FINDING OF NO SIGNIFICANT IMPACT 

SAN PASQUAL BAND OF DIEGUEÑO MISSION 

INDIANS 

9-ACRE FEE-TO-TRUST PROJECT 

San Diego County, California 

September 2010 
TABLE OF CONTENTS 

SAN PASQUAL BAND OF DIEGUEÑO MISSION 

INDIANS 9-ACRE FEE-TO-TRUST PROJECT 

Finding of No Significant Impact 

 Agency .....................................................................................................................1 

 Action .......................................................................................................................1 

 Summary ..................................................................................................................1 

 Background ..............................................................................................................1 

 Description of the Proposed Action .........................................................................2 

 Alternatives Considered ...........................................................................................2 

 Environmental Impacts ............................................................................................2 

 Summary of Final EA Protective Measures, BMPs, and Mitigation Measures .......4 

 Response to Draft EA Comments ..........................................................................10 

 Public Availability .................................................................................................10 

 Determination ........................................................................................................10 

Attachment A: Comment Letters submitted on Draft Environmental Assessment 

Attachment B: Response to Comments on the Draft Environmental Assessment 

 

 Attachment 1: Bracketed Comment Letters 

Attachment C: Final Environmental Assessment for the San Pasqual 9-Acre 

Fee-to-Trust Project 

 Appendix A: Public Notices 

 Appendix B: VCMWD Will Serve Letter 

 Appendix C: Grading/Drainage Plan 

 Appendix D: Biological Resource Reports 

 Appendix E: United States Fish & Wildlife Service’s Data File 

 Appendix F: Cultural Resource Inventory 

 Appendix G: Supplemental Cultural Resources Information 

 Appendix H: Traffic Impact Analysis 

Appendix I: Bureau of Land Management Manual 8410 Visual Resources 

Inventory Guidelines 

Appendix J: URBEMIS Files 
1

NOTICE OF FINDING OF NO SIGNIFICANT IMPACT FOR THE PROPOSED 

SAN PASQUAL BAND OF DIEGUEÑO MISSION INDIANS 9-ACRE FEE-TOTRUST PROJECT 

AGENCY: Bureau of Indian Affairs 

ACTION: Finding of No Significant Impact 

SUMMARY: 

The San Pasqual Band of Diegueño Mission Indians (Tribe) submitted a request to the 

Bureau of Indian Affairs (BIA) to approve the acquisition in trust of approximately 9.08 

acres of fee land for commercial development. The land proposed for development and 

trust acquisition is located in Valley Center, California, on the southwest corner of Valley 

Center Road and North Lake Wohlford Road. The project site is located in Section 15 of 

Township 11 South, Range 1 West, on the Rodriguez MT, California U.S. Geological 

Survey (USGS) 7.5-Minute Topographic Quadrangle (quad), San Bernardino Baseline & 

Meridian. 

Based on the analysis contained in the Draft Environmental Assessment (EA), public 

comments made on the Draft EA (Attachment A), the response to those comments (refer 

to Attachment B), and the mitigation imposed within the Final EA (Attachment C), the 

BIA makes a finding of no significant impact (FONSI) for the Proposed Action. This 

finding constitutes a determination that the Proposed Action is not a federal action 

significantly affecting the quality of the human environment; therefore, preparation of an 

Environmental Impact Statement (EIS) is not required. 

BACKGROUND: 

The San Pasqual Reservation is situated in the Peninsular Mountains, located in the 

unincorporated area of San Diego County known as Valley Center, about 11 miles 

northeast of Escondido. It comprises 1,380 acres consisting of five separate parcels in a 

semi-checkerboard configuration. It is situated primarily on steep and rolling hills; only 

about fifteen percent, or 207 acres, of the Reservation is considered appropriate for 

development. Because of this limitation, the Tribe began purchasing additional lands 

contiguous to and surrounding the Reservation in order to provide an economically viable 

land base for its membership and to increase opportunities for economic development and 

tribal self-determination. 

 

The Proposed Action would facilitate Tribal self-determination and economic 

development, and allow the Tribe to exercise sovereignty over lands currently held in fee 

title. The development of a portion of the site into a small retail plaza would increase 

tribal revenues, provide employment and managerial experience for tribal members, help 

serve the needs of Valley Center from anticipated community growth, and would offer 
2

important economic development opportunities that would support the Tribe’s pursuit of 

self-determination. 

DESCRIPTION OF THE PROPOSED ACTION: 

The BIA’s Proposed Action consists of the transfer of the site into federal trust status for 

the benefit of the Tribe. The proposed fee-to-trust conveyance is for one parcel totaling 

approximately 9.08 acres. A reasonably foreseeable consequence of this action is the 

subsequent development of the site into a small retail plaza (Proposed Project). The retail 

plaza would include a commercial building, a restaurant, and a gas station. The 

remainder of the site would continue to be utilized as an overflow parking area for the 

Valley View Casino. 

ALTERNATIVES CONSIDERED: 

The BIA considered two alternatives to the Proposed Action, the No Action Alternative 

and the Reduced Intensity Alternative, which are described in the Final EA (Attachment 

C) and summarized below. The No Action Alternative was evaluated in full detail in the 

Final EA. The Reduced Intensity Alternative was considered but ultimately eliminated 

from further detailed evaluation as it would not meet the purpose and need for the 

Proposed Action. 

1) No Action Alternative: Under the No-Action Alternative, the 9.08-acre site would 

not be placed into trust for the benefit of the Tribe. The Tribe would develop the 

eastern half of the site as a 143-space parking lot, with ancillary structures, in 

accordance with the Site Plan for the Valley View Casino Employee Parking Lot. 

2) Reduced Intensity Alternative: The Reduced Intensity Alternative, like the 

Proposed Action, consists of the conveyance of the site from private ownership 

into federal trust status for the benefit of the Tribe. Under this alternative, the 

existing overflow parking lot for the Valley View Casino would be expanded to 

cover the entire 9.08-acre parcel. No commercial development would occur. 

ENVIRONMENTAL IMPACTS: 

A Draft EA, documenting and analyzing the potential impacts of the Proposed Action and 

Alternatives, was completed in April 2010. The Draft EA was distributed for public 

review from May 10, 2010 to June 11, 2010. The BIA received nine comment letters, 

included within this FONSI as Attachment A. A Final EA was completed in August 

2010 in accordance with the requirements set out in the National Environmental Policy 

Act (NEPA) of 1969 (42 U.S.C. §4321 et seq.), the Council on Environmental Quality 

(CEQ) Guidelines for Implementing NEPA, and the BIA’s NEPA handbook (59 IAM 3-

H). The Final EA has been included within this FONSI as Attachment C. 

As part of the Final EA, potential impacts to land resources, water resources, air quality, 

biological resources, cultural resources, socioeconomic conditions/environmental justice, 
3

transportation and circulation, land use, public services, noise, hazardous materials, and 

visual resources were evaluated, with the following conclusions: 

A. Project design and Best Management Practices (BMPs) incorporated into the 

Proposed Project will ensure impacts to land resources will be less than 

significant. See Final EA Sections 4.1.1 and 2.1. 

B. Project design, BMPs incorporated into the Proposed Project, and mitigation 

measures will ensure that impacts to water resources are not significant. See Final 

EA Sections 4.1.2, 2.1, and 5.2. 

C. BMPs incorporated into the Proposed Project will ensure impacts to air quality 

will be less than significant. See Final EA Sections 4.1.3 and 2.1. 

D. Implementation of mitigation measures will ensure that impacts to biological 

resources are not significant. See Final EA Sections 4.1.4 and 5.4. 

E. No potentially significant cultural or paleontological resources were identified 

within the project site. There will be no significant impacts to known cultural 

resources. Mitigation measures will ensure impacts to unknown cultural 

resources are less than significant. See Final EA Sections 4.1.5 and 5.5. 

F. Implementation of mitigation measures will ensure that impacts associated with 

socioeconomic conditions and environmental justice are not significant. See Final 

EA Sections 4.1.6 and 5.6. 

G. Implementation of mitigation measures will ensure that impacts associated with 

transportation and circulation are not significant. See Final EA Sections 4.1.7 and 

5.7. 

H. There will be no significant land use impacts. See Final EA Section 4.1.8. 

I. Project Design and implementation of mitigation measures will ensure that 

impacts to public services are not significant. See Final EA Sections 4.1.9, 2.1, 

and 5.10. 

J. Implementation of mitigation measures will ensure that impacts associated with 

noise are not significant. See Final EA Sections 4.1.10 and 5.11. 

K. Project Design and implementation of mitigation measures will ensure that 

impacts associated with hazardous materials are not significant. See Final EA 

Sections 4.1.11, 2.1, and 5.12. 

L. Implementation of mitigation measures will ensure that impacts associated with 

visual resources are not significant. See Final EA Sections 4.1.12 and 5.13. 

M. Cumulative impacts associated with land use would be less than significant. 

BMPs incorporated into the Proposed Project and mitigation measures will ensure 

that cumulative impacts to water resources, air quality, biological resources, 

cultural resources, socioeconomic conditions and environmental justice, 

transportation and circulation, public services, noise, hazardous materials, and 

visual resources are not significant. See Final EA Sections 4.3, 2.1, 5.1, 5.2, 5.3, 

5.4, 5.5, 5.6, 5.7, 5.10, 5.11, 5.12 and 5.13. 

 
4

SUMMARY OF FINAL EA PROTECTIVE MEASURES, BMPS, AND 

MITIGATION MEASURES: 

The protective measures, BMPs, and mitigation measures described in the Final EA are 

included either to reduce significant impacts to a less than significant level, to further 

reduce already less than significant impacts, or both. To ensure that the mitigation 

measures required to reduce significant impacts to a less than significant level are 

enforceable as applicable, the mitigation measures are either included as an integral part 

of the project description, required by Federal law, and/or included within an enforceable 

NEPA document. 

Following is a summary of protective measures, BMPs, and mitigation measures that 

have been incorporated into the project design to eliminate or substantially reduce 

environmental impacts from the project (see the Final EA for a detailed description of all 

measures and BMPs). 

Land Resources 

 All structures shall meet the California Building Code requirements for the site; 

including the seismic design criteria of the most recent edition of the International 

Building Code for Seismic Zone 4. 

 Design-level geotechnical specifications addressing the specific grading and 

development plans shall be developed prior to finalization of the grading and 

development plans for the property. 

Water Resources 

 A detailed drainage plan shall be prepared by a registered civil engineer prior to 

the site development that shall include the following items: 

o An accurate calculation of pre- and post-development runoff conditions 

shall be performed using appropriate hydraulic models. 

o Vegetated detention swales shall be constructed according to the 

engineer’s recommendations and engineering specifications to mitigate for 

increased peak flows from impervious surfaces. Recommendations from 

EPA Publication 832-F-99-006 (EPA, 1999) regarding vegetated detention 

swales shall be followed to the extent feasible. 

 The Tribe shall obtain a National Pollutant Discharge Elimination System permit 

(NPDES General Permit) from the USEPA for construction site runoff during the 

construction phase in compliance with the Clean Water Act (CWA). A Storm 

Water Pollution and Prevention Plan (SWPPP) shall be prepared, implemented, 

and maintained throughout the construction phase of the development, consistent 

with General Permit requirements. The SWPPP shall detail the BMPs to be 

implemented during construction and post-construction operation of the Proposed 

Project. 

 The Tribe shall submit development plans to the County of San Diego 

Development Services for approval of any necessary off-site improvements and 

encroachment permits. The plans shall include the site-specific stormwater 

drainage plan. 
5

 In the event that the Valley Center Municipal Water District (VCMWD) cannot 

serve the Proposed Action in the future and groundwater must be explored as a 

supplemental or replacement water supply, a groundwater feasibility study shall 

be prepared which, at a minimum, characterizes the existing water table, 

determines groundwater levels and flow directions in the vicinity, estimates 

available supply, calculates the impact of the Proposed Action on nearby water 

supply wells, and recommends appropriate conservation measures to avoid 

impacting ongoing beneficial uses of groundwater and to preserve the water 

supply for the future of the Proposed Action. Should the groundwater feasibility 

study find that the Proposed Action would have an unmitigateable adverse impact 

on nearby supply wells, groundwater would no longer be considered as a potable 

water source, and potable water would be purchased and trucked through private 

suppliers to the site. 

 All storm drains shall be equipped with silt and grease traps to remove oils, 

debris, and other pollutants. Storm drain inlets shall also be labeled “No 

Dumping-Drains to Rivers and Streams.” 

 The parking lot shall be designed to allow stormwater runoff to be directed 

toward vegetative filter strips to help control sediment. 

 Gasoline and diesel refueling/ dispensing sites shall be contoured to drain into 

oil/water catchment basins. 

 To prevent leaks of fuel from the gas station storage tanks and dispensing stations, 

the gas station shall be designed and constructed in accordance with all Federal 

regulations governing gasoline operations. Specific design, construction and 

operation practices shall include the following to prevent spills, overfills, and 

corrosion: 

o The gas station shall be equipped with catchment basins of sufficient size 

to contain mall spills. As a minimum, the basin shall be large enough to 

contain what may spill when the delivery hose is uncoupled form the fill 

pipe. Any spilled fuel shall be removed and disposed of immediately. 

o Gas station attendants and delivery personnel shall follow industry 

standard filling practices such as American Institute recommended 

Practice 1007, “Loading and Unloading of MC306/DOT 406 Cargo Motor 

vehicles.” Filling practices shall include provisions that ensure that the 

volume available in the tank is greater than the volume of product to be 

transferred to the tank before the transfer is made; and that the transfer 

operation is monitored constantly to prevent overfilling and spilling. 

o Gasoline storage tanks shall be equipped with overfill protection such as 

automatic shutoff devices, overfill alarms or ball and float valves. 

o Gasoline storage tanks shall be constructed to meet Federal corrosion 

performance standards. 

o Gasoline storage tanks shall be periodically inspected to ensure that the 

tank is structurally sound and free of corrosion or holes. Frequency of 

inspections shall be consistent with Federal requirements. 

o The tanks shall be equipped with leak detection systems to provide early 

detection of leaks from the tanks and dispensing equipment. 
6

Air Quality 

 The project owner shall designate an on-site Air Quality Construction BMP 

Manager (AQCBM) who shall be responsible for directing compliance with 

BMPs for the project construction heavy-duty equipment. The AQCBM shall be 

responsible for directing compliance with the following BMPs for fugitive dust 

control practices during project construction: 

o For any earth moving activities which would occur more than 100 feet 

from the subject property boundaries, conduct watering and/or cover as 

necessary to prevent visible dust emissions from exceeding 100 feet in 

length in any direction 

o For all disturbed surface areas apply dust suppression in a sufficient 

quantity and frequency to maintain a stabilized surface; any areas, which 

cannot be stabilized, as evidenced by wind driven dust, must have an 

application of water at least twice per day, and/or covered. 

o Establish a vegetative ground cover as soon as feasible after active 

operations have ceased. 

o For all unpaved roads either water all roads used for any vehicular traffic 

as often as necessary to minimize dust; or apply chemical stabilizer to all 

unpaved road surfaces on sufficient quantity and frequency to maintain a 

stabilized surface. 

o Provide track-out control to minimize tracking of soil onto neighboring 

roadways. 

o For all off site haul vehicles, cover loads. 

Biological Resources 

 A focused botanical survey will be conducted by a qualified botanist during the 

blooming periods for the San Diego thornmint, thread-leaved brodiaea, and San 

Diego button celery prior to commencement of construction activities within the 

ruderal/disturbed areas. One botanical survey may be conducted in April, May, or 

June to satisfy the bloom periods for these species. A letter report will be 

completed following the preconstruction survey to document the results. Should 

no species be observed, then no additional precautionary measures would be 

required. Should any of the federal listed plants be observed during the focused 

botanical survey, the biologist would contact the Tribe within one day of the 

survey to report the findings. A ten-foot buffer would be established around the 

species using construction flagging prior to commencement of construction 

activities. 

 A species sensitivity training program will be established. This program will be 

designed to educate construction personnel about the mitigation measures 

required for the execution of the project. All construction personnel will attend 

the sensitivity training that will provide instruction on identification, status, and 

detailed protocol of the actions that should be taken in the event that the Stephens’ 

kangaroo rat is encountered onsite during construction activities. The 

construction personnel will sign a sheet documenting attendance at the training. 

A qualified biologist will prepare a letter report within 30 days following the 
7

training to document the results of the preconstruction survey and training. The 

letter report will be submitted to the Tribe for its records. 

 A preconstruction survey will be conducted for Stephens’ kangaroo rat not more 

than 14 days prior to construction activities occurring within the ruderal/disturbed 

areas. Should the biologist observe Stephens’ kangaroo rat within the project site, 

consultation with the USFWS would be initiated within 24 hours of the survey. 

No work would commence until the USFWS authorizes the commencement of 

such work. 

 If the construction crew observes Stephens’ kangaroo rat within the construction 

area, all construction activities will immediately cease. The construction crew 

will contact the biologist within 24 hours of the sighting. The biologist will 

consult with the USFWS within 24 hours of notification. No work shall 

commence until the USFWS authorizes the commencement of such work. 

 If construction begins during the nesting season for raptors and other migratory 

birds (between February and October), a qualified biologist will conduct a 

preconstruction survey for active nests within 250 feet of the project site no more 

than 14 days prior to construction. If no active nests are found, then no further 

mitigation is necessary. 

 If any active nests are located in the project parcels, a 100-foot diameter buffer 

zone will be established around the nest to maximum extent practicable. A 

biologist should monitor nests weekly during construction to evaluate potential 

nesting disturbance caused by construction activities. The boundary of the buffer 

will be marked with yellow caution tape, surveyor’s flagging, pin flags, stakes, 

etc. The buffer zone will be maintained until the end of the breeding season or 

until the young have fledged. No construction activities should occur within 100 

feet of a nest tree while young are in the nest. The biological monitor will have 

the authority to stop construction if construction results in evidence of potential 

nest abandonment. The caution tape, surveyor’s flagging, pin flags, stakes, etc., 

may be removed when a biologist, whose qualifications are acceptable to approval 

agency staff, confirms that the nest(s) is no longer occupied and all young have 

fledged. 

 If an active nest occurs in a tree scheduled for removal or during demolition of an 

existing structure, the species of nesting bird will be determined to identify 

whether the species is protected under the MBTA. The nest tree will be preserved 

until the USFWS is contacted to obtain guidance on alternative buffers based on 

the species requirements. 

Cultural Resources 

 If human remains are discovered or suspected, work shall halt in that area and 

procedures set forth in 36 CFR § 800.13 shall be followed. 

 Once in Federal trust, and in the event of any inadvertent discovery, all such 

finds shall be subject to the implementing regulations under 36 CFR § 800.13. 

 Although not required to reduce effects to less than significant, it is 

recommended that a qualified archaeologist and Native American Monitor shall 

be present during all ground disturbing activity. 
8

Socioeconomic Conditions / Environmental Justice 

 The Tribe shall adopt an ordinance governing the sale and use of alcohol at the 

site; including, but not limited to, the prohibition of the sale of alcohol to minors 

less than 21 years of age, as well as the prohibition of public drinking and/or 

intoxication at the site. 

 The Tribe shall adopt an ordinance prohibiting loitering and suspicious behavior 

on site. 

Transportation and Circulation 

 Project redesign is recommended to align the internal driveway to the western 

parking lot further south along Street A, opposite the access point to the eastern 

parking lot. 

 The Tribe shall contribute funding for the following improvements to reduce 

potential traffic impacts to less than significant in the buildout year 

o Valley Center Road/ Street “A” intersection: Restripe Valley Center Road 

to provide a westbound left-turn lane with 150-feet of storage and a 90-

foot bay taper and an eastbound dedicated right-turn lane. Provide two 

outbound (northbound) lanes on Street “A”, one left-turn lane and one 

right-turn lane with an overlap phase. Conduct an annual traffic count at 

the Valley Center Road/ Street “A” intersection as part of a monitoring 

program of the intersection to determine when signal warrants are met. 

Install the traffic signal once warrants are met. 

o Valley Center Road between Lake Wohlford Road (N.) and Cole Grade 

Road: Provide the intersection improvements listed above and in addition, 

provide a westbound left-turn only lane at the Valley Center Road/Molly 

Anne Court intersection (entering into Citrus Point Subdivision). 

 The Tribe shall make a fair share contribution into the County Traffic Impact Fee 

Program to reduce potential cumulative traffic impacts on Valley Center Road, 

between Cole Grade Road and Lake Wohlford Road; Lake Wohlford Road, 

between Valley Center Road and Guejito Road; and Cole Grade Road, between 

Valley Center Road and Fruitvale Road, to a less than significant level. 

Public Services 

 Any construction equipment that normally includes a spark arrester shall be 

equipped with an arrester in good working order. This includes, but is not limited 

to, vehicles, heavy equipment, and chainsaws. 

 During construction, staging areas, welding areas, or areas slated for development 

using spark-producing equipment would be cleared of dried vegetation or other 

materials that could serve as fire fuel. To the extent feasible, the contractor shall 

keep these areas clear of combustible materials in order to maintain a firebreak. 

 Structural fire protection shall be provided through compliance with the 

International Fire Code requirements for commercial structures of this size. The 

Tribe shall ensure that appropriate water supply and pressure is available for 

emergency fire flows. 

 Typical fire flow allowances shall be confirmed with the local Fire Marshall prior 

to construction water tank storage if constructed. 
9

 For the gas station, the Tribe shall create and maintain a facility equipped with the 

latest early detection systems that insure an initial response to any fire alarm 

(automatic, local, or report). This shall rely on automatic sprinkler systems in the 

areas of the facility that are normally unoccupied, such as storerooms and 

mechanical areas. 

 Residents of the property will be required to participate in any future water 

conservation measures that may be adopted by the District. 

 The project shall be subject to the District’s Administrative Code including but 

not limited to Article 160 regarding Water Service, Article 190 Developer Project 

Requirements, Article 175 regarding Recycled Water, and Article 230 regarding 

Water Supply Shortage Conditions. 

