetation
management would reduce the risk of fire ignition along roadways and ensure ease of accessibility for ingress and
egress of fire apparatus and would not be anticipated to exacerbate wildfire risk.
Utilities
As discussed in Section 5.13, existing utility service lines are located within the vicinity of the project site, and
connection to utility service lines would be implemented as part of the project. Connections to utility service lines,
including those for water, wastewater, electric power, natural gas, and telecommunications services, would be
extended underground from their current locations nearby the project site to the proposed residential structures,
which would decrease fire risks. However, given that the activity of connecting utilities from their current locations
(i.e., within Olympic Parkway) to the project site would require ground disturbance and the use of heavy machinery
associated with trenching, the installation of these utility service lines would introduce new potential sources of
ignition to the site, such as the use of heavy machinery, welding, or other hot work. However, as previously
discussed, vegetation management activities would occur prior to the start of construction, which would reduce the
likelihood of fire ignition during installation and connection of utilities.
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Further, other than lateral connections to nearby utility mains, the project would not require or result in the
relocation or construction of new or expanded service utilities facilities, the construction or relocation of which could
exacerbate wildfire risk or cause significant environmental effects.
Summary
Installation and maintenance of project roads, service utilities, fuel modification, drainage and water quality
improvements, and other associated infrastructure would not exacerbate wildfire risks provided that the
appropriate fire prevention and vegetation management activities are implemented as required by the CVMC.
Given that the activities involved with installation or maintenance of associated infrastructure would require ground
disturbance and the use of heavy machinery associated with trenching, grading, site work, and other construction
and maintenance activities, the installation of related infrastructure could potentially result in temporary or ongoing
impacts to the environment. However, the proposed project would be required to comply with all regulatory
requirements such as the CVMC and the requirements of the FPP.
Therefore, the installation and maintenance of associated infrastructure would not exacerbate wildfire risk or result in
impacts to the environment beyond those already disclosed in this EIR, and impacts would be less than significant.
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.
The project would introduce a new residential use with associated infrastructure and open space, resulting in more
impervious area to the site, which would result in more surface runoff. However, the development of the project site would
include adding storm drains, curb inlets, cleanouts along the proposed on-site public and private streets and parking areas
to collect and convey the storm runoff to the two proposed detention/water quality control basins located at northeast and
northwest part of the development area. After the majority of the on-site runoff is treated and detained by the biofiltration
basin, the outflow will confluence with the bypass storm drain and discharge into the Poggi Canyon Creek.
To analyze whether the project would create adverse impacts related to flooding, the Drainage Report prepared for
the project (Appendix H2) evaluates the existing and proposed peak flows from the project site, assuming the
proposed project incorporates the aforementioned attenuation measures. The findings determined that the runoff
generated by the project would not exceed pre-project peak flow rates, and runoff velocities would be dissipated by
rock riprap at storm drain outfalls. Refer to Appendix H2 for further details. Additionally, the project site is located
in Zone X, an area of minimal flood hazard per the FEMA FIRM panel 06073C1914G effective May 16, 2012 (FEMA
2020). This area is higher in elevation than the 0.2% annual chance flood (i.e., 500-year flood). Although internal
drainage patterns would be somewhat altered as a result of project development, the project would maintain
adequate stormwater conveyance as to not result in an increase of surface runoff that wo uld result in flooding on
or off site. Furthermore, there is low potential for landslides to occur on the project site. With compliance to the
City’s Grading Ordinance, current seismic design specifications, current CBC standards, and other regulatory
requirements, the potential for impacts associated with landslides would be further minimalized. In the event of a
fire, the project site would potentially experience physical changes to the landscape which could result in increased
risk of flooding or landslides. However, as previously discussed, under existing conditions the project has low risk
for landslides and flooding. Additionally, proposed drainage improvements and adherence to the aforementioned
CBC standards and regulatory requirements would further reduce potential impacts. Therefore, impacts associated
with downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage
changes would be less than significant.
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5.17.4 Level of Significance Prior to Mitigation
Prior to mitigation, the proposed project would have potentially significant impacts associated with the project
facilitating wildfire spread or exacerbating wildfire risk. The remaining issues addressed in this section would be
less than significant.
5.17.5 Mitigation Measures
Implementation of the mitigation measure MM-WF-1 (see Section 5.8 of this EIR) would reduce identified significant
impacts associated with wildfire to a less-than-significant level.
5.17.6 Level of Significance After Mitigation
Implementation of MM-WF-1 would reduce potential impacts associated with wildfire to a less-than-significant level.
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6 Cumulative Impacts
6.1 Introduction
Although the environmental effects of an individual project may not be significant when that project is considered
independently, the combined effects of several projects may be significant when considered collectively. Such
impacts are referred to as “cumulative impacts.” Section 15355 of the California Environmental Quality Act (CEQA)
Guidelines defines cumulative impacts as “two or more individual effects which, when considered together, are
considerable or which compound or increase other environmental impacts.” Section 15130 of the CEQA Guidelines
provides guidance for analyzing significant cumulative impacts in an environmental impact report (EIR). According
to this section of the CEQA Guidelines, the discussion of cumulative impacts “need not provide as great detail as is
provided for the effects attributable to the project alone. The discussion should be guided by standards of
practicality and reasonableness.” The discussion should also focus only on significant effects resulting from a
project’s incremental effects and the effects of other projects. According to Section 15130(a)(1), “an EIR should
not discuss impacts which do not result in part from the project evaluated in the EIR.”
Cumulative impacts can occur from the interactive effects of a single project. For example, the combination of noise and
dust generated during construction activities can be additive and can have a greater impact than either noise or dust
alone. However, substantial cumulative impacts more often result from the combined effect of past, present, and future
projects located in proximity to the project under review. Therefore, it is important for a cumulative impacts analysis to
be viewed over time and in conjunction with other related past, present, and reasonably foreseeable future developments
whose impacts might compound or interrelate with those of the project under review.
6.2 Methodology
According to Section 15130(b) of the CEQA Guidelines, cumulative impact analysis may be conducted and
presented by either of two methods: (1) a list of past, present, and probable activities producing related or
cumulative impacts, or (2) a summary of projections contained in an adopted general plan or related planning
document, or in a prior environmental document that has been adopted or certified that described or evaluated
regional or area-wide conditions contributing to the cumulative impact. Other than for air quality, greenhouse gas
emissions, noise, and transportation/traffic, the cumulative list approach has been used in the cumu lative analysis
presented in this chapter, as discussed below. Air quality, greenhouse gas emissions, noise, and
transportation/traffic cumulative impacts were evaluated using the summary of projections method because
impacts can only be analyzed on a broa d, area-wide scope, and in a cumulative context. Table 6-1 describes the
geographic scope of the cumulative impact analyses.
Table 6-1. Geographic Scope of Cumulative Impact Analyses
Topic Geographic Scope of Cumulative Impact Analyses
Aesthetics The cumulative study area associated with aesthetics and lighting and glare impacts is the
viewshed of the project, which is a geographic area from which a proposed project is likely to be
seen, based on topography and land use patterns.
Air Quality The geographic scope of cumulative impact analysis for criteria air pollutants, sensitive receptors,
and air quality plans is the San Diego Air Basin. Impacts relative to objectionable odors are
limited to the area immediately surrounding the odor source and are not cumulative in nature
because the air emissions that cause odors disperse beyond the sources of the odor.
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Table 6-1. Geographic Scope of Cumulative Impact Analyses
Topic Geographic Scope of Cumulative Impact Analyses
Biological
Resources
The geographic scope of cumulative impact analysis for biological resources includes the Chula
Vista Multiple Species Conservation Program Subarea Plan area.
Cultural
Resources and
Tribal Cultural
Resources
The geographic context for the analysis of cumulative impacts to archaeological resources,
historic resources, human remains, and tribal cultural resources includes the San Diego region,
which has a similar archaeological, ethnohistoric, historic, and prehistoric setting as the project
site.
Energy The City of Chula Vista is the geographic scope of cumulative impacts to energy.
Geology and
Soils
Impacts relative to seismic hazards and other geologic/soil conditions (i.e., fault rupture,
groundshaking, ground failure, liquefaction/collapse, landslides, lateral spreading, subsidence,
and expansive soils) and septic systems are generally site specific. Similarly, impacts to
paleontological resources are generally site specific.
Greenhouse
Gas Emissions
Due to the nature of assessment of greenhouse gas emissions and the effects of climate change,
impacts can currently only be analyzed from a cumulative context; therefore, the geographic
scope for the cumulative analysis of greenhouse gas emissions and their effect on climate
change is the global atmosphere.
Hazards and
Hazardous
Materials
The geographic context for the analysis of cumulative impacts relative to the transport, use and
disposal of hazardous materials, and associated accidental releases, encompasses the
roadways and freeways used by vehicles transporting hazardous materials to and from the
project sites. The geographic context for the analysis of cumulative impacts relative to wildland
fires and emergency response and evacuation plans is the City of Chula Vista. Impacts relative to
listed hazardous materials sites and airport hazards are generally specific to the project site.
Hydrology/
Water Quality
The geographic context for the analysis of cumulative impacts relative to water quality standards,
alteration of drainage patterns, mudflows, dam inundation, tsunamis, seiches, and flood hazard
areas are generally site-specific.
Land Use/
Planning
Incompatibilities with adjacent land uses are generally site specific; therefore, the geographic
context for the analysis of cumulative impacts relative to adjacent land use incompatibilities
includes the area surrounding the project site. The geographic context for the analysis of
cumulative impacts relative to physical division of an established community is generally site
specific.
Noise The area of cumulative impact that would be considered for the noise and vibration cumulative
analysis would be only those cumulative projects within the immediate vicinity of the project.
Exposure to aircraft noise is also a localized impact and the area of cumulative impact that would
be considered for aircraft impacts would be only those projects located within 2 miles of Brown
Field.
Population and
Housing
The City of Chula Vista is the geographic scope of cumulative impacts to housing and population.
Public Services The City of Chula Vista is the geographic scope of cumulative impacts for public services.
Recreation The City of Chula Vista is the geographic scope of cumulative impacts for recreation.
Transportation The cumulative study area associated with traffic hazards, alternative transportation, and
emergency access is the study area for the project-specific transportation impact analysis
(Appendix K). Impacts related to aircraft traffic are generally specific and limited to the area
within 2 miles of a specific airport. The cumulative study area associated with impacts related to
vehicle miles traveled (VMT) include the City.
Utilities and
Service
Systems
The City of Chula Vista is the geographic scope of cumulative impacts to utilities and service
systems.
Wildfire The geographic context for the analysis of cumulative impacts relative to wildland fires and
emergency response and evacuation plans is the City of Chula Vista.
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6.3 Cumulative Projects
6.3.1 Land Development
Other than air quality, greenhouse gas emissions, noise, and transportation/traffic, cumulative impacts for all other
environmental issue areas are based on a list of projects within the proposed Sunbow Sectional Planning Area (SPA) Plan
Amendment for the Sunbow II, Phase 3 Project’s (project) study area that either have applications submitted or approved,
are under construction, or have recently been completed. The cumulative projects identified in the study area are listed in
Table 6-2 and shown on Figure 6-1.
Table 6-2. Cumulative Projects
Project
No. Name Location Description Status
1 University
Villages
Otay Ranch The project encompasses Village Three, Village Eight
East, and Village Ten. The development program for
the project is based on the Chula Vista General Plan
and the approved Otay Ranch planning documents
(Otay Ranch General Development Plan (GDP),
Overall Design Plan, and other SPA plans for Otay
Ranch.
Village Three: 1,638 residential units (813 single
family, 457 multi-family, and 327 unallocated units);
20,000 square feet of retail (7.4 acres); 29.3 acres
of industrial; 15.3 acres of parks; 4.3 acres of CPF;
and 8.3 acres of school.
Village Eight East: 3,276 residential units (943
single family and 2,333 multi-family); 20,000
square feet of retail; 4.2 acres of CPF; 30.4 required
acres of parks; and 10.8 acres of school.
Village Ten: 1,740 residential units (695 single
family and 1,045 multi-family); 7.6 acres of parks;
4.3 acres of CPF; and 9.2 acres of school.
Approved
2 Eastern Urban
Center
(Millenia)
East of SR
125 and
west of
Eastlake
Parkway,
south of
Birch Street
Designated uses and density at buildout of the
project include 2,983 multi-family residential units
and 3.324 million square feet of non-residential use
including regional and specialty shopping, multi-use
cultural arts facilities, local parks, business parks,
visitor commercial, a transit station, an elementary
school, and other civic facilities.
Approved
3 Village Four
South
Residential
Otay Ranch 275 multi-family and 75 single family homes. Approved
4 Planning Area
12 Freeway
Commercial
East of SR
125 and
west of
Eastlake
Parkway,
south of
Olympic
Parkway
The project includes development of 900 multi-
family homes, commercial, mixed use, hotel, and
park uses.
Approved
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Table 6-2. Cumulative Projects
Project
No. Name Location Description Status
5 Village Two West of La
Media
Road, south
of Olympic
Parkway
The project includes development of 4,538
residential units (614 single-family and 3,924 multi-
family units), 87.9 acres of industrial uses, along
with commercial, parks, and open space.
Approved
6 Village Eight
West
Southwest
portion of
Otay Ranch
The project will be built in several phases. The
following components of the project were included
in the project’ near-term cumulative analysis: 561
single family homes, 1,773 multi-family homes, up
to 50,000 SF of office uses and 250,000 SF of
commercial retail, an elementary school, and 23.4
acres of parks
Approved
7 Village Nine Southwest
portion of
Otay Ranch
3,959 residential units (266 single family and 3,693
multi-family); 1,200,000 square feet of
commercial/office; 300,000 square feet of retail; 5
acres of CPF; 27.5 acres of parks; and 19.8 acres of
school.
Approved
8 Eastlake
Behavioral
Health
Hospital
North of
Otay Lake
Road, west
of Hunte
Parkway
The proposed project would include construction of
a new single-story behavioral health acute
psychiatric hospital, which would accommodate 120
beds within an approximately 97,050-square-foot
single-story structure.
Project Submitted
– Pending Review
6.3.2 Adopted Plans
From a regional approach, the cumulative analysis relies on the R egional Comprehensive Plan; General
Development Plan (GDP); the Chula Vista General Plan; and other regional planning documents, including the
Multiple Species Conservation Program (MSCP) Subarea Plan and Regional Air Quality Strategy (RAQS) in
accordance with CEQA Section 15130(b)(1)(B).
6.4 Cumulative Impact Analysis
The discussion below evaluates the potential for the proposed project to contribute to an adverse cumulative impact
on the environment. For issues addressed in this Draft EIR, the thresholds used to determine significance are those
presented in each of the sections of Chapter 5, Environmental Analysis. For issues in which project impacts were
determined to be less than significant during the preliminary environmental review process, the thresholds consist of
the questions posed for that respective issue in Appendix G of the CEQA Guidelines. For each resource area, an
introductory statement is made regarding what would amount to a significant cumulative impact in that resource area.
Discussion is then presented regarding the potential for the identified cumulative projects to result in such a
cumulative impact, followed by discussion of whether the project’s contribution to any cumulative impact would be
cumulatively considerable.
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6.4.1 Aesthetics
As described in Section 5.1, Aesthetics, development of the proposed project would result in less than significant
impacts to scenic vistas, and no impacts to scenic resources, including, but not limited to, trees, rock outcroppings,
and historic buildings within a state scenic highway. In addition, the proposed project would not conflict with the
applicable zoning as the GDP and SPA Plan amendments and Rezone would be approved concurrently with the proposed
project to allow for the changes in land use and zoning. Lastly, with compliance with the CVMC and County Light
Pollution Ordinance, new sources of light and glare would not result in adverse day or nighttime views in the area,
and impacts would be less than significant.
The list of cumulative projects in Table 6-2 consists of primarily new residential projects, as well as industrial and
commercial projects and a behavioral health hospital, which overall are similar in size, scale, and scope to the proposed
project. Although the existing visual quality or character of the site and its surroundings would be impacted as a result of
the proposed project and cumulative projects, none of the projects would substantially degrade a scenic resource or
unique topographic feature or result in a substantial impediment to scenic views because the developments would be
required to be planned land uses and include applicable development and design guidelines. Some cumulative projects
would be located within already developed areas, as opposed to others which would result in the conversion of large
areas of undeveloped land to developed uses (see Figure 6-1). The proposed project, in combination with the cumulative
projects, would contribute to a cumulative loss of views of natural open space in the increasingly developed eastern area
of Chula Vista. The project site is surrounded by existing development and would not impact scenic vistas. However,
similar to the proposed project, all cumulative projects would be required to comply with the zoning of their respective
sites and applicable regulations governing scenic quality, including preservation of planned open space areas. Therefore,
in combination with planning future development, the project would not result in a cumulatively considerable contribution
to a cumulative impact to aesthetics.
Development in the vicinity of the project site include sources of nighttime lighting in the form of interior and exterior
security lighting and parking, architectural highlighting, and landscape lighting. In addition, automobile headlights
streetlights and stoplights along the roadway network contribute to ambient nighttime lighting levels on the project
site. Development of the proposed project would contribute new sources of light to the surrounding area. The project
includes lighting performance standards to minimize the proposed projects contribution to nighttime lighting and
light sources. Lighting would be consistent with lighting standards prevalent in urbanized areas would adhere to all
applicable City ordinances and standards. Also, compliance with the City and state energy conservation measures
currently in place would limit the amount of unnecessary interior illumination during evening and nighttime hours.
Therefore, in combination with all other cumulative projects, the proposed project would not considerably contribute
to lighting and glare.
6.4.2 Air Quality
See Threshold B in Section 5.2.3, for a discussion of the cumulative air quality impacts of the proposed project. As
described in this section, air pollution is largely a cumulative impact. The San Diego Air Pollution Control District
(SDAPCD) develops and implements plans for future attainment of ambient air quality standards. Based on these
considerations, project-level thresholds of significance for criteria pollutants are relevant in the determination of
whether a project’s individual emissions would have a cumulatively significant impact on air quality.
The SDAB is a nonattainment area for ozone (O3) under the National Ambient Air Quality Standards (NAAQS) and
California Ambient Air Quality Standards (CAAQS). The poor air quality in the San Diego Air Basin (SDAB) is the result
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of cumulative emissions from motor vehicles, off-road equipment, commercial and industrial facilities, and other
emission sources. Projects that emit these pollutants or their precursors (i.e., volatile organic compounds [VOCs]
and NOx for O3) potentially contribute to poor air quality. In analyzing cumulative impacts from a project, the analysis
must specifically evaluate the project’s contribution to the cumulative increase in pollutants for which the SDAB
is designated as nonattainment for the CAAQS and NAAQS. However, a project would only be considered to have
a significant cumulative impact if the project’s contribution accounts for a significant proportion of the cumulative
total emissions (i.e., it represents a “cumulatively considerable contribution” to the cumulative air quality impact).
Additionally, for the SDAB, the RAQS serves as the long-term regional air quality planning document for the purpose
of assessing cumulative operational emissions in the SDAB to ensure that the SDAB continues to make progress
toward NAAQS and CAAQS attainment status. As such, cumulative projects located in the San Diego region would
have the potential to result in a cumulative impact to air quality if, in combination, they would conflict with or
obstruct implementation of the RAQS. Similarly, individual projects that are inconsistent with the regional planning
documents on which the RAQS is based would have the potential to result in cumulative operational impacts if they
represent development and population increases beyond regional projections.