Noise 

 Construction shall be limited to between the hours of 7am and 7pm Monday 

through Saturday. 

 During construction, stationary equipment and staging areas shall be located as far 

as practical from noise sensitive receptors. 

 All construction vehicles or equipment, fixed or mobile, shall be equipped with 

properly operating and maintained mufflers and acoustical shields or shrouds, in 

accordance with manufacturers’ recommendations. 

 The general contractors for all construction activities shall provide a contact 

number for citizen complaints and a methodology for dealing with such 

complaints such as designating a noise disturbance coordinator. This noise 

disturbance coordinator shall receive all public complaints about constructionrelated noise and vibration, shall be responsible for determining the cause of the 

complaint, and shall implement any feasible measures to be taken to alleviate the 

problem. 

 A sound wall shall be constructed along the southern border of the Site prior to 

other improvements on the site to greatly reduce noise impacts to the adjacent 

Valley Center School and residences. The height, length, placement, and 

construction of the sound wall shall be designed to reduce noise levels from 

construction and operation to below the federal standard at nearby sensitive noise 

receptors. The sound wall shall be of at least eight feet in height to provide an 

attenuation level of 8 dBA, as noise attenuates at approximately one dBA per 

vertical foot (Caltrans, 2009). 

Hazardous Materials 

 A worksite safety plan shall be prepared for construction 

 Secondary containment shall be stressed for the handling and storage of all 

hazardous materials. 

 Mitigation provided under Water Resources would minimize impacts to 

stormwater from hazardous materials handling during construction activities. 

Visual Resources 

 The Proposed Action should employ only shielded low-pressure sodium cutoff 

light fixtures, which will conform to San Diego County Dark Sky Ordinance. 

ATTACHMENTS
ATTACHMENT A 

COMMENTS ON THE

DRAFT ENVIRONMENTAL ASSESSMENT FOR THE 

9-ACRE FEE-TO-TRUST AND RETAIL PLAZA PROJECT
ATTACHMENT A 

COMMENTS ON DRAFT ENVIRONMENTAL ASSESSMENT 

This attachment to the response to comments provides all of the comments received by the BIA during 

the public review period for the Draft Environmental Assessment for the 9 Acre Site San Pasqual Band of 

Diegueño Mission Indians (April, 2010). The comments presented herein were submitted by way of letter 

and email. A total of nine comment letters were received by the BIA: five from public agencies or 

organizations and four from private citizens and groups. All of the comments received are indexed in 

Table A1-1. The comment letters are presented immediately after the comment index. 

Table A1-1: Index of All Comments Received on the Draft EA. 

Letter No. Name Agency / Organization Date of Letter 

1 Chandra L. Walker Deputy Chief Administrative Officer, San Diego 

County 

June 4, 2010 

2 Leal Montgomery Chair, Valley Center Design Review Board June 1, 2010 

3 Dr. Lou Obermayer Superintendent, Valley Center Pauma Unified School 

District 

June 2, 2010 

4 Dave Singleton Program Analyst, Native American Heritage 

Commission 

May 12, 2010 

5 Oliver Smith & Paul 

Herigstad Valley Center Community Planning District June 7, 2010 

6 Bill Trok Senior Pastor, Ridgeview Church June 7, 2010 

7 Irma Montejano June 11, 2010 

8 Amy Archipov June 11, 2010 

9 Robert J. Caven, Jr. June 11, 2010 









































































ATTACHMENT B 

RESPONSE TO COMMENTS ON THE

DRAFT ENVIRONMENTAL ASSESSMENT FOR THE 

9-ACRE FEE-TO-TRUST AND RETAIL PLAZA PROJECT
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ATTACHMENT C 

FINAL ENVIRONMENTAL ASSESSMENT FOR THE 

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Table of Contents 

San Pasqual 9 Acre Fee‐to‐Trust i August 2010 

Final Environmental Assessment

Table of Contents 

Section 1 INTRODUCTION ....................................................................................................... 1-1 

1.1 Introduction ...................................................................................................................... 1-1 

1.2 Background ...................................................................................................................... 1-1 

1.3 Location and Setting ........................................................................................................ 1-2 

1.4 Purpose and Need for the Proposed Action ..................................................................... 1-5 

1.5 Overview of the Environmental Review Process ............................................................ 1-5 

1.6 Environmental Issues Addressed ..................................................................................... 1-7 

1.7 Regulatory Requirements and Approvals ........................................................................ 1-8 

Section 2.0 PROPOSED ACTION AND ALTERNATIVES ..................................................... 2-1 

2.1 Proposed Acton ................................................................................................................ 2-1 

2.2 No-Action Alternative ..................................................................................................... 2-6 

2.3 Alternatives Eliminated from Consideration: Reduced Intensity. ................................... 2-8 

2.4 Comparison of the Proposed Action and the Project Alternatives .................................. 2-9 

Section 3.0 DESCRIPTION OF THE AFFECTED ENVIRONMENT ...................................... 3-1 

3.1 Land Resources ................................................................................................................ 3-1 

3.1.1 Topography (land forms, drainage, gradients) ........................................................... 3-1 

3.1.2 Geologic Setting and Seismicity ................................................................................ 3-2 

3.1.3 Soils (type, characteristics) ........................................................................................ 3-2 

3.2 Water Resources .............................................................................................................. 3-5 

3.2.1 Surface Water, Drainage, and Flooding ..................................................................... 3-5 

3.2.2 Climate & Precipitation ............................................................................................. 3-7

3.2.3 Water supply and Groundwater ................................................................................. 3-9 

3.2.4 Wastewater Treatment ............................................................................................... 3-9 

3.2.5 Water Quality ............................................................................................................. 3-9 

3.3 Air Quality ..................................................................................................................... 3-11 

3.3.1 Project Area and Vicinity ......................................................................................... 3-11 

3.3.2 Regulatory Context .................................................................................................. 3-12 

3.3.3 Pollutants of Concern ............................................................................................... 3-15 

3.3.4 Sensitive Receptors .................................................................................................. 3-16 
 Table of Contents 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment ii 

3.4 Biological Resources ..................................................................................................... 3-16 

3.4.1 Regulatory Setting ................................................................................................... 3-17 

3.4.2 Habitat Types ........................................................................................................... 3-18 

3.4.3 Potential Waters of the U.S ...................................................................................... 3-19 

3.4.4 Federal Listed Special Status Species ...................................................................... 3-19 

3.4.5 Migratory Birds and Birds of Prey ........................................................................... 3-21 

3.5 Cultural Resources ......................................................................................................... 3-21 

3.5.1 Prehistoric and Ethnographic Setting ....................................................................... 3-21 

3.5.2 Findings.................................................................................................................... 3-25 

3.5.3 Regulatory Background ........................................................................................... 3-26 

3.5.4 Native American Consultation ................................................................................. 3-28 

3.6 Socioeconomic Conditions/ Environmental Justice ....................................................... 3-28 

3.6.1 San Diego County .................................................................................................... 3-28 

3.6.2 Demographic Trends ................................................................................................ 3-29 

3.6.3 Property Taxes ......................................................................................................... 3-29 

3.6.4 Lifestyle and Cultural Values .................................................................................. 3-29 

3.6.5 Environmental Justice for Minority and Low Income Populations ......................... 3-30 

3.7 Transportation and Circulation ..................................................................................... .3-30 

3.8 Land Use ........................................................................................................................ 3-34 

3.9 Public Services ............................................................................................................... 3-36 

3.9.1 Water Supply ........................................................................................................... 3-36 

3.9.2 Wastewater Services ................................................................................................ 3-36

3.9.3 Solid Waste .............................................................................................................. 3-37 

3.9.4 Electricity and Telecommunications ........................................................................ 3-37 

3.9.5 Law Enforcement ..................................................................................................... 3-37 

3.9.6 Fire Protection and Emergency Medical ................................................................. .3-38 

3.10 Noise .......................................................................................................................... 3-38 

3.10.1 Acoustical Background and Terminology ............................................................. 3-38 

3.10.2 Regulatory Environment ........................................................................................ 3-40 

3.10.3 Existing Noise Sources .......................................................................................... 3-42 
 Table of Contents 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment iii 

3.11 Hazardous Materials .................................................................................................... 3-42 

3.12 Visual Resources .......................................................................................................... 3-43 

Section 4 ENVIRONMENTAL CONSEQUENCES .................................................................. 4-1 

4.1 Alternative A – Proposed Action ..................................................................................... 4-1 

4.1.1 Land Resources .......................................................................................................... 4-1 

4.1.2 Water Resources ........................................................................................................ 4-1 

4.1.3 Air Quality ................................................................................................................. 4-3 

4.1.4 Biological Resources ................................................................................................. 4-8 

4.1.5 Cultural Resources ..................................................................................................... 4-9 

4.1.6 Socioeconomic Conditions/Environmental Justice .................................................... 4-9 

4.1.7 Transportation and Circulation ................................................................................ 4-11 

4.1.8 Land Use .................................................................................................................. 4-16 

4.1.9 Public Services ......................................................................................................... 4-16 

4.1.10 Noise ...................................................................................................................... 4-18 

4.1.11 Hazardous Materials .............................................................................................. 4-21 

4.1.12 Visual Resources .................................................................................................... 4-22 

4.1.13 Public Safety and Health ........................................................................................ 4-23 

4.2 No Action Alternative .................................................................................................... 4-23 

4.2.1 Land Resources ........................................................................................................ 4-23 

4.2.2 Water Resources ...................................................................................................... 4-23 

4.2.3 Air Quality ............................................................................................................... 4-24 

4.2.4 Biological Resources ............................................................................................... 4-24 

4.2.5 Cultural Resources ................................................................................................... 4-24 

4.2.6 Socioeconomic Conditions ...................................................................................... 4-24 

4.2.7 Noise ........................................................................................................................ 4-24 

4.2.8 Visual and Scenic Resources ................................................................................... 4-24 

4.2.9 Transportation and Circulation ................................................................................ 4-24 

4.2.10 Public Services ....................................................................................................... 4-25 

4.2.11 Hazardous Materials .............................................................................................. 4-25 

4.3 Cumulative Effects......................................................................................................... 4-25 
 Table of Contents 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment iv 

4.3.1 Land Resources ........................................................................................................ 4-25 

4.3.2 Water Resources ...................................................................................................... 4-25 

4.3.3 Air Quality ............................................................................................................... 4-26 

4.3.4 Biological Resources ............................................................................................... 4-26 

4.3.5 Cultural Resources ................................................................................................... 4-26 

4.3.6 Socioeconomic Conditions/ Environmental Justice ................................................. 4-26 

4.3.7 Transportation and Circulation ................................................................................ 4-27 

4.3.8 Land Use .................................................................................................................. 4-27 

4.3.9 Agriculture ............................................................................................................... 4-27 

4.3.10 Public Services ....................................................................................................... 4-27 

4.3.11 Noise ...................................................................................................................... 4-28 

4.3.12 Hazardous Materials .............................................................................................. 4-28 

4.3.13 Visual Resources .................................................................................................... 4-28 

Section 5.0 MITIGATION MEASURES .................................................................................... 5-1 

5.1 Land Resources ................................................................................................................ 5-1 

5.2 Water Resources .............................................................................................................. 5-1 

5.3 Air Quality ....................................................................................................................... 5-4 

5.4 Biological Resource ......................................................................................................... 5-4 

5.5 Cultural Resources ........................................................................................................... 5-5 

5.6 Socioeconomic Conditions/ Environmental Justice ......................................................... 5-5 

5.7 Transportation and Circulation ........................................................................................ 5-6 

5.8 Land Use .......................................................................................................................... 5-7 

5.9 Agriculture ....................................................................................................................... 5-7 

5.10 Public Services ............................................................................................................... 5-7 

5.11 Noise ............................................................................................................................ 5-7 

5.12 Hazardous Materials ...................................................................................................... 5-8 

5.13 Visual Resources ............................................................................................................ 5-8 

Section 6.0 REFERENCES ......................................................................................................... 6-1 

Section 7.0 LIST OF PREPARERS............................................................................................. 7-1 
 Table of Contents 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment v 

List of Figures 

Figure 1-1: Regional Location ..................................................................................................... 1-3 

Figure 1-2: Site and Vicinity........................................................................................................ 1-4 

Figure 1-3: Aerial View Map ....................................................................................................... 1-6 

Figure 2-1: Proposed Action Site Plan......................................................................................... 2-2 

Figure 2-2: No Action Site Plan ................................................................................................... 2-7 

Figure 3-1: Regional Fault Map ................................................................................................... 3-3 

Figure 3-2: Site Soil Map ............................................................................................................. 3-4 

Figure 3-3: Site Drainage Patterns ............................................................................................... 3-6 

Figure 3-4: FEMA Flood Zones .................................................................................................. 3-8 

Figure 3-5: Well Data Map ........................................................................................................ 3-10 

List of Tables 

Table 2-1: Proposed Retail Plaza Components ............................................................................ 2-3 

Table 3-1: Soils Map Units .......................................................................................................... 3-2 

Table 3-2: Site Groundwater Data ............................................................................................... 3-9 

Table 3-3: Ambient Air Quality ................................................................................................. 3-13 

Table 3-4: San Diego Race/Income Profile ............................................................................... 3-30 

Table 3-5: Existing Traffic Volumes ......................................................................................... 3-32 

Table 3-6: Intersection Level of Service .................................................................................... 3-33 

Table 3-7: Roadway Segment Level of Service ........................................................................ 3-34 

Table 3-8: Typical A-Weighted Sound Levels of Common Noise Sources .............................. 3-39 

Table 3-9: Typical A-Weighted Sound Levels .......................................................................... 3-40 

Table 3-10: Federal Noise Abatement Criteria (Hourly – DBA Soundlevel) ........................... 3-41 

Table 3-11: Scenic Quality Rating Summary ............................................................................ 3-46 

Table 3-12: Overall Viewer Sensitivity ..................................................................................... 3-47 

Table 4-1: Unmitigated Construction Emissions – Proposed Action .......................................... 4-4 

Table 4-2: Unmitigated Operation Emissions – Proposed Action ............................................... 4-5 

Table 4-3: Greenhouse Gas CO2 Equivalent ............................................................................... 4-7 

Table 4-4: Proposed Action Project Related GHG Emissions..................................................... 4-8 

Table 4-5: Trip Generation ........................................................................................................ 4-13 

Table 4-6: Intersection Level of Service .................................................................................... 4-14 

Table 4-7: Street Segment Level of Service .............................................................................. 4-15 

Table 4-8: Typical Construction Noise Levels .......................................................................... 4-19 

Table 4-9: Reference and Predicted PPV from Construction .................................................... 4-20 

Table 5-1: Summary of Environmental Impacts .......................................................................... 5-9 

Appendices 

Appendix A Publication Notices 
 Table of Contents 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment vi 

Appendix B VCMWD Will Serve Letter 

Appendix C Grading/Drainage Plan 

Appendix D Biological Resource Reports (2009 Biological Assessment and 2010 Biological 

Technical Memorandum) 

Appendix E United States Fish & Wildlife Services Data File 

Appendix F Cultural Resource Inventory – Confidential (Bound Under Separate Cover) 

Appendix G Supplemental Cultural Resources Information (SHPO Concurrence Letter and 

Cultural Resources Report Addendum) 

Appendix H Traffic Impact Analysis 

Appendix I Bureau of Land Management Manual 8410 Visual Resources Inventory 

Guidelines 

Appendix J URBEMIS Files
Introduction 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 1-1

Section 1 INTRODUCTION 

1.1 Introduction 

This Final Environmental Assessment (EA) has been prepared for the U.S. Bureau of Indian 

Affairs (BIA) to support an application from the San Pasqual Band of Diegueño Mission Indians 

(Tribe) for land to be placed into federal trust (Proposed Action). The BIA is the federal agency 

that is charged with reviewing and approving tribal applications to take land into federal trust 

status. The Proposed Action consists of (1) the transfer of a 9.08 acre site into federal trust status 

for the Tribe and (2) the subsequent development of a portion of the project site into a small 

retail plaza. 

The Draft EA for the proposed San Pasqual Band of Diegueño Mission Indians (Tribe) 9-acre 

Fee-to-Trust and Retail Plaza Project, (GreenWave Inc., April 2010) (SCH #2010054003) was 

submitted to the State Clearinghouse and released for public and agency review for a 30-day 

comment period beginning on May 10, 2010 and ending on June 8, 2010. A Notice of 

Availability was published in the San Diego Union-Tribune and North County Times on May 7 

and 23, 2010, announcing the release of the Draft EA for public review and comment (Appendix 

A). 

This Final EA has been completed in accordance with the requirements set out in the National 

Environmental Policy Act (NEPA) of 1969 (42 U.S.C. §4321 et seq.), the Council on 

Environmental Quality (CEQ) Guidelines for Implementing NEPA, and the BIA’s NEPA 

handbook (59 IAM 3-H). This document provides a detailed description of the Proposed Action 

and an analysis of the potential environmental consequences associated with the development of 

the project. This document also includes a discussion of alternatives, impact avoidance, and 

mitigation measures. Consistent with the requirements of NEPA, the BIA will review and 

analyze the environmental consequences associated with the Proposed Action, and either 

determine that a Finding of No Significant Impact (FONSI) is appropriate, or request that an 

Environmental Impact Statement (EIS) be prepared. 

1.2 Background 

The San Pasqual Band of Indians is one of thirteen Kumeyaay or I’pai bands who traditionally 

inhabited the San Diego County area. The San Pasqual Band was originally populated by 

Indians from the San Diego Mission, the first Mission established in Alta California by Father 

Junipero Serra in 1769. Today, San Pasqual counts Rincon, Pauma, Pala, La Jolla, Mesa Grande, 

Santa Ysabel, and Pechanga as its neighbors, along with non-Indian populations interspersed 

throughout the area. 

In 1970, the San Pasqual Band created an independent arm called the San Pasqual Economic 

Development Agency (“Agency”). The Agency was established to “implement Tribal Economic 

Development programs for the benefit of the Tribal lands and Tribal members.” The Agency 

adopted an Ordinance on November 21, 1999, which provides the procedural structure under 

which the Agency operates. 
Introduction 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 1-2

The San Pasqual Reservation is situated in the Peninsular Mountains, located in the 

unincorporated area of San Diego County known as Valley Center, about 11 miles northeast of 

Escondido. It comprises 1,380 acres consisting of five separate parcels in a semi-checkerboard 

configuration. A network of three County roads, four BIA roads, and nineteen tribal roads serve 

the San Pasqual Reservation. Interstate Route 15 is the major highway serving the area, locating 

17 miles to the West, running in a North/South direction through Escondido. 

The San Pasqual Reservation has no individual allotments of land, and much of the Reservation 

is dedicated to land assignments to tribal members, generally 2.5 or 5 acres per assignment. 

There are approximately 230 residential units on the Reservation. Other developments include 

Valley View Casino with supporting offices, Tribal facilities consisting of administration offices, 

the Gaming Commission offices, a community hall, an education resource center, a fire station, a 

housing and community development office, and environmental protection offices. 

1.3 Location and Setting 

The project site (Assessor’s Parcel Number 189-051-02) addressed in this EA is located in 

Valley Center, California, on the southwest corner of Valley Center Road and North Lake 

Wohlford Road. The project site is located in Section 15 of Township 11 South, Range 1 West, 

on the Rodriguez MT, California U.S. Geological Survey (USGS) 7.5-Minute Topographic 

Quadrangle (quad), San Bernardino Baseline & Meridian. Figure 1-1 shows the regional 

location and Figure 1-2 shows the project site and vicinity. The parcel is described as: 

THAT PORTION OF THE NORTHWEST QUARTER OF SECTION 15, 

TOWNSHIP 11 SOUTH, RANGE 1 WEST, SAN BERNARDINO MERIDIAN, 

IN THE COUNTY OF SAN DIEGO, STATE OF CALIFORNIA, ACCORDING 

TO OFFICIAL PLAT THEREOF, DESCRIBED AS FOLLOWS: 

BEGINNING AT THE SOUTHWEST CORNER OF SAID NORTHWEST 

QUARTER OF THE NORTHWEST OF SECTION 15; THENCE ALONG THE 

SOUTHERLY LINE OF SAID NORTHWEST QUARTER OF NORTHWEST 

QUARTER, NORTH 89o57’20” EAST, 1366.60 FEET TO THE SOUTHEAST 

CORNER OF SAID NORTHWEST QUARTER OF THE NORTHWEST 

QUARTER; THENCE ALONG THE EASTERLY LINE OF SAID 

NORTHWEST QUARTER OF THE NORTHWEST QUARTER, NORTH 

00o20’40” EAST, 1023.76 FEET TO THE TRUE POINT OF BEGINNING; 

THENCE NORTH 89o35’50” WEST, 1361.35 FEET MORE OR LESS, TO THE 

WESTERLY LINE OF SAID SECTION 15; THENCE NORTH 00o38’00” EAST 

TO THE NORTHWEST CORNER OF SAID SECTION 15; THENCE SOUTH 

89o34’00” EAST ALONG THE NORTH LINE OF SAID SECTION 15; TO THE 

NORTHEAST CORNER OF THE NORTHWEST QUARTER OF THE 

NORTHWEST QUARTER OF SAID SECTION 15; THENCE SOUTH 

00o20’40” WEST TO THE TRUE POINT OF BEGINNING. 

EXCEPTING THEREFROM THE WESTERLY 235.00 FEET THEREOF. 

 
^_

PROJECT

SITE

Figure 1-1

Regional Location

SOURCE: ESRI Data, 2007; AES 2010

^_

0 5 10

Miles

SCALE

^_ Project Site

San Diego County

San Pasqual Band 9-acre Fee-to-Trust and Retail Plaza Project EA / 209543
^_

PROJECT

SITE

VALLEY VIEW

CASINO

Valley Center Rd

Lake Wohlford Rd

Woods Valley Rd

LEGEND

0 1,000 2,000

Feet

!¢N O R T H

Ð

San Pasqual Band 9-acre Fee-to-Trust and Retail Plaza Project EA / 209543

9 Acre Site

Figure 1-2

Site and Vicinity

SOURCE: “Rodriguez MT, CA” USGS 7.5 Minute Topographic Quadrangle, 

T11S, R1W, Sections 15; San Bernardino Baseline & Meridian; AES, 2010
Introduction 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 1-5

The Site is located within an area to which the Tribe has strong cultural and historical 

connections, having occupied the area surrounding the Site since 1911 (Eargle, 1986). 