The SDAB has been designated as a federal nonattainment area for O3 and a state nonattainment area for O3,
PM10, and PM2.5. The nonattainment status is the result of cumulative emissions from all sources of these air
pollutants and their precursors within the SDAB. As discussed in more detail in Section 5.2.1, the project would not
exceed significance thresholds during construction or operation. As such, the project would result in less-than-
significant impacts to air quality relative to emissions. In addition, the proposed project would implement Project
Design Feature (PDF)-AQ-1, Fugitive Dust Control, and PDF-AQ-2, Architectural Coating, to ensure impacts to air
quality are less than significant (see Section 4.4.8 for details). As a result, the project would not result in a
cumulatively considerable contribution to criteria pollutant emissions. Cumulative impacts associated with project -
generated construction and operational criteria air pollutant emissions would be less than significant.
6.4.3 Biological Resources
Cumulative impacts consider the potential regional effects of a project and how a project may affect an ecosystem
or one of its members beyond the project limits and on a regional scale. As discussed in Section 5.3, with
implementation of Mitigation Measure (MM) BIO-1 through MM-BIO-16, impacts to biological resources anticipated
under the proposed project would be less than significant. In addition, the proposed project would require a Multiple
Species Conservation Program (MSCP) Preserve Boundary Line Adjustment (BLA) to resolve a conflict between the
proposed project and mapped MSCP Preserve. In addition to the BLA, the project would be required to comply with
Subarea Plan conditions for coverage. Implementation of the proposed project, in combination with cumulative
projects, would contribute to the cumulative loss of biological resources within the City. However, cumulative
projects would be required to implement similar mitigation as the proposed project to ensure impacts to biological
resources would be less than significant. In addition, cumulative projects would be required to comply with the
Subarea Plan conditions for coverage, which provides consideration for and mitigation of cumulative impacts to
biological resources, and all existing regulations related to biological resources. Therefore, the proposed project, in
combination with development of cumulative projects, would not result in a cumulatively considerable contribution
to biological impacts.
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6.4.4 Cultural Resources and Tribal Cultural Resources
A cumulative impact to cultural resources, refers to the mounting aggregate effect upon cultural resources due to
modern or recent historic land use, such as residential development, and natural processes, such as erosion, that
result from human acts. The issue that must be explored in a cumulative impact analysis is the aggregate loss of
information and the loss of recognized cultural landmarks and vestiges of a community’s cultural history.
As discussed in Section 5.4, no historic sites were identified within the project site in previous cultural investigations,
records search, or the 2020 pedestrian survey. Therefore, construction and operation of the proposed project would
not cause a substantial change in the significance of an historical resource as defined in CEQA Guidelines Section
15064.5, and no impact to historic resources would occur. In addition, although no cultural resources have been
identified or recorded within the proposed project’s area of potential effect (APE), the proximity of known sites beyond
the southern boundary indicates a high sensitivity of encountering intact subsurface cultural resources. As there is
potential to encounter previously unidentified subsurface cultural deposits, impacts to archaeological resources would
be potentially significant and MM-CUL-1 would be required to reduce impacts to less than significant. In addition, in
the event that human remains are discovered during project grading and construction, impacts would be potentially
significant and MM-CUL-1 would reduce potentially significant impacts to a level below significance. Lastly, as
discussed in Section 5.4, impacts to tribal cultural resources would be potentially significant and MM-CUL-1 would be
implemented to reduce impacts to less than significant.
The majority of cumulative projects in the area have centered on residential development, although commercial
and industrial project and a behavioral health hospital project are also included in the cumulative projects list (see
Table 6-2). Collectively, these projects reflect the eastward expansion of planned residential communities in the
City and the need for improved and additional infrastructure. In addition to modern development, much of the area
has been previously disturbed by agriculture activities, including plowing, disking, and grazing, including the project
site. Nearly all of the land in the vicinity of the project site has been surveyed for cultural resources, and several
archaeological sites located within this survey area have been identified, tested, and evaluated for significance.
Some past projects in the area, including especially habitation sites and temporary camps in the general vicinity and on
the Otay Mesa, have contributed to a cumulative impact on prehistoric cultural resources, since it represents the
continued destruction of cultural resources. However, as discussed in Section 5.4, the proposed project would not result
in impacts to any known cultural resources. In addition, MM-CUL-1 would be implemented to reduce potential impacts
to cultural resources, if any unknown resources are discovered during project implementation.
There is the potential for nearby cumulative projects, especially those that would result in ground -disturbing
activities that would impact intact native soils, to inadvertently discover and adversely affect historical and
archaeological resources. Cumulative projects would implement appropriate mitigation measures to reduce
historical resources impacts to less than significant. Important information about prehistory would not be lost through
a well-planned and executed mitigation program that documents and gathers all data from these non-replaceable and
non-renewable resources. When considered with other cumulative projects, cumulative impacts to historical
resources would not be cumulatively considerable.
6.4.5 Energy
Implementation of the proposed project and cumulative projects in the surrounding area would result in an
increased energy demand at full buildout. A significant cumulative impact to energy resources would result if a
project results in wasteful, inefficient, or unnecessary consumption of energy resources or conflicts with or obstructs
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a state or local plan for renewable energy or energy efficiency. As discussed in Section 5.5, the proposed project
would be required to comply with existing regulations such as Part 11 of Title 24 of the California Green Building
Standards Code as well as the City’s Climate Action Plan (CAP). Additionally, the proposed project includes a non-
renewable energy conservation plan that incorporates project design measures to minimize energy use. The project
would also implement energy reducing measures through implementation of MM-GHG-1, the effects of which would
be increased through implementation of green building standards, impacts to energy would be less than significant.
San Diego Gas & Electric has indicated that without an increased import capacity, including a new substation within
the Otay Ranch area, future energy needs for the eastward expansion of planned residential communities in the
City could not be ensured. Construction of a new substation located south of the east end of Hunte Parkway began
in 2016 and was completed in June 2018 (CPUC 2018). Therefore, infrastructure for the continued long-term
delivery of energy to the area is in place and to serve the proposed and cumulative projects. Because the project
would not result in the wasteful or inefficient use of energy , and because there is adequate energy infrastructure
to serve the proposed and cumulative projects, the project’s contribution to a significant cumulative energy impact
would not be cumulatively considerable.
6.4.6 Geology and Soils
Potential cumulative impacts on geology and soils would result from projects that combine to create g eologic
hazards, including unstable geologic conditions, or substantially contribute to coastal erosion. Most geology and
soil hazards associated with development on surrounding projects would be site -specific and can be mitigated
on a project-by-project basis. Such hazards include direct or indirect substantial adverse effects to cause rupture
of an earthquake fault, liquefaction, landslides, unstable geologic units, and expansive soils. Individual project
mitigation for these hazards would ensure that the re are no residual cumulative impacts. Proper engineering
design, utilization of standard construction practices, adherence to the erosion control standards established by
the City’s Grading Ordinance, implementation of best management practices (BMPs) req uired by the Stormwater
Pollution Prevention Plan (SWPPP), and implementation of the recommendations found in the Geotechnical
Investigation Report (Appendix G) would ensure that the potential for geological impacts resulting from the project
would be less than significant. Since geologic hazards are site-specific and not cumulative in nature, the
proposed project would not have a cumulatively considerable impact to geologic hazards.
In addition, the potential for impacting paleontological resources vary from site to site and are dependent on
specific excavation requirements for each project. As discussed in Section 5.6, the proposed project has a high
potential to produce paleontological resources during planned construction activities. Thus, the project shall
implement MM-GEO-1 to reduce potential impacts in the event paleontological resources are uncovered during
construction activities. Incorporation of mitigation would ensure proper handling and recordation of any
paleontological resources encountered, and all cumulative projects with potential to encounter paleontological
resources would be subject to similar requirements. Therefore, the project would not result in a cumulatively
considerable impact to paleontological resources.
6.4.7 Greenhouse Gas Emissions
Greenhouse gas (GHG) emissions and their contribution to climate change are widely recognized as a global
problem, and California has acknowledged this phenomenon as a state concern. As such, the analysis of the
proposed project’s impacts to climate change is cumulative in nature. Therefore, the information and analysis
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provided in Section 5.7, Greenhouse Gas Emissions, to determine project-level impacts, applies here and the
project’s contribution to global climate change would not be cumulatively considerable.
As discussed in Section 5.7, using the estimated operational plus amortized construction emissions of 7,860 MT
CO2e and service population (SP) of 2,321, the project would have a GHG efficiency metric of 3.39 MT CO2e per SP.
The project’s efficiency metric would exceed the significance threshold efficiency metric of 1.37 MT CO 2e per SP.
Therefore, impacts related to GHG emissions associated with the project would be potentially significant. MM-
GHG-1, outlined in Section 5.7.5, would be implemented and would minimize GHG emissions associated with
project operations. However, approximately 75% of the proposed project’s annual GHG emissions are from mobile
sources; therefore, to reduce GHG emissions to a less-than-significant level, the project would need to reduce its total
GHG emissions by approximately 76% to reduce the project-generated GHG emissions below the City’s efficiency
threshold. Because the project’s SP-based emissions would be more than the City’s efficiency metric of 1.37 MT
CO2e per SP, potential GHG emissions impacts associated with exceedance of the City’s efficiency metric would be
considered significant and unavoidable. Therefore, because the proposed project’s impacts to climate change is
cumulative in nature, the proposed project would result in a significant and unavoidable cumulative impact to GHGs.
6.4.8 Hazards and Hazardous Materials
Cumulative impacts related to hazards and hazardous materials would result from projects that combine to increase
exposure to hazards and hazardous materials. As discussed in Section 5.8, Hazards and Hazardous Materials, the
proposed project would have less-than-significant impacts related to hazardous materials. Past, current, and
reasonably foreseeable commercial projects in the region would result in the use and transport of incrementa lly
more oils, greases, and petroleum products for operation purposes. Although these could be subject to accidental
spillage, there is no quantifiable cumulative effect, since accidents are indiscriminate events, not related or
contributory to one another. Provided that individual projects adhere to current laws governing storage,
transportation, and handling of hazardous materials, no significant cumulative hazards or threats to human health
and safety are anticipated. In addition, although soil vapor attributable to the adjoining Otay Class III landfill is
present on site, methane was not detected in soils samples on-site indicating that the landfill gas control system
(LFGCS), installed and operated by the landfill owner, is effectively controlling the m igration of methane from the
adjoining Class III landfill. Potential soil contamination associated with cumulative projects listed in Table 6-2 could
create a hazard to public health during grading and excavation. However, cumulative projects listed in Table 6-2
would be required to analyze soils and mitigate any potentially significant hazards. Therefore, the proposed project’s
impact would not be cumulatively considerable.
In addition, as discussed in Section 5.8 and 5.17, the project could result in an impact related to exacerbating wildfire
risk that exposes project occupants to pollutant concentrations from a wildfire or the uncontrollable spread of a
wildfire if it would increase the risk of a wildfire occurring and the climatic, topographic, vegetation, weather
conditions, and other factors that aid in increasing the severity of such an occurrence. The project site is within a
wildland urban interface (WUI) location that is in an area statutorily designated a Local Respon sibility Area (LRA)
Non-Fire Hazard Severity Zone (FHSZ) by the City and California Department of Forestry and Fire Protection (CAL
FIRE). The project site is within a Supplemental Fire Hazard Zone as designated by the City. In addition, project site
is designated as a High Hazard area (City of Chula Vista 2005). However, the proposed project would be required
to comply with the CVMC, the California Fire Code, and the requirements of the Fire Protection Plan (FPP) prepared
for the proposed project, including implementation of Fire Management Zones (FMZs) (Appendix H3). However, due
to site constraints, it is not feasible to achieve a 100-foot FMZ width on the south side of the project site. Therefore,
MM-WF-1 would be incorporated, only to the walls of the structures that face the open space areas adjacent to the
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project site, to ensure impacts would be less than significant. Cumulative projects would also be required to
implement similar fire safety features and structure protection features to reduce impacts. Preparation of FPPs
would further reduce cumulative project impacts. Therefore, through compliance with existing regulations
associated with wildland fires, impacts associated with wildfire would not be cumulatively considerable.
6.4.9 Hydrology and Water Quality
Cumulative hydrology impacts also result from projects combining to alter the course of surface water flow or to
increase flood hazards in a particular area, either through diverting floodways or constructing structures within the
floodways. Cumulative water quality impacts result from projects that combine to either pollute or increase the
turbidity of water. As stated in Section 5.9, Hydrology and Water Quality, during construction and operation, the
proposed project has the potential to violate water quality standards. However, compliance with the Chula Vista
Storm Water Management and Discharge Control Ordinance, the City of Chula Vista Subdivision Manual, Design
and Construction Standards of the City of Chula Vista, as well as the preparat ion of site-specific Storm Water
Stormwater Quality Management Plan (SWQMP) and Drainage Study (Appendices I1 and I2), impacts would remain
below a level of significance. Furthermore, because all surrounding projects are regulated under the same City and
Regional Water Quality Control Board standards, they too would be required to attenuate all drainage on site (to
maintain pre development flow quantities) and to incorporate hydrology and water quality design features to prevent
cumulative impacts to local drainage systems or water quality. Therefore, the proposed project would not contribute
to a cumulatively considerable impact related to hydrology and water quality.
6.4.10 Land Use and Planning
Significant adverse cumulative land use impacts would result from projects that contribute to development that is
inconsistent with applicable plans or incompatible with existing or planned uses or planned addition of incompatible uses.
As described in Section 5.10, Land Use and Planning, the proposed project would not physically divide an
established community. In addition, with incorporation of mitigation measures MM-GHG-1, MM-CUL-1, MM-GEO-1,
and MM-WF-1, the proposed project would be consistent with the City’s General Plan. In addition, the proposed
project wou ld not conflict with the goals and objectives of the GDP. Further, upon approval, the proposed
project would not conflict with the land use designations of the GDP and SPA Plan because these plans would
be amended concurrently with approval of the proposed project, to allow for the proposed land uses. The
proposed project would also be consistent with the Parkland Dedication Ordinance and Parks and Recreation
Master Plan. With notification of the Federal Aviation Administration (FAA), the proposed project would comply with
the Brown Field Airport Land Use Compatibility Plan (ALUCP). Lastly, as discussed in Section 5.3 and Section 5.10,
the proposed project would not result in conflicts with the City’s MSCP Subarea Plan through compliance with
the MSCP BLA functional equivalency and future facility criteria.
The cumulative projects listed in Table 6-2 would all include similar project features, design standards, and balance
of land uses. Additionally, all cumulative projects would be subject to similar criteria as the proposed project, which
would ensure compliance with existing applicable land use plans with jurisdiction over the project site. Analysis of
individual projects as they are submitted to the City will ensure compatibility with applicable plans and policies.
Since all current and future projects would be analyzed for compatibility and compliance with land use regulations,
the proposed project would not result in a cumulatively considerable impact.
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6.4.11 Noise
Potential cumulative impacts on noise would result when projects combine to generate noise levels in excess of
the City of Chula Vista Ordinance standards, either during construction or operation. As discussed in Section
5.11, typical construction noise during allowable daytime hours would not exceed the Federal Transit
Administration (FTA) guidance-based standard. Thus, temporary construction-related noise impacts associated
with the project would be less than significant. Similarly, project-specific noise impacts during operations would
be less than significant.
Noise effects of the project would, for the most part, be confined to the project site and were evaluated on a project-
specific basis. Long-term on-site activities associated with the project would not have a regional effect upon
community noise levels (see Section 5.11), and therefore need not be considered in combination with approved or
proposed projects in the region. The one exception is the project’s contribution to traffic-related noise levels, which
would extend beyond the site boundaries, and must be considered in the context of proposed projects in the region.
However, as discussed in Section 5.11.3, the proposed project’s impact to off-site traffic noise increases would be
less than significant. Thus, the project’s contribution to cumulatively significant noise impacts would not be
cumulatively considerable.
6.4.12 Population and Housing
As discussed in Section 5.12, Population and Housing, the proposed project would introduce an estimated 2,314.83
persons to the project site (rounded to 2,315). The proposed residential development was originally identified to be
developed as Industrial Park in the GDP and SPA Plan . As such, the change in land use from Industrial Park to
Medium-High and High Residential would be considered unplanned population growth in excess of the original
estimates in the GDP and SPA Plan. Although this population growth would be considered unplanned, the proposed
project would only represent 5.9 percent of forecasted population growth and 6 percent of forecasted housing
growth between 2020 and 2035, based on SANDAG’s Series 13 forecast. Additionally, development of an Industrial
Park would directly result in some amount of population growth within the City due to new employment in the area.
Further, the proposed project would satisfy its affordable housing obligations via a Balanced Communities Affordable
Housing Agreement between the project Applicant and the City. This Balanced Communities Affordable Housing
Agreement will document satisfaction with affordable housing requirements which would help the City fulfill both
deficits from past 5th Cycle allocations and projections for current 6th Cycle allocations for low income housing.
While the proposed project would directly contribute to population growth in the area as compared to existing
conditions, the population inducement resulting from the proposed project would not be considered substantial.
Impacts would be less than significant.
Various cumulative projects listed in Table 6-2 would either directly or indirectly induce population growth. The
majority of the cumulative projects listed in Table 6-2 involve residential and development projects that may
increase population growth in the surrounding area. However, the introduction of a new population is not, in and of
itself, a significant impact. Although projects included in Table 6-2 would contribute to population growth, many of
these project sites have been previously slated for development, similar to the proposed project, and thus these
increases in population have largely been accounted for in appropriate planning documents. In addition, these
projects would be required to provide affordable housing units, which would help the City fulfill deficits of 5 th and
6th cycle low income housing allocations. Therefore, cumulative impacts to population and housing would not be
cumulatively significant.
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6.4.13 Public Services
Cumulative impacts on public services, including fire and police protection, parks, schools, and libraries, would
result when projects combine to increase demand on services such that additional services must be constructed
or provided. This would usually result from the incremental addition of people occupying an area or the incremental
construction of new or larger buildings requiring public services provision. As discussed in Section 5.13, with
implementation of MM-PS-1, which requires payment of a Public Facilities Development Impact Fee (PFDIF) and
implementation of existing Community Facilities Districts (CFDs), impacts to fire and police protection, schools, and
libraries would be less than significant. In addition, MM-PS-2, which requires payment of Development Impact Fees
(DIFs) pursuant to SB 50/Government Code Section 65995 and implementation of existing CFDs, would be required
to further reduce impacts to the schools to less than significant. Lastly, MM-PS-3, which requires payment of the
Park Benefit Fee, equal to the City’s Park Acquisition and Development (PAD) Fee Update pursuant to CVMC Section
17.10, would be implemented to reduce potentially significant impacts to public parks. Cumulative projects
included in Table 6-2 would be required to implement similar mitigation and payment of associated fees prior to
the issuance of each building permit. Therefore, through compliance with appropriate mitigation, cumulative
impacts related to public services would be less than significant.
6.4.14 Recreation
As discussed in Section 5.14, the proposed project would pay the appropriate development fees to offset potential
impacts to recreational facilities and parkland. A Community Benefit Agreement between the City and the Applicant
stipulates that the Applicant shall pay the City a Park Benefit Fee, equal to the Park Acquisition and Development
(PAD) fee that would have been due pursuant to CVMC Section 17.10, of approximately $11.03 million based on
2019 PAD fees, which may be revised by the City from time to time (MM-PS-3). Payment of the Park Benefit Fee
would fund parkland acquisition and construction, as determined by the City. Adverse physical effects resulting
from the construction of recreational facilities as addressed throughout this EIR as part of the proposed project and
with incorporation of proposed mitigation measures impacts would be less than significant. It is anticipated that all
cumulative projects included in Table 6-2 would be required to implement similar mitigation and payment of
associated fees prior to the issuance of each building permit. Therefore, through compliance with appropriate
mitigation, cumulative impacts related to recreation would be less than significant.