The proposed trust parcel is currently used as an overflow parking lot for the Valley View 

Casino, which is located approximately 0.5 miles to the southeast. Approximately 50 percent of 

the proposed trust parcel is either paved or covered with gravel while the remaining 50 percent 

exists as a vacant lot and contains no unique vegetation or wildlife. Figure 1-3 presents an aerial 

photograph of the project site. 

1.4 Purpose and Need for the Proposed Action 

Opportunities for economic development on the San Pasqual Reservation (Reservation) are 

constrained by the Reservation’s geography. The Reservation consists of approximately 1,380 

acres situated on five separate parcels of land. It is situated primarily on steep and rolling hills; 

only about fifteen percent, or 207 acres, of the Reservation is considered appropriate for 

development. Because of this limitation, the Tribe started purchasing additional lands contiguous 

to and surrounding the Reservation in order to provide an economically viable land base for its 

membership and to increase opportunities for economic development and tribal selfdetermination. 

The proposed action would facilitate Tribal self-determination and economic development, and 

allow the Tribe to exercise sovereignty over lands currently held in fee title. The development of 

a portion of the Site into a small retail plaza would offer important economic development 

opportunities that would support the Tribe’s pursuit of self-determination. It would increase 

tribal revenues and provide employment and managerial experience for tribal members, and 

would help serve the needs of Valley Center from anticipated community growth. 

1.5 Overview of the Environmental Review Process 

This EA has been prepared to analyze and document the environmental consequences associated 

with: 1) the proposed transfer of 9.08 acres of land into federal trust status for the Tribe, and 2) 

the anticipated development of a portion of the Site into a small retail plaza. The BIA will use 

this EA to determine if the Proposed Action would result in significant impacts to the 

environment and whether a Finding of No Significant Impact can be made or an Environmental 

Impact Statement should be prepared. 

This EA is intended to satisfy the environmental review process of 59 IAM 3-H, 40 CFR § 

1501.3, and 40 CFR § 1508.9. The BIA, its internal manual setting forth NEPA procedures, 

recognizes that an EA must meet two sets of requirements: 

• The first set is based on NEPA as amended and the implementing regulations issued by 

the Council on Environmental Quality found in 40 CFR Parts 1500 through 1508, and; 

• The second set is derived from the other statutory and regulatory requirements of various 

Federal agencies such as the U.S. Environmental Protection Agency, the Advisory 

Council on Historic Resources, or the BIA’s own requirements. 

 
Valley Center Rd

Lake Wohlford Rd

Sunset Rd

Viso Thundernut Ln

Station Rd

Sunset Ter

Ahern Ranch Rd

Mary Anne Ct

School Bus Rd

LEGEND

0 250 500

Feet

9 Acre Site

Figure 1-3

Aerial View Map

SOURCE: Aerial Express aerial photograph, 3/2008; AES, 2010 San Pasqual Band 9-acre Fee-to-Trust and Retail Plaza Project EA / 209543
Introduction 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 1-7

1.6 Environmental Issues Addressed 

Preparation of this Final EA has included ongoing consultation with the BIA; the U.S. Fish and 

Wildlife Service, United States Department of Agriculture, U.S. Environmental Protection 

Agency (EPA), Natural Resources Conservation Service (NRCS), South Coastal Information 

Center, and California Native American Heritage Commission. Based on this consultation, a 

review of relevant literature, and field reconnaissance, this Final EA evaluates the following key 

environmental issues associated with the Proposed Action: 

Land Resources 

• The Proposed Action would have impacts on soils at the site in the grading and 

construction phases, and with the permanent change to land surfaces. There would be 

minimal impacts to the site topography since the lands are nearly level. 

Water Resources 

• There would be potential impacts to the affected environment from increased stormwater 

runoff under the proposed action during the construction period. There may be impacts 

to groundwater resources if groundwater is contacted during construction. However, 

groundwater contamination is unlikely at the site. Mitigation measures presented in this 

EA, and the attached Stormwater/ Drainage Report (Appendix C) are presented to help 

minimize impacts to the site and the surrounding area. 

Air Quality 

• The proposed action would result in the emission of criteria air pollutants from 

construction and mobile emissions. Further, the permanent presence of a gas station at 

the Site could create potential impacts from gasoline fume emission that could affect air 

quality at the site. 

Biological Resources 

• There would be impacts to existing vegetation at the Site as a result of the proposed 

action. However, there are no known endangered or special status species at the Site, so 

impacts to living resources would be small. An analysis of existing living resources at 

the Site, and possible impacts are discussed in this EA and in the attached Biological 

Resources Reports (Appendix D). 

Cultural Resources 

• A cultural assessment has been completed at the site and mitigation measures that would 

minimize potential impacts to unanticipated discoveries are discussed within this EA. 

Socioeconomic Conditions 

• The proposed action would have a positive effect on current socioeconomic conditions in 

the surrounding area. The Tribe would benefit from increased revenues that they could 

use to invest in programs to help improve living conditions for Tribal members and the 

surrounding community. 
Introduction 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 1-8

Noise 

• There could be impacts to local sensitive receptors from the proposed action during the 

construction period, and on a permanent basis with the presence of a multi-use retail 

facility at the site. Mitigation measures that would minimize anticipated impacts are 

discussed in this EA. 

Visual and Scenic Resources 

• The proposed action could create small view impacts to the affected environment. 

Mitigation measures that would minimize anticipated impacts are discussed in this EA.

Traffic 

• The proposed action would lead to increased traffic flow at the site, and within the 

surrounding transportation corridors. Detailed traffic circulation impacts, as well as 

mitigation measures to minimize these impacts, are presented in this EA, and in the 

attached site-specific Traffic Analysis (Appendix H). 

1.7 Regulatory Requirements and Approvals 

The following direct and indirect agency approvals and actions may be required for 

implementation of the Proposed Action: 

• Transfer of the 9.08-acre site into Federal trust status for the Tribe by the Secretary of the 

Interior. 

• USEPA approval of an application for an NPDES General Permit for Storm Water 

Discharges Associated with Construction Activity. 

• Consultation with the State Historic Preservation Office under Section 106 of the 

National Historic Preservation Act, if cultural resources may be impacted by the project. 

• Approval of encroachment permits by the County Departments of Planning and Land Use 

and Public Works for off-site roadway improvements. 

• Consultation with the Valley Center-Pauma Unified School District regarding the 

realignment design of School Bus Road. 
Proposed Action and Alternatives 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 2-1

Section 2 PROPOSED ACTION AND ALTERNATIVES 

The Proposed Action and project alternatives are described in this section. This section also 

summarizes the potential environmental consequences associated with each alternative as well as 

the protective measures and Best Management Practices (BMPs) incorporated into the project to 

reduce potential adverse impacts to environmental resources. A summary of each development 

alternative and associated components is provided below. The project alternatives evaluated in 

the Environmental Assessment (EA) include: 

• Proposed Action – Placement of a 9.08 acre parcel into federal trust and the subsequent 

development of a retail plaza; 

• No-Action Alternative – Development of a parking lot on the eastern portion of the site; 

and 

• Other alternatives eliminated from consideration. 

2.1 Proposed Action 

The Proposed Action consists of two main components: (1) placing one parcel of 9.08 acres into 

Federal trust status, and (2) development of a portion of the Site into a small retail plaza. The 

Proposed Action is described in more detail below. 

Land Into Trust Action 

The Proposed Action consists of the fee simple conveyance of the 9.08-acre site into Federal 

trust status for the benefit of the Tribe. The land transfer would be in accordance with 

procedures set forth in 25 CFR § 151.3 and involves numerous steps. The trust action would 

shift civil regulatory jurisdiction over the 9.08 acres from the State of California and San Diego 

County to the Tribe and the federal government; the State and County would continue to exercise 

criminal jurisdiction under 18 U.S.C. § 1162 and other federal laws pertaining to jurisdiction in 

Indian country. 

Proposed Development 

The Tribe intends to develop a small retail plaza on the eastern portion of the Site. The retail 

plaza is expected to contain a commercial building, a restaurant, and a gas station. These 

components are shown in Table 2-1. The remainder of the Site would continue to be utilized as 

an overflow parking area for the Valley View Casino. A guard shack and two shuttle stops will 

be located within the parking lot. School Bus Road would be realigned so that it runs from 

Valley Center Road south along the western border of the site then east along the southern 

boundary of the site until it exits the Site. The site plan for the proposed development is shown 

in Figure 2-1. 

It should be noted that once the Federal government acquires the land in trust for the Tribe, trust 

land would not be subject to municipal land use regulations. Only Tribal land use regulations are 
SOURCE: Howard Parsell Company, 2009; AES, 2010
Proposed Action and Alternatives 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 2-3

applicable on trust lands. The Tribal Government relies upon the Tribal Council, the governing 

body of the Tribal Government, to guide and regulate land use on Tribal lands. However, the 

Tribal Government wishes to work cooperatively with local communities, and to the extent 

feasible, intends to develop the property in manner reasonably consistent with adopted County 

and Valley Center design guidelines and ordinances. 

Access to the retail plaza and parking lot would be provided via one full access driveway on 

Valley Center Road and one right-turn in/out only driveway on Lake Wohlford Road. No access 

to the retail plaza or parking lot will be available through the realigned one-way School Bus 

Road. 

The Tribe would enter into a lease with the Casino Board for the use of this land, which the San 

Diego County Board of Supervisors has recently re-zoned for parking use (Special PurposeParking (S86)). This type of structure provides the Tribe additional flexibility regarding land 

management. 

 Table 2-1: Proposed Retail Plaza Components 

Component Approximate Square 

Footage 

Commercial Building 27,600 

Restaurant 8,800 

Gas Station with Canopy 25,500 

Total 61,900

Source: AES, 2010.

Public Services 

Through an existing contractual agreement with the Tribe, the San Diego County Sheriff’s 

Department would provide law enforcement services to the site. Fire protection services would 

be provided by the Valley Center Fire Protection District and the San Pasqual Reservation Fire 

Department. The Valley Center Fire Protection District has three fire rescue stations within the 

vicinity of the site, and the San Pasqual Reservation Fire Department also has a fire station 

located approximately one mile south of the site at 16150 Kumeyaay Way. These facilities 

would provide fire protection and emergency medical services. Solid waste collection would be 

provided through contract with the regional solid waste collector. Electric and telephone 

services would be extended to the site as needed. 

The following best management practices would be included as part of the Proposed Action to 

minimize the risk of fire during construction: 

• Any construction equipment that normally includes a spark arrester would be equipped 

with an arrester in good working order. This includes, but is not limited to, vehicles, 

heavy equipment, and chainsaws. 
Proposed Action and Alternatives 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 2-4

• During construction, staging areas, welding areas, or areas slated for development using 

spark-producing equipment would be cleared of dried vegetation or other materials that 

could serve as fire fuel. To the extent feasible, the contractor would keep these areas 

clear of combustible materials in order to maintain a firebreak. 

• Structural fire protection would be provided through compliance with the International 

Fire Code requirements for commercial structures of this size. The Tribe would ensure 

that appropriate water supply and pressure is available for emergency fire flows. 

• Typical fire flow allowances would be confirmed with the local Fire Marshall prior to 

construction water tank storage if constructed. 

• For the gas station, the Tribe would create and maintain a facility equipped with the latest 

early detection systems that insure an initial response to any fire alarm (automatic, local, 

or report). This would rely on automatic sprinkler systems in the areas of the facility that 

are normally unoccupied, such as storerooms and mechanical areas. 

Water Supply 

Water will be supplied to the site by the Valley Center Municipal Water District (VCMWD) via 

an existing one-inch water line and meter set on the northern border of the site which is fed from 

an 8-inch district water line (see Will Serve letter included as Appendix B). This water meter is 

an active account and is assigned a Commercial user code (Valley Center Municipal Water 

District Communication, 2009). VCMWD has indicated that facilities to serve the Proposed 

Action are reasonably expected to be available within the next five years based on the capital 

facility plans of the VCMWD. However, given the long term hydrologic, legal, and regulatory 

conditions impacting water supplies from the State Water Project and Colorado River, there is a 

possibility that VCMWD may not have capacity to serve the project in the future. Groundwater 

resources or privately purchased water may be utilized to serve the water demands of the 

Proposed Action in the future. 

Wastewater Treatment and Disposal 

Wastewater generated from the proposed retail plaza would be directed to a 20,000-gallon onsite raw wastewater holding tank that would be constructed beneath the parking lot on the 

western portion of the site. The raw wastewater would be pumped from the holding tank and 

trucked, as required, to the Tribe’s wastewater treatment facility at the Valley View Casino. 

Grading and Drainage 

All structures would meet the California Building Code requirements for the site; including the 

seismic design criteria of the most recent edition of the International Building Code for Seismic 

Zone 4. Prior to finalization of the grading and development plans for the property, design-level 

geotechnical specifications addressing the specific grading and development plans shall be 

developed. The specifications should include, but not be limited to, the following: 

• Site, building and facility-specific grading recommendations regarding site preparation, 

clearing and grubbing. 
Proposed Action and Alternatives 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 2-5

• Select grading procedures, remedial grading procedures, material suitability and 

compaction criteria. 

• Cut and fill slope stability analyses, recommend slope configurations and inclinations. 

• Evaluation of soil expansion and corrosion potential. 

• Building-specific foundation design parameters. 

• Site-specific seismic design parameters. 

• Lateral earth pressure parameters for retaining wall design, if any. 

• Pavement design specifications. 

A detailed drainage plan would be prepared by a registered civil engineer prior to site 

development that shall include the following items: 

• An accurate calculation of pre- and post-development runoff conditions shall be 

performed using appropriate hydraulic models. 

• Vegetated detention swales shall be constructed according to the engineer’s 

recommendations and engineering specifications to mitigate for increased peak flows 

from impervious surfaces. The following recommendations from EPA Publication 832-

F-99-006 (EPA, 1999) would be followed to the extent feasible. 

o Construction: 

• Swales should be constructed with the suggested ratio of 500 square feet of 

swale per acre of impervious surface. 

• Location of swales should include areas adjacent to parking areas, adjacent to 

roadways, and along property boundaries along a natural grade. 

• Swales should utilize a parabolic or trapezoidal cross-section with side slopes 

no steeper than 1:3. 

• Check dams should be used every 50 feet if slopes exceed 4 percent. 

o Operation: 

• Maintenance activities should include periodic mowing (with grass kept above 

design flow depth), weed control, watering during drought, reseeding of bare 

areas, clearing of debris and blockages. 

• Accumulated sediment should be removed manually to avoid the transport of 

re-suspended sediments in periods of low flow and prevent damming effects 

from sand bars. 

• Fertilizer and pesticide use should be minimized. 

The Tribe would submit a National Pollutant Discharge Elimination System (NPDES) General 

Construction Permit to the U.S. Environmental Protection Agency (EPA). Additionally, the 

Tribe would submit development plans to the County of San Diego Development Services for 

approval of any necessary off-site improvements and encroachment permits. The plans would 

include the site-specific stormwater drainage plan. 
Proposed Action and Alternatives 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 2-6

Roadway Improvements 

Roadway improvements would be constructed at the site to provide proper access to the 

proposed facilities. Encroachment permits (if needed) would be submitted to the County of San 

Diego to construct suitable access to the Site. 

Project Construction 

The project components would be constructed after the site has been placed in federal trust. 

Construction would involve earthwork, placement of concrete foundations, steel and wood 

structural framing, masonry, electrical and mechanical work, building finishing, and paving, 

among other construction trades. The following measures would be incorporated into 

construction operations at the site: 

• A worksite safety plan would be prepared for construction 

• Secondary containment would be stressed for the handling and storage of all hazardous 

materials. 

Generation of construction-related emissions is considered a short-term nuisance impact. The 

following Best management Practices (BMPs) would be implemented to reduce these temporary 

construction emissions. 

• The project owner shall designate an on-site Air Quality Construction BMP Manager 

(AQCBM) who shall be responsible for directing compliance with BMPs for the project 

construction heavy-duty equipment. The AQCBM shall be responsible for directing 

compliance with the following BMPs for fugitive dust control practices during project 

construction: 

o For any earth moving activities which would occur more than 100 feet from the 

subject property boundaries, conduct watering and/or cover as necessary to 

prevent visible dust emissions from exceeding 100 feet in length in any direction 

o For all disturbed surface areas apply dust suppression in a sufficient quantity and 

frequency to maintain a stabilized surface; any areas, which cannot be stabilized, 

as evidenced by wind driven dust, must have an application of water at least twice 

per day, and/or covered. 

o Establish a vegetative ground cover as soon as feasible after active operations 

have ceased. 

o For all unpaved roads either water all roads used for any vehicular traffic as often 

as necessary to minimize dust; or apply chemical stabilizer to all unpaved road 

surfaces on sufficient quantity and frequency to maintain a stabilized surface. 

o Provide track-out control to minimize tracking of soil onto neighboring roadways. 

o For all off site haul vehicles, cover loads. 

2.2 No Action Alternative 

Under the No-Action Alternative, the 9.08-acre site would not be placed into trust for the benefit 

of the Tribe. The Tribe would develop the eastern half of the site as a 143-space parking lot, 

with ancillary structures, in accordance with the Site Plan for the Valley View Casino Employee 
San Pasqual Band 9-acre Fee-to-Tru

SOURCE: Wynn Engineering, 2009; Jones & Stokes, 2009; AES, 2010

SCALE

NORTH 0 40’ 80’
Proposed Action and Alternatives 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 2-8

Parking Lot (Site Plan Number 06-004), hereafter referred to as Site Plan 06-004. The grading, 

drainage, and striping plan drawing for Site Plan 06-004 is depicted in Figure 2-2. All of the 

conditions of approval and mitigation measures included within Site Plan 06-004 would be 

adhered to by the Tribe under this alternative. The western half of the site would remain 

undeveloped. An Initial Study for Site Plan 06-004 was completed in accordance with CEQA in 

May 2008. A Negative Declaration was adopted on July 10, 2008. Site Plan 06-004 was 

approved by the County of San Diego Director of Planning and Land Use on May 22, 2009. 

The No-Action alternative would not provide economic development for the Tribe, which would 

not increase tribal revenues. Nor would it provide employment and managerial experience for 

tribal members. Under the No-Action alternative, the retail plaza would not exist and thus would 

not be able to help alleviate need in the surrounding community for certain neighborhood serving 

retail stores and other amenities. 

2.3 Alternative Eliminated from Consideration: Reduced Intensity 

The Reduced-Intensity Alternative would include (1) placing the 9.08-acre site into trust for the 

benefit of the Tribe, similar to the Proposed Action, and (2) the subsequent expansion of the 

existing overflow parking lot for the Valley View Casino. This alternative would expand the 

parking lot to cover the entire 9.08 acre parcel, but would not include any additional commercial 

development. While this alternative would provide additional parking for the Valley View 

Casino patrons and employees, it would not significantly enhance the economic conditions of the 

San Pasqual Indian Reservation. Nor would it provide new employment opportunities and 

managerial experience for tribal members. Expansion of the parking lot would only benefit the 

Valley View Casino and would not benefit the surrounding community, as would a small retail 

plaza. Because development of a portion of the Site into a small retail plaza would be more 

economically beneficial to the Tribe and would better provide for the needs of the surrounding 

community, the Overflow Parking Lot Expansion Alternative is not considered a reasonable 

alternative, and is hereby eliminated from further analysis in this EA. 

Public Services 

Public service providers would be the same as those listed for the Proposed Action. Best 

management practices for reducing the risk of fire would be implemented as for the Proposed 

Action, with the exception of those applying solely to the commercial development. 

Water Supply and Wastewater Facilities 

Since the Reduced-Intensity Alternative would include the expansion of the existing parking lot 

at the site, the existing municipal water source may be temporarily advanced and utilized to 

supply water during the construction period. However, long-term water usage would not be 

anticipated to occur at the site. 

Grading and Drainage 

Grading and drainage would be similar to that described for the Proposed Action, 
Proposed Action and Alternatives 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 2-9

Roadway Improvements 

There would be additional roadway construction at the Site to create access to the western 

portion of the parcel, as well as an additional ingress/ egress point onto the site from Valley 

Center Road. All access points and traffic flow patterns at the Site would be submitted to the 

City of San Diego Development Services for approval. 

Project Construction 

Project construction under the Reduced-Intensity Alternative would involve minor grading work, 

the expansion of the existing parking lot, as well as the construction of a new road to provide 

access to the expanded parking lot. The contractor would need to design a new drainage plan to 

accommodate new surface water flow patterns at the Site. The same BMPs and construction 

mitigation measures described in the Proposed Action would be instituted under the ReducedIntensity Alternative. 

2.4 Comparison of the Proposed Action and the Project Alternatives 

Proposed Action 

The Proposed Action would create some moderate, but mitigable environmental effects 

associated with the following areas: 

• Air Quality 

• Noise 

• Water Resources 

• Traffic 

• Visual Resources 

The Proposed Action would best meet the Tribe’s objectives by facilitating Tribal selfdetermination and economic development, and allowing the Tribe to exercise sovereignty over 

lands currently held in fee title. The development of a portion of the site into a small retail plaza 

would offer important economic development opportunities that would support the Tribe’s 

pursuit of self-determination. It would increase tribal revenues and provide employment and 

managerial experience for tribal members, and would help serve the needs of Valley Center from 

anticipated community growth. 

No-Action Alternative 

While the No-Action Alternative would result in respectively less potentially adverse 

environmental effects than identified for the Proposed Action, the No-Action alternative would 

not provide economic development for the Tribe, which would not increase tribal revenues, nor 

would it provide employment and managerial experience for tribal members. Under the NoAction alternative, the retail plaza would not exist and thus would not be able to help alleviate 

need in the surrounding community for certain stores and other needs. The No-Action 

Alternative would not meet the purpose and need for the Proposed Action. 
Proposed Action and Alternatives 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 2-10

Reduced-Intensity Alternative 

The Reduced-Intensity Alternative would generally result in similar short-term environmental 

impacts, and less long-term impacts when compared to the Proposed Action. However this 

alternative would not meet the Tribe’s objective of generating increased revenues through the 

creation of new jobs and services that would help the Tribe to become more self sufficient, and 

add a wider range of services to the local community. Therefore, the reduced alternative has 

been eliminated from detailed consideration within this EA as it would not meet the purpose and 

need for the Proposed Action. 
Description of the Affected Environment 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 3-1

Section 3 DESCRIPTION OF THE AFFECTED ENVIRONMENT 

This section presents relevant information about existing resources and other values that may be 

affected by the Proposed Project and alternatives. In accordance with the National 

Environmental Policy Act (NEPA) and the Bureau of Indian Affairs’ (BIA) implementing 

guidelines (59 IAM 3-H), the existing conditions described herein provide the base line for 

determining the environmental effects identified in Section 4.0. Descriptions include the 

following resource and issue areas: 

• Land Resources 

• Water Resources 

• Air Quality 

• Biological Resources 

• Cultural Resources 

• Socioeconomic Conditions / Environmental Justice 

• Transportation and Circulation 

• Land Use 

• Public Services 

• Noise 

• Hazardous Materials 

• Visual Resources 

3.1 Land Resources 

The site is currently used as an overflow parking lot for the Valley View Casino. The site 

occupies 9.08 acres of land in Valley Center, California. Approximately 20 percent of the site is 

covered with pavement, and approximately 30 percent of the site is covered with gravel and a 

thin layer of asphalt. The remaining 50 percent of the site is vacant land and is unimproved. 

There are no existing structures on the site. 

3.1.1 Topography (land forms, drainage, gradients) 

The 1997 United States Geological Survey (USGS) Topographic Map of the area shows the site 

as generally flat with an elevation of approximately 1,520 feet above mean sea level (msl). The 

site is approximately 1,650 feet southeast of an unnamed creek and approximately 3,000 feet 

southwest of a second unnamed creek. There are no surface water bodies on the site or adjacent 

to the site. There are no other significant topographic features near the site. 

There are no municipal storm drains on or in the vicinity of the site. The only stormwater 

infrastructure on the property at this time besides the roads, curbs, and gutters is the culvert 

under School Bus Road. This culvert conducts water from the eastern portion of the property to 

the western portion. Stormwater drains to a low area in the southwest corner of the property and 

flows off property on the southern boundary. 
Description of the Affected Environment 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 3-2

3.1.2 Geologic Setting and Seismicity 

The site is located in the Coastal Plain/Foothill providence of San Diego County. The geologic 

history of the area generally consists of Pre-Cretaceous metasedimentary rocks intruded by 

Mesozoic granitic plutons. Based on the Geologic Map of California (1965), the site sits atop 

igneous mesozoic granitic rocks, primarily tonolite and diorite. The site lies within the 

International Building Code Seismic Zone 4, or high probability for a major seismic event. 

While Southern California is well known for seismic activity, historical seismicity of the San 

Diego region is low compared to the rest of Southern California. San Diego County has 

experienced strong shaking and damage from several earthquakes, but none of the recent ones 

have been particularly destructive. All of the faults which could affect San Diego County are 

part of the San Andreas system of faults (Figure 3-1). In addition to the main San Andreas fault, 

there are several other faults associated with this system, including: San Jacinto, Coyote Creek, 

Earthquake Valley, Agua Caliente, Elsinore, Rose Canyon, San Miguel (Mexico), Agua Blanca 

(Mexico), and Coronado Banks (offshore). The following faults may affect the site: San 

Andreas Fault, Coyote Creek Fault, and Elsinore Fault. For the site, the Elsinore Fault is the 

largest, clearly active major fault near the San Pasqual Indian Reservation. In order to address 

the seismic zone designation for the site, all facilities would be constructed according to the 

International Building Code criteria for Seismic Zone 4. 

3.1.3 Soils (types, characteristics) 

The soils within the site are composed of two main associations as designated by the United 

States Department of Agriculture (USDA): the Fallbrook sandy loam and Visalia sandy loam. 

The site has approximately equal amounts of these two soil types. The Visalia series consists of 

moderately well drained, very deep sandy loams derived from granitic alluvium. The Fallbrook 

sandy loam is very similar but includes more fine grain size materials. Both of these soils are on 

alluvial fans and flood plains that have slopes of 0 to 15%. The soils are typically used to grow 

avocados, citrus, walnut orchards, truck crops, irrigated pasture, field crops, tomatoes, flowers, 

and nursery stock. Figure 3-2 displays the site soil map. Table 3-1 shows the corresponding 

soil type descriptions and levels of soil occurrence at the site. 

 Table 3-1: Soil Map Units 

Map Unit Symbol Map Unit Name Site Area 

(acres) 

Site Coverage 

(percent) 

FaC2 Fallbrook sandy loam 4.7 52% 

VaB Visalia sandy loam 4.3 48% 

Source: SSURGO, 2002-2007 

Soil Hydrological Classification 

Hydrologic soil groups are based on estimates of runoff potential. Soils are assigned to one of 

four groups according to the rate of water infiltration when the soils are not protected by 
"

"

"

"

"

"

"

^_

Murrieta Cre ek fault

Clark fault

Wildomar fault

Elsinore fault

Elsinor

Clark fault

Elsinore fault

Wildomar fault

C

Wildomar fault

Clark fault

Wildomar fault

Elsinore fault

Clark fault

Elsinore fault

Willard fault

Thomas Mountain fault

unnamed

Murrietta Hot Springs fault

Elsinore fault

Aguanga

UV76

UV79

UV78

UV371

UV67

UV15

UV215

UV79

UV79

UV78

§ ̈¦5

17.0 miles

12.0 miles

7.36 miles

6.97 miles

Pala

Poway

Vista

Ramona

Del Mar

Bonsall

Aguanga

Rainbow

Del Dios Leucadia

Temecula

Murrieta

Fernbrook

Encinitas

Escondido

Fallbrook

San Marcos

Mesa Grande

Solana Beach

Jesmond Dene

San Luis Rey

Valley Center

Hidden Meadows

Rancho Santa Fe

Lake San Marcos

Cardiff-by-the-Sea

Murrieta Hot Springs

San Diego Country Estates

Historic

Holoscene

<15,000 - Latest Quaternary

<100,000 - Late Quaternary

<1,600,000 - Quaternary

LEGEND

0 1 2 3 4 5

Miles

Figure 3-1

Regional Fault Map

SOURCE: USGS Earthquake Hazards Program, 2007; AES, 2010 San Pasqual Band 9-acre Fee-to-Trust and Retail Plaza Project EA / 209543
Valley Center Rd

Lake Wohlford Rd

Sunset Rd

Viso Thundernut Ln

Station Rd

Sunset Ter

Ahern Ranch Rd

Mary Anne Ct

School Bus Rd

VaB

FaD2

FaC2

PfC

CnG2

FvE

CmrG

Figure 3-2

Soils Map

SOURCE: Soil Survey Geographic (SSURGO) database for San Diego County, 

California, 2002-2007; Aerial Express aerial photograph, 3/2008; AES, 2010

San Pasqual Band 9-acre Fee-to-Trust and Retail Plaza Project EA / 209543

LEGEND

9 Acre Site

Soil Type Boundary

FaC2 - Fallbrook sandy loam, 5 to 9 percent slopes, eroded

VaB - Visalia sandy loam, 2 to 5 percent slopes

0 250 500

Feet

!¢N O R T H

Ð
Description of the Affected Environment 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 3-5

vegetation, are thoroughly wet, and receive precipitation from long-duration storms. The lowest 

to highest runoff potential runs from group A to D respectively. Both of the Site soils are 

classified in the soil hydrologic group B as described below according to the USDA 

classification. 

Soil drainage class refers to the frequency and duration of wet periods under conditions similar 

to those under which the soil formed. Alterations of the water regime by human activities, either 

through drainage or irrigation, are not a consideration unless they have significantly changed the 

morphology of the soil. Seven classes of natural soil drainage are recognized: excessively 

drained, somewhat excessively drained, well drained, moderately well drained, somewhat poorly 

drained, poorly drained, and very poorly drained. Both of the site soils are classified as “well 

drained” as defined below according to the USDA classification. 

• Hydrologic Group B: Soils having a moderate infiltration rate when thoroughly wet. 

These consist chiefly of moderately deep or deep, moderately well drained or well 

drained soils that have moderately fine texture to moderately coarse texture. These soils 

have a moderate rate of water transmission. 

• Well drained: Water is removed from the soil readily but not rapidly. Internal free water 

occurrence commonly is deep or very deep; annual duration is not specified. Water is 

available to plants throughout most of the growing season in humid regions. Wetness 

does not inhibit growth of roots for significant periods during most growing seasons. The 

soils are mainly free of the deep to redoximorphic features that are related to wetness. 

Based on the existing hydrologic soil group B and “well drained” drainage class, exposed soil on 

the Site has a moderate potential for runoff and erosion in extreme precipitation events. 

There are no municipal storm drains on or in the vicinity of the site. The only stormwater 

infrastructure on the property at this time besides the roads, curbs and gutters is the culvert at the 

south boundary of the site. This culvert runs under the School Bus Road easement acting as a 

conduit for water from the eastern portion of the property to the western portion. A review of the 

high definition aerial and ground photos of the site shows stormwater draining to a low area in 

the southwest corner of the property. Much of the water appears to settle on the site; any 

remaining runoff appears to exit the property into a small wooded area. Some runoff flow may 

also drain toward the western site boundary into a channel which possibly flows into a small 

settling basin in the adjoining parcel. Figure 3-3 below illustrates the drainage patterns inferred 

from the photos. 

3.2 Water Resources 

3.2.1 Surface Water, Drainage, and Flooding 

The site does not have any permanent surface water bodies. Based on a review of aerial 

photographs, there is an intermittent drainage channel and possibly a settling basin in the vacant 

lot to the west of the site. From the photos, vegetation, and regional climate pattern, the channel 

appears to flow solely during and after heavy rainfall events. The potential settling basin is an 

oval feature in the adjoining vacant lot sized approximately 30 feet by 60 feet (Figure 3-3). 
#

##

#

#

#

#

#

#

#

#

#

# 

#

#

Valley Center Road

Drainage Culvert

Settling Basin

San Pasqual Band 9-acre Fee-to-Tru

SOURCE: Wynn Engineering, 2009; Jones & Stokes, 2009; AES, 2010

SCALE

NORTH 0 75’ 150’
Description of the Affected Environment 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 3-7

A July 2010 site visit confirmed the lack of permanent surface water bodies. One roadside ditch 

occurs within the site. The roadside ditch was excavated wholly in uplands and does not carry a 

relatively permanent flow of water as the manmade ditch only receives water from surrounding 

developed areas and through direct precipitation. The roadside ditch does not flow off of the 

site. A discussion of the potential Waters of the U.S. can be found in Section 3.4. 

Drainage 

The Site has a slight slope that channels surface waters to the west through the intermittent 

drainage described above. Water within the approximately one-foot wide roadside ditch flows 

west, is culverted beneath a paved road, continues for approximately 20 feet in an approximately 

five-foot wide channel, and ponds water where it abruptly loses its defined bed and banks at its 

terminus with a dirt road. 

Flooding 

A Flood Insurance Rate Map (FIRM) displays the floodplains in a town or area. Such maps are 

used for town planning, the insurance industry, and by individuals. It is the official map showing 

Federal Emergency Management Agency (FEMA) delineations of both special hazard areas and 

the risk premium zones. 

The entire Site is designated as Zone Z as shown in Figure 3-4. FEMA describes Zone Z as an 

area determined to be outside the 500-year floodplain. According to FEMA, for Zone Z areas, 

flood insurance is available to all property owners and renters as long as the community 

participates in the National Flood Insurance Program. 

3.2.2 Climate & Precipitation 

The site area has a semiarid climate with warm dry summers and mild winters. The average 

annual precipitation is approximately 15 inches resulting in a borderline arid climate. Rainfall is 

strongly concentrated in the cooler half of the year, particularly December through March. The 

summer months are virtually rainless. Rainfall amounts are highly variable from year to year 

and from month to month. 

A nearby rain gauge for the site is located at Lake Wohlford. The station was in operation from 

1948 to 1992. As part of a study by the National Climatic Data Center, Hourly Precipitation 

Data (HPD) rainfall event statistics for this station were computed based on recordings made of 

rainfall and time. The HPD statistics were generated through a process of computer statistical 

analysis of the station precipitation data in 2003. A data documentation paper on the process and 

the HPD statistical results for Lake Wohlford are attached as an appendix to the Stormwater/ 

Drainage report (Appendix C of this EA). A cursory review of the data shows that the station 

recorded precipitation values of 4-7 inches within a 24 hour period several times in the station 

operating period. The data displays these levels of precipitation occurring at least once if not 

multiple times every decade from 1940s-1980s. The large rainfall values are almost exclusively 

during the winter months. The highest value noted in the data is 12.1 inches over 23.5 hours in 

the early months of 1969. This peak value is collaborated by a nearby Escondido rain gauge 

station recording 7.7 inches over 16 hours during the same time frame. 
^_

PROJECT SITE

Valley Center Rd

Lake Wohlford Rd

Woods Valley Rd

Figure 3-4

FEMA Flood Zones

SOURCE: FEMA FIRM data, 2008; FEMA Q3 Flood Data, 1996; AES, 2010 San Pasqual Band 9-acre Fee-to-Trust and Retail Plaza Project EA / 209543

FEMA FLOOD DATA

Zone A-This code identifies an area inundated by 100-year flooding, for which no BFEs have been determined.

Zone A0-This code identifies an area inundated by 100-year flooding, for which average depths have been determined

Zone AE- Identifies area inundated by 100-year flooding, BFEs have been determined but are expressed in meters for some communities.

Zone Z-This code identifies an area that is determined to be outside the 100- and 500-year floodplains.

0 1,000 2,000

Feet

!¢N O R T H

Ð
Description of the Affected Environment 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 3-9

3.2.3 Water Supply and Groundwater 

Numerous wells have been drilled within the vicinity of the site. Five wells have been drilled at 

locations on or very near the site as shown in Figure 3-5. The ground water level data for these 

wells was reported and archived to the Water Data Library, California Department of Water 

Resources. Table 3-2 displays the ground water level depths which have been consistently 

reported at less than 100 feet below the ground surface. The shallow ground water level is 

consistent with the flat basin topography of the area. The well ground water level data below 

may be slightly different now as all of the data was recorded in 1966-1967. For the Phase I 

Environmental Assessment of the site, GreenWave Consulting found no information available 

regarding the status of the wells. Contact with the respective state and federal agencies did not 

yield any information. There is a 1-inch water supply pipe owned by the Valley Center 

Municipal Water District located on the North border of the site. Usage at the site is designated 

as “Commercial.” 

Table 3-2: Site Groundwater Data 

State Well Number 

Approximate Depth to 

Groundwater (below ground 

surface) 

11S01W15D001S 30 Feet 

11S01W10N002S 49 Feet 

11S01W10N001S 50 Feet 

11S01W15C003S 48 Feet 

11S01W10P001S 50 Feet 

Source: California Department of Water Resources, 2010 

Since the site is used as an overflow parking lot for the Valley View Casino, and as undeveloped 

land, there is no existing water supply or wastewater treatment system developed on-site. The 

existing 1-inch service line and meter at the project site are not connected to any potable water 

system and are not in use. There are no groundwater supply wells on the project site. 

3.2.4 Wastewater Treatment 

There is no municipal wastewater treatment service within the vicinity of the site. Most of the 

residences and businesses in the area utilize private on-site septic treatment systems built to San 

Diego County specifications. The Tribe owns a private wastewater facility which services the 

Valley View Casino. The wastewater facility is located approximately one mile southeast of the 

site. The nearest public wastewater facility is the Valley Center Municipal District Wastewater 

Treatment Plant. 

3.2.5 Water Quality 

Regulatory Context 

The Clean Water Act (CWA) (33 U.S.C §1251) is the primary federal legislation for the 

prevention of pollutions of the nations navigable waters. The goal of the Clean Water Act is the 
Well ID: 11S01W15D001S

A@

A@

A@

A@

Well ID: 11S

Well ID: 11S01W15C003S

Well ID: 11S01W10N002S

Well ID: 11S01W10N001S

A@

Valley Center Road

Lake Wohlford Road

San Pasqual Band 9-acre Fee-to-Tru

SOURCE: Wynn Engineering, 2009; Jones & Stokes, 2009; AES, 2010

SCALE

NORTH 0 150’ 300’
Description of the Affected Environment 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 3-11

“restoration and maintenance of chemical, physical and biological integrity of Nation’s waters” 

(33 U.S.C §1251). The Safe Drinking Water Act (42 U.S.C. §300f) is the major federal 

legislation that protects groundwater quality, as both current and potential drinking water 

sources. 

Surface Water 

The State Water Resources Control Board, in compliance with CWA section 303, has prepared a 

list of impaired water bodies in the State of California. Impaired water bodies occur where 

industrial and technological waste limits or other legal mechanisms for pollution control are not 

enough to meet water quality standards. The list includes a priority schedule for the 

development of total maximum daily loads for each contaminant or “stressor” impacting the 

water body. There are no surface water bodies listed on the 303(d) list within the vicinity of the 

site. 

Accidental release of petroleum products into navigable waters of the United States is regulated 

by the CWA. In event of accidental release of petroleum products to navigable waters of the 

United States, the owner and operator of a facility that stores or handles petroleum products 

would bear liability for the cost of the removal, clean-up, and damages of the facility under the 

Oil Pollution Act (USC Title 33 Chapter 40 Subchapter I). All other discharges are subject to the 

provisions of 40 CFR Part 280, discussed in Section 3.11. 

Groundwater 

In order to protect water supplies and under the mandate of the Safe Drinking Water Act, the 

EPA defines National Primary Drinking Water Regulations (primary standards). These are 

legally enforceable standards that apply to public water systems. These standards are established 

to protect human health by limiting the levels of contaminants in drinking water. The EPA also 

defines National Secondary Drinking Water Regulations (secondary standards). 

3.3 Air Quality 

3.3.1 Project Area and Vicinity 

The Site is located in the northwestern portion of the San Diego Air Basin (SDAB). Air quality 

in the SDAB is influenced by pollutants transported from the South Coast Air Basin (Los 

Angeles area) in the north and from the Tijuana, Mexico region in the south. A large portion of 

the air pollution in the SDAB comes from mobile-source emissions (i.e. vehicle exhaust). 

Pollutants in this air basin tend to be generated in areas of concentrated urban development along 

the coastal plain. 

The topography of San Diego County is varied, resulting in climatic differences within the 

county. The Climate in the eastern portion of the county differs from that of the western portion. 

The elevation and slope of the eastern portion of the county results in a much hotter and drier 

climate compared to that of the coastal areas. Precipitation is heavier in the winter months. 

Winds in mountainous terrain are far more variable, in both speed and direction, than at the 

valley floor. Wind direction is typically up-slope during the daytime and downslope at night. 
Description of the Affected Environment 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 3-12

The overall general wind is westerly, although terrain effects can distort this general flow 

substantially. 

3.3.2 Regulatory Context 

Because the subject property will be taken in to federal trust for the Tribe, the project site would 

not be subject to state regulatory authority for air quality. The Federal government is responsible 

for directly administering Federal Clean Air Act (CAA) mandated programs on Tribal land in 

instances where the Tribe is not administering provisions of these programs. The EPA will 

provide assistance to the Tribe if they wish to develop their own air quality regulations under the 

CAA for managing air quality on their reservation. 

For the reasons above, the EA analysis focuses on the regulation of air quality at the federal 

level. However, state regulations and regional air district requirements are also discussed to 

provide a broader context for air quality planning activities within the state and the region. 

Federal 

The CAA of 1970, as amended, establishes air quality standards for several pollutants. These 

pollutants are termed "criteria" pollutants because the EPA has established specific concentration 

threshold criteria for them based upon health effects. The EPA has designated six criteria air 

pollutants: ozone (O3), carbon monoxide (CO), particulate matter (PM10 and PM2.5), nitrogen 

dioxide (NO2), sulfur dioxide (SO2), and lead (Pb). The national ambient air quality standards 

(NAAQS) for these pollutants are divided into primary standards and secondary standards. 

Primary standards are designed to protect the public health, and secondary standards are intended 

to protect the public welfare from effects such as visibility reduction, soiling, nuisance, and other 

forms of damage. NAAQS for the pollutants of greatest concern in the SDAB are presented in 

Table 3-3. 

Air basins or portions thereof are classified with respect to their attainment or the extent of their 

nonattainment of the NAAQS. Non-attainment areas must take steps towards attainment within 

a specific timeline. The CAA places most of the responsibility for achieving compliance with 

the NAAQS on the states. A state achieves compliance through measures set forth in its State 

Implementation Plan (SIP). The SIP consists of a number of measures that set forth the state’s 

strategies for achieving the NAAQS. C.F.R. Title 40, Chapter I, Part 52, Subpart F, Section 

52.220 lists the requirements for a SIP. The SIP is a compilation of new and previously 

submitted plans, programs (such as monitoring, modeling, permitting, etc.), district rules, state 

regulations, and federal controls. California's SIPs detail control strategies, including emission 

standards for cars and heavy trucks, fuel regulations, and limits on emissions from consumer 

products. Local air districts and other agencies prepare SIP elements and submit them to the 

California Air Resources Board (CARB) for review and approval. CARB is the lead agency for 

all purposes related to the SIP. 