6.4.15 Transportation
As discussed in Section 5.15, the project would not conflict with a program, plan, ordinance or policy addressing the
circulation system, including transit, roadway, bicycle and pedestrian facilities. In addition, the proposed project would
be required to implement PDF-TRA-1 (see Section 4.4.8) in order to ensure consistency with CEQA Guidelines section
15064.3, subdivision (b). PDF-TRA-1 would include various strategies to reduce automobile trips, such as ride share
coordination services, on-site transit opportunities information, and bicycle use encouragement. With implementation of
PDF-TRA-1, impacts would be less than significant. It is anticipated that all cumulative projects included in Table 6-2
would be required to implement similar mitigation or design features to reduce or avoid potential impacts.
In addition, as discussed in Section 5.15, the project would not substantially increase hazards due to a geometric
design feature or incompatible use and would not result in inadequate emergency access. It is anticipated that
cumulative projects included in Table 6-2 would implement access and circulation features that would ensure
projects would not result in an increase in hazards or inadequate emergency access. Therefore, cumulative impacts
related to transportation would be less than significant.
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6.4.16 Utilities and Service Systems
Cumulative impacts to utilities and services systems would result when projects combine to increase demand for utilities
and service systems such that additional facilities must be provided or expanded. This would usually result from the
incremental addition of people occupying an area or the incremental construction of new or larger buildings requiring public
services provision. As discussed in Section 5.16, with implementation of utility infrastructure associated with the project,
the proposed project would not result in relocation or construction of new or expanded water, wastewater treatment, or
storm water drainage, electric power, natural gas, or telecommunications facilities or expansion of existing facilities.
Although water demand would increase with implementation of the proposed project, water supplies are available to provide
a reliable local water source to the project during normal, dry, and multiple dry years. In addition, adequate wastewater
treatment would be available to serve the proposed project. Lastly, solid waste generated under the proposed project would
not exceed state or local standards, or capacity of local infrastructure. Cumulative projects would be required to perform
similar analyses, in accordance with CEQA, to ensure projects would have sufficient utilities. The SPA Plans implemented in
the City, including the proposed project, include development standards that would apply to future build-out of the planning
area and specifically include development elements and/or policies and measures to ensure that adequate utilities and
service systems such as water and wastewater are provided in conjunction with buildout of the proposed and cumulative
projects. Specific to water, each SPA Plan is required to prepare a water conservation plan to minimize use of water.
Total permitted capacity at the Otay Landfill is approximately 62.4 million cubic yards, and the landfill has a remaining
capacity of 53%, or 33.1 million cubic yards. The 2005 General Plan Update EIR (City of Chula Vista 2005) concluded
that there is sufficient capacity within the Otay Landfill to accommodate project solid waste generated and anticipated
under the General Plan Update. The Otay Landfill is scheduled to close in 2030; however, under the current franchise
agreement between the City of Chula Vista and Republic Services, solid waste would be disposed of at the Sycamore
Landfill once the Otay Landfill meets its permitted capacity and terminates solid waste services (City of Chula Vista 2012).
As such, solid waste service would continue following closure of the Otay Landfill and permitted capacity would be
available to accommodate the proposed project and cumulative projects. Waste collection for proposed and planned
land uses would be provided by the City under its contract agreement with Republic Services. The waste collection
procedures and programs for the proposed and cumulative projects would be required to comply with the municipal
requirements for recycling and collection of solid waste, including provision for litter control for public events. The
proposed and cumulative projects would be required to comply with all applicable statutes and regulations and therefore
would not have cumulatively considerable impacts with respect to solid waste collection and management.
6.4.17 Wildfire
With regard to wildfire hazards, as discussed in Section 5.17, the project site is located within a wildland-urban interface
(WUI) location that is in an area statutorily designated LRA FHSZ by the City and CAL FIRE (CAL FIRE 2009). While the project
site is not designated as a FHSV by CALFIRE, the General Plan has identified fire hazard zones (FHZ) within the City to
acknowledge areas that are potentially susceptible to wildfire. As such, the General Plan designates the project site as a
High Hazard area which suggests the area may contain substantial fire risk and hazards (City of Chula Vista 2005). However,
with implementation of MM-WF-1, impacts associated with wildfire risk would be less than significant. In addition, the project
would be required to comply with CVMC requirements and the Fire Protection Plan (FPP) prepared for the project (Appendix
H3). All cumulative projects within the WUI would be required to meet minimum fire fuel modification and/or clearing
requirements in addition to meeting the standards of the various fire codes in effect at the time of building permit issuance.
Cumulative projects would also be required to prepare FPPs, to evaluate and identify potential fire risks associated with the
project. As such, through compliance with existing regulations and similar project design features, as applicable, cumulative
impacts to wildfire would not be cumulatively considerable.
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City of Chula Vista
Cumulative Projects
1 - University Villages
2 - Eastern Urban Center
3 - Village 4 South Residential
4 - Planning Area 12 Freeway Commercial
5 - Village 2
6 - Village 8 West
7 - Village 9
8 - Eastlake Behavioral Health Hospital
FIGURE 6-1
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7 Growth Inducement
Section 15126.2(d) of the California Environmental Quality Act (CEQA) Guidelines mandates that the growth-
inducing nature of a proposed project be discussed. This CEQA Guideline states that the growth inducing analysis
is intended to address the potential for the project to “foster economic or population growth, or the construction
of additional housing, either directly or indire ctly, in the surrounding environment.” Further, the CEQA Appendix
G Checklist (Population and Housing) mandates that a CEQA document address a project’s likelihood to induce
substantial population growth in an area, either directly (for example, by proposi ng new homes or businesses) or
indirectly (for example, through extension of roads or other infrastructure).
A project may be distinguished as either facilitating planned growth or inducing unplanned growth. Facilitating
growth relates to the establishment of direct employment, population, or housing growth that would occur within a
project site. Inducing growth is related to lowering or removing barriers to growth or by creating an amenity or facility
that attracts new population/economic activity. For purposes of this EIR analysis, a significant growth-inducement
impact would occur if the project, and all associated infrastructure improvements, directly or indirectly removes
obstacles to growth such that the induced growth would significantly burden existing community services or the
environment, or cause a demand for a General Plan Amendment.
This chapter contains a discussion of the growth -inducing factors related to the proposed Sunbow Sectional
Planning Area Plan Amendment for the Sunbow II, Phase 3 Pr oject (project) and as defined under CEQA
Guidelines Section 15162.2(d). A project is defined as growth inducing when it directly or indirectly:
1. Fosters population growth;
2. Fosters economic growth;
3. Includes the construction of additional housing in the surrounding environment;
4. Removes obstacles to population growth;
5. Taxes existing community service facilities, requiring construction of new facilities that could cause
significant environmental effects; and/or
6. Encourages or facilitates other activities that could significantly affect the environment, either individually
or cumulatively.
It must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to
the environment.
7.1 Growth Inducement Due to Population Growth
As discussed in Section 5.12, Population and Housing, t he proposed project would directly contribute to
population growth in the City of Chula Vista (City). The proposed project would develop 718 multi-family
residential units composed of medium -high- and high-density units. The proposed project would directly
contribute to population growth in the area through the development of these dwelling units . Based on SANDAG’s
Series 13 forecast, the interpolated persons per household ratio in 2028 is 3.224. Thus, the proposed project would
result in 2,314.83 persons (rounded to 2,315) (Appendix F). Through existing Sunbow General Development Plan
(GDP) planning efforts, the project area was originally identified to be developed as Industrial Park and Open
Space . As such, the proposed project would result in unplanned population growth due to the change in land use
from Industrial Park to Medium-High and High residential. However, development of an Industrial Park would directly
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result in some amount of population growth within the City due to new employment in the area (i.e. relocation of
employees to the area). Based on the SANDAG Series 13 growth forecast, employment density1 in the City in 2035 is
anticipated to be 17.5 jobs per developed employment acre (SANDAG 2013). At this rate, a project consistent with the
existing Industrial Park land use would result in approximately 957 employees in 2035, some percentage of which
would move to the area resulting in population growth. Although the proposed project would likely result in greater
population inducement, development under the existing Industrial Park land use was already anticipated to generate
population under the City’s growth projections.
The San Diego Forward: Regional Plan (SANDAG 2015) combines the region’s two most important existing
planning documents: the Regional Comprehensive Plan (RCP) and the Regional Transportation Plan and its
Sustainable Communities Strategy (RTP/SCS). The RCP, adopted in 2004, laid out key principles for managing
the region’s growth while preserving natural resources and limiting urban sprawl. The plan covers policy areas
including urban form, transportation, housing, hea lthy environment, economic prosperity, public facilities, our
borders, and social equity (SANDAG 2004). These policy areas were addressed in the 2050 Regional
Transportation Plan and its Sustainable Communities Strategy (2050 RTP/SCS) (SANDAG 2011) and are now
fully integrated into San Diego Forwa rd. As part of the regional planning effort for San Diego Forward, the San
Diego Association of Governments (SANDAG) solicited input from the City for projects that were in the planning
phases. Development on the p roject site under existing plans would be included in the growth forecasts
associated with San Diego Forward.
Furthermore, the City of Chula Vista Growth Management Program, outlined in the Chula Vista Municipal Code
Chapter 19.09, Growth Management, call s for directing growth in and around the City in an orderly fashion, to
avoid “leapfrog” development, to protect and preserve the City’s amenities, and to guide growth in a general west
to east direction. The proposed project fosters a development pattern that promotes orderly growth and prevents
urban sprawl by developing on a site surrounded by existing development and planned for development for
several decades. Refer to Section 5.12 for additional information.
7.2 Growth Inducement Due to Economic Growth
An increase in population would foster economic growth by increasing demand for regional and local goods and
services. It is expected that future residents would demand a variety of goods and services from the existing and
future commercial uses within the surrounding area. The proposed project would not provide services on site and
therefore would not generate direct employment opportunities for residents. The proposed project would relate
closely to the Sunbow SPA and greater East Planning Area, relying on these areas’ retail, employment
opportunities, and other services. As the project proposes development of 718 residences, a community purpose
facility, and designation of open space, the project is not expected to result in substantial growth inducement
associated with economic growth.
7.3 Growth Inducement Due to Additional Housing
As discussed in Section 5.12, t hrough previous GDP planning efforts, the project site was identified to be
developed as Industrial Park with no residential units. The proposed project would result in the development of
718 residential units on the project site which were not previously planned in the GDP or SPA Plan. As a result,
it is anticipated the proposed project would result in a population of 2,315 persons, based on SANDAG’s Series
1 Civilian jobs per developed employment acre (industrial, retail, office, schools, and half of mixed-use acres).
7– Growth Inducement
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13 forecast (Appendix F). However, although this additional housing would be considered unplanned, t he
proposed project would only represent approximately 5.9% of forecasted population growth and 6% of forecasted
housing growth between 2020 and 2035, based on SANDAG’s Series 13 forecast. Furthermore, the project would
include a variety of housing types. The project Applicant would be required to enter into a Balanced Community
Affordable Housing Agreement, a policy adopted to support the City’s Balanced Communities Policy in order to
increase the diversity of housing prices and rent throughout the communi ty and meet the City’s Regional Housing
Allocation requirements. As shown in Table 5.12-2 of Section 5.12, the City was 4,271 units under the RHNA
allocation for the 5th Cycle (2013 –2020) and specifically for Very Low to Moderate income levels. As shown in
Table 5.12-3 of Section 5.12 , the City also has a current RHNA allocation of 11,105 units for the 6th Cycle
(2021–2029), including 6,438 units for Extremely Low to Moderate income levels. Therefore, as a small
percentage of the City’s forecasted housing growth between 2020 and 2035, the addition of 718 units between
2024 and 2028 would provide balanced and diverse housing to the City and would provide housing to
accommodate the City’s future growth projections.
7.4 Growth Inducement Due to Removal of Obstacles
Improvements to transportation, utilities, and public service infrastructure as part of the proposed project would
accommodate the direct growth induced by the proposed project. These improvements would not open up new areas to
development because they would connect to existing transportation and utility infrastructure (including water and sewer)
adjacent to the project site on and within Olympic Parkway. Furthermore, these improvements would provide access and
utility service solely to the proposed project. Areas of the project site outside of the development area would also remain
open space and would be part of the City’s MSCP Preserve. Therefore, the project site would not be capable of supporting
future development due to these transportation and utility improvements.
The proposed project would also include a storm drain system which would be designed to address peak flows
and to integrate water quality features needed to comply with the City’s Standard Urban Stormwater Mitigation Plan
requirements for water quality. The proposed storm drain system would be designed to prevent the co-mingling of treated
flows with untreated runoff and would include two proposed detention and water quality basins within the northeast and
northwest portions of the development area to treat stormwater runoff. The proposed storm drain system would
accommodate the proposed project and would not be capable of supporting future growth or development.
Public services such as schools, and police and fire services would be provided by existing and planned surrounding
facilities. As discussed above and in Section 5.13, Public Services, payment of Public Facilities Development Impact Fees
would ensure the proposed project would not significantly impact public services and facilities. Additionally, as discussed
in Section 5.14, Recreation, the proposed project would pay Park Benefit Fees, equal to the City’s Park Acquisition and
Development Fee Update, to fulfill parkland obligation requirements for population induced by the proposed project and
ensure the proposed project would not significantly impact parks and recreational facilities.
Infrastructure would not provide surplus capacity that would allow for additional, unplanned development. Public
Facilities Financing Plans (PFFPs) are included with each SPA Plan to ensure that public utilities provided for the
project would be provided concurrently with development. The Supplemental PFFP prepared for the proposed
project provides a complete description of all public facilities included within the boundaries of the SPA Plan
area, including phasing and financing of infrastructure. The proposed project would not provide surplus
infrastructure capacity that would induce growth in surrounding areas, but would, rather, help accommodate the
continued population influx in eastern Chula Vista over the next several decades. Therefore, the proposed project
would not result in growth inducement due to the removal of obstacles.
7– Growth Inducement
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7.5 Taxation of Existing Public Facilities and Services
As described in Section 5.12, the proposed project would comply with the City of Chula Vista Growth Management
Ordinance (GMO) and established “quality of life” threshold standards. The Growth Management Oversight
Commission is charged with reviewing the GMO annually to ensure compliance and make recommendations, as
necessary. The GMO requires PFFPs for every SPA Plan. A Supplemental PFFP is required in conjunction with the
preparation of a SPA Plan Amendment to ensure that development of the proposed project is consistent with the
overall goals and policies of the General Plan and would not degrade public services. The PFFP provides a
complete description of all public facilities included within the bound aries of the SPA Plan area, including phasing
and financing of infrastructure. The PFFPs ensure that development of the SPA Plan would not adversely impact
the City’s quality of life standards by requiring public facilities and services to be provided concurrent with
demand. Therefore, compliance with the regulations listed above would ensure that development of the
proposed project would not tax existing public facilities and services.
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8 Significant Irreversible
Environmental Changes
The California Environmental Quality Act (CEQA) Guidelines Section 15126.2(c) indicates the following:
[U]ses of non-renewable resources during the initial and continued phases of the project may be
irreversible since a large commitment of such resources makes removal or non-use thereafter
unlikely. Primary impacts and, particularly, secondary impacts (such as highway improvement
which provides access to a previously inaccessible area) generally commit future generations to
similar uses. Also irreversible damage can result from environmental accidents associated with the
project. Irretrievable commitments of resources should be evaluated to assure that such current
consumption is justified.
Implementation of the proposed Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II, Phase
3 Project (project or proposed project) would involve consumption of limited, slowly renewable, and non-renewable
resources. This consumption would occur during the construction phase of the project and would continue
throughout its operational lifetime. The project would require a commitment of resources that would include (1)
building materials, (2) fuel and operational materials/resources, and (3) the transportation of goods and people to
and from the project site.
Construction of the project would require the consumption of resources that are not renewable or that may renew
so slowly as to be considered non-renewable. These resources would include the following construction supplies:
certain types of lumber and other forest products; aggregate materials used in concrete and asphalt such as sand,
gravel, and stone; metals such as steel, copper, and lead; petrochemical construction materials such as plastics;
water; and fossil fuels such as gasoline and oil.
The resources that would be committed during operation of the project would include water for drinking and bathing,
and fossil fuels for electricity, natural gas, and transportation. Section 5.7.5 outlines a mitigation measure which
would include greenhouse gas emission reduction measures that would reduce consumption of fossil fuels such as
gasoline and oil during construction and operational activities. Additionally, Section 4.4.8 includes a transportation
project design feature that provides strategies to reduce the number of automobile trips generated by residents of
the project. However, while implementation of the mitigation measure and project design feature would reduce the
use of non-renewable resources, fossil fuels would represent the primary energy source associated with
construction and ongoing operation of the project, and the existing, finite supplies of these natural resources would
be incrementally reduced. Additionally, the project includes a Water Conservation Plan (Appendix L3) that includes
mandatory water reduction measures.
Additionally, the project would involve an unquantifiable, but limited, use of potentially hazardous materials typical
of residential uses, including cleaning solvents, and fertilizers and pesticides for landscaping. These materials
would be contained, stored, and used on site in accordance with manufacturers’ instructions, and applicable
standards and regulations. Compliance with regulations would serve to protect against a significant and irreversible
environmental change that could result from the accidental release of hazardous materials.
Furthermore, the project would result in the permanent commitment of land to the proposed project. The project
would result in direct permanent impacts to sensitive vegetation communities/habitats consisting of native
grassland, Diegan coastal sage scrub, and non‐native grassland habitats. Permanent project impacts consist of
8 – Significant Irreversible Environmental Changes
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vegetation clearing, grading, and residential development including houses, a private recreation facility, fuel
modification zone activities, detention basins, and roadways. Permanent impacts to these sensitive upland
habitats, as well as sensitive plant species and habitats, would be considered potentially significant under CEQA
and require implementation of mitigation measures outlined in Section 5.3.5. These mitigation measures would be
consistent with the City of Chula Vista Multiple Species Conservation Program Subarea Plan and the Habitat Loss
and Incidental Take Ordinance and would reduce impacts to a level below significance.
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9 Effects Found Not to Be Significant
Section 15128 of the California Environmental Quality Act (CEQA) Guidelines requires that an environmental impact
report (EIR) briefly describe potential environmental effects that were determined not to be significant and therefore
were not discussed in detail in the EIR. The environmental issues discussed below are not considered significant
for the proposed Sunbow Sectional Planning Area (SPA) Plan Amendment for the Sunbow II, Phase 3 Project (project
or proposed project), and the reasons for the conclusion of non-significance are discussed below.
9.1 Agriculture and Forestry Resources
Under existing conditions, the project site is vacant, undeveloped land containing a variety of grasses, shrubs, and
trees. According to the Department of Conservation’s California Important Farmland Finder, the project site is
designated as Farmland of Local Importance on the northern boundary and eastern portion, Grazing Land within
the western portion and slightly within the southeastern corner, and Urban and Built-Up Land within small sections
in the northwestern and southeastern corners (DOC 2016). In total, the project site contains 72.97-acres of
Farmland of Local Importance, 62.61-acres of Grazing Land and 0.14-acres of Urban and Built-Up Land. Farmland
of Local Importance is considered land important to the local agricultural economy. Grazing land consists of existing
vegetation that is suited to the grazing of livestock. And lastly, Urban and Built-Up Land is defined as vacant and
nonagricultural land which is surrounded on all sides by development and is less than 40 -acres in size. While the
project site is predominantly designated as Farmland of Local Importance and Grazing Land, the project site is
currently zoned under the Sunbow Sectional Planning Area (SPA) Plan as open space preserve, open space, and
limited industrial. Further, the SPA Plan does not identify current agricultural use within the project site.