Federal Hazardous Air Pollutant Program 

Title III of the CAA requires the EPA to promulgate National Emissions Standards for 

Hazardous Air Pollutants (NESHAPs). The NESHAPs may differ between regional sources and 
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Table 3-3: National Ambient Air Quality Standards 

Pollutant Averaging 

Time 

Standard Violation 

Criteria parts per million 

microgram per 

cubic meter 

NAAQS NAAQS NAAQS 

Ozone 8 hours 0.075 157 

If exceeded on 

more than 3 days 

in 3 years 

CO 

8 hours 9 10,000 

If exceeded on 

more than 1 day 

per year 

1 hour 35 40,000 

If exceeded on 

more than 1 day 

per year 

NOx

Annual 

average 

0.053 100 If exceeded 

SOx

Annual 

average 

0.03 80 If exceeded 

24 hours 0.14 365 

If exceeded on 

more than 1 day 

per year 

PM10 24 hours N/A 150 

If exceeded on 

more than 1 day 

per year 

PM2.5

Annual 

arithmetic 

mean 

N/A 15 If exceeded 

24 hours N/A 35 

If exceeded on 

more than 1 day 

per year 

SOURCE: CARB, 2010 

area sources of hazardous air pollutants (HAPs). Major sources are defined as stationary sources 

with potential to emit more than 10 tons per year (tpy) of any HAP or more than 25 tpy of any 

combination of HAPs; all other sources are considered area sources. The emissions standards 

were promulgated in two phases. In the first phase (1992–2000), EPA developed technologybased emission standards designed to produce the maximum emission reduction achievable for 

major sources. For area sources, the standards were based on generally available control 

technology. In the second phase (2001–2008), the EPA promulgated health risk–based 

emissions standards necessary to address risks remaining after implementation of the 

technology-based NESHAP standards. 

In addition to standards for stationary sources of HAPs, the CAA also requires the EPA to 

promulgate vehicle or fuel standards to include reasonable controls for toxic emissions, 

addressing at a minimum benzene and formaldehyde. Performance criteria were established to 
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limit mobile-source emissions of toxics, including benzene, formaldehyde, and 1,3-butadiene. In 

addition, Section 219 of the CAA requires the use of reformulated gasoline in selected U.S. cities 

(those with the most severe ozone nonattainment conditions) to further reduce mobile-source 

emissions. NESHAP regulations are also used to ensure emissions of HAPs (such as asbestos) 

are reduced or eliminated from gasoline dispensing facilities. 

Federal General Conformity 

The federal General Conformity Rule implements Section 176(c) of the CAA, and establishes 

minimum thresholds for reactive organic compounds (ROGs) and nitrogen oxides (NOx) (ozone 

precursors), particulate matter (PM), and other regulated constituents for non-attainment and 

maintenance areas. 

Under the General Conformity Rule, the lead agency with respect to a federal action is required 

to demonstrate that the proposed federal action conforms to the applicable SIP before the action 

is taken. There are two phases to a demonstration of general conformity: 

1) The Conformity Review process, which entails an initial review of the federal action to 

assess whether a full conformity determination is necessary, and 

2) The Conformity Determination process, which requires that a proposed federal action be 

demonstrated to conform to the applicable SIP. 

The Conformity Review requires the lead agency to compare estimated emissions to the 

applicable general conformity de minimus threshold(s). If the emission estimates from step one 

are below the applicable threshold(s), then a general conformity determination is not necessary 

and the full Conformity Determination is not required. If emission estimates are greater than de 

minimus levels, the lead agency must conduct a formal Conformity Determination. Since the 

San Diego County Air Basin (SDAB) is designated non-attainment for ozone, the de minimus

threshold level of 100 tons per year applies to ozone precursors (ROG and NOx). The SDAB is 

in attainment or unclassifiable for all other national ambient air quality standards. 

Climate Change 

Climate change is a global phenomenon attributable to the sum of all human activities and 

natural processes. In 1997, the Council on Environmental Quality (CEQ) circulated an internal 

draft memorandum (CEQ, 1997a) on how global climate change should be treated for the 

purposes of the National Environmental Policy Act (NEPA). The CEQ draft memorandum 

advised federal lead agencies to consider how proposed actions subject to NEPA would affect 

sources and sinks of green house gases (GHGs). During the same year, CEQ released guidance 

on the assessment of cumulative effects in NEPA documents (CEQ, 1997b). Consistent with the 

CEQ draft memorandum, climate change impacts were offered as one example of a cumulative 

effect. 

The following are the most recent regulatory actions taken by the USEPA: 

• On July 23, 2009, USEPA published a final “rule which proposes to establish the criteria 
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for including sources or sites in a Registry of Recoverable Waste Energy Sources 

(Registry),” as required by the Energy Independence and Security Act of 2007. Waste 

energy can be used to produce clean electricity. The clean electricity produced by waste 

energy would reduce the need for non-renewable forms of electricity production, thus 

reducing greenhouse gas (GHG) emissions. 

• On September 15, 2009, USEPA and the Department of Transportation’s National 

Highway Traffic Safety Administration (NHTSA) proposed a new national program that 

would reduce GHG emissions and improve fuel economy for all new cars and trucks sold 

in the United States. USEPA proposed the first national GHG emissions standards under 

the Clean Air Act, and NHTSA proposed an increase in the Corporate Average Fuel 

Economy (CAFE) standards under the Energy Policy and Conservation Act. 

• In response to the FY2008 Consolidated Appropriations Act (H.R. 2764; Public Law 

110–161), USEPA issued the Final Mandatory Reporting of Greenhouse Gases Rule. 

Signed by the Administrator on September 22, 2009, the rule requires that suppliers of 

fossil fuels and industrial GHGs, manufacturers of vehicles and engines outside of the 

light duty sector, and facilities that emit 25,000 metric tons or more of GHGs per year to 

submit annual reports to USEPA. The rule is intended to collect accurate and timely 

emissions data to guide future policy decisions on climate change. 

• On September 30, 2009, USEPA proposed new thresholds for greenhouse gas emissions 

(GHG) that define when Clean Air Act permits under the New Source Review and title V 

operating permits programs would be required. 

• In February, 2010 The CEQ Chair released a memorandum, Draft NEPA Guidance on 

Consideration of the Effects of Climate Change and Greenhouse Gas Emissions. The 

memorandum provides guidance on how project-related GHG emission should be 

analyzed in NEPA documents. The Draft Guidance provides that a NEPA climate 

change analysis shall provide quantification and mitigation to reduce GHG emissions. 

The guidance also provides that 25,000 metric tons of GHG emissions per year may be a 

helpful guideline to assist lead agencies in making informed decisions on climate change 

impacts resulting from a project subject to NEPA. The guidance notes that the 25,000 

metric tons is not a threshold for evaluating climate change on the project level. 

3.3.3 Pollutants of Concern 

The project area, which is within San Diego Air Basin, is in nonattainment for ozone; therefore, 

it is considered a pollutant of concern with regard to the construction and operation of the 

Proposed Project. Diesel particulate matter (DPM) is not considered a pollutant of concern due 

to EPA not assigning DPM an attainment status or classification; however, given the nature of 

the project, DPM was considered in the analysis. The following is a brief description of ozone 

and DPM: 

Ozone 

Photochemical reactions involving ROG and NOX resulting from the incomplete combustion of 
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fossil fuels are the largest source of ground-level ozone. Because photochemical reaction rates 

depend on the intensity of ultraviolet light and air temperature, ozone is primarily a summer air 

pollution problem. As a photochemical pollutant, ozone is formed only during daylight hours 

under appropriate conditions, but is destroyed throughout the day and night. Ozone is considered 

a regional pollutant, as the reactions forming it take place over time and are often most 

noticeable downwind from the sources of the emissions. 

Diesel Particulate Matter (DPM) 

Diesel Particulate matter is not a criteria air pollutant, however, diesel particulate matter is of 

great concern to public health. DPM is considered a pollutant of concern when heavy duty diesel 

construction equipment and diesel transportation trucks are in operation. DPM is defined as a 

Toxic Air Contaminate (TACs). TACs are substances that are known or suspected to be emitted 

in California and have potential adverse health effects. Currently, there are 244 TACs listed by 

CARB. According to CARB, the estimated health risk from TACs can be primarily attributed to 

relatively few compounds, such as DPM. DPM differs from many other TACs in that it is not a 

single substance, but rather a complex mixture of air pollutants, composed of gaseous and solid 

material. The visible emissions in diesel exhaust are known as particulate matter or PM, which 

includes carbon particles or “soot.” The major source of DPM in the project area is diesel trucks 

on local roadways. There are no large stationary sources of DPM is the immediate vicinity of the 

Proposed Project. 

3.3.4 Sensitive Receptors 

Sensitive receptors are generally defined as residential areas and other land uses associated with 

people susceptible to adverse impacts from air pollution emissions, and as such, should be given 

special consideration when evaluating air quality impacts. Sensitive receptors include facilities 

that house or attract children, the elderly, people with illnesses, or others who are especially 

sensitive to the effects of air pollutants, such as hospitals, schools, convalescent facilities. 

Sensitive receptors in the vicinity of the Site include: the Valley Center Middle School, which is 

located approximately 280 feet south of the site boundary. There are also residences situated to 

the north, east, and west of the Site. The closest residence is approximately 170 feet from the 

southeastern border of the Site. There are no hospitals within the immediate vicinity of the Site. 

3.4 Biological Resources 

A Biological Assessment (BA) was prepared for the project site and is included in Appendix D. 

Since the circulation of the draft Environmental Assessment (EA), an additional biological 

survey of the site was conducted and a separate BA Technical Memorandum was prepared (AES, 

2010), which is provided as Appendix D. The 2010 memo supplements and updates the 

findings of the 2009 BA. The memo includes a detailed evaluation of the Site, summarizes 

regionally occurring federal listed species in the vicinity of the project site, and provides a 

rationale as to whether the species has the potential to occur within the Site based on the July 20, 

2010 biological survey. The Biological Resources section of this Final EA reflects the findings 

identified within the BA and memo. Potential impacts and mitigation measures in Sections 4 and 

5 are based on the evaluation of potentially occurring federal listed species identified in Section 
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3 of this Final EA. 

3.4.1 Regulatory Setting 

Federal Endangered Species Act 

The U.S. Fish and Wildlife Service (USFWS) and the National Marine Fisheries Service 

(NMFS) enforce the provisions of the federal Endangered Species Act (FESA). The USFWS 

administers FESA for all terrestrial species. NMFS administers FESA for marine fish species, 

including anadromous salmonids. Section 9 (§1538) prohibits the "taking" of a listed species by 

anyone, including private individuals, and state and local agencies. Threatened and endangered 

species on the federal list (50 CFR Sections 17.11 and 17.12) are protected from take, defined as 

direct or indirect harm. If "take" of a listed species is necessary to complete an otherwise lawful 

activity, this triggers the need for consultation under Section 7 of FESA for federal agencies, 

including Tribes. A Section 7 Biological Opinion with incidental take provisions would be 

rendered. 

Pursuant to the requirements of FESA, a federal agency reviewing a proposed project within its 

jurisdiction must determine whether any federally listed species may be present in the study area 

and whether the proposed project will have a potentially significant impact upon such species. 

Under FESA, habitat loss is considered to be an impact to the species. In addition, the agency is 

required to determine whether the project is likely to jeopardize the continued existence of any 

species that is proposed for listing under FESA or to result in the destruction or adverse 

modification of critical habitat proposed to be designated for such species (16 USC Section 

1536[3], [4]). Therefore, project-related impacts to these species, or their habitats, would be 

considered significant and require mitigation. 

Under FESA, critical habitat may be designated by the Secretary of the Interior for any listed 

species. The term "critical habitat" for a threatened or endangered species refers to the 

following: specific areas within the geographical range of the species at the time it is listed that 

contain suitable habitat for the species, which may require special management considerations or 

protection; and specific areas outside the geographical range of the species at the time it is listed 

that contain suitable habitat for the species and is determined to be essential for the conservation 

of the species. Under Section 7 of the FESA, all federal agencies (including USFWS and 

NMFS) are required to ensure that any action they authorize, fund, or carry out will not likely 

jeopardize the continued existence of a listed species or modify their critical habitat. Critical 

habitat does not include occupied habitat areas on Indian lands. The Indian lands specifically 

excluded from critical habitat are those defined in the Secretarial Order, including: lands held in 

trust by the U.S. for the benefit of any Indian Tribe and land held in trust by the U.S. for any 

Indian Tribe or individual subject to restrictions by the U.S. against alienation (70 FR 52488-

52627). 

Waters of the U.S. 

Any person, firm, or agency planning to alter or work in navigable waters of the U.S., including 

the discharge of dredged or fill material, must first obtain authorization from the USACE. 

Permits, licenses, variances, or similar authorization may also be required by other federal, state, 
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and local statutes. Section 10 of the Rivers and Harbors Act of 1899 prohibits the obstruction or 

alteration of navigable waters of the U.S. without a permit from the USACE (33 U.S.C. 403). 

Section 301 of the Federal Water Pollution Control Act and Amendments of 1972 (CWA) 

prohibit the discharge of pollutants, including dredged or fill material, into waters of the U.S. 

without a Section 404 permit from the USACE (33 U.S.C. 1344). A Section 401 Water Quality 

Certification may be required by the Environmental Protection Agency for trust lands before 

other permits are issued. 

Migratory Bird Treaty Act 

Migratory birds are protected under the federal Migratory Bird Treaty Act (MBTA) of 1918 (16 

U.S.C 703-711). The MBTA makes it unlawful to take, possess, buy, sell, purchase, or barter 

any migratory bird listed under 50 CFR 10, including feathers or other parts, nests, eggs, or 

products, except as allowed by implementing regulations (50 CFR 21). The direct injury or 

death of a migratory bird, due to construction activities or other construction-related disturbance 

that causes nest abandonment, nestling abandonment, or forced fledging would be considered 

take under federal law. As such, project-related disturbances must be reduced or eliminated 

during the nesting season. 

North County Multiple Habitat Conservation Program 

The North County Multiple Habitat Conservation Program (MHCP) is a comprehensive 

conservation planning process, adopted in 2003, that addresses the needs of multiple plant and 

animal species in North Western San Diego County. The MHCP encompasses the cities of 

Carlsbad, Encinitas, Escondido, Oceanside, San Marcos, Solana Beach, and Vista. Its goal is to 

conserve approximately 19,000 acres of habitat for the protection of more than 80 rare, 

threatened, or endangered species. Subarea plans for the cities of Carlsbad, Encinitas, 

Escondido, Oceanside, San Marcos, and Vista are being prepared and must be adopted by each 

City Council and implementing agreements with the California Department of Fish and Game 

and U.S. Fish and Wildlife Service must be signed before incidental take permits can be issued. 

The MHCP is one of three subregional habitat conservation planning programs in the region that, 

together, will contribute to a coordinated preserve system for the San Diego region and Southern 

California. The Site does not occur within the MHCP boundaries. 

3.4.2 Habitat Types 

Habitat types in the Site include ruderal/disturbed areas, developed areas, and a roadside ditch. 

Ruderal/Disturbed 

Approximately half of the Site is comprised of ruderal/disturbed areas. The ruderal/disturbed 

areas include dirt roads and ornamental trees and nonnative species on disturbed land. Dominant 

vegetation in the ruderal/disturbed areas of the Site includes Bermuda grass (Cynodon dactylon), 

black mustard (Brassica nigra), narrowleaf plantain (Plantago lanceolata), soft chess (Bromus 

hordeaceus), smooth cat’s ear (Hypochaeris glabra), common dandelion (Taraxacum officinale), 

coastal sagebrush (Artemesia californica), common deerweed (Lotus scoparius), common 

purslane (Portulaca oleracea), puncture vine (Tribulus terrestris), alfalfa (Medicago sativa), 

Cooper’s goldenbush (Ericameria cooperi), ragweed (Ambrosia sp.), Mexican palo verde 
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(Parkinsonia aculeate), and California buckwheat (Eriogonum fasciculatum). Ornamental trees 

include an isolated palm (Washingtonia sp.) and peppertree (Schinus sp.). 

 Developed 

Approximately half of the Site is developed. The developed areas include paved roads and a 

paved parking lot. 

Roadside Ditch 

A roadside ditch occurs on the south-central portion of the Site. Water within the approximately 

one-foot wide roadside ditch flows west, is culverted beneath a paved road, continues for 

approximately 20 feet in an approximately five-foot wide channel, and ponds water where it 

abruptly loses its defined bed and banks at its terminus with a dirt road. No vegetation was 

observed within the roadside ditch on the east side of the culverts during the July 2010 survey. 

The roadside ditch to the west of the culverts was sparsely vegetated at the time of the July 2010 

survey of the Site. Vegetation observed in the bed and along the banks of the roadside ditch 

includes Bermuda grass, ragweed, narrowleaf plantain, puncture vine, and panic grass (Panicum 

capillare). 

3.4.3 Potential Waters of the U.S. 

An informal wetland delineation was conducted within the Site in conjunction with the July 20, 

2010 biological survey. One roadside ditch occurs within the Site. The roadside ditch was 

excavated wholly in uplands and does not carry a relatively permanent flow of water as the 

manmade ditch only receives water from surrounding ruderal/disturbed and developed areas and 

through direct precipitation. The roadside ditch does not have a hydrologic connection with a 

waters of the U.S. because water within the roadside ditch does not flow off of the Site. In 

accordance with RGL 07-01, the roadside ditch is not considered a potentially jurisdictional 

feature. No potentially jurisdictional features occur within the Site. 

3.4.4 Federal Listed Special Status Species 

For the purposes of this assessment, special status has been defined to include those species that 

are listed as endangered or threatened under the FESA (or formally proposed for, or candidates 

for, listing). A summary of regionally occurring federal listed species in the vicinity of the Site 

based on the USFWS file data, a description of habitat requirements, and a rationale as to 

whether the species has the potential to occur within the Site is provided as an attachment to the 

memo, which is provided in Appendix E. Presence of species or their habitat was evaluated 

during the July 2010 biological survey. Species without the potential to occur in the Site are not 

further discussed. The Site does not occur within designated critical habitat for any federal listed 

species. The Site does not occur within the boundaries of the MHCP. 

San Diego Thornmint (Acanthomintha ilicifolia) 

Federal Status – Threatened 

This species is an annual herb found usually on clay soils in chaparral, coastal scrub, valley and 

foothill grassland, and vernal pools from 10 to 960 meters. The blooming period is from April 
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through June. This species is known from San Diego and Baja California (CNPS, 2010). There 

is one CNDDB record for San Diego thornmint within five miles of the Site. The record is from 

1990 and is approximately 2.5 miles southwest of the Site (CNDDB record number: 49). The 

record states that the seed and soil were transplanted to the Site outside its native habitat and 

range. Although the species is usually found on clay soils within valley and foothill grassland, 

the sandy loam soils within the weedy vegetation of the ruderal/disturbed areas may provide 

marginal habitat for this species. This species was not observed during the July 20, 2010 

biological survey. Because the July 20, 2010 biological survey of the Site was conducted outside 

the evident and identifiable period for this species, it may have been present and not detected. 

San Diego thornmint has a low potential to occur within the Site. 

Thread‐Leaved Brodiaea (Brodiaea filifolia) 

Federal Status – Threatened 

This species is usually found on clay soils within chaparral, occasionally in openings, 

cismontane woodland, coastal scrub, playas, valley and foothill grassland, and vernal pools from 

25 to 1,219 meters. The blooming period is from March through June (CNPS, 2010). There are 

no documented CNDDB records for thread‐leaved brodiaea within five miles of the Site. 

Although the species is usually found on clay soils, the sandy loam soils within the 

ruderal/developed areas of the Site may provide marginal habitat for this species. This species 

was not observed during the July 20, 2010 biological survey. Because the July 20, 2010 

biological survey of the Site was conducted outside the evident and identifiable period for this 

species, it may have been present and not detected. Thread-leaved brodiaea has a low potential 

to occur within the Site. 

San Diego Button Celery (Eryngium aristulatum var. parishii) 

Federal Status – Endangered 

This species is an annual to perennial herb usually found in mesic vernal pools, valley and 

foothill grassland, and coastal scrub from 20 to 620 meters. The blooming period is from April 

through June (CNPS, 2010). There are no CNDDB records for San Diego button celery within 

five miles of the Site. Although the species is usually found on clay soils and within valley and 

foothill grassland, the sandy loam soils within the weedy vegetation of the ruderal/disturbed 

areas may provide marginal habitat for this species. This species was not observed during the 

July 20, 2010 biological survey. Because the July 20, 2010 biological survey of the Site was 

conducted outside the evident and identifiable period for this species, it may have been present 

and not detected. San Diego button celery has a low potential to occur within the Site. 

Stephens’ Kangaroo Rat (Dipodomys stephensi) 

Federal Status: Endangered 

Stephens’ kangaroo rat is found in sagebrush and grassy patches on sandy or gravelly soils. 

Stephens’ kangaroo rat is known from the San Jisinto Valley of San Diego, Riverside, and San 

Bernardino counties (Jameson and Peeters, 2004). There are three documented CNDDB records 

for Stephens’ kangaroo rat within five miles of the Site. The nearest CNDDB record that is 

presumed extant is from 2004 and is approximately 2.6 miles northeast of the Site (occurrence 

number: 226). The record states that 100 individuals were trapped in 73 locations in native 

grasslands, elevated areas, well drained hillsides, ridges, saddles, trails, dirt roadways, and 
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adjacent lands in a trapping study (CDFG, 2003). Although the species is usually found in 

sagebrush habitat types, the weedy vegetation of the ruderal/disturbed areas may provide 

marginal habitat for this species. However, given that the Site is highly disturbed and is 

surrounded by development, it is unlikely that this species would occur within the Site. This 

species was not observed during the biological survey of the Site. Although unlikely, this 

species has a low potential to occur within the Site. 

3.4.5 Migratory Birds and Birds of Prey 

The MBTA of 1918 (16 U.S.C. 703-711) protects migratory birds by making it unlawful to take, 

possess, buy, sell, purchase, or barter any migratory bird listed in 50 CFR 10 including feathers 

or other parts, nests, eggs, or products, except as allowed by implementing regulations (50 CFR 

21). No birds were observed nesting during the July 20, 2010 biological survey of the Site. 