Furthermore, as discussed in the Phase I Environmental Site Assessment (ESA) prepared for the project (Appendix
G1), aerial images of the project site show that the project site remained undeveloped from as early as 1943. While
the aerial images of the area surrounding the project site identified former agriculture use south of the project site,
the aerials did not reveal any previous agricultural use on the project site itself. However, despite the lack of agriculture
use shown in aerials in the Phase I ESA (Appendix G1), due to proximity to the agricultural use shown in the aerial
images of the surrounding area, the project site may have potentially been used as grazing land for animals.
The proposed project is primarily a residential project with associated infrastructure and open space areas.
Development would be centered within the southeastern portion of the site. The approximately 67.5-acre
development area would be composed of 44.2 acres of residential uses, a 0.9-acre Community Purpose Facility
(CPF), 5.9 acres of public streets, and 16.5 acres of manufactured slopes and basins. The project also includes
63.6 acres of MSCP Preserve area, 4.3 acres of Poggi Creek Conservation Easements and a 0.3 -acre wetland
avoidance area. As part of proposed discretionary actions, the project would include rezoning and General Plan and
SPA Plan amendments. Thus, upon approval of these amendments and rezone, the proposed project would be
consistent with the land use designation and zoning of the project site. Additionally, the project site has been slated
for development since the adoption of the Sunbow General Development Plan on December 5, 1989 and is not
planned to be utilized for agriculture use. Furthermore, approximately 63.6 acres designated Multiple Species
Conservation Program (MSCP) Preserve located within the project site would be permanently preserved. As such,
because the project site is not currently used for agriculture, has been planned for development since 1989, and
would propose to preserve 63.6 acres as MSCP Preserve, impacts to agriculture and forestry resources would be
less than significant.
9 – Effects Found Not to Be Significant
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9.2 Mineral Resources
The Surface Mining and Reclamation Act of 1975 (SMARA) includes requirements and programs to ensure the long-
term availability of mineral resources and that the significant adverse environmental impacts of surface mining are
adequately mitigated. As mandated by the Surface Mining and Reclamation Act of 1975, aggregate mineral
resources within the state are classified by the State Mining and Geology Board through application of the Mineral
Resource Zone (MRZ) system. The MRZ system is used to map all mineral commodities within identified
jurisdictional boundaries, with priority given to areas where future mineral resource extraction may be prevented or
restricted by land use compatibility issues, or where mineral resources may be mined during the 50-year period
following their classification. The MRZ system classifies lands that contain mineral deposits and identifies the
presence or absence of substantial sand and gravel deposits and crushed rock source areas (i.e., commodities
used as, or in the production of, construction materials). The state geologist classifies MRZs within a region based
on the following factors:
MRZ-1: Areas where adequate information indicates that no significant mineral deposits are present, or where
it is judged that little likelihood exists for their presence.
MRZ-2: Areas where adequate information indicates that significant mineral deposits are present or where it
is judged that a high likelihood for their presence exists.
MRZ-3: Areas containing mineral deposits for which the significance cannot be determined from available data.
MRZ-4: Areas where geologic information does not rule out either the presence or absence of mineral resources.
According to a map obtained through the San Diego Association of Governments (SANDAG), the project site is located within
an MRZ-3 zone, meaning that mineral resources cannot be determined from available data (SANDAG n.d.).
As discussed in the General Plan, Environmental Element, portions of the Otay River Valley are identified as an MRZ-2
area (City of Chula Vista 2005). Additionally, two other MRZ-2 areas are located on and just outside the General Plan
area: one in the Sweetwater River Valley east of the Sweetwater Reservoir; and the other along the Jamul/Dulzura Creek
east of Lower Otay Lake (City of Chula Vista 2005). However, the project site is located outside of the “Regionally
Significant” MRZ-2 Aggregate Resource Areas (SANDAG n.d.). Additionally, the project would not be designated for
extractive uses, but rather for residential and open space. More specifically, approximately 63.6 acres of the project site
would be designated for MSCP Preserve and remain undeveloped. Thus, the City would not permit or plan for mining
operations as future use in these areas. Therefore, no impacts to mineral resources would occur.
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10 Alternatives
10.1 Introduction
Pursuant to the California Environmental Quality Act (CEQA) Guidelines, environmental impact reports (EIRs) are
required to “describe a range of reasonable alternatives to the project, or to the location of the project, which would
feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the
significant effects of the project, and evaluate the comparative merits of the alternatives” (14 CCR 15126.6(a)).
This EIR “must consider a reasonable range of potentially feasible alternatives that will foster informed decision
making and public participation” (14 CCR 15126.6(a)). The alternatives discussion is required even if these
alternatives “would impede to some degree the attainment of the project objectives, or would be more costly” (14
CCR 15126.6(b)).
The inclusion of an alternative in an EIR does not constitute definitive evidence that the alternative is in fact
“feasible.” The final decision regarding the feasibility of alternatives lies with the decision maker for a given project
who must make the necessary findings addressing the potential feasibility of reducing the severity of significant
environmental effects (California Public Resources Code, Section 21081; see also 14 CCR 15091).
10.2 Project Objectives
Following are the objectives of the proposed Sunbow Sectional Planning Area (SPA) Plan Amendment for the
Sunbow II, Phase 3 Project (project or proposed project):
1. Develop a pedestrian-oriented community on an under-utilized site with a range of residential uses, open
space and MSCP Preserve areas, and recreational opportunities, which are compatible with the a djacent
established residential communities.
2. Contribute to the growing housing needs of the City and region by providing for multi-family housing units
with a range of housing types to accommodate a spectrum of demographics.
3. Preserve portions of the project site as permanent open space and increase the MSCP Preserve Areas.
4. Provide pedestrian and bicycle facilities, including a pedestrian connection to the Chula Vista Regional Trail
and connections to bike lanes within Olympic Parkway and nearby transit.
5. Implement the goals, objectives, and policies of the Chula Vista General Plan; the MSCP Subarea Plan; the
Sunbow GDP; and the Sunbow SPA Plan.
6. Implement the City of Chula Vista’s Growth Management Ordinance to ensure that public and community
facilities, such as transportation, water, flood control, sewage disposal, schools and parks, are provided in a
timely manner and financed by the parties creating the demand for, and benefiting from, the improvements.
7. Ensure new uses are compatible with the existing community by establishing setbacks, design regulations and
guidelines, best practices, and performance standards that enhance quality of life for neighboring properties.
8. Create a land use plan that can realistically be developed within a foreseeable time frame and under
projected economic conditions.
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10.3 Alternatives Considered but Rejected
State CEQA Guidelines Section 15126.6(c) provides guidance in selecting a range of reasonable alternatives for the
project. The EIR should also identify any alternatives that were considered by the lead agency, but were rejected during
the planning or scoping process and briefly explain the reasons underlying the lead agency’s determination. Among
the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet
most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental impacts. State
CEQA Guidelines Section 15126.6(c) provides the following guidance in selecting a range of reasonable alternatives
for the project. There are many factors that may be taken into account when addressing the feasibility of range of
potential alternatives for the project, such as site suitability, economic viability, availability of infrastructure, general
plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can
reasonably acquire, control or otherwise have access to the alternative site (or the site is already owned by the
proponent). The alternatives discussion shall include those that could feasibly accomplish most of the basic objectives
of the project, and could avoid or substantially lessen one or more of the significant effects.
The EIR need not discuss every alternative to the project. A range of alternatives that are “reasonable” for analysis have
been evaluated and are discussed below in Section 4.4, Alternatives Under Consideration. The following describes other
alternatives considered by the City but dismissed from further evaluation in this EIR, and a brief description of the reasons
for their rejection.
Alternative Location
Pursuant to Section 15126.6(f)(2) of the CEQA Guidelines, the City considered the potential for alternative locations
to the project. There are sites within the City of an approximately equivalent size to the project site that could be
redeveloped with a residential project; however, the project applicant does not control another site within the City
of comparable land area that is available for development of the proposed project. One of the factors for feasibility
of an alternative is “whether the proponent can reasonably acquire, control or otherwise have access to the
alternative site.” Because the City is highly urbanized and is largely built out, obtaining another site of a similar size
in a similar location is not considered feasible. It should also be noted that the project site is surrounded on all
sides by development. As such, an alternative location was ultimately rejected from further analysis in the EIR.
10.4 Alternatives under Consideration
Section 15126.6 of the California Environmental Quality Act (CEQA) Guidelines states that the Environmental
Impact Report (EIR) shall “describe a range of reasonable alternatives to the project, or to the location of the project,
which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any
of the significant effects of the project, and evaluate the comparative merits of the alternatives.”
The range of alternatives evaluated in an EIR is governed by the “rule of reason” that requires the EIR set forth only
those alternatives necessary to permit a reasoned choice. An EIR need not consider an alternative whose effects
cannot be reasonably ascertained and whose implementation is remote and speculative [Section 15126.6(a) of
the CEQA Guidelines].
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In developing the alternatives to be addressed in this EIR, the potential alternatives were evaluated in terms of their
ability to meet the basic objectives of the project, while reducing or avoiding the environmental impacts of the
project identified in Section 5.0, Environmental Analysis, of the EIR.
In determining what alternatives should be considered in the EIR, it is important to acknowledge the objectives
of the project, the project’s significant effects, and unique project considerations. These fac tors are crucial to
the development of alternatives that meet the criteria specified in Section 15126.6(a). Although, as noted above,
EIRs must contain a discussion of “potentially feasible” alternatives, the ultimate determination as to whether
an alternative is feasible or infeasible is made by the lead agency’s decision ‐making body, the Chula Vista City
Council (see PRC Section 21081[a] [3].)
This chapter discusses alternatives to the proposed project, including the No Project/No Build Alternative. The No
Project/No Build Alternative is a required element of an EIR pursuant to Section 15126.6(e) of the CEQA Guidelines
that examines the environmental effects that would occur if the project were not to proceed. The alternatives
addressed in this chapter are listed below, followed by a more detailed discussion of each:
1. No Project/No Build Alternative
2. Existing Land Use Designations Alternative
3. Reduced Development Alternative
10.5 Alternatives Impact Summary
10.5.1 No Project/No Build Alternative
CEQA Guidelines Section 15126.6 requires the inclusion of a No Project/No Build Alternative to be analyzed. Under
the No Project/No Build Alternative, no development would occur on the project site. Accordingly, the site
characteristics of this alternate would be equivalent to the existing conditions for each category analyzed in Chapter
5, Environmental Impact Analysis, of this EIR. Although no development would occur, surrounding land uses in the
region would continue to be built out.
Comparison to Proposed Project
Aesthetics
The No Project/No Build Alternative would not result in any changes to the existing visual character, views, or lighting
and glare. The site would remain as vacant and undeveloped land. Although the proposed project would result in
less than significant impacts associated with aesthetics, no impacts would occur under the No Project/No Build
Alternative because no development would occur on the project site. Therefore, impacts would be reduced under
the No Project/No Build Alternative.
Air Quality
There would be no direct construction or operational air quality impacts associated with the No Project /No Build
Alternative since the site would remain in its current state and no construction would occur. Although the proposed
project would result in less than significant impacts associated with air quality, no impacts would occur under the
No Project/No Build Alternative because no development would occur on the project site. Therefore, impacts would
be reduced under the No Project/No Build Alternative.
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Biological Resources
The No Project/No Build Alternative would not result in any changes to the currently vacant and undeveloped project
site. The project site would remain designated as Open Space Preserve, Open Space, and Industrial Park. Although
the No Project/No Build Alternative would not require a Boundary Line Adjustment to the MSCP Preserve on
the project site , this alternative would result in less acreage of MSCP Preserve lands on the project site.
Additionally, the No Project/No Build Alternative would not result in any direct impacts to biological resources
as would occur with development of the proposed project since there would be no construction involved.
Therefore, impacts to biological resources would be reduced under the No Project/No Build Alternative.
Cultural and Tribal Cultural Resources
The No Project/No Build Alternative would not result in excavation of soils that may contain significant cultural or
tribal cultural resources; therefore, impacts to cultural and tribal cultural resources would be reduced under the No
Project/No Build Alternative.
Energy
The No Project/No Build Alternative would not result in the use of energy as no changes to the currently vacant and
undeveloped project site would occur. Although the proposed project would result in less than significant impacts
associated with energy, including the wasteful, inefficient, or unnecessary consumption of energy re sources, no
impacts would occur under the No Project/No Build Alterative because no energy consumption would occur.
Therefore, impacts would be reduced under the No Project/No Build Alternative.
Geology and Soils
The No Project/No Build Alternative would not result in any changes to the currently vacant and undeveloped project
site. Although the proposed project would result in less than significant impacts associated with geologic hazards ,
the No Project/No Build Alternative would not place people or structures on the project site so no impacts would
occur. Additionally, as compared to the proposed project, the No Project/No Build Alternative would not result in
excavation of soils that may contain significant paleontological resources. Therefore, impacts to geology and soils,
and specifically paleontological resources, would be reduced under the No Project/No Build Alternative.
Greenhouse Gas Emissions
There would be no direct construction or operational greenhouse gas emission impacts associated with the No
Project/No Build Alternative since the site would remain in its current state and no development would occur.
Significant and unavoidable impacts associated with greenhouse gas emissions would be avoided. Impacts
would be reduced under the No Project/No Build Alternative.
Hazards and Hazardous Materials
As no construction would occur, the No Project/No Build Alternative would not result in any potential impacts
associated with hazards or hazardous materials. Compared to the proposed project, the No Project/No Build
Alternative would not introduce future residents to potential hazards or hazardous materials during operation,
including wildfires, because no development would occur. Therefore, impacts to hazards, and specifically wildfire
hazards, would be reduced under the No Project/No Build Alternative.
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Hydrology and Water Quality
The No Project/No Build Alternative would not result in any direct impacts related to hydrology and water quality since
no construction would occur and there would be no increase in runoff from the site. No construction or development
activities would take place that could generate potential pollutants. Although the proposed project would result in less
than significant impacts associated with hydrology and water quality, no impacts would occur under the No Project/No
Build Alternative. Therefore, impacts would be reduced under the No Project/No Build Alternative.
Land Use and Planning
No changes to the existing zoning or land use designations would occur under the No Project/No B uild Alternative
as the project site would remain vacant and undeveloped. Although the proposed project would result in less than
significant impacts associated with land use and planning, no impacts would occur under the No Project/No Build
Alternative. Therefore, impacts would be reduced under the No Project/No Build Alternative.
Noise
The No Project/No Build Alternative would not result in any construction-related noise since no construction would
occur. The No Project/No Build Alternative would not contribute to an increase in ambient noise levels either as no
development would be introduced on the project site. Although the proposed project would result in less than
significant noise impacts, no impacts would occur under the No Project/No Build Alternative. Therefore, impacts
would be reduced under the No Project/No Build Alternative.
Population and Housing
No impacts related to population growth would occur under this alternative because no residential or economic
growth would occur and no infrastructure would be developed on the project site. Although the proposed project
would result in less than significant impacts associated with population and housing, no impacts would occur under
the No Project/No Build Alternative. Therefore, impacts would be reduced under the No Project/No Build Alternative.
Public Services
Under the No Project/No Build Alternative there would be no increase in demand for public services, as would occur under
the proposed project. Therefore, impacts to public services would be reduced under the No Project/No Build Alternative.
Recreation
Under the No Project/No Build Alternative there would be no increase in demand for parks and recreation facilities
or the development of new or expanded parks and recreation facilities . Impacts associated with recreation would
be reduced under the No Project/No Build Alternative.
Transportation
The No Project/No Build Alternative would not generate any new traffic that wo uld affect the local roadway
network or result in an increase in vehicle miles traveled (VMT). Although transportation impacts would be less
than significant under the proposed project, no transportation impacts would occur under the No Project/No
Build Alternative. Therefore, impacts would be reduced under the No Project/No Build Alternative.
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Utilities and Service Systems
Under the No Project/No Build Alternative, there would be no increase in demand for public utilities and service systems.
Therefore, impacts to public utilities and service systems would be reduced under the No Project/No Build Alternative.
Wildfire
As no construction would occur, the No Project/No Build Alternative would not result in any potential impacts
associated with wildfire hazards. Compared to the proposed project, the No Project/No Build Alternative would not
introduce future residents to potential wildfires hazards, because no development would occur. However, under
this alternative, the project site would remain in a natural state and more susceptible to potential wildfire compared
to the proposed project. Therefore, impacts associated with wildfire hazards would be similar under the No
Project/No Build Alternative.
Relation to Project Objectives
The No Project/No Build Alternative would not meet any of the project objectives.
10.5.2 Existing Land Use Designations Alternative
The Existing Land Use Designations Alternative would include the development consistent with the City’s General
Plan, Sunbow General Development Plan (GDP) and Sectional Planning Area (SPA) Plan. The City’s General Plan
designates the development area within the southeastern portion of the site as Research & Limited Industrial (see
Figure 3-1, Existing General Plan Land Use). The Sunbow GDP designated the 54.7 acres as Industrial Park to
include research/development and light industrial uses (see Figure 3-3, Existing General Development Plan Land
Use Designation), with approximately 700,000 square feet of leasable area generating approximately 2,800
employment opportunities; however, actual leasable area may be less than this approximation when accounting for
required infrastructure and amenities. Note, that the development areas under the existing land use designations
and the proposed project are different between the MSCP hardline, established after the approval of the Sunbow
GDP and SPA Plan. The rest of the project site would be preserved as Open Space and MSCP Preserve, similar to
the proposed project. It is anticipated that access would be provided via Olympic Parkway and internal circulation
on the project site would be similar to the proposed project. However, features such as pedestrian and bicycle
circulation, the Community Purpose Facility (CPF), and active and passive recreational open space areas, proposed
to be developed throughout the residential uses under the proposed project, would not be developed under the
Existing Land Use Designations Alternative.
Comparison to Proposed Project
Aesthetics
The Existing Land Use Designations Alternative would result in development of an industrial park within a similar
footprint as the proposed project. As discussed above, the industrial park footprint would be approximately 12.8
acres smaller than the proposed project’s development area. However, development of an industrial park would
introduce substantial bulk and scale associated with the 700,000 square feet of leasable area. The industrial park
in this alternative would be located in the same portion of the pro ject site as the development footprint of the
proposed project, which would be set back approximately 500 feet from Olympic Parkway. Additionally, this
alternative would be required to comply with applicable rules and regulations concerning lighting, glare, setbacks,
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landscaping, and others related to scenic quality. Similar to the proposed project, the Existing Land Use
Designations Alternative would introduce new sources of lighting and glare to a currently vacant and undeveloped
project site. Additionally, due to the same location of the project site, this alternative would not impact a scenic
vista or state scenic highway, same as with the proposed project. Therefore, the Existing Land Use Designations
Alternative would result in similar impacts as the proposed project with regard to aesthetics.
Air Quality
The Existing Land Use Designations Alternative would result in similar ground disturbing activities as the proposed project
due to the relatively similar development footprint. Although air quality emissions from electricity and natural gas usage
associated with residential uses are typically higher per dwelling unit than industrial uses, air quality emissions would
most likely increase due to mobile source emissions generated from an industrial land use. For instance, under this
alternative, a higher percentage of trips would be associated with the use of higher duty trucks, which would result in
higher emissions than passenger vehicles associated with residential development. In addition, it is anticipated that
heavy duty truck distances would usually be higher (up to 40 miles). Therefore, air quality impacts associated with the
Existing Land Use Designations Alternative would be increased compared to the proposed project.