Migratory birds and other birds of prey have the potential to nest within the ornamental shrubs 

and trees within the Site. 

3.5 Cultural Resources 

A Cultural Resource Inventory was completed at the site by Laguna Mountain Environmental, 

Inc. in October, 2009, and is attached to this EA as Appendix F. The survey consisted of a 

record and literature search conducted at the South Coastal Information Center at San Diego 

State University and the San Diego Museum of Man, as well as a site survey conducted by 

Laguna Environmental staff on October 21, 2009. The records search included a one-mile radius 

around the site to provide background on the types of cultural resources that would be expected 

in the region. Copies of historic maps were provided by the South Coastal Information Center. 

Cultural resource work was conducted in accordance with National Historic Preservation Act 

(NHPA) and NEPA. 

3.5.1 Prehistoric and Ethnographic Setting 

Paleoindian Period 

The earliest well-documented prehistoric sites in southern California are identified as belonging 

to the Paleoindian period, which has locally been termed the San Dieguito complex/tradition. 

The Paleoindian period is thought to have occurred between 9,000 years ago, or earlier, and 

8,000 years ago in this region. Although varying from the well-defined fluted point complexes 

such as Clovis, the San Dieguito complex is seen as a hunting- focused economy with limited 

use of seed grinding technology. The economy generally focuses on highly ranked resources 

such as large mammals and relatively high mobility, which may be related to following large 

game. Archaeological evidence associated with this period has been found around inland dry 

lakes, on old terrace deposits of the California desert, and also near the coast where it was first 

documented at the Harris Site. 

Early Archaic Period 

Native Americans during the Archaic period had a generalized economy that focused on hunting 

and gathering. In many parts of North America, Native Americans chose to replace this 
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Final Environmental Assessment 3-22

economy with types based on horticulture and agriculture. Coastal southern California 

economies remained largely based on wild resource use until European contact. Changes in 

hunting technology and other important elements of material culture have created two distinct 

subdivisions within the Archaic period in southern California. 

The Early Archaic period is differentiated from the earlier Paleoindian period by a shift to a more 

generalized economy and an increased focus on the use of grinding and seed processing 

technology. At sites dated between approximately 8,000 and 1,500 years before present, the 

increased use of groundstone artifacts and atlatl dart points, along with a mixed core-based tool 

assemblage, identify a range of adaptations to a more diversified set of plant and animal 

resources. Variations of the Pinto and Elko series projectile points, large bifaces, manos and 

portable metates, core tools, and heavy use of marine invertebrates in coastal areas are 

characteristic of this period, but many coastal sites show limited use of diagnostic atlatl points. 

Major changes in technology within this relatively long chronological unit appear limited. 

Several scientists have considered changes in projectile point styles and artifact frequencies 

within the Early Archaic period to be indicative of population movements or units of cultural 

change (Moratto 1984), but these units are poorly defined locally due to poor site preservation. 

Late Archaic or Late Prehistoric Period 

Around 2,000 B.P., Yuman-speaking people from the eastern Colorado River region began 

migrating into southern California, representing what is called the Late Prehistoric Period. The 

Late Prehistoric Period in San Diego County is recognized archaeologically by smaller projectile 

points, the replacement of flexed inhumations with cremation, the introduction of ceramics, and 

an emphasis on inland plant food collection and processing, especially acorns (True 1966). 

Inland semi-sedentary villages were established along major water courses, and montane areas 

were seasonally occupied to exploit acorns and piñon nuts, resulting in permanent milling 

features on bedrock outcrops. Mortars for acorn processing increased in frequency relative to 

seed grinding basins. This period is known archaeologically in southern San Diego County as 

the Yuman (Rogers 1945) or the Cuyamaca Complex (True 1970). 

The Kumeyaay (formerly referred to as Diegueño) who inhabited the southern region of San 

Diego County, western and central Imperial County, and northern Baja California (Almstedt 

1982; Gifford 1931; Hedges 1975; Luomala 1976; Shipek 1982; Spier 1923) are the direct 

descendants of the early Yuman hunter-gatherers. Kumeyaay territory encompassed a large and 

diverse environment, which included marine, foothill, mountain, and desert resource zones. 

Their language is a dialect of the Yuman language which is related to the large Hokan super 

family. 

There seems to have been considerable variability in the level of social organization and 

settlement variance. The Kumeyaay were organized by patrilineal, patrilocal lineages that 

claimed prescribed territories, but did not own the resources except for some minor plants and 

eagle aeries (Luomala 1976; Spier 1923). Some lineages occupied procurement ranges that 

required considerable residential mobility, such as those in the deserts (Hicks 1963). In the 

mountains, some of the larger groups occupied a few large residential bases that would be 

occupied biannually, such as those occupied in Cuyamaca in the summer and fall, and in Guatay 

or Descanso during the rest of the year (Almstedt 1982; Rensch 1975). According to Spier 
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(1923), many Eastern Kumeyaay spent the period of time from spring through autumn in larger 

residential bases in the upland procurement ranges, and wintered in mixed groups in residential 

bases along the eastern foothills on the edge of the desert (i.e., Jacumba and Mountain Springs). 

This variability in settlement mobility and organization reflects the great range of environments 

in the territory. 

Acorns were the single most important food source used by the Kumeyaay. Their villages were 

usually located near water, which was necessary for leaching acorn meal. Other storable 

resources such as mesquite or agave were equally valuable to groups inhabiting desert areas, at 

least during certain seasons (Hicks 1963; Shackley 1984). Seeds from grasses, manzanita, sage, 

sunflowers, lemonadeberry, chia and other plants were also used along with various wild greens 

and fruits. Deer, small game and birds were hunted and fish and marine foods were eaten. 

Houses were arranged in the village without apparent pattern. The houses in primary villages 

were conical structures covered with tule bundles, having excavated floors and central hearths. 

Houses constructed at the mountain camps generally lacked any excavation, probably due to the 

summer occupation. Other structures included sweathouses, ceremonial enclosures, ramadas, 

and acorn granaries. The material culture included ceramic cooking and storage vessels, baskets, 

flaked lithic and ground stone tools, arrow shaft straighteners, stone, bone, and shell ornaments. 

Hunting implements included the bow and arrow, curved throwing sticks, nets and snares. Shell 

and bone fishhooks, as well as nets, were used for fishing. Lithic materials including quartz and 

metavolcanics were commonly available throughout much of the Kumeyaay territory. Other 

lithic resources, such as obsidian, chert, chalcedony and steatite, occur in more localized areas 

and were acquired through direct procurement or exchange. Projectile points including the 

Cottonwood Series points and Desert Side-notched points were commonly produced. 

Kumeyaay culture and society remained stable until the advent of missionization and 

displacement by Hispanic populations during the eighteenth century. The effects of 

missionization, along with the introduction of European diseases, greatly reduced the native 

population of southern California. By the early 1820s, California was under Mexico's rule. The 

establishment of ranchos under the Mexican land grant program further disrupted the way of life 

of the native inhabitants.

Ethnohistoric Period 

The Ethnohistoric period refers to a brief period when Native American culture was initially 

being affected by Euroamerican culture and historical records on Native American activities 

were limited. When the Spanish colonists began to settle California, the project area was within 

the territory of a loosely integrated cultural group historically known as the Kumeyaay or 

Northern and Southern Diegueño because of their association with the San Diego Mission. The 

Kumeyaay as a whole speak a Yuman language, which differentiates them from the Luiseño to 

the north, who speak a Takic language (Kroeber 1925). Both of these groups were huntergatherers with highly developed social systems. European contact introduced diseases that 

dramatically reduced the Native American population and helped to break down cultural 

institutions. The transition to a largely Euroamerican lifestyle occurred relatively rapidly in the 

nineteenth century.
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Final Environmental Assessment 3-24

Historic Period 

Cultural activities within San Diego County between the late 1700s and the present provide a 

record of Native American, Spanish, Mexican, and American control, occupation, and land use. 

An abbreviated history of San Diego County is presented for the purpose of providing a 

background on the presence, chronological significance, and historical relationship of cultural 

resources within the county. 

Native American control of the southern California region ended in the political views of western 

nations with Spanish colonization of the area beginning in 1769. De facto Native American 

control of the majority of the population of California did not end until several decades later. In 

southern California, Euroamerican control was firmly established by the end of the Garra 

uprising in the early 1850s (Phillips 1975). 

The Spanish Period (1769-1821) represents a period of Euroamerican exploration and settlement. 

Dual military and religious contingents established the San Diego Presidio and the San Diego 

and San Luis Rey Missions. The Mission system used Native Americans to build a footing for 

greater European settlement. The Mission system also introduced horses, cattle, other 

agricultural goods and implements; and provided construction methods and new architectural 

styles. The cultural and institutional systems established by the Spanish continued beyond the 

year 1821, when California came under Mexican rule. 

The Mexican Period (1821-1848) includes the retention of many Spanish institutions and laws. 

The mission system was secularized in 1834, which dispossessed many Native Americans and 

increased Mexican settlement. After secularization, large tracts of land were granted to 

individuals and families and the rancho system was established. Cattle ranching dominated other 

agricultural activities and the development of the hide and tallow trade with the United States 

increased during the early part of this period. The Pueblo of San Diego was established during 

this period and Native American influence and control greatly declined. The Mexican Period 

ended when Mexico ceded California to the United States after the Mexican-American War of 

1846-48. 

Soon after American control was established (1848-present), gold was discovered in California. 

The tremendous influx of American and Europeans that resulted quickly drowned out much of 

the Spanish and Mexican cultural influences and eliminated the last vestiges of de facto Native 

American control. Few Mexican ranchos remained intact because of land claim disputes and the 

homestead system increased American settlement beyond the coastal plain. 

The San Pasqual Band originally lived along the San Dieguito River in the San Pasqual Valley. 

During the 1850s and 1860s, Americans began to settle portions of the San Pasqual Valley and 

encroach on the Native American lands associated with the Pueblo they had built there. In 1856, 

Panto, the well-known Capitan of the San Pasqual Indians, asked the U.S. Army for protection 

from encroachment on their lands (Rustvold 1983). During this period, encroachment on Native 

American lands occurred throughout southern California and eventually a reservation was 

established in San Pasqual on January 31, 1870, by President Ulysses S. Grant (Peet 1949). This 

reservation was retracted only five months later due to protests from the American community 

and political pressure. Eventually, although the Indians continued to press claims to this land, a 
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Final Environmental Assessment 3-25

Deputy Sheriff evicted them from the Pueblo in 1878 and destroyed the structures he found there 

(Ferris 1984). The Native Americans scattered until the current San Pasqual Reservation was 

established for them in 1910 in the Valley Center area. This reservation is located north of their 

original territory, however, due to a past mapping error (Shipek 1987). 

3.5.2 Findings 

Records and Literature Search 

The archival research consisted of literature and record searches at local archaeological 

repositories, in addition to an examination of historic maps, and historic site inventories. This 

information was used to identify previously recorded resources and determine the types of 

resources that might occur in the survey area. The methods and results of the archival research 

are described below. 

The records and literature search for the project was conducted at the South Coastal Information 

Center at San Diego State University and the San Diego Museum of Man. The records search 

included a one-mile radius around the site to provide background on the types of sites that would 

be expected in the region. Copies of historic maps were provided by the South Coastal 

Information Center. 

A total of 25 documented archaeological investigations have taken place in the vicinity of the 

site. These studies include those for sewer and water projects, significance assessments, 

telecommunication projects, private land development projects, and other projects on San 

Pasqual Reservation lands. A total of two previously conducted cultural resources investigations 

were completed within the project area (Dallas 2007; WhatFJ, 2007). 

Previous research within a one-mile radius of the site has revealed the presence of cultural 

resources, however none were found within the parcel at the site. 

Field Survey 

A survey of the site was conducted on October 21, 2009 by Mr. Andrew R. Pigniolo, RPA and 

Ms. Elizabeth Davidson, RPA. The site was surveyed on foot at approximately 5 to 10 meter 

intervals. The site includes a paved parking area and an open field. The survey focused on the 

identification of potential historic features and prehistoric resource evidence. Surface visibility 

was good, although some areas of non-native grass were dense. Overall surface visibility 

averaged approximately 40 percent. The cultural resources inventory of the site served to 

identify cultural resources within the constraints of surface visibility and paved areas. 

Cultural resources identified during the survey were recorded on appropriate Department of 

Parks and Recreation forms and will be submitted to the South Coastal Information Center for 

trinomials. Photographs and project records for this inventory will be temporarily curated at 

Laguna Mountain until final curation arrangements can be made at the San Diego Archaeological 

Center or another appropriate regional repository. 
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Final Environmental Assessment 3-26

A sacred lands file search was conducted at California Native American Heritage Commission. 

The California Native American Heritage Commission also provided a list of appropriate local 

Native American contacts. 

The cultural resource survey identified two prehistoric Santiago Peak Volcanic flake isolates 

within the site. The cultural resources identified during the survey are described in greater detail 

in the Cultural Resources Inventory provided as Appendix F (confidential) and addendum to the 

Cultural Resources Inventory provided in Appendix G. As described in Appendix G, evaluation 

of the sites’ significance determined that they are not eligible for inclusion within the National 

Register of Historic Places. 

3.5.3 Regulatory Background 

National Historic Preservation Act 

Section 106 of the National Historic Preservation Act (NHPA) as amended, and its implementing 

regulations found in 36 CFR Part 800, require federal agencies to identify cultural resources that 

may be affected by actions involving federal lands, funds, or permitting. The significance of the 

resources must be evaluated using established criteria outlined in 36 CFR 60.4, as described 

below. 

If a resource is determined to be a historic property, Section 106 of the NHPA requires that 

effects of the federal undertaking on the resource be determined. A historic property is defined 

as: 

“...any prehistoric or historic district, site, building, structure or object included 

in, or eligible for inclusion in the National Register of Historic Places, including 

artifacts, records, and material remains related to such a property...” (NHPA Sec. 

301(5)) 

Section 106 of the NHPA prescribes specific criteria for determining whether a project would 

adversely affect a historic property, as defined in 36 CFR 800.5. An impact is considered 

significant when prehistoric or historic archaeological sites, structures, or objects that are listed, 

or eligible for listing, in the NRHP are subjected to the following: 

• physical destruction of or damage to all or part of the property; 

• alteration of a property; 

• removal of the property from its historic location; 

• change of the character of the property’s use or of physical features within the property’s 

setting that contribute to its historic significance; 

• introduction of visual, atmospheric, or audible elements that diminish the integrity of the 

property’s significant historic features; 

• neglect of a property that causes its deterioration; and 

• transfer, lease, or sale of the property out of federal control without adequate and legally 

enforceable restrictions or conditions to ensure long-term preservation of the property’s 

historic significance. 
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Final Environmental Assessment 3-27

If the historic property will be adversely affected by development, then prudent and feasible 

measures to avoid or reduce adverse impacts must be taken. The State Historic Preservation 

Officer (SHPO) must be provided an opportunity to review and comment on these measures 

prior to project implementation. 

National Register of Historic Places (NRHP) 

The eligibility of a resource for listing in the NRHP is determined by evaluating the resource 

using criteria defined in 36 CFR 60.4 as follows: The quality of significance in American 

history, architecture, archaeology, and culture is present in districts, sites, buildings, structures, 

and objects of state and local importance that possess integrity of location, design, setting, 

materials, workmanship, feeling, association, and 

A. That are associated with events that have made a significant contribution to the broad 

patterns of our history; 

B. That are associated with the lives of persons significant in our past; 

C. That embody the distinctive characteristics of a type, period, or method of construction, 

or that represent the work of a master, or that possess high artistic values, or that 

represent a significant and distinguishable entity whose components may lack 

individual distinction; or 

D. That have yielded, or may be likely to yield, information important to prehistory or 

history. 

Sites younger than 50 years, unless of exceptional importance, are not eligible for listing in the 

NRHP. 

In addition to meeting at least one of the criteria listed above, the property must also retain 

enough integrity to enable it to convey its historic significance. The NRHP recognizes seven 

aspects or qualities that, in various combinations, define integrity (NPS, 1990). These seven 

elements of integrity are: location, design, setting, materials, workmanship, feeling, and 

association. To retain integrity a property will always possess several, and usually most, of these 

aspects. 

While most historic buildings and many historic archaeological properties are significant because 

of their association with important events, people, or styles (criteria A, B, and C), the 

significance of most prehistoric and some historic-period archaeological properties is usually 

assessed under criterion D. This criterion stresses the importance of the information contained in 

an archaeological site, rather than its intrinsic value as a surviving example of a type or its 

historical association with an important person or event. It places importance not on physical 

appearance but rather on information potential. 

3.5.4 Native American Consultation 

On October 5, 2009, the State of California Native American Heritage Commission (NAHC) was 

asked to review the Sacred Lands file for information on Native American cultural resources 
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Final Environmental Assessment 3-28

within the vicinity of the Site (Appendix F). On November 3, 2009 the NAHC completed a 

records search for the Site, as well as for significant cultural sites within 1 mile of the Site. The 

records search did not indicate the presence of Native American cultural resources within a onehalf mile radius of the Site. Additional Native American consultation included a letter to the San 

Pasqual Band of Mission Indians, as well as several other known tribes in the area. The Pala 

Band of Mission Indians issued a response letter revealing that the proposed project at the Site 

would be outside the tribe’s Traditional Use Area, and therefore would not impact any known 

cultural sites or activities relating to the tribe. All Native American correspondence can be found 

in Appendix F. 

3.6 Socioeconomic Conditions/ Environmental Justice 

3.6.1 San Diego County 

The Site is located in San Diego County, within the town of Valley Center. The closest city is 

Escondido, located approximately 5 miles south of Valley Center. 

Population 

The population of Valley Center as of the 2000 census was 14,559, while the population of 

Escondido as of 2009 is 144,831. The population of San Diego County as of 2009 is 3,173,407. 

The city of San Diego is the largest city within the County with a population of 1,353,993 as of 

2009 (State of California Department of Finance, 2009). 

Housing 

As of January, 2009 there are 1,149,647 total housing units within San Diego County. There are 

585,907 detached units, and 99,177 attached units. There are 48,223 mobile homes registered in 

the County. Approximately 4.39% of the housing units are vacant (State of California 

Department of Finance, 2009). 

Employment 

The County of San Diego County employs approximately 1,528,814 residents, and the 

unemployment rate in San Diego County is approximately 6%. The Valley Center labor force 

includes approximately 6,784 citizens. The median household income in San Diego County is 

approximately $63,727, while the Valley Center median household income is approximately 

$58,147. 

Despite the fact that the Tribe has benefitted from increased prosperity due to the expansion of 

Valley View Casino, Tribal unemployment remains at approximately 25% due to the restrictive 

employment prerequisites at the Casino which include credit history and criminal conviction 

restrictions. 

Most of the employment opportunities for the tribal members are available in Escondido and San 

Marcus. 
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The proposed retail plaza would provide economic development for the Tribe, which would 

increase tribal revenues and provide additional employment opportunities and managerial 

experience for tribal members. In addition, because of the growth of Valley Center it is expected 

that the retail plaza would be able to help alleviate demand in the surrounding community for 

certain stores and other needs. The jobs created from the Proposed Action would be potentially 

filled by tribal members, other Native Americans, and residents of the Reservation – a significant 

portion of which could be considered minority and low-income populations. 

According to 2000 U. S. Census data, the population on the Reservation is 752 tribal members. 

There are approximately 230 residential units in the community which range from very 

substandard to relatively new homes. Some current facilities include the Tribal Administration 

Building and the Education Center. The Reservation community does not have a store, post 

office, bank, or business district. These services are available at surrounding communities such 

as Escondido or Valley Center. 

3.6.2 Demographic Trends 

The population of the San Pasqual Indian Reservation appears stable and is experiencing very 

moderate growth rates. Situated in a rural environment in San Diego County, the area has been 

largely sheltered from the rapid growth experienced by other portions of the county. 

3.6.3 Property Taxes 

The Project site is located on San Diego County tax parcel 189-051-02-00. According to the San 

Diego County Treasurer-Tax Collector, the total annual property tax for the parcel in the 2009-

2010 fiscal year was approximately $1,778 for the Site (San Diego County, 2010). 

3.6.4 Lifestyle and Cultural Values 

The San Pasqual Band consists of family based groups that share a common language and 

culture. Their traditional language is the I’pai, which is part of the Yuman-Cochimi language 

family. The San Pasqual Band members continue to participate in traditional celebrations, 

dances, and games, such as peon. Currently there are approximately 300 enrolled members. 

Tribal Members support the proposed action and view the proposed development as a method of 

expanding the economic base of the Tribe. The lifestyle and cultural values of the Tribal 

community (other than enhanced economic conditions) is not expected to be altered by the 

Proposed Action. 

3.6.5 Environmental Justice For Minority And Low Income Populations 

On February 11, 1994, President Clinton issued Executive Order 12898, “Federal Actions to 

Address Environmental Justice in Minority Populations and Low-Income Populations,” and an 

accompanying Presidential Memorandum to focus Federal attention on the environmental and 

human health conditions in minority communities and low-income communities. The Executive 

Order, as amended, directs federal agencies to develop an Environmental Justice Strategy that 

identifies and addresses disproportionately high human health or environmental effects of their 
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Final Environmental Assessment 3-30

programs, policies, and activities on minority populations and low-income populations. 

Compliance with this Executive Order has been incorporated into the NEPA compliance 

requirements of the BIA for the Proposed Action. 

San Diego County is approximately 25% minority (Table 3-4). In San Diego County, Native 

Americans make up 1.5% of the population. 

Table 3-4: San Diego Race/Income Profile 

Race/Ethnic Population Total Percentage of Total 

White 2,208,841 74.5 

Black or African American 176,135 5.9 

American Indian and Alaska 

Native 

45,546 1.5 

Asian 347,193 11.7 

Native Hawaiian and Other 

Pacific Islander 

23,584 0.8 

Other Race 283,420 9.6 

Household Median Income 

2008 

$63,727 -- 

Poverty Status (All Ages) -- 11.7 

Source: US Census, 2009 

3.7 Transportation and Circulation 

Transportation Networks 

This section describes the existing transportation system in the vicinity of the site. A Traffic 

Impact Analysis (Appendix H) was conducted by Linscott, Law and Greenspan (LLG) in 

August, 2010. The results of the analysis are summarized below. 

Valley Center Road is classified on the Adopted County of San Diego Circulation Element as a 

Prime Arterial west/south of Cole Grade Road and as a Collector east/north of Cole Grade Road. 

In the County’s General Plan (GP) Update, Valley Center Road is classified as a 4.1A Major 

Road Series from Woods Valley Road to Lilac Road, a 4.2A Boulevard Series from Lilac Road 

to Miller Road, a 4.2A Boulevard Sereies from Miller Road to Vesper Road and a 2.1D 

Community Collector Series from Vesper Road to Lake Wohlford Road. From north of Lake 

Wohlford Road (S.) to Cole Grade Road, Valley Center Road has recently been widened to 

major road standards (four-lane divided roadway with bike lanes). East of Cole Grade Road, 

Valley Center Road becomes a two-lane undivided roadway. Beginning at Sunset Road, Valley 

Center Road provides a two-way left-turn lane (TWLTL) continuing to Lake Wohlford Road 
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Final Environmental Assessment 3-31

(N.). The posted speed limit ranges from 45 to 60 mph with bus stops provided. Bike lanes are 

provided and curbside parking is prohibited for the entirety of the roadway. 

Lake Wohlford Road is classified on the Adopted County of San Diego Circulation Element as 

a Collector. In the County’s GP Update, Lake Wohlford Road (N.) is classified as a 2.2D Light 

Collector. Lake Wohlford Road (N.) is currently constructed as a two-lane undivided roadway. 

The posted speed limit within the project area varies between 45 to 50 mph. Curbside parking is 

generally prohibited, and no bike lanes or bus stops are provided. 

Woods Valley Road is classified on the Adopted County of San Diego Circulation Element as a 

Rural Collector. In the County’s GP Update, Woods Valley Road is classified as a 2.2C Light 

Collector Series from Lake Wohlford Road to Oakmont Road and a 2.1D Community Collector 

Series from Oakmont Road to Valley Center Road. Woods Valley Road is currently constructed 

as a two-lane undivided roadway. Curb, gutter and sidewalks are not provided. The posted 

speed limit ranges from 40 to 45 mph in the project vicinity. 

Cole Grade Road is classified on the Adopted County of San Diego Circulation Element as a 

Collector. In the County’s Update, Cole Grade Road is classified as a 4.2A Boulevard Series 

from Valley Center Road to Horse Creek Road. It is currently constructed as a two-lane road 

with a TWLTL within the study area. Curb and gutter are provided and sidewalks are not 

provided. The posted speed limit ranges from 45 to 50 mph. 

Lilac Road is classified on the Adopted County of San Diego Circulation Element as a 

Collector. In the County’s Update, Lilac Road is classified as a 4.2A Boulevard Series from 

Valley Center Road to Betsworth Road. It is currently constructed as a two-lane undivided road. 

Curb, gutter and sidewalks are not provided. The posted speed limit ranges from 45 to 50 mph in 

the project vicinity. 

School Bus Road is an unclassified private roadway. It currently operates primarily as a oneway roadway with vehicles entering from Valley Center Road and exiting at Lake Wohlford 

Road (N.). Currently, school buses, casino shuttle buses and private vehicles driven by casino 

employees utilize School Bus Road. A small portion of School Bus Road between Valley Center 

Road and the parking lot driveway operates as a two-way roadway used for private casino 

employee vehicles and shuttle service. The remainder of the roadway operates one-way and 

serves as a student pick-up zone for the middle school. 

Existing Traffic Volumes 

Peak hour intersections turning movement traffic counts and segment counts within the project 

area were conducted by LLG in July 2009 and July 2010. Traffic counts were conducted 

between 7:00 AM and 9:00 AM and the highest hour of traffic within this period was utilized. 

Similarly, the highest hour of traffic between 4:00 PM and 6:00 PM was used in the analysis. 

Since school was not in session during the time of data collection, a 5% growth factor was used 

to forecast non-summer counts. This rate is based on a comparison of previous non-summer 

counts collected in the general vicinity of the project area to the data collected in July 2010. 

Table 3-5 is a summary of the most recent available average daily traffic volumes (ADTs). 
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Final Environmental Assessment 3-32

Table 3-5: Existing Traffic Volumes 

Street Segment ADTa

Valley Center Road 

Lake Wohlfored Road (N.) to Cole Grade Road 11,180 

Cole Grade Road to Lilac Road 22,910 

Lilac Road to Woods Valley Road 24,100 

Woods Valley Road to Lake Wohlford Road (S) 24,930 

Lake Wohlford Road (N) 

Valley Center Road to Woods Valley Road 9,420 

Woods Valley Road to Guejito Road 5,970 

Woods Valley Road 

Valley Center Road to Lake Wohlford Road (N) 2,450 

Cole Grade Road 

Valley Center Road to Fruitvale Road 12,230 

Source: TIA, 2010 (Appendix H) 

Footnotes: a. Average Daily Traffic Volumes. 

The project is located in the community of Valley Center, north of the San Pasqual Indian 

Reservation, in the County of San Diego. The site is located on the southwest corner of the 

Valley Center Road/Lake Wohlford Road intersection. 

Access to the project site is via a driveway on Valley Center Road at School Bus Road. 

Currently, school buses, shuttle buses and casino employee private vehicles utilize the Valley 

Center Road/ School Bus Road intersection. 

Existing Conditions 

School buses currently use School Bus Road to drop-off students in the morning and pick them 

up in the afternoon on weekdays during the school year. The buses enter School Bus Road from 

Valley Center Road, pick-up and drop-off students at the sidewalk along the south side of the 

road within the west-to-east section of the School Bus Road, and exit onto Lake Wohlford Road. 

Shuttle buses are currently used to transport casino employees. The shuttle buses make a rightturn onto School Bus Road (two-way portion) from Valley Center Road, make a left-turn into the 

existing parking lot, load or unload the employees at the shelters within the existing parking lot, 

return to School Bus Road where they make a right-turn to exit the lot, and lastly turn right at 

Valley Center Road and head east toward Lake Wohlford Road where they make a right-turn to 

travel south toward the casino. It should be noted that the shuttle buses only utilize a short 
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Final Environmental Assessment 3-33

segment of School Bus Road (two-way portion) to ingress the parking lot. No left turns exiting 

the parking lot onto School Bus Road are allowed. 

Private vehicles driven by casino employees enter the parking lot from Valley Center Road by 

turning onto School Bus Road (two-way portion), and then make a left-turn into the existing 

parking lot. Vehicles exiting the parking lot make a right-turn onto School Bus Road and 

continue onto Valley Center Road to reach their destination. No left turns exiting the parking lot 

onto School Bus Road are allowed. 

Existing Intersection and Roadway Segment Level of Service 

Table 3-6 and 3-7 show the existing level of service (LOS) of intersections and roadway 

segment, respectively, within the project study area. 

Table 3-6: Intersection Level of Service 

No. Intersection Control 

Type 

Peak 

Hour 

Existing 

Delaya LOSb

1 Valley Center Road/Cole Grade Road Signal AM 

PM 

32.2 

32.9 

C 

C 

2 Valley Center Road/ Street “A” TWSC AM 

PM 

20.3 

13.1 

C 

B 

3 Valley Center Road/Lake Wohlford Road (N) Signal AM 

PM 

23.3 

26.0 

C 

C 

4 Lake Wohlford Road (N)/School Bus Road TWSC AM 

PM 

14.6 

10.2 

B 

B 

5 Lake Wohlford Road (N)/Wood Valley Road AWSC AM 

PM 

11.1 

10.7 

B 

B 

6 Lake Wohlford Road (N)/ Project Access TWSC AM 

PM 

- 

- 

- 

- 

7 Valley Center Road/Lilac Road Signal AM 

PM 

14.9 

13.7 

B 

B 

8 Valley Center Road/Woods Valley Road Signal AM 

PM 

16.1 

17.7 

B 

B 

Source: TIA, 2010 (Appendix D).

Currently all intersections within the project study area operate at an acceptable LOS. All 

roadway segments with the exception of Valley Center Road between Lake Wohlford Road (N.) 

to Cole Grade Road operate at an acceptable LOS. 

 
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Final Environmental Assessment 3-34

Table 3-7: Roadway Segment Level of Service 

Street Segments Capacity 

(LOS E) 

Existing 

ADT LOS

Valley Center Road 

Lake Wohlford Road (N) to Cole Grade Road 16,200 11,180 E 

Cole Grade Road to Lilac Road 37,000 22,910 B 

Lilac Road to Woods Valley Road 37,000 24,100 B 

Woods Valley Road to Lake Wohlford Road (S) 37,000 24,930 C 

Lake Wohlford Road (N.) 

Valley Center Road to Woods Valley Road 16,200 9,420 D 

Woods Valley Road to Guejito Road 16,200 5,970 C 

Woods Valley Road 

Valley Center Road to Lake Wohlford Road (N) 16,200 2,450 B 

Cole Grade Road 

Valley Center Road to Fruitvale Road 19,000 12,230 C 

Source: TIA, 2010 (Appendix D).

3.8 Land Use 

Valley Center Community Plan Area 

The site is located within the Valley Center Community Plan Area, and is currently used as an 

overflow parking lot for Valley View Casino, and as undeveloped ruderal land. This Community 

Plan Area comprises approximately 94 square miles in the unincorporated area of northern San 

Diego County. According to the County of San Diego, Department of Planning and Land Use, 

the site is zoned as Special Purpose, Parking (S86). The site was rezoned to this designation on 

February 28, 2009. 

According to the Valley Center Community Plan,1

 the general land use goals of the Valley 

Center Community Plan are to: 

“Provide a land use pattern which will give the Valley Center Community 

Planning Area the opportunity to remain economically and socially viable. 

Encourage a balance of land uses which will conserve natural and man-made 

resources, retain Valley Center’s rural character, and will accommodate people of 

diverse lifestyles, occupations, and interests. 

 

1

 Part II, Valley Center Community Plan, San Diego County General Plan, Amended April 17, 2002. 
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Final Environmental Assessment 3-35

Provide a land use pattern that accommodates and provides for primarily rural 

residential development on two-acre home sites 

Maintain a rural atmosphere and manage the density and locations of 

development.”2 

As to commercial development specifically, the goal of the Valley Center Community Plan is to: 

“Provide for well planned and designed small scale centralized and contained 

commercial areas that are compatible with a low density rural residential 

community.”3 

As the Site would be located on Federal trust land, no San Diego County or State of California 

land use regulations or permit requirements would be applicable to the development of the 

proposed retail plaza. Although San Diego County land use restrictions are not applicable to the 

Proposed Action, the Tribe desires to comply, to the extent possible, with existing land use 

requirements that apply to nearby land under county jurisdiction. 

Although the Valley Center Community Plan discourages commercial strip development, the 

proposed development would be on a small scale and would be compatible with the surrounding 

rural residential community. Several of the adjacent properties are already occupied by 

commercial-type buildings, including the Valley Center Middle School. The Tribe desires to 

comply with the adopted Design Guidelines for Valley Center during the design of the proposed 

retail plaza to the extent possible. 

Site-Specific Land Use Agreements 

The Tribe entered into an agreement (Site Plan 06-004) with the County of San Diego regarding 

the development of the site in February 2009. In the agreement, the Tribe has agreed to comply 

with County zoning ordinance set forth by the County of San Diego Department of Planning and 

Land Use. Some of the land use controls and construction best management practices relating to 

preserving the environmental quality of the site and the surrounding area that are included in the 

agreement are: 

To comply with County zoning ordinances by dedicating areas at the site for easements relating 

to utility placement and access, surface water drainage, the construction of sidewalks and bike 

lanes for pedestrian access, creating a landscape plan, as well as other land use controls. 

However, under the Proposed Action the property would be taken into federal trust on behalf of 

the Tribe and therefore would no longer be subject to local zoning regulations including Site 

Plan 06-004. The agreement also addresses the Tribe’s compliance with construction best 

management practices relating to controlling dust particulate generated at the site. 

 

2

 Supra, n. 1 at page 6. 

3

 Supra, n.1 at page 9. 
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Final Environmental Assessment 3-36

Agriculture 

Williamson Act Program 

The California Land Conservation Act of 1965, commonly referred to as the Williamson Act 

enables local governments to enter into contracts with private landowners for the purpose of 

restricting specific parcels of land to agricultural or related open space use. In return, 

landowners receive property tax assessments which are much lower than normal because they 

are based upon farming and open space uses as opposed to full market value. Local governments 

receive an annual subvention of forgone property tax revenues from the state via the Open Space 

Subvention Act of 1971 (State of California Department of Conservation, 2010). 

Project Site Conditions 

The site is not currently used for agriculture, nor is the project site under Williamson Act 

contract. However, the site was zoned Limited Agricultural Use (A70) until February 28, 2009, 

when its zoning was changed to Special Purpose, Parking (S86). Under the Proposed Action, the 

property would be taken into federal trust on behalf of the Tribe and therefore would not be 

subject to local zoning regulations. The project site is designated under the Farmland Mapping 

and Monitoring Program (FMMP) as “Other Lands” under the San Diego County Important 

Farmland Map 2006 (California Department of Conservation, 2009). There are no prime or 

unique farmlands on the Site. 

3.9 Public Services 

3.9.1 Water Supply 

Since the site is undeveloped, aside from its use as a parking lot for the Valley View Casino, 

there is no public or private water supply utilized at the site. However, public water service is 

available at the site through an existing water line and service meter that was installed by the 

Valley Center Municipal Water District. This water meter is an active account and has a user 

code of “Commercial”. A Will Serve letter was obtained from Valley Center Municipal Water 

District (VCMWD) for the property for the next two years (Appendix B). 

3.9.2 Wastewater Service 

No municipal or private wastewater service is currently utilized at the site. There are no existing 

municipal wastewater service mains in the project area. As described in Section 3.2, surrounding 

residences and businesses rely on on-site septic systems and leachfields for wastewater treatment 

and disposal. Wastewater at the proposed facility would be directed to the Tribe’s wastewater 

treatment facility at the Valley View Casino. 

3.9.3 Solid Waste 

Management of non-hazardous solid waste in San Diego County is mandated by Assembly Bill 

(AB) 939, the California Integrated Waste Management Act. The purpose of the AB 939 is to 

reduce, recycle, and reuse solid waste generated in the State to the maximum extent feasible; 

improve regulation of existing solid waste landfills; ensure that new solid waste landfills are 

environmentally sound; streamline permitting procedures for solid waste management facilities; 
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and specify the responsibilities of local governments to develop and implement integrated waste 

management programs. 

The primary solid waste disposal contractor in the Valley Center area is EDCO, a southern 

California-based private company that specializes in waste collection and recycling services. 

Solid waste is taken from Valley Center to a transfer station in Escondido. From the transfer 

station, a majority of solid waste is hauled to the Sycamore Sanitary Landfill. 

The Sycamore Sanitary Landfill is located at 8514 Mast Boulevard in San Diego, California. 

The landfill is permitted for a maximum capacity of 3,965 tons per day. As of September 30, 

2006 the remaining capacity is 47,388,428 cubic yards out of a total disposal capacity of 

48,124,462 cubic yards. The landfill disposal area covers 324 acres. Accepted waste types 

include agricultural, asbestos, contaminated soils, mixed municipal, sludge, tires, shreds, wood 

waste, and other designated wastes. 

3.9.4 Electricity and Telecommunications 

There is currently no electrical meter connection at the site, and the proposed development 

would require a service meter (or meters) adequate for the power needs of the development. 

Electricity in the vicinity of the project site is provided by San Diego Gas & Electric Company. 

Telephone service and cable television is supplied through Cox Communications. Wireless 

telephone service is also offered by several national carriers, such as Verizon Wireless and 

AT&T. 

3.9.5 Law Enforcement 

Police protection is provided by the San Diego County Sheriff’s Department and California 

Highway Patrol. The Project Site is located within Operation Area 1. The Tribe has an 

agreement with the San Diego County Sheriff’s Department to provide law enforcement services 

on the reservation. The nearest substation is located on Lake Wohlford Road, approximately 

1,000 feet from the site. The substation has a staff of 17 sworn deputies, three sergeants, one 

lieutenant, and three detectives. The substation is staffed 24-hours a day by a minimum of two 

deputies (SDCSD, 2010). The Pauma-Valley Center Substation covers an area of approximately 

333 square miles. 

According to State Public Law 280, the State of California would maintain criminal jurisdiction 

on trust land. Most civil jurisdiction has been transferred to the Tribe, relieving San Diego 

County Sheriff’s Department from civil enforcement matters. 

3.9.6 Fire Protection and Emergency Medical 

Fire Protection Services are provided by the San Pasqual Reservation Fire Department, which 

includes four fire trucks in a firehouse located two minutes from the site. The San Pasqual RFD 

has 18 full-time staff and 15 paid reserves. The San Pasqual FD is staffed 24 hours a day with a 

minimum of 8 staff. On-site equipment includes two Type I Structure Engines, a Ladder truck, a 

Type III engine, and one command vehicle (San Pasqual RFD, 2010). Additional fire protection 

for the surrounding areas is provided by the Valley Center Fire Department through the 
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Final Environmental Assessment 3-38

California Department of Forestry. An agreement exists between the BIA and the California 

Department of Forestry and Fire Protection (CAL FIRE) to provide services on tribal land within 

the State of California. The nearest CAL FIRE station is located at 16971 Highway 76, Pauma 

Valley, CA. This seasonal fire station would provide additional wildlife protection to the project 

site during the summer months, when regional wildland fires most commonly occur. 

Emergency medical service is provided by the San Pasqual Reservation RFD located two 

minutes from the site. Additional emergency medical services are available from Valley Center 

located one-half mile from the site. Patients are usually transported to Palomar Medical Center 

on East Valley Parkway in the City of Escondido approximately 5 miles south of the site. 

3.10 Noise 

This section describes the existing noise and vibration conditions in the vicinity of the project 

site. This section includes a discussion of acoustical background and terminology, regulatory 

environment, and the existing noise and vibration conditions. 

3.10.1 Acoustical Background and Terminology 

Sound is defined as any pressure variation in air that the human ear can detect, and is technically 

described in terms of loudness (amplitude) and frequency (pitch). The standard unit of sound 

amplitude measurement is the decibel (dB). The decibel scale uses the hearing threshold (20 

micropascals of pressure), as a point of reference, defined as 0 dB. Other sound pressures are 

then compared to the reference pressure, and the logarithm is taken to keep the numbers in a 

practical range. The decibel scale allows a million-fold increase in pressure to be expressed as 

120 dB. 

The perceived loudness of sounds is dependent upon many factors, including sound pressure 

level and frequency content. However, within the usual range of environmental noise levels, 

perception of loudness is relatively predictable, and can be approximated by weighing the 

frequency response of a sound level meter by means of the standardized A-weighing network. 

There is a strong correlation between A-weighted sound levels (expressed as dBA) and 

community response to noise. For this reason, the A-weighted sound level has become the 

standard tool of environmental noise assessment. All noise levels reported in this section are in 

terms of A-weighted levels in dB. 

Community noise is commonly described in terms of the “ambient” noise level, which is defined 

as the all-encompassing noise level associated with a given noise environment. A common 

statistical tool to measure the ambient noise level is the average, or equivalent, sound level (Leq) 

over a given time period (usually one hour). The Leq is the foundation of the Day-Night Average 

Level noise descriptor, Ldn, and shows very good correlation with community response to noise. 

 

Table 3-8 contains definitions of acoustical terminology used in this section. Table 3-9 shows 

examples of noise sources, which correspond to various sound levels. The Day-night Average 

Level (Ldn) is based upon the average noise level over a 24-hour day, with a +10 decibel 

weighing applied to noise occurring during nighttime (10:00 p.m. to 7:00 a.m.) hours. The 

nighttime penalty is based upon the assumption that people react to nighttime noise exposures as 
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Final Environmental Assessment 3-39

though they were louder than daytime exposures. Because Ldn represents a 24-hour average, it 

tends to disguise short-term variations in the noise environment. Ldn-based noise standards are 

commonly used to assess noise effects associated with traffic, railroad, and aircraft noise sources. 

 Table 3-8: Typical A-Weighted Sound Levels of Common Noise Sources 

Terms Definitions 

Decibel, dB 

A unit describing the amplitude of sound, equal to 20 times the 

logarithm to the base 10 of the ration of the pressure of the sound 

measured to the reference pressure, which is 20 micropascals (20 

micronnewtons per square meter) 

Frequency, Hz The number of complete pressure fluctuations per second above and 

below atmospheric pressure. 

A-Weighted Sound 

Level, dBA 

Sound pressure level in decibels as measured on a sound level meter 

using the A-weighting filter network, which de-emphasizes very low 

and very high frequency components of the sound in a manner similar 

to the frequency response of the human ear and correlates well with 

subjective reactions to noise. 

L01, L10, L50, L90 The A-weighted noise levels that are exceeded 1%. 10%, 50%, and 

90% (respectively of the time during the measurement period. 

Equivalent Noise 

Level, Leq The average A-weighted noise level during the measurement period. 

Community Noise 

Equivalent Level, 

CNEL 

The average A-weighted noise level during a 24-hour day, obtained 

after adding 5 decibels to measurements taken in the evening (7 to 10 

pm) and 10 decibels to measurements taken between 10 pm and 7am. 

Day/Night Noise 

Level, Ldn 

The average A-weighted noise level during a 24-hour day, obtained 

after addition of 10 decibels to levels measured in the night between 

10:00 pm and 7:00 am. 

Lmax, Lmin The maximum and minimum A-weighted noise level during the 

measurement period. 

Ambient Noise 

Level 

The composite of noise from all sources near and far. The normal or 

existing level of environmental noise at a given location. 