Biological Resources
The Existing Land Use Designations Alternative would disturb less land than the proposed project due to the slightly
reduced development footprint. Additionally, the Existing Land Use Designations Alternative would not overlap with the
existing MSCP Preserve lands on the project site and thus would not require a Boundary Line Adjustment. It should be
noted that the project’s proposed MSCP Boundary Line Adjustment would result in an increase in MSCP Preserve Area
and would be required to result in equal or higher biological value as compared to the existing MSCP Preserve. While the
development footprint would be slightly reduced under this alternative, the Existing Land Use Designations Alternative
would result in similar direct/indirect impacts to biological resources as the proposed project and would require similar
mitigation because development would occur on the same portion of the project site. Therefore, the Existing Land Use
Designations Alternative would result in similar impacts to biological resources.
Cultural and Tribal Cultural Resources
Although the Existing Land Use Designations Alternative would disturb less land than the proposed project, the Existing
Land Use Designations Alternative still has the potential to impact archaeological resources or human remains, and
would require the same mitigation as the proposed project. Therefore, compared to the proposed project, the Existing
Land Use Designations Alternative would result in similar impacts as the proposed project regarding cultural resources.
Energy
The Existing Land Use Designations Alternative would result in the consumption of energy during both construction
and operation. As discussed under Air Quality, above, compared to the proposed project, natural gas and electricity
usage are typically higher per dwelling unit than industrial uses. However, under an industrial land use, a higher
percentage of trips would be associated with the use of higher duty trucks, creating an increase in petroleum usage,
compared to the proposed project. Nonetheless, similar to the proposed project, the Existing Land Use Designations
Alternative would not result in a significant environmental impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project construction or operation , or a conflict with or obstruct a state or
local plan for renewable energy or energy efficiency. Therefore, impacts would be similar to the proposed project
and remain less than significant.
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Geology and Soils
The Existing Land Use Designations Alternative would also introduce people and structures to the project site. The
project site would remain the same under this alternative as under the proposed project and therefore, similar
potential for geologic hazards would occur. The proposed project would result in less than significant impacts to
geology and soils, aside from paleontological resources. As such, the Existing Land Use Designations Alternative
would result in similar impacts as the proposed project to geology and soils due to the same project location.
Although the Existing Land Use Designations Alternative would disturb less land than the proposed project due to the
reduced development footprint, this alternative still has the potential to impact paleontological resources, and would
require the same mitigation as the proposed project. Therefore, compared to the proposed project, the Existing Land Use
Designations Alternative would result in similar impacts as the proposed project regarding geology and soils.
Greenhouse Gas Emissions
As identified in Section 5.7, Greenhouse Gas Emissions, the proposed project would have significant and
unavoidable impacts associated with the project’s efficiency metric and the state’s ability to meet future GHG
emission reductions. Even with incorporation of mitigation, impacts would remain significant and unavoidable. As
discussed under Air Quality and Energy, above, the Existing Land Use Designations Alternative would result in an
increase of heavy duty trucks, which would result in higher emissions than passenger vehicles associated with
residential development. In addition, although residents would not be introduced on-site under this alternative, the
alternative would introduce 2,800 employees, which are still anticipated to result in an increase in the efficiency
threshold. While this alternative would place employment in proximity to existing and planned residential uses , in
the context of the City’s GHG efficiency threshold, impacts would be similar to the proposed project and remain
significant and unavoidable.
Hazards and Hazardous Materials
The proposed project would result in less than significant impacts associated with hazards and hazardous
materials, with the exception of wildfire hazards. Under the Existing Land Use Designations Alternative, the potential
for hazards and hazardous materials related impacts on the project site from construction activities would be similar
to the proposed project as location would remain the same. During operations of the industrial park, it is possible
that the Existing Land Use Designations Alternative could result in increased transport, use or disposal of hazardous
materials and the reasonably foreseeable upset and accident conditions involving the release of hazardous
materials. However, hazardous materials are highly regulated in California, including the methods by which they are
transported, used, and stored. Therefore, it is likely that if any hazardous materials are used for operation of a
potential industrial use under this alternative, potential impacts would be less than significant upon compliance
with applicable regulations.
Similar to the proposed project, the Existing Land Use Designations Alternative would also introduce people and
structures to potential wildfire hazards due to the same location. Therefore, the Existing Land Use Designations
Alternative would result in similar impacts as the proposed project regarding hazards and hazardous materials.
Hydrology and Water Quality
As identified in Section 5.9, Hydrology and Water Quality, the proposed project would have less than significant
impacts regarding hydrology and water quality on the project site. Under the Existing Land Use Designations
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Alternative, the potential for hydrology and water quality related impacts on the project site would be slightly
reduced because less land would be altered from the existing and undeveloped condition with the reduced
development footprint. When compared to the proposed project, the Existing Land Use Designations Alternative
would result in similar impacts to water quality and hydrology.
Land Use and Planning
Under the Existing Land Use Designations Alternative, there would be no General Plan amendment, Sunbow General
Development Plan (GDP) amendment, Sunbow Sectional Area Plan (SPA Plan) amendment, Rezone, or MSCP
Boundary Line Adjustment. The development of an industrial park would be consistent with existing zoning and land
use designations. However, as discussed in Section 5.10, Land Use and Planning, the proposed project would not
result in any environmental impacts due to conflicts with relevant plans, policies, or regulation, including these
discretionary actions. Additionally, as a part of the proposed MSCP Boundary Line Adjustment, the proposed
project is required to set aside a potentially suitable area currently located outside of the MSCP Preserve to
incorporate into the MSCP Preserve at a 1:1 acreage ratio. The proposed MSCP Boundary Line Adjustment would
be required to result in e qual or higher biological value as compared to the existing MSCP Preserve. Although the
Existing Land Use Designations Alternative would not require these discretionary actions and would conform with
the existing site designations, the inclusion of these d iscretionary actions under the proposed project would not
result in any land use and planning impacts. Therefore, the Existing Land Use Designations Alternative would
result in similar as the proposed project regarding land use and planning.
Noise
Construction of this alternative would require more heavy duty traffic, which tends to result in greater mobile source
noise emissions. However, the Existing Land Use Designations Alternative would result in greater project generated
traffic trips associated with the 2,800 employment opportunities generated by development of an industrial park
as compared to the 2,315 residents generated by the proposed project . As such, mobile source noise emissions
would be increased under this alternative. Additionally, operational noise levels would be greater, as an industrial
park use would emit greater noise levels than a residential use. Therefore, impacts would be increased under the
Existing Land Use Designations Alternative.
Population and Housing
The Existing Land Use Designations Alternative would result in 2,800 employment opportunities and no residential
units, as compared to the proposed project’s 718 residential units. As such, population would not be induced in
the area due to new unplanned residential uses. The new employment opportunities at the industrial park under
this alternative would contribute to growth in the area, as it is reasonably anticipated that some employees of the
industrial park would move to the area. It is also reasonably anticipated that some employees of the industrial park
would already be living within the project area. However, the industrial park land use is already assumed in planning
documents including the City’s General Plan, GDP, and SPA Plan. As such, the potential growth induced by an
industrial park land use would not be considered unplanned. Although the proposed project would result in less
than significant impacts to population and housing, including due to unplanned growth, the Existing Land Use
Designations Alternative would not result in any unplanned growth. As such, impacts would be reduced under the
Existing Land Use Designations Alternative.
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Public Services
As identified in Section 5.13, Public Services, prior to mitigation, the proposed project would have potentially
significant impacts on public services due to the increase in demand for services. Mitigation in the form of payment
of fees would reduce impacts to public services to a less than significant level. Under the Existing Land Use
Designations Alternative, the potential for public services related impacts would still occur and mitigation in the form
of payment of fees would still be required. Therefore, the Existing Land Use Designations Alternative would result in
similar impacts as the proposed project with regard to public services.
Recreation
As identified in Section 5.14, Recreation, prior to mitigation, the proposed project would have potentially significant
impacts on parks and recreation facilities due to the increase in demand for service . Mitigation in the form of
payment of the Public Benefit Fee would reduce impacts to parks and recreation facilities to a less than significant
level. Under the Existing Land Use Designations Alternative, less demand for parks and recreation facilities would
occur from development of an industrial park. However, some demand on parks and recreation facilities may occur if
employees of the industrial park move to the City and area surrounding the project site. However, development of an
industrial park would not require payment of fees and impacts would be less than significant. Finally, the Existing Land
Use Alternative would not include any recreational facilities, contrary to the CPF and recreational facilities included
under the proposed project, and therefore would result in no impacts from the construction or expansion of
recreational facilities. As such, impacts would be reduced under the Existing Land Use Designations Alternative.
Transportation
The Existing Land Use Designations Alternative would result in greater project generated traffic trips associated
with the 2,800 employment opportunities generated by development of an industrial park as compared to the
2,315 residents generated by the proposed project. Accordingly, this alternative would have a greater impact on
the local street network and roadway capacity. Additionally, more heavy vehicles would be used under the Existing
Land Use Designations Alternative. However, it is likely that vehicle miles travelled (VMT) would be reduced due to
placement of employment opportunities in proximity to existing and planned residential uses. Therefore, impacts
to transportation would be similar under the Existing Land Use Designations Alternative.
Utilities and Service Systems
The Existing Land Use Designations Alternative would increase demand for utilities and service systems on the
project site, similar to the proposed project. As discussed in Section 5.16, the proposed project would result in a
total water demand of 122,060 gallons per day (GPD) or 44,551,900 gallons per year. In addition, per Section
5.16, the proposed project would result in a generation of 331.2 tons of solid waste per year. California Emissions
Estimator Model (CalEEMod) User’s Guide Version 2016.3.2 was used to estimate utility and service system usage
associated with this alternative (CAPCOA 2017). Per the CalEEMod User’s Guide, development of an approximately
700,000 square feet light industrial building would result in solid waste generation of 161,875,000 gallons per
year of water use. Per the CalEEMod User’s Guide, development of the Existing Land Use Designations Alternative
would result in a solid waste generation of 686 tons per year (CAPCOA 2017). Therefore, impacts to utilities and
service systems would be increased under the Existing Land Use Designations Alternative.
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Wildfire
As discussed in Section 5.17, Wildfire, prior to mitigation, the proposed project would result in potentially significant
impacts associated with the project facilitating wildfire spread or exacerbating wildfire risk. Similar to the proposed
project, the Existing Land Use Designations Alternative would introduce people and structures to the project site. As such,
under the Existing Land Use Designations Alternative, the potential for wildfire hazards on the project site would be similar
to the proposed project as the location would remain the same. Mitigation would still be required under the Existing Land
Use Designations Alternative to minimize risk on industrial park employees. Therefore, the Existing Land Use
Designations Alternative would result in similar impacts as the proposed project regarding wildfire hazards.
Relation to Project Objectives
The Existing Land Use Designations Alternative would meet project Objective 5, because this alternative would
implement the goals, objectives, and policies of the Chula Vista General Plan, the MSCP Subarea Plan, the Sunbow
GDP, and the Sunbow SPA Plan; Objective 6, because public services and facilities would be provided under this
alternative in accordance with the City’s Growth Management Ordinance; and Objective 7, because the industrial
park would be compatible with surrounding development and would establish setbacks and implement design
standards in accordance with City regulations.
The Existing Land Use Designations Alternative would not meet Objectives 1, 2, 3, 4, or 8. Objectives 1, 2, and 4
pertain to residential development and associated pedestrian and bicycle facilities which would not be included
under this alternative. While this alternative would preserve portions of the site, it would not result in an increase
in MSCP Preserve Areas (Objective 3). This alternative would not meet Objective 9 given that the site has been
designated for industrial uses for approximately 30 years yet has remained undeveloped.
10.5.3 Reduced Development Alternative
The Reduced Development Alternative would include the development of 360 residential units, within a similar
development footprint as the proposed project. This number of units, which is 358 fewer units than the proposed
project was chosen in order to provide low to medium density residential. This alternative would still include
associated infrastructure, a reduced size Community Purpose Facility, and Open Space/MSCP Preserve areas as
proposed under the project. Due to the decreased number of units within a similar development footprint, the
Reduced Development Alternative is assumed to be developed with low to medium density residential rather than
medium-high and high density residential as proposed under the project. As discussed in Section 5.3, the proposed
project would require a Boundary Line Adjustment between the currently proposed development boundaries and
the mapped Multiple Species Conservation Program (MSCP) preserve on-site. Due to the reduced development of
this alternative, this Boundary Line Adjustment would be avoided under this alternative. However, it should be noted
that the Boundary Line Adjustment proposed under the project would result in an increase MSCP Preserve Areas.
Comparison to Proposed Project
Aesthetics
The Reduced Development Alternative would result in a reduced number of residential units developed within a
similar development footprint and the housing density would be reduced to low and medium density residential. As
such, the bulk and scale of the Reduced Development Alternative would be slightly reduced in conjunction with the
reduced density, including a potential reduction in the amount of retaining walls, manufactured slopes, and off-site
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buttressing. However, the Reduced Density Alternative would still alter the visual character of the project site as
development would still occur. Additionally, the Reduced Development Alternative would introduce new sources of
lighting and glare to the currently vacant and undeveloped project site, similar to the propo sed project. Although
the Reduced Development Alternative would reduce the housing density, the project site would still change from
vacant and undeveloped land to residential with open space, same as with the proposed project. In addition, the
proposed project would result in less than significant impacts associated with aesthetics. Therefore, the Reduced
Development Alternative would result in similar impacts as the proposed project with regard to aesthetics.
Air Quality
The Reduced Development Alternative would require a shorter construction schedule because there would be fewer
residential units developed. As such, construction emissions would be reduced as compared to the proposed
project. Further, operational emissions would also be reduced under the Reduced Development Alternative due to
the reduction in project generated traffic trips associated with less population induced on the project site. Although
the proposed project would result in less than significant air quality impacts, the Reduced Development Alternative
would result in reduced construction and operational emissions. A s such, impacts would be reduced under the
Reduced Development Alternative, but remain less than significant.
Biological Resources
The Reduced Development Alternative would disturb approximately the same area of land as the proposed project.
Additionally, the Reduced Development Alternative would not overlap with the existing MSCP Preserve lands on the
project site and thus would not require a Boundary Line Adjustment. It should be noted that the project’s proposed
MSCP Boundary Line Adjustment would result in an increase in MSCP Preserve Area and would be required to result
in equal or higher biological value as compared to the existing MSCP Preserve. The Reduced Development
Alternative would result in similar direct/indirect impacts to biological resources as the proposed project and would
require similar mitigation because development would generally occur on the same portion of the project site but
would not require a Boundary Line Adjustment. Therefore, the Reduced Development Alternative would result in
similar impacts to biological resources but would not increase Preserve Lands.
Cultural and Tribal Cultural Resources
The Reduced Development Alternative would disturb approximately the same area of land than the proposed
project. As such, the Reduced Development Alternative would have the potential to impact archaeological resources
or human remains, and would require the same mitigation as the proposed project. Therefore, compared to the
proposed project, the Reduced Development Alternative would result in similar impacts as the proposed project
regarding cultural resources.
Energy
The Reduced Development Alternative would result in a lower energy consumption during construction as compared
to the proposed project due to the reduction in residential units developed and shortened construction period.
Furthermore, with less population induced on the project site, operational energy use would also be reduced under
the Reduced Development Alternative. Although the proposed project would result in less than significant impacts
associated with energy, including the wasteful, inefficient, or unnecessary consumption of energy resources, the
Reduced Development Alternative would result in slightly reduced construction and operational energy
consumption. Therefore, impacts would be reduced under the Reduced Development Alternative.
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Geology and Soils
The Reduced Development Alternative would introduce people and structures to the project site. However, the
proposed project would result in less than significant impacts to geology and soils, aside from paleontological
resources. Like the proposed project, the Reduced Development Alternative would also result in less than significant
impacts associated with geologic hazards because the project site would remain the same. The Reduced
Development Alternative still has the potential to impact paleontological resources, and would require the same
mitigation as the proposed project. Therefore, compared to the proposed project, the Reduced Development
Alternative would result in similar impacts as the proposed project regarding geology and soils.
Greenhouse Gas Emissions
As identified in Section 5.7, Greenhouse Gas Emissions, the proposed project would have significant and
unavoidable impacts associated with the p roject’s efficiency metric and the state’s ability to meet future GHG
emission reductions. Even with incorporation of mitigation, impacts would remain significant and unavoidable
under the proposed project. The Reduced Development Alternative would reduce the construction and
operational GHG emissions as compared to the proposed project. Approximately 64% of the proposed project’s
annual GHG emissions are from mobile sources; thus, reducing the development to 360 residential units would
not only reduce the mobile emissions but also reduce construction emissions (i.e., building construction and
architectural coating phases) and operational area, energy use, solid waste disposal, and generation of electricity
associated with water supply, treatment, and distri bution and wastewater treatment emissions as compared to
the proposed project. However, because the City’s GHG efficiency metric threshold is based on service population
(residents and/or employees), the Reduced Development Alternative service population (residents) would also
be reduced due to the reduction in number of residential units, resulting in similar impacts as the proposed
project in the context of the City’s GHG efficiency metric threshold . Therefore, impacts to GHGs would remain
significant and unavoidable under this alternative.
Hazards and Hazardous Materials
The proposed project would result in less than significant impacts associated with hazards and hazardous
materials, with the exception of wildfire hazards. Under the Reduced Development Alternative, the potential for
hazards and hazardous materials related impacts on the project site would be similar to the proposed project as
the land use and location would remain the same. Moreover, compared to the proposed project, the Reduced
Development Alternative would also introduce future residents to potential wildfire hazards due to the same project
location. Therefore, the Reduced Development Alternative would result in similar impacts as the proposed project
regarding hazards and hazardous materials.
Hydrology and Water Quality
As identified in Section 5.9, Hydrology and Water Quality, the proposed project would have less than significant
impacts regarding hydrology and water quality on the project site. Under the Reduced Development Alternative, the
potential for hydrology and water quality related impacts on the project site would be the same as the proposed
project. However, this alternative would still require the same permits as the proposed project, preparation of a
SWPPP, and incorporation of BMPs, due to the introduction of new development to a vacant and undeveloped site.
When compared to the proposed project, the Reduced Development Alternative would result in similar impacts to
water quality and hydrology.
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Land Use and Planning
With the exception of the MSCP BLA, the Reduced Development Alternative would require all the same discretionary
actions listed in Section 4.5 of Chapter 4, Project Description, because the project site is not currently zoned or
designated for residential development. This would include the General Plan amendment, GDP amendment, SPA
Plan amendment, and Rezone. However, as discussed in Section 5.10, Land Use and Planning, the proposed project
would not result in any environmental impacts due to conflicts with relevant plans, policies, or regulation, including
due to the MSCP BLA. As a part of the proposed MSCP BLA, the proposed project is required to propose a potentially
suitable area currently located outside of the MSCP Preserve to incorporate into the MSCP Preserve at a 1:1 acreage
ratio. The proposed MSCP BLA would be required to result in equal or higher biological value as compared to the
existing MSCP Preserve. Although the Reduced Development Alternative would not require a BLA, the BLA under
the proposed project would not result in any land use and planning impacts. Therefore, the Reduced Development
Alternative would result in similar as the proposed project regarding land use and planning.
Noise
Construction of this alternative would require a shorter schedule resulting in overall fewer noise generating
construction equipment and less groundwork. Additionally, the Reduced Development Alternative would result in
less project generated traffic trips thereby reducing mobile source noise emissions. Operational noise levels would
also be reduced due to the reduction in residential units. Although the proposed project would result in less than
significant noise impacts, the Reduced Development Alternative would result in slightly reduced noise levels during
both construction and operation. Therefore, impacts would be reduced under the Reduced Development Alternative
but remain less than significant.
Population and Housing
The Reduced Development Alternative would result in 360 residential units, which is 358 fewer units than the
proposed project, thereby resulting in less induced growth in the area as compared to the proposed project.
Although the Reduced Development Alternative would induce less growth in the area, both this alternative and the
proposed project would result in unplanned population growth on the project site, as the site is not currently zoned
for residential development. Nonetheless, for the reasons discussed in Section 5.12, Population and Housing, this
growth would not be considered substantial and impacts would be less than significant. With less growth induced
under this alternative, impacts would also be less than significant. Therefore, impacts under the Reduced
Development Footprint Alternative would be similar to the proposed project.
Public Services
As identified in Section 5.13, Public Services, prior to mitigation, the proposed project would have potentially
significant impacts on public services due to the increase in demand for service. Mitigation in the form of payment
of fees would reduce impacts to public services to a less than significant level. Under the Reduced Development
Alternative, the potential for public services related impacts would still occur and mitigation in the form of payment of
fees would still be required. However, the induced population would be smaller than the proposed project due to the
reduction in residential units developed. Thus, the increase in demand for public services would be less under this
alternative. When compared to the proposed project, the Reduced Development Alternative would result in reduced
impacts associated with public services.
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Recreation
As identified in Section 5.14, Recreation, prior to mitigation, the proposed project would have potentially significant
impacts on parks and recreation facilities due to the increase in demand for service. Mitigation in the form of
payment of fees would reduce impacts to parks and recreation facilities to a less than significant level. Under the
Reduced Development Alternative, the potential for parks and recreation facilities related impacts would still occur
and mitigation in the form of payment of fees would still be required. However, because the induced population would
be smaller than the proposed project, the increase in demand would be reduced under this alternative. When
compared to the proposed project, the Reduced Development Alternative would result in reduced impacts associated
with parks and recreation facilities.
Transportation
The Reduced Development Alternative would result in less traffic trips associated with both construction and
operation due to the reduction in residential units and reduced population inducement on the project site. The
Reduced Development Alternative would not result in a change in traffic patterns, substantially increase hazards
due to a design feature, or result in inadequate emergency access, similar to the proposed project. Additionally,
VMT would be similar under the Reduced Development Alternative as it is calculated on a per capita basis and the
land use type and project location would remain the same as the proposed project. Although the proposed project
would result in less than significant transportation impacts, the Reduced Development Alternative would result in
less traffic. Therefore, impacts would be reduced under the Reduced Development Alternative.
Utilities and Service Systems
The Reduced Development Alternative would increase demand for utilities and service systems on the project site,
similar to the proposed project. However, due to the reduction in residential units and reduced population
inducement on the project site, the demand for public utilities and service systems would be less than under the
proposed project. Therefore, impacts would be reduced under the Reduced Development Alternative.
Wildfire
As discussed in Section 5.17, Wildfire, prior to mitigation, the proposed project would result in potentially significant
impacts associated with the project facilitating wildfire spread or wildfire risk. Similar to the proposed project, the
Reduced Development Alternative would introduce future residents to the project site. As such, under the Reduced
Development Alternative, the potential for wildfire hazards on the project site would be similar to the proposed
project as the land use and location would remain the same. Mitigation would still be required under the Reduced
Development Alternative. Therefore, the Reduced Development Alternative would result in similar impacts as the
proposed project regarding wildfire hazards.
Relation to Project Objectives
The Reduced Development Alternative would meet most of the project objectives, with the exception of Objectives
1, 2, and 3. This alternative because the reduction in housing density to low and medium would not allow for multi-
family housing units with a range of housing types or residential uses. This alternative would not contribute to the
growing housing needs of the City and the region to the same extent as the proposed project. While this alternative
would preserve portions of the project site, it would not result in an increase to MSCP Preserve Areas that would
occur under the project.
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10.6 Environmentally Superior Alternative
The No Project Alternative would result in the least environmental impacts and would be the environmentally
superior alternative. However, Section 15126.6(e)(2) of the CEQA Guidelines states that if the environmentally
superior alternative is the No Project Alternative, the EIR shall also identify an environmentally superior alternative
among the other alternatives. In this case, the environmentally superior alternative is the Reduced Development
Alternative. The Reduced Development Alternative would meet most of the project objectives, but to a lesser degree
than the proposed project while reducing impact resulting from greater population growth of the proposed project.
The project’s impacts are compared to each alternative’s impacts in Table 10-1.
Table 10-1. Alternatives Impact Summary
Environmental Issue
Proposed
Project
Impacts Prior
to Mitigation
Proposed
Project
Impacts with
Mitigation
No
Project/
No Build
Alternative
Existing Land
Use
Designation
Alternative
Reduced
Development
Alternative
Aesthetics LTS LTS ▼ ▬ ▬
Air Quality LTS LTS ▼ ▲ ▼
Biological Resources PS LTS ▼ ▬ ▬
Cultural and Tribal Cultural
Resources
PS LTS ▼ ▬ ▬
Energy LTS LTS ▼ ▬ ▼
Geology and Soils PS LTS ▼ ▬ ▬
Greenhouse Gas Emissions PS SU ▼ ▬/SU impact
remains
▼/SU impact
remains
Hazards and Hazardous Materials PS LTS ▼ ▬ ▬
Hydrology and Water Quality LTS LTS ▼ ▬ ▬
Land Use and Planning LTS LTS ▼ ▬ ▬
Noise LTS LTS ▼ ▲ ▼
Population and Housing LTS LTS ▼ ▼ ▬
Public Services PS LTS ▼ ▬ ▼
Recreation LTS LTS ▼ ▼ ▼
Transportation LTS LTS ▼ ▬ ▼
Utilities and Service Systems LTS LTS ▼ ▲ ▼
Wildfire PS LTS ▬ ▬ ▬
Meets Most Project Objectives Yes Yes No No Yes
▲ Alternative is likely to result in greater impacts to issue when compared to proposed project.
▬ Alternative is likely to result in similar impacts to issue when compared to proposed project.
▼ Alternative is likely to result in reduced impacts to issue when compared to proposed project.
LTS = Less than significant impact.
PS = Potentially significant impact.
SU = Significant and unavoidable impact.
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11 References
Section 2 Introduction
City of Chula Vista. 1989. Sunbow General Development Plan. December 5, 1989. https://www.chulavistaca.gov/
departments/development-services/planning/planning-digital-library/spa-plan.
City of Chula Vista. 1990. Sunbow Sectional Planning Area Plan. As revised February 20, 1990.
https://www.chulavistaca.gov/departments/development-services/planning/planning-digital-library/spa-plan.
City of Chula Vista. 2003. City of Chula Vista MSCP Subarea Plan. February 2003. https://www.chulavistaca.gov/
departments/development-services/planning/habitat-conservation.
City of Chula Vista. 2005. City of Chula Vista General Plan. Adopted December 13, 2005; amended March 17,
2020. https://www.chulavistaca.gov/departments/development-services/planning/
planning-digital-library/general-plan.
Section 3 Environmental Setting
City of Chula Vista. 1989. Sunbow General Development Plan. December 5, 1989. https://www.chulavistaca.gov/
departments/development-services/planning/planning-digital-library/spa-plan.
City of Chula Vista. 1990. Sunbow Sectional Planning Area Plan. As revised. February 20, 1990.
https://www.chulavistaca.gov/departments/development-services/planning/planning-digital-library/
spa-plan.
City of Chula Vista. 2005. City of Chula Vista General Plan. Adopted December 13, 2005; amended March 17,
2020. https://www.chulavistaca.gov/departments/development-services/planning/
planning-digital-library/general-plan.
City of Chula Vista. 2020. Chula Vista Maps -- Zoning. Accessed October 2020. https://gisweb.chulavistaca.gov/
mapgallery/map.html?_ga=2.115709766.1596714540.1600270066-1733676646.1577724470&
webmap=936b5efd6fcc4585a1dde41ff7c7cd47
WRCC (Western Region Climate Center). 2017. Climate Summary for Chula Vista, California. Accessed October
2017. https://wrcc.dri.edu/cgi-bin/cliMAIN.pl?ca1758.
Section 4 Project Description
Chula Vista Elementary School District. 2020. School Site Locator. Accessed July 20, 2020.
http://apps.schoolsitelocator.com/?districtcode=10005.
City of Chula Vista. 1989. Sunbow General Development Plan. December 5, 1989. https://www.chulavistaca.gov/
departments/development-services/planning/planning-digital-library/spa-plan.
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City of Chula Vista. 1990. Sunbow Sectional Planning Area Plan. February 20, 1990. As revised.
https://www.chulavistaca.gov/departments/development-services/planning/planning-digital-library/spa-plan.
City of Chula Vista. 2005. City of Chula Vista General Plan. Adopted December 13, 2005; amended March 17,
2020. https://www.chulavistaca.gov/departments/development-services/planning/
planning-digital-library/general-plan.
Sweetwater Union High School District. 2020. School Site Locator. Accessed July 20, 2020.
http://apps.schoolsitelocator.com/?districtcode=79000.
Section 5.1 Aesthetics
Caltrans (California Department of Transportation). 2020. Scenic Highways System Lists. Accessed September
2020. https://dot.ca.gov/programs/design/lap-landscape-architecture-and-community-livability/
lap-liv-i-scenic-highways.
City of Chula Vista. 1989. Sunbow General Development Plan. Adopted December 5, 1989.
https://www.chulavistaca.gov/home/showdocument?id=19285.
City of Chula Vista. 19 90. Sunbow Sectional Planning Area Plan. As revised February 20, 1990.
https://www.chulavistaca.gov/departments/development-services/planning/planning-digital-library/
spa-plan.
City of Chula Vista. 2003. Chula Vista Greenbelt Master Plan. Adopted September 16, 2003.
https://www.chulavistaca.gov/departments/development-services/planning/
chula-vista-greenbelt-master-plan.
City of Chula Vista. 2005. City of Chula Vista General Plan. Adopted December 13, 2005; amended March 17,
2020. https://www.chulavistaca.gov/departments/development-services/planning/general-plan.
City of Chula Vista. 2011. Design Manual. Updated by the City Council on January 18, 2011. Accessed September
2020. https://www.chulavistaca.gov/departments/development-services/planning/
planning-digital-library/manuals.
City of Chula Vista. 2020. Chula Vista Maps – Zoning. https://gisweb.chulavistaca.gov/mapgallery/
map.html?_ga=2.115709766.1596714540.1600270066-1733676646.1577724470&webmap=
936b5efd6fcc4585a1dde41ff7c7cd47.
County of San Diego. 2009. Light Pollution Code. Adopted April 3, 2009. Accessed September 2020.
https://www.sandiegocounty.gov/pds/docs/LightPollutionCode.pdf.
US Census Bureau. 2019. QuickFacts: Chula Vista city, California. July 1, 2019. Accessed September 2020.
https://www.census.gov/quickfacts/chulavistacitycalifornia.
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Section 5.2 Air Quality
CalRecycle (Department of Resources Recycling and Recovery. 2020. “Solid Waste Information System Facility
Detail: Otay Landfill (37-AA-0010).” Accessed April 2020. https://www2.calrecycle.ca.gov/SWFacilities/
Directory/37-AA-0010/Detail/.
Caltrans (California Department of Transportation). 1998a. CALINE4 – A Dispersion Model for Predicting Air
Pollutant Concentrations near Roadways. Version 1.32. Written by Sonoma Technology Inc., Petaluma,
California. Sponsored by the University of California, Davis, Institute of Transportation Studies and
Caltrans. http://www.dot.ca.gov/hq/InfoSvcs/EngApps/.
Caltrans. 1998b. User’s Guide for CL4: A User-Friendly Interface for the CALINE4 Model for Transportation Project
Impact Assessments. User’s Guide STI-997480-1814-UG. June 1998. http://www.dot.ca.gov/hq/env/air/
documents/CL4Guide.pdf.
CAPCOA (California Air Pollution Control Officers’ Association). 2017. California Emissions Estimator Model
(CalEEMod) User’s Guide Version 2016.3.2 Prepared by Trinity Consultants and the California Air
Districts. Accessed October 2017. http://www.aqmd.gov/docs/ default-source/caleemod/
upgrades/2016.3/01_user-39-s-guide2016-3-1.pdf?sfvrsn=2.
CARB (California Air Resources Board). 2000. Risk Reduction Plan to Reduce Particulate Matter Emissions from
Diesel-Fueled Engines and Vehicles. October 2000. Accessed August 2016. http://www.arb.ca.gov/
diesel/documents/rrpfinal.pdf.
CARB. 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April 2005. Accessed August
2016. http://www.arb.ca.gov/ch/landuse.htm.
CARB. 2014. “California Greenhouse Gas Inventory for 2000–2012—by Category as Defined in the 2008 Scoping
Plan.” Last updated March 24, 2014. Accessed October 2017. http://www.arb.ca.gov/ cc/inventory/
data/tables/ghg_inventory_scopingplan_00-12_2014-03-24.pdf.
CARB. 2016a. “Glossary of Air Pollution Terms.” CARB website. Accessed June 2016. http://www.arb.ca.gov/
html/gloss.htm.
CARB. 2016b. “Ambient Air Quality Standards.” May 4, 2016. Accessed August 2016. http://www.arb.ca.gov/
research/aaqs/aaqs2.pdf.
CARB. 2018. In-Use Off-Road Diesel-Fueled Fleets Regulation. April 11, 2018. Accessed April 2020.
https://ww3.arb.ca.gov/msprog/ordiesel/fac.htm.
CDPH (California Department of Public Health). 2019. Epidemiologic Summary of Coccidioidomycosis in
California, 2018. https://www.cdph.ca.gov/Programs/CID/DCDC/CDPH%20Document%20Library/
CocciEpiSummary2018.pdf.
City of Chula Vista. 1969. Chula Vista Municipal Code Section 19.66.090, Odors. Accessed November 2017.
http://www.codepublishing.com/CA/ChulaVista/#!/ChulaVista19/ChulaVista1966.html#19.66.090.
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City of Chula Vista. 1989. Sunbow General Development Plan. December 5, 1989. Accessed April 2020.
https://www.chulavistaca.gov/home/showdocument?id=19285.
City of Chula Vista. 1990. Sunbow Sectional Planning Area Plan. As revised February 20, 1990.
https://www.chulavistaca.gov/departments/development-services/planning/planning-digital-library/spa-plan.
City of Chula Vista. 2005. City of Chula Vista General Plan. Adopted December 13, 2005; amended March 17,
2020. Accessed October 2017. http://www.chulavistaca.gov/departments/development-services/
planning/general-plan.
County of San Diego. 2007. Guidelines for Determining Significance and Report Format and Content
Requirements – Air Quality. Department of Planning and Land Use, Department of Public Works.
March 19, 2007.
EPA (U.S. Environmental Protection Agency). 1995. Compilation of Air Pollutant Emission Factors, Fifth Edition.
AP-42. January 1995, as amended.
EPA. 2009. Integrated Science Assessment for Particulate Matter. EPA/600/R-08/139F.
EPA. 2013. Integrated Science Assessment of Ozone and Related Photochemical Oxidants. EPA/600R-10/076F.
EPA. 2016. Integrated Science Assessment for Oxides of Nitrogen–Health Criteria (2016 Final Report).
EPA/600/R-15/068.
EPA. 2019a. “What is MERV Rating?” August 1, 2019. Accessed April 2020. https://www.epa.gov/
indoor-air- quality-iaq/what-merv-rating-1.
EPA. 2019b. “AirData: Access to Air Pollution Data.” Accessed March 2019. https://www.epa.gov/
outdoor-air-quality-data/monitor-values-report.
Gould, C. 2020a. APCD_Public_Records_Request Otay Landfill 37-AA-0010-signed.pdf. Email from C. Gould (San
Diego Air Pollution Control District) to S. Wang (Dudek). March 25, 2020.
Gould, C. 2020b. Chula Vista MET Data. Email from C. Gould (San Diego Air Pollution Control District) to S. Wang
(Dudek). February 21, 2020.
Kern County. 2017. Draft Environmental Impact Report for the Kern County Cannabis Land Use Ordinance
Project. July. Accessed April 2020. https://psbweb.co.kern.ca.us/planning/pdfs/eirs/CLUO/
CLUO_DEIR_Vol2_Appendix_A-J.pdf.
Kleipeis, N.E., W.C. Nelson, W.R. Ott, J.P. Robinson, A.M. Tsang, P. Switzer, J.V. Behar, S.C. Hern, and W.H.
Engelmann. 2001. “The National Human Activity Pattern Survey (NHAPS): A Resource for Assessing
Exposure to Environmental Pollutants.” Journal of Exposure Analysis and Environmental Epidemiology
11(3): 231–252.
Lakes Environmental. 2019. AERMOD View, Version 9.8.3.
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Nelson, J. 2019. Coccidioidomycosis Data Requests. Email from J. Nelson (County of San Diego Health & Human
Services Agency, Epidemiologist II) to A. Poll (Dudek). October 11, 2019.
OEHHA (Office of Environmental Health Hazard Assessment). 2015. Guidance Manual for Preparation of Health
Risk Assessments. OEHHA, Air Toxics Hot Spots Program, Risk Assessment Guidelines. February 2015.
Accessed October 2017. http://oehha.ca.gov/air/hot_spots/2015/2015GuidanceManual.pdf.
SANDAG (San Diego Association of Governments). 2015. San Diego Forward: The Regional Plan. October 2015.
https://sdforward.com/previous-plan-dropdown/chapters-and-appendices.
SANDAG. 2016. Regional Transportation Improvement Program. September 2016. https://www.sandag.org/
uploads/publicationid/publicationid_2071_21174.pdf.
SANDAG. 2017a. Series 13: 2050 Regional Growth Forecast. Accessed June 2017. http://www.sandag.org/
index.asp?classid=12&subclassid=84&projectid=503&fuseaction=projects.detail.
SANDAG. 2017b. 2050 Regional Transportation Plan. Accessed June 2017. http://www.sandag.org/
index.asp?projectid=349&fuseaction=projects.detail.
SANDAG. 2020a. 2019 Federal Regional Transportation Plan. Accessed September 21, 2020. https://sdforward.com/
mobility-planning/2019FederalRTP#:~:text=The%20public%20comment%20period%20for%20the%
20proposed%20draft%20transportation%20network,house%20on%20August%2013%2C%202019.
SANDAG. 2020b. About San Diego Forward, Developing the 2021 Regional Plan. September 2020.
https://www.sdforward.com/about-san-diego-forward/developing-the-2021-regional-plan.
SCAQMD (South Coast Air Quality Management District). 1993. CEQA Air Quality Handbook.
SCAQMD. 2007. “Table XI-E, Mitigation Measure Examples: Fugitive Dust from Storage Piles.” April 2007.
Accessed April 2020. http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysis-
handbook/mitigation-measures-and-control-efficiencies/fugitive-dust.
SCS (SCS Engineers). 2013a. Air Toxics Health Risk Assessment for Otay Ranch Village 3 North. May 2013.
SCS. 2013b. Otay Ranch Village 3 North Nuisance Study. October 2013.
SCS. 2016. AB2588 Health Risk Assessment for Otay Landfill. December 2016.
SDAPCD (San Diego Air Pollution Control District). 1969. Rules and Regulations. Regulation IV. Prohibitions. Rule
51. Nuisance. Effective January 1, 1969.
SDAPCD. 1997. Rules and Regulations. Regulation IV. Prohibitions. Rule 50. Visible Emissions. Effective August
13, 1997. Accessed June 2017. http://www.sandiegocounty.gov/content/dam/sdc/apcd/PDF/
Rules_and_Regulations/Prohibitions/APCD_R50.pdf.
SDAPCD. 2005. Measures to Reduce Particulate Matter in San Diego County. December 2005. Accessed October
2017. http://www.sdapcd.org/planning/plan.html.
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SDAPCD. 2009a. 2009 Regional Air Quality Strategy Revision. April 2009. Accessed October 2017.
http://www.sdapcd.org/content/dam/sdc/apcd/PDF/Air%20Quality%20Planning/ 2009-RAQS.pdf.
SDAPCD. 2009b. SDAPCD Regulation IV: Prohibitions; Rule 55: Fugitive Dust Control. June 24, 2009. Accessed
October 2017. http://www.sandiegocounty.gov/content/dam/sdc/apcd/PDF/Rules_and_Regulations/
Prohibitions/APCD_R55.pdf.
SDAPCD. 2015. SDAPCD Regulation IV: Prohibitions; Rule 67.0.1: Architectural Coatings. June 24. Accessed May
2017. http://www.sdapcd.org/content/dam/sdc/apcd/PDF/Rules_and_Regulations/Prohibitions/
APCD_R67-0-1.pdf.
SDAPCD. 2016a. 2008 Eight-Hour Ozone Attainment Plan for San Diego County. Final. Updated December 2016.
http://www.sdapcd.org/content/dam/sdc/apcd/PDF/Air%20Quality %20Planning/8-Hr-O3%
20Attain%20Plan-08%20Std.pdf.
SDAPCD. 2016b. 2016 Revision of the Regional Air Quality Strategy for San Diego County. December 2016.
Accessed June 2017. http://www.sdapcd.org/content/dam/sdc/apcd/PDF/Air%20Quality%
20Planning/2016%20RAQS.pdf.
SDAPCD. 2017a. Regulation XII. Toxic Air Contaminants; Rule 1200: Toxic Air Contaminants – New Source
Review. Accessed October 2017. http://www.sdapcd.org/content/dam/sdc/apcd/PDF/
Rules_and_Regulations/Toxic_Air_Cotaminants/ACPD_R1200.pdf.
SDAPCD. 2017b. Regulation XII. Toxic Air Contaminants; Rule 1210: Toxic Air Contaminants – Public Notification
and Risk Reduction. Accessed October 2017. http://www.sdapcd.org/content/dam/sdc/apcd/PDF/
Rules_and_Regulations/Toxic_Air_Cotaminants/APCD_R1210.pdf.
SDAPCD. 2019a. Supplemental Guidelines for Submission of Air Toxics “Hot Spots” Program. May 2019.
Accessed April 2020. https://www.sandiegocounty.gov/content/dam/sdc/apcd/PDF/Toxics_Program/
APCD_Hot_Spots_Supplemental_Guidelines.pdf.
SDAPCD. 2019b. Permit APCD2009-PTO-971112. May 24, 2019.
U.S. Army Corps of Engineers. 2006. Draft Environmental Impact Statement Success Dam Seismic Remediation
Project. October. Accessed April 2020. https://archive.epa.gov/region9/nepa/web/pdf/success-dam.pdf.
USGS (U.S. Geological Survey). 2000. Operational Guidelines (Version 1.0) for Geological Fieldwork in Areas 1
Endemic for Coccidioidomycosis (Valley Fever).
WRCC (Western Region Climate Center). 2017. Climate Summary for Chula Vista, California. Accessed October 2017.
https://wrcc.dri.edu/cgi-bin/cliMAIN.pl?ca1758.
Section 5.3 Biological Resources
ACOE (U.S. Army Corps of Engineers). 1987. Corps of Engineers Wetlands Delineation Manual. Technical Report Y‐87‐
1. Vicksburg, Mississippi: U.S. Army Engineer Waterways Experimental Station, Environmental Laboratory.
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ACOE. 2008. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Arid West Region
(Version 2.0). Environmental Laboratory, ERDC/EL TR-08-28. Vicksburg, Mississippi: U.S. Army Engineer
Research and Development Center. September 2008. http://www.usace.army.mil/Portals/
2/docs/civilworks/regulatory/reg_supp/trel08-28.pdf.
AECOM, California Department of Fish and Wildlife, and Conservation Biology Institute. 2011. Vegetation Classification
Manual for Western San Diego County, First Edition. Prepared for San Diego Association of Governments.
American Ornithological Society. 2019. Check‐list of North American Birds (online). Prepared by R.T. Chesser, K.J.
Burns, C. Cicero, J.L. Dunn, A.W. Kratter, I.J. Lovette, P.C. Rasmussen, J.V. Remsen, Jr., D.F. Stotz, and
K. Winker. http://checklist.aou.org/taxa.
CDFW (California Department of Fish and Wildlife). 2019. “Special Animals List.” Periodic publication. California Natural
Diversity Database. August 2019. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=109406&inline.
CDFW. 2020a. “Special Vascular Plants, Bryophytes, and Lichens List.” Quarterly publication. California Natural
Diversity Database. January 2020. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=109383&inline.
City of Chula Vista. 2003. City of Chula Vista Multiple Species Conservation Plan (MSCP) Subarea Plan. Adopted
February 2003. Accessed October 2020. https://www.chulavistaca.gov/home/showdocument?id=7106.
City of Chula Vista. 2019. Chula Vista Municipal Code. Chapter 17.35 Habitat Loss and Incidental Take (HLIT). Passed
November 12, 2019.
CNPS (California Native Plant Society). 2020. “California Rare Plant Ranks” webpage. Accessed November 2020.
https://www.cnps.org/rare-plants/cnps-rare-plant-ranks.
Crother, B.I. (ed.). 2017. Scientific and Standard English Names of Amphibians and Reptiles of North America
North of Mexico, with Comments Regarding Confidence in Our Understanding.
Dudek and Associates, Inc. 2006. Biological Resources Report and Impact Assessment for Otay Ranch Villages 2
& 3, City of Chula Vista, San Diego County, California. Prepared for the Otay Ranch Company. February
2006. 97pp.
Hall, E.R. 1981. The Mammals of North America. 2nd Edition. New York: John Wiley & Sons. Two volumes.
Holland, R.F. 1986. Preliminary Descriptions of the Terrestrial Natural Communities of California. California
Department of Fish and Game, Nongame‐Heritage Program.
Oberbauer, T., M. Kelly, and J. Buegge. 2008. Draft Vegetation Communities of San Diego County [Internet]. Based
on “Preliminary Descriptions of the Terrestrial Natural Communities of California,” R.F. Holland, 1986.
http://www.sdcounty.ca.gov/dplu/docs/Veg_Comm_SDCounty_2008.pdf.
Rebman, J.P., and M.G. Simpson. 2014. Checklist of the Vascular Plants of San Diego County. 5th Edition. ISBN 0‐
918969‐08‐5. San Diego, California: San Diego Natural History Museum.
San Diego Natural History Museum. 2002. Butterflies of San Diego County [Internet]. Prepared by M.W. Klein.
http://www.sdnhm.org/research/entomology/sdbutterflies.html.
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USDA (U.S. Department of Agriculture). 2002. USDA, Natural Resources Conservation Service.
http://SoilDataMart.nrcs.usda.gov/.
USFWS (U.S. Fish and Wildlife Service). 2004. Recovery Plan for Deinandra conjugens (Otay Tarplant). Portland,
Oregon. http://ecos.fws.gov/docs/recovery_plan/041228.pdf.
USFWS. 2019a. GIS Division Species Occurrence Data Download (zip) updated May 2019. http://www.fws.gov/
carlsbad/giswebpage/giswebpage.htm.
USFWS 2019b. GIS Division Critical Habitat Data Download (zip) updated May 2019. https://www.fws.gov/
carlsbad/GIS/CFWOGIS.html
Wilson, D.E., and D.M. Reeder. 2005. Mammal Species of the World: A Taxonomic and Geographic Reference.
3rd edition. Johns Hopkins University Press. Available online. http://www.departments.bucknell.edu/
biology/resources/msw3/.
Section 5.4 Cultural and Tribal Cultural Resources
City of Chula Vista. 2005. City of Chula Vista General Plan. Adopted December 13, 2005; amended March 17,
2020. Accessed September 8, 2020. https://www.chulavistaca.gov/home/showdocument?id=9341.
City of Chula Vista. 2011. City of Chula Vista Historic Preservation Program. Adopted July 19, 2011. Accessed
September 8, 2020. http://www.chulavistaca.gov/home/showdocument?id=10964.
CVMC (Chula Vista Municipal Code). 2011. City of Chula Vista Municipal Code – 21.04.100 Historical Designation
– Findings of fact and eligibility criteria. Amended 2011. Accessed September 4, 2020.
https://chulavista.municipal.codes/CVMC/21.04.100.
Section 5.5 Energy
CALGreen (California Green Building Code). 2019. 2019 California Green Building Standards Code, Title 24, Part 11 with
Jan 2020 Errata. Accessed September 16, 2020. https://codes.iccsafe.org/content/CGBC2019P3.
California Gas and Electric Utilities (Southern California Gas Company, Pacific Gas and Electric Company, San
Diego Gas & Electric Company, Southwest Gas Corporation, City of Long Beach Gas & Oil Department,
and Southern California Edison Company). 2016. 2016 California Gas Report. Accessed March 20, 2017.
https://www.socalgas.com/regulatory/cgr.shtml.
CAPCOA (California Air Pollution Control Officers Association). 2017. California Emissions Estimator Model
(CalEEMod) User’s Guide Version 2016.3.2. Prepared by Trinity Consultants and the California Air
Districts. November 2017. http://www.caleemod.com.
CARB (California Air Resources Board) 2008. Climate Change Scoping Plan: A Framework for Change. Adopted
December 2008. Accessed September 17, 2020. https://ww2.arb.ca.gov/sites/default/files/classic//
cc/scopingplan/document/adopted_scoping_plan.pdf.
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CARB. 2017. “Clean Car Standards – Pavley, Assembly Bill 1493.” January 11, 2017. Accessed April 17, 2017.
https://www.arb.ca.gov/cc/ccms/ccms.htm.Scag 2012
CARB. 2020. EMFAC 2017. Accessed October 2020. https://www.arb.ca.gov/emfac/2017/.
CEC (California Energy Commission). n.d. “2022 Building Energy Efficiency Standards” webpage. Accessed
September 15, 2020. https://www.energy.ca.gov/programs-and-topics/programs/building-energy-
efficiency-standards/2022-building-energy-efficiency.
CEC. 2018. “2019 Building Energy Efficiency Standards Fact Sheet.” March 2018. https://www.energy.ca.gov/
title24/2019standards/documents/2018_Title_24_2019_Building_Standards_FAQ.pdf
CEC. 2020a. 2019 Integrated Energy Policy Report. Adopted February 20, 2020. Accessed September 16, 2020.
https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/
2019-total-system-electric-generation.
CEC. 2020b. “Electricity Consumption by County.” Accessed October 2020. http://ecdms.energy.ca.gov/
elecbycounty.aspx.
CEC. 2020c. “Gas Consumption by County.” Accessed October 2020. http://ecdms.energy.ca.gov/gasbycounty.aspx
City of Chula Vista. 2001. City Energy Strategy and Action Plan. Approved May 29, 2001. Accessed
September 17, 2020. https://www.chulavistaca.gov/home/showdocument?id=5439.
City of Chula Vista 2005. City of Chula Vista General Plan. Adopted December 13, 2005; amended March 17, 2020.
Accessed September 17, 2020. https://www.chulavistaca.gov/home/showdocument?id=9337.
City of Chula Vista 2011. Climate Adaptation Strategies – Implementation Plans. Adopted May 2011. Accessed
September 15, 2020. https://www.chulavistaca.gov/home/showdocument?id=5443.
City of Chula Vista 2017. Chula Vista Climate Action Plan (CAP). Adopted September 2017. Accessed September
15, 2020. https://www.chulavistaca.gov/home/showdocument?id=15586.
City of Chula Vista. 2020a. “Clean and Renewable Energy.” Accessed October 2020. https://www.chulavistaca.gov/
departments/clean/conservation/climate-action-plan/community-choice-aggregation#:
~:text=What%20is%20Community%20Choice%20Aggregation,San%20Diego%20Gas%20%26%20Electric).
City of Chula Vista. 2020b. “Chula Vista – Select Snapshot Activity Data.” Accessed October 2020.
https://www.chulavistaca.gov/home/showdocument?id=20826.
CPUC (California Public Energy Commission). 2011. CA Energy Efficiency Strategic Plan. Updated January 2011.
Accessed September 2020.
CPUC. 2016. Biennial RPS Program Update. Report prepared in compliance with Public Utilities Code Section
913.6. January 1, 2016. http://www.cpuc.ca.gov/uploadedfiles/cpuc_website/content/
utilities_and_industries/energy/reports_and_white_papers/final12302015section913_6report.pdf.
CPUC. 2020. “Natural Gas and California.” Accessed May 2020. http://www.cpuc.ca.gov/natural_gas/.
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EIA (U.S. Energy Information Administration). 2010. “Trends in U.S. Residential Natural Gas Consumption.”
Accessed June 2010. https://www.eia.gov/pub/oil_gas/natural_gas/feature_articles/2010/
ngtrendsresidcon/ngtrendsresidcon.pdf.
EIA. 2016. “Today in Energy – EIA Creates Winter Version of Its Daily Energy Dashboard for Southern California.”
November 2016. Accessed April 18, 2017. https://www.eia.gov/todayinenergy/detail.php?id=28852.
EIA. 2020a. “State Electricity Profiles – California Electricity Profile 2018.” December 31, 2019; corrected March
23, 2020. Accessed May 2020. https://www.eia.gov/electricity/state/california/index.php.
EIA. 2020b. “California State Energy Profile.” Last updated January 16, 2020. Accessed May 2020.
https://www.eia.gov/state/print.php?sid=CA.
EIA. 2020c. “Natural Gas Consumption by End Use.” May 2020. Accessed May 2020. https://www.eia.gov/
dnav/ng/ng_cons_sum_a_EPG0_VC0_mmcf_a.htm.
EIA. 2020d. “California State Profile and Energy Estimates – Table F16: Total Petroleum Consumption Estimates, 2017.”
Accessed May 2020. https://www.eia.gov/state/seds/data.php?incfile=/state/seds/sep_fuel/html/
fuel_use_pa.html&sid=US&sid=CA.
EPA (U.S. Environmental Protection Agency). 2017. “Overview for Renewable Fuel Standard.” Last updated June
7, 2017. Accessed February 2019. https://www.epa.gov/renewable-fuel-standard-program/
overview-renewable-fuel-standard
SANDAG (San Diego Association of Governments). 1994. San Diego Regional Energy Plan. Adopted December
1994. Accessed September 17, 2020. https://www.sandag.org/uploads/publicationid/
publicationid_1381_8416.pdf.
SANDAG. 2009. Regional Energy Strategy for the San Diego Region. Adopted December 2009. Accessed
September 17, 2020. https://www.sandag.org/uploads/publicationid/publicationid_1476_10631.pdf.
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SDRWQCB (Regional Water Quality Control Board, San Diego Region). 2013. Order Number R9-2013-0001,
National Pollutant Discharge Elimination System (NPDES) Permit and Waste Discharge Requirements for
Discharges from the Municipal Separate Storm Sewer System (MS4) Draining the Watersheds Within the
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SDRWQCB. 2018. San Diego Region–Basin Plan Review. Accessed September 2020.
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Section 5.10 Land Use and Planning
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City of Chula Vista. 1990. Sunbow Sectional Planning Area Plan. February 20, 1990.
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City of Chula Vista. 2003. City of Chula Vista MSCP Subarea Plan. February 2003. http://www.chulavistaca.gov/
home/showdocument?id=7106.
City of Chula Vista. 2005. City of Chula Vista General Plan. Adopted December 13, 2005; amended March 17,
2020. http://www.chulavistaca.gov/departments/development-services/planning/general-plan.
City of Chula Vista. 2013. Chula Vista Vision 2020, General Plan – Housing Element. Adopted April 23, 2013.
https://www.chulavistaca.gov/home/showdocument?id=5503.
City of Chula Vista. 2018. Chula Vista Parks and Recreation Master Plan. Adopted August 7, 2018.
https://www.chulavistaca.gov/departments/development-services/planning/
parks-recreation-master-plan-update.
HR&A Advisors, Inc. (HR&A). 2020. Sunbow II Phase 3 Market and Financial Analysis of Industrial Use.
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Section 5.11 Noise
Caltrans (California Department of Transportation). 2013a. Transportation and Construction Vibration Guidance
Manual. Division of Environmental Analysis, Environmental Engineering, Hazardous Waste, Air, Noise,
Paleontology Office. Sacramento, California. September 2013.
Caltrans. 2013b. Technical Noise Supplement to the Traffic Noise Analysis Protocol. September 2013.
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planning-digital-library/general-plan.
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https://chulavista.municipal.codes/CVMC.
DOT (U.S. Department of Transportation). 2006. FHWA Roadway Construction Noise Model: User’s Guide. Final
Report. FHWA-HEP-06-015. DOT-VNTSC-FHWA-06-02. Cambridge, Massachusetts: DOT, Research and
Innovative Technology Administration. August 2006.
FHWA (Federal Highway Administration). 2004. FHWA Traffic Noise Model Version 2.5.
FHWA. 2008. Roadway Construction Noise Model (RCNM), Software Version 1.1. U.S. Department of Transportation,
Research and Innovative Technology Administration, John A. Volpe National Transportation Systems Center,
Environmental Measurement and Modeling Division. Washington, D.C. December 8, 2008.
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analysis_and_abatement_guid ance/revguidance.pdf.
FTA (Federal Transit Administration). 2018. Transit Noise and Vibration Impact Assessment. Final Report. FTA-
Report No. 0123. September 2018. https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/
research-innovation/118131/transit-noise-and-vibration-impact-assessment-manual-fta-report-
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ICC (International Construction Code). 2019. California Building Code. Section 1206 – Sound Transmission.
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OPR (Governor’s Office of Planning and Research). 2017. 2017 State of California General Plan Guidelines.
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Plan. January 25, 2010. https://www.san.org/DesktopModules/Bring2mind/DMX/API/Entries/
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Section 5.12 Population and Housing
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https://www.chulavistaca.gov/home/showdocument?id=19285.
City of Chula Vista. 1990. Sunbow Sectional Planning Area Plan. As revised February 20, 1990.
https://www.chulavistaca.gov/departments/development-services/planning/planning-digital-library/
spa-plan.
City of Chula Vista. 2005. City of Chula Vista General Plan. Adopted December 13, 2005; amended March 17,
2020. https://www.chulavistaca.gov/departments/development-services/planning/
planning-digital-library/general-plan.
City of Chula Vista. 2013. Chula Vista Vision 2020, General Plan, Housing Element. Adopted April 23, 2013.
http://www.chulavistaca.gov/home/showdocument?id=5503.
City of Chula Vista. 2020a. “Housing Element Update 2021 – FAQs.” Accessed September 2020.
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housing-element-update-faqs.
City of Chula Vista. 2020b. “Housing Element Update 2021–2029 Presentation.” Accessed September 2020.
https://www.chulavistaca.gov/home/showdocument?id=21346.
SANDAG (San Diego Association of Governments). 2004. Regional Comprehensive Plan for the San Diego Region.
San Diego, California. Adopted July 23, 2004. http://www.sandag.org/uploads/publicationid/
publicationid_1094_3362.pdf.
SANDAG. 2011a. 2050 Regional Transportation Plan. October 2011. http://www.sandag.org/uploads/
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SANDAG. 2011b. Regional Housing Needs Assessment Plan; Fifth House Element Cycle, Planning for Housing in
the San Diego Region, 2010–2020. October 28, 2011. http://www.sandag.org/uploads/publicationid/
publicationid_1661_14392.pdf.
SANDAG. 2013. Series 13 Regional Growth Forecast, San Diego Region. October 2013. Accessed December 8,
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SANDAG. 2015a. San Diego Forward: The Regional Plan. October 2015. https://sdforward.com/
previous-plan-dropdown/chapters-and-appendices.
SANDAG. 2015b. Series 13 Forecast for the Jurisdiction of Chula Vista. Accessed December 8, 2016.
http://datasurfer.sandag.org/dataoverview.
SANDAG. 2020. “About San Diego Forward, Developing the 2021 Regional Plan.” September 2020.
https://www.sdforward.com/about-san-diego-forward/developing-the-2021-regional-plan.
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Section 5.13 Public Services
City of Chula Vista. 2003. City of Chula Vista Greenbelt Master Plan. Adopted September 16, 2003. Accessed
September 16, 2020. https://www.chulavistaca.gov/home/showdocument?id=212.
City of Chula Vista. 2005a. City of Chula Vista General Plan. Adopted December 13, 2005; amended March 17, 2020.
Accessed September 3, 2020. https://www.chulavistaca.gov/home/showdocument?id=9337.
City of Chula Vista. 2005b. “Public Facilities Development Impact Fee.” Approved December 2005. Accessed
September 21, 2020. https://www.chulavistaca.gov/home/showdocument?id=16189.
City of Chula Vista. 2011. Chula Vista Public Library (CVPL) Strategic Facilities Plan. Approved April 2011.
Accessed September 21, 2020. https://www.chulavistaca.gov/home/showdocument?id=4812
City of Chula Vista. 2014. Chula Vista Public Library (CVPL) Strategic Vision Plan. Approved February 20, 2014.
Accessed September 21, 2020. https://www.chulavistaca.gov/home/showdocument?id=11716.
City of Chula Vista. 2018. City of Chula Vista Parks and Recreation Master Plan. Updated August 7, 2020.
Accessed September 18, 2020. https://www.chulavistaca.gov/home/showdocument?id=18294.
City of Chula Vista. 2020a. City of Chula Vista Growth Management Oversight Commission – Annual Report for
Fiscal Year 2019 (July 1, 2018–June 20, 2019). Approved January 30, 2020. Accessed September 21,
2020. http://lfweblink.chulavistaca.gov:27630/weblink8/0/doc/215869/Page1.aspx.
City of Chula Vista. 2020b. Fire Stations and Locations webpage. Accessed September 21, 2020.
https://www.chulavistaca.gov/departments/fire-department/stations-locations/fire-stations-map.
City of Chula Vista. 2020c. Chula Vista Fire Department (CVFD) homepage. Accessed September 21, 2020.
https://www.chulavistaca.gov/departments/fire-department.
City of Chula Vista. 2020d. About Us – Fire Department webpage. Accessed September 21, 2020.
https://www.chulavistaca.gov/departments/fire-department/about-us.
City of Chula Vista. 2021. UAS Drone Program. Accessed January 15, 2021.
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CVESD (Chula Vista Elementary School District). 2010. Chula Vista Elementary School District – School Facilities
Needs Analysis. Adopted June 2010. Accessed September 22, 2020. http://schools.cvesd.org/district/
district/Documents/Business%20Services%20and%20Support%20(Lisa%20Brannen)/School%
20Facilities%20Needs%20Analysis%20(2010).pdf.
CVESD. 2020a. Chula Vista Elementary School District Map. Accessed September 21, 2020.
CVESD. 2020b. Chula Vista Elementary School District – About Our District webpage. Accessed September 2020.
https://www.cvesd.org/cms/One.aspx?portalId=412034&pageId=884900.
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CVFD (Chula Vista Fire Department). 2019. Chula Vista Fire Department Annual Report 2019. Accessed
September 21, 2020. https://www.chulavistaca.gov/Home/ShowDocument?id=21499.
CVPD (Chula Vista Police Department). 2020a. Chula Vista Police Department Organization Chart. Published
August 28, 2020. Accessed September 21, 2020. https://www.chulavistaca.gov/home/
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CVPD. 2020b. Growth Management Oversight Commission (GMOC) Response Times webpage. Accessed
September 21, 2020. https://www.chulavistaca.gov/departments/police-department/about-us/
gmoc-response-times.
SARC (School Accountability Report Card). 2019a. Valle Lindo Elementary School 2018-19 School Accountability
Report Card. Accessed September 22, 2020. https://www.cvesd.org/common/pages/
DisplayFile.aspx?itemId=14609861.
SARC. 2019b. Rancho Del Rey Middle School 2018-19 School Accountability Report Card. Accessed September
22, 2020. https://www.sarconline.org/SarcPdfs/11/37684116114276.pdf.
SARC. 2019c. Castle Park Middle School 2018-19 School Accountability Report Card. Accessed September 22,
2020. https://www.sarconline.org/SarcPdfs/11/37684116059752.pdf.
SARC. 2019d. Otay Ranch Senior High School 2018-19 School Accountability Report Card. Accessed September
22, 2020. https://www.sarconline.org/SarcPdfs/11/37684113731627.pdf.
SARC. 2019e. Castle Park Senior High 2018-19 School Accountability Report Card. Accessed September 22,
2020. https://www.sarconline.org/SarcPdfs/11/37684113730801.pdf.
SUHSD (Sweetwater Union High School District). 2020a. Sweetwater Union High School District Map. Accessed
September 21, 2020.
SUHSD. 2020b. Sweetwater Union High School District (SUHSD) – About webpage. Accessed September 22,
2020. http://www.sweetwaterschools.org/about-suhsd/.
SUHSD. 2020c. Sweetwater Union High School District (SUHSD) – Developer Fees webpage. Accessed
September 22, 2020. http://finance.sweetwaterschools.org/developer-fees/.
Section 5.14 Recreation
City of Chula Vista 2003a. City of Chula Vista Greenbelt Master Plan. Adopted September 16, 2003. Accessed
September 16, 2020. https://www.chulavistaca.gov/home/showdocument?id=212.
City of Chula Vista 2003b. City of Chula Vista Greenbelt Maintenance Map. Adopted September 16, 2003.
Accessed September 16, 2020. https://www.chulavistaca.gov/home/showdocument?id=234.
City of Chula Vista. 2005. City of Chula Vista General Plan. Adopted December 13, 2005; amended March 17, 2020.
Accessed September 16, 2020. https://www.chulavistaca.gov/home/showdocument?id=9341.
11– References
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 11-21
City of Chula Vista. 2018. City of Chula Vista Parks and Recreation Master Plan. Adopted August 7, 2018.
Accessed September 18, 2020. https://www.chulavistaca.gov/home/showdocument?id=18294.
City of Chula Vista. 2020a. City of Chula Vista Active Transportation Plan (ATP). Approved May 12, 2020. Accessed
September 18, 2020. https://www.chulavistaca.gov/home/showdocument?id=20838.
City of Chula Vista. 2020b. Growth Management Oversight Commission: Annual Report for Fiscal Year 2019.
January 30, 2020.
County of San Diego 2020. County of San Diego Parks and Recreation – Otay Lakes County Park webpage. Accessed
September 29, 2020. https://www.sdparks.org/content/sdparks/en/park-pages/OtayLakes.html.
Section 5.15 Transportation
Caltrans (California Department of Transportation). 2014. California Manual on Uniform Traffic Control
Devices. Revision 5. Published 2014; revised March 27, 2 020. https://dot.ca.gov/programs/
safety-programs/camutcd/camutcd-rev5.
Caltrans. 2015. 2015 Interregional Transportation Strategic Plan. Caltrans, Division of Transportation Planning.
December 2015.
CAPCOA (California Air Pollution Control Officers ’ Association). 2010. Quantifying Green House Gas Mitigation
Measures. August 2010.
City of Chula Vista. 1989. Sunbow General Development Plan. December 5, 1989. https://www.chulavistaca.gov/
departments/development-services/planning/planning-digital-library/spa-plan.
City of Chula Vista. 2005. City of Chula Vista General Plan. Adopted December 13, 2005; amended March 17,
2020. http://www.chulavistaca.gov/departments/development-services/planning/general-plan.
County of San Diego. 2018. San Diego County Emergency Operations Plan. Prepared by the Unified San Diego
County Emergency Services Organization and the County of San Diego. September 2018. Accessed
September 2020. https://www.sandiegocounty.gov/content/sdc/oes/emergency_management/
oes_jl_oparea.html.
CVMC (Chula Vista Municipal Code). 2020. Chapter 12.12, Street Obstructions. Accessed October 2020.
https://chulavista.municipal.codes/CVMC/12.12.
OPR (Governor’s Office of Planning and Research). 2018. Technical Advisory on Evaluating Transportation
Impacts in CEQA. December 2018.
SANDAG (San Diego Association of Governments). 2014. 2014 Regional Transportation improvement Program.
Final. September 2014.
SANDAG. 2015a. 2016 State Transportation Improvement Program. Submitted to the California Transportation
Commission December 10, 2015. https://www.sandag.org/uploads/projectid/projectid_520_20063.pdf.
SANDAG. 2015b. San Diego Forward: The Regional Plan. October 2015.
SANDAG. 2020. VMT Analysis.
11– References
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 11-22
Section 5.16 Utilities and Service Systems
CalRecycle (California Department of Resources Recycling and Recovery). 2016a. “Otay Landfill.” Accessed
October 2020. https://www2.calrecycle.ca.gov/SolidWaste/Site/Summary/2863.
CalRecycle. 2016b. Sycamore Landfill detailed summary. Accessed October 2020.
https://www2.calrecycle.ca.gov/SolidWaste/Site/Summary/2871.
City of Chula Vista 2005. City of Chula Vista General Plan. Adopted December 13, 2005; amended March 17, 2020.
Accessed October 1, 2020. https://www.chulavistaca.gov/home/showdocument?id=9337.
City of Chula Vista. 2012a. A Supplemental Environmental Impact Report for Amendments to the City of Chula
Vista General Plan (GPA-09-01) and Otay Ranch General Development Plan (PCM-09-11). Approved June
2012. Accessed October 1, 2020. https://www.chulavistaca.gov/home/showdocument?id=11414.
City of Chula Vista 2012b. City of Chula Vista Subdivision Manual. Revised March 13, 2012. Accessed October 1,
2020. http://www.chulavistaca.gov/home/showdocument?id=7819.
City of Chula Vista 2013. “City of Chula Vista Growth Management Program.” Accessed October 1, 2020.
http://www.chulavistaca.gov/city_services/development_services/planning_building/Planning/Growth/
Management.asp.
City of Chula Vista 2014. City of Chula Vista Wastewater Master Plan. Approved 2014. Accessed October 1, 2020.
https://www.chulavistaca.gov/departments/public-works/master-plans/wastewater-master-plan.
City of Chula Vista 2020. City of Chula Vista Growth Management Oversight Commission – Annual Report for
Fiscal Year 2019 (July 1, 2018 – June 20, 2019). Approved January 30, 2020. Accessed September 21,
2020. http://lfweblink.chulavistaca.gov:27630/weblink8/0/doc/215869/Page1.aspx.
MWD (Metropolitan Water District). 2016a. 2015 Regional Urban Water Management Plan. Approved June 2016.
Accessed October 1, 2020. http://www.mwdh2o.com/PDF_About_Your_Water/
2.4.2_Regional_Urban_Water_Management_Plan.pdf.
MWD. 2016b. Integrated Water Resources Plan. 2015 Update. Approved 2016. Accessed October 1, 2020.
http://www.mwdh2o.com/Reports/2.4.1_Integrated_Resources_Plan.pdf.
Otay Water District (OWD) 2016. 2015 Urban Water Management Plan Update. Approved May 2016. Accessed
October 1, 2020. http://www.otaywater.gov/wp-content/uploads/2015/10/OWD-2015-UWMP-Draft_
20160503_with-appendices.pdf.
OWD n.d.a. “At-A-Glance” webpage. Accessed October 9, 2020. https://otaywater.gov/about-otay/
otay-at-a-glance/.
SDCWA (San Diego County Water Authority). 2016. 2015 Urban Water Management Plan. Approved June 2016.
Accessed October 1, 2020. http://www.sdcwa.org/sites/default/files/files/water-management/
water_resources/2015%20UWMP%20Final%2006222016.pdf.
11– References
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 11-23
Section 5.17 Wildfire
CAL FIRE (California Department of Forestry and Fire Protection). 2009. Fire Hazard Severity Zones in Local
Responsibility Areas. Riverside County City FHSZ Maps, Murrieta. http://www.fire.ca.gov/
fire_prevention/fhsz_maps/FHSZ/riverside/Murrieta.pdf.
CAL FIRE. 2018. 2018 Strategic Fire Plan for California. August 22, 2018.
City of Chula Vista. 1989. Sunbow General Development Plan. December 5, 1989. https://www.chulavistaca.gov/
departments/development-services/planning/planning-digital-library/spa-plan.
City of Chula Vista. 2003. City of Chula Vista MSCP Subarea Plan. February 2003. Accessed October 2020.
https://www.chulavistaca.gov/home/showdocument?id=7106.
City of Chula Vista. 2005. City of Chula Vista General Plan. Adopted December 13, 2005; amended March 17,
2020. https://www.chulavistaca.gov/departments/development-services/planning/
planning-digital-library/general-plan.
City of Chula Vista Municipal Code. 2020. Chula Vista Municipal Code, Chapter 15.36 Fire Code. Current through
July 28, 2020. Accessed September 2020. https://chulavista.municipal.codes/CVMC/15.36.
County of San Diego. 2017. Multi-Jurisdictional Hazard Mitigation Plan. Accessed September 2020.
https://www.sandiegocounty.gov/content/dam/sdc/oes/emergency_management/HazMit/2018/
2018%20Hazard%20Mitigation%20Plan.pdf.
County of San Diego. 2018. San Diego County Emergency Operations Plan. Accessed September 2020.
https://www.sandiegocounty.gov/content/sdc/oes/emergency_management/oes_jl_oparea.html.
DOI (U.S. Department of the Interior) and USDA (U.S. Department of Agriculture). 2000. “Managing the Impact of
Wildfires on Communities and the Environment.” September 8, 2000.
FEMA (Federal Emergency Management Agency). 2020. “FEMA Flood Map Service Center,” FIRM panel
06071C6490H. Effective August 28, 2008. Accessed September, 2020. https://msc.fema.gov/
portal/search?AddressQuery=chulavista%20#searchresultsanchor.
International Fire Chiefs Association. 2013. Ready Set Go – My Personal Wildland Fire Action Guide. Accessed
November 2, 2020. https://www.wildlandfirersg.org/s/iafc2/iafc-wildland-fire-programs-20Y3
m0000004EhqEAE?language=en_US
ICC (International Code Council). 2014. 2015 International Wildland–Urban Interface Code. May 30, 2014.
https://codes.iccsafe.org/content/document/556?site_type=public.
ICC. 2017. 2018 International Fire Code. August 31, 2017. https://codes.iccsafe.org/content/
IFC2018?site_type=public.
International Fire Chiefs Association. 2013.
National Wildfire Coordinating Group. 2009. Guidance for Implementation of Federal Wildland Fire Management
Policy. February 13, 2009.
11– References
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 11-24
Section 6 Cumulative Impacts
CAL FIRE (California Department of Forestry and Fire Protection). 2009. Fire Hazard Severity Zones in Local
Responsibility Areas. Riverside County City FHSZ Maps, Murrieta. http://www.fire.ca.gov/
fire_prevention/fhsz_maps/FHSZ/riverside/Murrieta.pdf.
CPUC (California Public Utilities Commission). 2018. San Diego Gas & Electric Salt Creek Substation Project. Last
updated on June 15, 2018. Accessed November 2, 2020. https://www.cpuc.ca.gov/environment/
info/panoramaenv/Salt_Creek/index.html#:~:text=Construction%20of%20the%20Salt%
20Creek,completed%20as%20of%20June%202018.
City of Chula Vista. 2005. Final Environmental Impact Report, Chula Vista Vision 2020, General Plan Update.
December 2005. https://www.chulavistaca.gov/home/showdocument?id=11971.
City of Chula Vista. 2012. A Supplemental Environmental Impact Report for Amendments to the City of Chula
Vista General Plan (GPA-09-01) and Otay Ranch General Development Plan (PCM-09-11). Approved June
2012. Accessed October 1, 2020. https://www.chulavistaca.gov/home/showdocument?id=11414.
Section 7 Growth Inducement
SANDAG (San Diego Association of Governments). 2004. Regional Comprehensive Plan for the San Diego Region.
San Diego, California. Adopted July 23, 2004. http://www.sandag.org/uploads/publicationid/
publicationid_1094_3362.pdf
SANDAG. 2011. 2050 Regional Transportation Plan. October 2011. http://www.sandag.org/uploads/
2050RTP/F2050rtp_all.pdf.
SANDAG. 2013. Series 13 Regional Growth Forecast, San Diego Region. October 2013. Accessed December 8,
2016. http://www.sandag.org/uploads/projectid/projectid_503_19239.pdf.
SANDAG. 2015. San Diego Forward: The Regional Plan. October 2015. https://sdforward.com/
previous-plan-dropdown/chapters-and-appendices.
Section 9 Effects Found Not to be Significant
City of Chula Vista. 2005. City of Chula Vista General Plan. Adopted December 13, 2005; amended March 17,
2020. https://www.chulavistaca.gov/departments/development-services/planning/
planning-digital-library/general-plan.
DOC (California Department of Conservation). 2016. California Important Farmland Finder. Accessed September
04, 2020. https://maps.conservation.ca.gov/dlrp/ciff/.
San Diego Association of Governments (SANDAG). n.d. “Mineral Resource Zone (MRZ) Classification and
Correlations Map.” Accessed September 16, 2020. https://www.sandag.org/uploads/
publicationid/publicationid_1558_12641.pdf.
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 12-1
12 List of Preparers
City of Chula Vista
Steve Power, AICP, Principal Planner
Stacey Kurz, Senior Project Coordinator
Oscar Romero, Associate Planner
Michael Shirey, Deputy City Attorney III
Maggie Greene, Fire Inspector
Mary Radley, Landscape Architect
Paul Oberbauer, Senior Civil Engineer, Traffic
Scott Barker, Senior Transportation Engineer
Cheryl Goddard, Senior Planner
RH Consulting Group LLC
Ranie Hunter, Principal
Dudek
Brian Grover, AICP, Principal
Andrew Talbert, AICP, Environmental Planner
Iulia Roman, Environmental Planner
Joe Harrison, Environmental Analyst
Carolyn Somvilay, Environmental Analyst
Lilli Renier, Environmental Analyst
Samantha Wang, Air Quality Specialist
Jessica Colston, BA, Archaeologist
Angela Pham, MA, RPA, Archaeologist
Micah Hale, PhD, RPA, Cultural Senior Project Manager
Loukas Barton, PhD, RPA, Archaeologist
Michael Williams, PhD, Archaeologist
Michael Huff, Fire Protection Project Manager
Mike Scott, Senior Fire Protection Planner
Noam Stamm, Fire Protection Planner
Mark Storm, INCE Bd. Cert., Senior Technical Specialist
Connor Burke, Technical Analyst
Carrie Kubacki, Mapping/Surveying Analyst
Laurel Porter, ELS, Senior Technical Editor
Daniela Yurovsky, Publications Specialist
12 – List of Preparers
Sunbow Sectional Planning Area Plan Amendment for the Sunbow II, Phase 3 Project EIR 12612
July 2021 12-2
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