Intrusive 

That noise which intrudes over and above the existing ambient noise at 

a given location. The relative intrusiveness of a sound depends upon 

its amplitude, duration, frequency, and time of occurrence and tonal or 

informational content as well as the prevailing ambient noise. 

Source: General Plan Guidelines, Governors Office of Planning and Research, 2003. 

3.10.1 Regulatory Environment 

Noise criteria used in this EA includes the Federal Highway Administration (FHWA) Noise 

Abatement Criteria for the assessment of noise consequences related to surface traffic. In 

addition, environmental consequences are also evaluated relative to the change in ambient noise 
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Table 3-9: Typical A-Weighted Sound Levels 

Common Outdoor Activities 

Noise 

Level 

(dBA) 

Common indoor Activities 

110 Rock band 

Jet flyover at 1,000 feet 105 

100 

Gas lawnmower at 3 feet 95 

90 

Diesel truck at 50 feet at 50 mph 85 Food blender at 3 feet 

80 Garbage disposal at 3 feet 

Noisy urban area, daytime 75 

Gas lawnmower at 100 feet 70 vacuum cleaner at 10 feet 

Commercial area 65 Normal speech at 3 feet 

Heavy Traffic at 300 feet 60 

Rural daytime 55 Large business office 

Quiet urban daytime 50 Dishwasher in next room 

45 

Quiet urban nighttime 40 Theater, large conference room (background) 

Quiet suburban nighttime 35 

30 Library 

Quiet rural nighttime 25 Bedroom at night, concert hall (background) 

20 

15 Broadcast/recording studio 

Source: Federal Transit Administration, Transit Noise and Vibration Assessment, April 1995 

conditions at existing noise-sensitive uses in the project vicinity which would result from the 

project. These criteria are discussed below. 

Federal Noise Abatement Criteria 

The FHWA establishes Noise Abatement Criteria (NAC) for various land uses which have been 

categorized based upon activity. Land uses are categorized on the basis of their sensitivity to 

noise, as indicated in Table 3.10. This table provides standards which may be considered 

applicable to the land uses surrounding the project site. 

San Diego County Noise Standards 

The San Diego County General Plan, 2006 provides the following noise standard policy within 

Policy 4b: 

Because exterior community CNEL above 60 dB and/or interior CNEL above 45 
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Table 3-10: Federal Noise Abatement Criteria (Hourly – DBA Soundlevel) 

Activity 

Category 

Leq (h), dBA Activity Category Description 

A 57 (Exterior) 

Lands on which serenity and quiet are of extraordinary 

significance and serve an important public need and where the 

preservation of those qualities is essential if the area is to 

continue to serve its intended purpose. 

B 67 (Exterior) 

Picnic areas, recreation areas, playgrounds, active sports areas, 

parks, residences, motels, hotels, schools, churches, libraries, 

and hospitals. 

C 72 (Exterior) Developed lands, properties, or activities not included in 

Categories A or B above. 

D N/A Undeveloped lands not meeting the requirements of Category A 

and with no sensitive noise receptors within the area. 

E 52 (Interior) Residences, motels, hotels, public meeting rooms, schools, 

churches, libraries, hospitals, and auditoriums. 

N/A = Not Applicable 

Source: Federal Highway Administration, 2009 

dB may have an adverse effect on public health and welfare, it is the policy of the 

County of San Diego that: 

Whenever it appears that new development may result in any (existing or future) 

noise sensitive land use being subject to noise levels of CNEL equal to 60 dBA or 

greater, an acoustical analysis shall be required. 

If the acoustical analysis shows that noise level at any noise sensitive land use 

will exceed CNEL equal to 60 dB, modifications shall be made to the 

development which reduce the exterior noise level to less than CNEL of 60 dBA 

and the interior noise level to less than CNEL of 45 dBA. 

 

If modifications are not made to the development in accordance with paragraph 2 

above, the development shall not be approved unless a finding is made that there 

are specifically identified overriding social or economic considerations which 

warrant approval of the development without such modification; provided, 

however, if the acoustical study shows that sound levels for any noise sensitive 

land use will exceed a CNEL equal to 75 dBA even with such modifications, the 

development shall not be approved irrespective of such social or economic 

considerations. 

Sensitive Receptors 

Some land uses are considered more sensitive to noise than others due the types of activities 

typical to the land use. Residences, motels and hotels, schools, libraries, churches, hospitals, 

nursing homes, auditoriums, and parks and other outdoor recreation area land uses are generally 

more sensitive to noise than commercial and industrial land uses. 
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Sensitive noise receptors in the vicinity of the Site include; the Valley Center Middle School, 

which is located directly south, adjacent to the project site. The School buildings are 

approximately 280 feet from the southern property line. There are also residences situated to the 

north, east, and west of the Site. The closest residence is approximately 170 feet from the 

southeastern border of the Site. There are no hospitals within the immediate vicinity of the Site. 

 

3.10.2 Existing Noise Sources 

Ambient Noise and Vibration 

Ambient noise generated at the Site primarily comes from traffic on Lake Wohlford Road on the 

eastern boarder of the project site, and from Valley Center Road on the northern boundary of the 

project site. 

Other potentially significant noise sources affecting the ambient noise level include nighttime 

aircraft operations at the San Diego International, Montgomery Field, McClellan Palomar, and 

Blackinton airports and the Marine Corps Air Station at Miramar, all of which are located 

between 10 to 35 miles from the Site. There are no vibration sources in the vicinity of the 

project site. 

3.11 Hazardous Materials 

Project Site Conditions 

A Phase I site assessment was conducted in April, 2009 at the site by GreenWave. The 

assessment and report was performed in general accordance with the EPA “All Appropriate 

Inquiry” (40 Code of Federal Regulation (CFR) Part 312), as well as the American Society for 

Testing and Materials (ASTM) Standard E1527-05 “Standard Practice for Environmental site 

Assessments: Phase I Environmental site Assessment Process” (ASTM, 2006). Research 

consisted of a review of historical and regulatory records, present conditions, site geology and 

hydrogeology, and interviews with persons knowledgeable of the site. 

The assessment revealed no evidence of Recognized Environmental Conditions (RECs) in 

connection with the site, and has revealed no evidence of RECs associated with nearby 

properties. GreenWave was unable to obtain information regarding the status of wells listed 

within 0.25 mile of the site. This lack of information represents a data gap; however, this data 

gap does not appear to impact the identification of RECs at the site. 

Regulatory Setting 

As discussed in Section 3.2 the Tribe would be required to conform to federal regulations under 

40 CFR 280, Technical Standards and Corrective Action Requirements for Owners and 

Operators of Underground Storage Tanks (USTs). Systems subject to these requirements are 

exempt from other federal regulation, including 40 CFR 112 Oil Pollution Prevention, to 

eliminate redundancy and streamline paperwork. 

40 CFR 280 includes requirements for tank installation, monitoring and reporting, corrective 
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action, remediation and site cleanup, and tank closure and removal. The regulation cites industry 

standards for tank design, integrity testing, repair, corrosion protection, release detection, and 

interstitial monitoring. The regulation is implemented at the federal level by the EPA. The 

implementing agency for the project site would be EPA Region 9. 

3.12 Visual Resources 

The site is characterized as a low-land area surrounded by the eastern Escondido foothill system. 

Currently, the site is used as a parking lot for the Valley View Casino, and is open, unimproved 

land. 

Regulatory Setting 

The San Diego County Light Pollution Code (LPC) or Dark Skies Ordinance was initiated in 

order “to minimize light pollution for the enjoyment and use of property and the night 

environment by the citizens of San Diego Count and to protect the Palomar and Mount Laguna 

observatories from the effects of light pollution that have a detrimental effect on astronomical 

research by restricting the permitted use of outdoor light fixtures on private astronomical 

research by restricting the permitted use of outdoor light fixtures on private property” (Sec. 

59.101). There are five guidelines for determining significance for adverse impacts under the 

Dark Skies Ordinance: 

• The Project will install outdoor light fixtures that do not conform to the lamp type and 

shielding requirements described in Section 59.105 (Requirements for Lamp Source and 

Shielding) and are not otherwise exempted pursuant Section 59.108 or Section 59.109 of 

the San Diego County Light Pollution code. 

• The project will operate Class I or Class III outdoor lighting between 11:00 p.m. and 

sunrise that is not otherwise exempted pursuant Section 59.108 or Section 59.109 of the 

San Diego County Light Pollution Code. 

• The project will generate light tress pass that exceeds 0.2 foot candles measuring five feet 

onto the adjacent property. 

• The project will install highly reflective building materials, incluign but not limited to 

reflective glass and high-gloss surface color, that will create daytime glare and be visible 

from roadways, pedestrian walkways or areas frequently used for outdoor activities on 

adjacent properties. 

• The project does not conform to applicable Federal, State, or Local statute or regulation 

related to dark skies or glare including but not limited to the San Diego County Light 

Pollution Code (San Diego County, 2009). 

Methodology 

The U.S. Bureau of Land Management (BLM) Visual Resource Management (VRM) 

methodology is used in this EA to inventory visual resources at the Site, and to evaluate the 

potential effects of the proposed development on existing visual and scenic resources in the area. 

The VRM system involves “inventorying scenic values, which is broken down into a two-step 

process and evaluates: 
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• Visual Resources Inventory 

• Visual Contrast Ratings 

The Visual Resources Inventory establishes the visual standards of a region by determining the 

VRM Class. Through the inventory evaluation process, the region’s scenic value is determined 

to be high, moderate, or low, and is subsequently placed into one of five classes of visual 

standards. 

Once the VRM Class is established, the evaluation of the project itself can commence. The 

Visual Contrast Rating system compares the degree of the contrast of the project with the current 

landscapes and then evaluates if the VRM Class’s visual standards, established with the Visual 

Resources Inventory, are met. 

Visual Resources Inventory 

The visual resource inventory process provides the means for determining visual values. The 

inventory consists of a scenic quality evaluation, sensitivity level analysis, and a delineation of 

distance zones. Based on these three factors, lands are placed into one of four visual resource 

inventory classes. These inventory classes represent the relative value of the visual resources. 

Classes I and II being the most valued, Class III representing a moderate value, and Class IV 

being of least value. The following process establishes the Interim Visual Resource 

Management Class using the Visual Resource Inventory System for the purpose of this analysis. 

Scenic Quality Evaluation 

Scenic quality is a measure of the visual appeal of a tract of land. In the visual resource 

inventory process, lands within the site are given an A, B, or C rating based on the apparent 

scenic quality which is determined using seven key factors: landform, vegetation, water, color, 

adjacent scenery, scarcity, and cultural modifications. It is important to note that all lands have 

scenic value, but areas with the most variety and most harmonious composition have the greatest 

scenic value. Also, the evaluation of scenic quality is done in relationship to the natural 

landscape. Man-made features within a landscape do not necessarily detract from the scenic 

value; instead, if they compliment the natural landscape they may enhance the scenic value. 

Evaluations avoid bias against man-made modification to natural landscape. A complete 

discussion of the methodology used to determine scenic quality is presented in Appendix I. 

Delineating Scenic Quality Rating Units (SQRUs) 

The Site is subdivided into scenic quality rating units for rating purposes. Rating areas are 

delineated on a basis of: like physiographic characteristics; similar visual patterns, texture, color, 

variety, etc.; and areas which have similar effects from man-made modifications. The size of 

SQRUs varies depending on the homogeneity of the landscape features and the detail desired in 

the inventory. More detailed attention is given to highly scenic areas or areas of known high 

sensitivity. 

Landform: The landform of the SQRU is characterized by mountains and valleys of varied 

topography. The Site is located within the middle of a large, flat valley plain. 
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Final Environmental Assessment 3-45

Vegetation: The vegetative pattern of the Site is sparse, with approximately half of the Site being 

occupied by a parking lot, and the other half being occupied by mixed ruderal growth and dirt 

patches. 

Water: There are no significant water bodies or drainages at the Site. 

Color: The color of the landforms and vegetation within the SQRU include light and dark beige, 

pale and dark greens. The dark asphalt and painted parking space lines contrast with the natural 

patches of dirt and vegetation. 

Influence of Adjacent Scenery: The Site is part of the greater Escondido foothill and valley 

system. As a low-lying area, the Site helps to form a natural contrast with the abundant 

mountainous features in the area. The presence of adjacent peaks in the area, such as French 

Mountain and Rodriguez Mountain help to form the adjacent local visual and scenic resources. 

Scarcity: The landforms and vegetation within the SQRU are fairly common within the eastern 

San Diego region. 

Cultural Modifications: Cultural modifications in the area include residential, commercial, and 

infrastructure development expanding out along the valley floor where flat lands have been 

utilized to build such population centers as Escondido and Valley Center. 

Scenic Quality Rating Summary 

The ratings presented in Table 3-11 below were identified for the Site. An explanation of the 

rating score is provided in Appendix I. 

Table 3-11: Scenic Quality Rating Summary 

Key Factor Rating 

Landform 2 

Vegetation 2 

Water 0 

Color 1 

Adjacent Scenery 3 

Scarcity 1 

Cultural Modifications 0 

Total Score 9 

Source: BLM, 2007

The assigned letter grades to scenic quality scores are as follows: 
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Final Environmental Assessment 3-46

• A: 19 or more 

• B: 12-18 

• C: 11 or less 

Therefore, the overall scenic quality of this SQRU is C. 

Sensitivity Level Analysis 

Viewer Sensitivity 

Sensitivity levels are a measure of public concern for scenic quality. These levels were analyzed 

within the Sensitivity Level Rating Unit (SLRU). SLRUs are derived from the types of users, 

amount of use, adjacent land uses, and presence of special areas. 

Type of Users: Currently, the only users of the Site are patrons and workers of the Valley View 

Casino who use the Site for parking. Overall type of users is “low.” 

Amount of Use: The Site gets a fair amount of use since the Site is available for a variety of 

different users associated with the Valley View Casino. The amount of use at the Site is “high.” 

Adjacent Land Uses: Residential and community development is the primary land use within the 

SLRU. Sporadic residential communities and small agricultural developments contour the base 

of the foothills around the Site. The SLRU designation is “low.” 

Special Areas: Currently, there are no special areas of high sensitivity within the Site. There are 

no endangered species, or special status species within the Site, and therefore, the sensitivity 

level is “low.” 

Overall Sensitivity Level 

Based on the evaluation presented in Table 3-12, the overall sensitivity level of the SLRU is 

determined to be “Low.” 

 Table 3-12: Overall Viewer Sensitivity 

Factor Rating 

Type of Users Low 

Amount of Use High 

Adjacent Land Users Low 

Special Areas Low 

Source: Greenwave, 2010
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Delineation of Distance Zones 

Distance can enhance or diminish visual quality of a landscape. Project details and dominance, 

and therefore effect, increases the closer the viewer stands to that project. By delimiting the 

landscape into general regions according to their distances, general assumptions can be made 

about the effects of the visual quality to the user. 

Landscapes are subdivided into three distanced zones based on relative visibility from travel 

routes or observation points. The three zones are: foreground-middleground, background, and 

seldom seen. The foreground-middleground zone includes areas seen from highways, rivers, or 

other viewing locations which are less than three to five miles away. Areas visible beyond the 

foreground-middleground zone, but usually less than 15 miles away, are in the background zone. 

Areas not seen as foreground-middleground or background (i.e., hidden from view) are in the 

seldom-seen zone. 

The site falls within the foreground-middleground zone. 

The overall scenic quality of this SQRU is "C" and the overall sensitivity level of the SLRU is 

determined to be “Low." Given these collective rating parameters, the overall Interim VRM 

Class scenic quality rating for the site is Class IV. The BLM assigns the following management 

strategy to Class IV resources: “to provide for management activities which require major 

modifications of the existing character of the landscape. The level of change to the characteristic 

landscape can be high. These management activities may dominate the view and be the major 

focus of viewer attention. However, every attempt should be made to minimize the impact of 

these activities through careful location, minimal disturbance, and repeating the basic elements.” 
Environmental Consequences 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 4-1

Section 4 Environmental Consequences 

This section analyzes the effects of the Proposed Action, as well as the no action alternative on 

various components of the environment. Conceptual development plans are utilized for the basis 

of the environmental analysis. 

4.1 Alternative A - Proposed Action 

4.1.1 Land Resources 

Topography 

The proposed retail plaza would be constructed at the Site. The topography of the Site would not 

be significantly altered. There would be some grading during construction, but the Site is nearly 

level in its current condition. While specific construction plans have not yet been developed, 

construction activities would include a small amount of grading and site preparation, followed by 

the construction of the retail plaza. During the initial site preparation, efforts would need to be 

made to contain all construction-related runoff associated with grading and soil disturbance. The 

contractor would need to institute a drainage plan in order to minimize runoff onto adjacent lands 

in the event of flooding during construction. Since the Site is relatively flat, there would be 

minimal disturbance to existing topography. Overall impacts to topography would be small. 

Soils 

There may be impacts to soils at the Site. The dominant soil type, Visalia sandy loam, may be 

diluted by other types of soil and construction fill used in the site preparation and grading of the 

proposed Tribal facilities. The potential change in soil type would not have a significant adverse 

effect on the environment. Impacts to soils would be small. 

4.1.2 Water Resources 

Surface Water Quality, Drainage, and Flooding 

Construction 

Impacts to surface water resources, if they occur, would primarily be associated with erosion of 

soils during construction activities, and with vegetation removal. Vegetation acts as binder to 

hold in soil and rock materials during precipitation events. Additionally, rock and soil materials 

may be transported or temporarily stockpiled on the Site. The change in the landscape would 

have an effect on the rate and volume of runoff and sediment load in a direct relationship to the 

exposed rock materials. Based on the existing hydrologic soil group B and “well drained” 

drainage class, the Site has a moderate potential for runoff in extreme precipitation events. 

Additionally, the flat site topography should limit sediment transport. Nevertheless, the fine 

grain size materials of the Site soils do have the potential for erosion and sediment transport. 

Without appropriate erosion control practices, the excavation and construction activities on the 

site could contribute to increased sedimentation and runoff flow to the intermittent drainages on 

and bordering the Site. The increase in sediment load may lead to channel aggradation within 

the Site drainages. Changes could affect the channel hydraulic attributes and subsequent 

watercourse direction or flood behavior. To address these impacts, the Tribe would submit a 
Environmental Consequences 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 4-2

Notice of Intent to comply with the NPDES Construction General Permit for California Indian 

lands to the EPA prior to any construction activities associated with the proposed action. 

Under the requirements of the Clean Water Act, sites disturbing more than one acre must apply 

for coverage under the NPDES Construction General Permit. The Permit requires the 

preparation of a SWPPP and the inclusion of site-specific Best Management Practices (BMPs) 

that would prevent the degradation of stormwater quality from runoff leaving the construction 

project site. BMPs instituted by the construction contractor would lessen potential surface water 

runoff impacts at the Site. Effective BMPs would include on-site controls that institute a plan to 

contain potential flooding, such as; establishing a silt fence, gravel bag barriers, the use of fiber 

rolls, and the creation of an on-site settling basin. Selected BMPs for construction are provided 

as mitigation in Section 5.2. Implementation of these BMPs would reduce construction impacts 

to less than significant level. 

Post Construction 

Post construction impacts could result from increased of storm water runoff resulting from 

impervious pavement surfaces. Special attention to engineering and design of storm drainage 

facilities is important to minimize erosion potential. 

There are no municipal storm drains on or in the vicinity of the Site. The only stormwater 

infrastructure on the property at this time besides the roads, curbs and gutters is the culvert under 

School Bus Road. This culvert conducts water from the eastern portion of the property to the 

western portion. Stormwater drains to a low area in the southwest corner of the property and 

flows off property on the southern boundary. The proposed development, where possible, would 

make provisions for storm water to flow into unpaved planter areas, where it can percolate into 

the soil. Any excess flow during extreme rainfall would collect in a sedimentation system in the 

southwest area before flowing off property. 

Changes in the runoff and sediment levels may lead to an increased transport of chemical 

constituents due to leakage or spills from the development including the buildings, roadways and 

parking lots. Although industrial use is not planned, the development will likely have 

maintenance areas with potential contaminants especially from the commercial center and gas 

station. 

Detailed BMPs are outlined in the Stormwater Drainage Report (Appendix C) and discussed in 

Section 2.1. With the institution of the BMPs outlined in the Stormwater Drainage Report, 

impacts to both groundwater and surface water resources would be small. 

Water Supply and Groundwater 

Groundwater is not proposed to be used as the source of potable water supply for the 

development. Potable water would be provided by the Valley Center Municipal Water District 

(VCMWD). Refer to Section 4.1.9 for a discussion of the impacts on public water supply 

service. 
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Final Environmental Assessment 4-3

In the event that VCMWD water supply service is no longer available to the project due to 

hydrologic, legal, and regulatory conditions negatively impacting the availability of supplies 

from the State Water Project and Colorado River, groundwater or privately purchased water may 

be needed as supplemental or replacement water source. A study shall be done on the feasibility 

of groundwater as the potable water supply prior to the time water service from VCMWD 

becomes unavailable. Mitigation is provided in Section 5.2 to prevent impacts to groundwater in 

the unlikely event the groundwater resources are the only potable water supply option available 

to the development. Should the proposed study find that groundwater resources could not 

feasibly supply the Proposed Project, potable water would be purchased and trucked through 

private suppliers to the site. 

Wastewater Treatment and Disposal 

On-site wastewater treatment would not be conducted. Wastewater treatment and disposal 

would be provided by the Valley View Casino WWTP in accordance with the facility’s existing 

NPDES permit. Refer to Section 4.1.9 for a discussion of the projected impacts on public 

wastewater service. 

Water Quality 

The Tribe would truck wastewater generated on-site to the Valley View Casino wastewater 

treatment facility for waste treatment at the proposed retail plaza. 

The Tribe would adhere to the provisions of the Clean Water Act. To reduce the effects of 

increased surface runoff volume and entrained pollutants, the Tribe would comply with the terms 

of the General Construction NPDES Permit and ensure that BMPs are used to reduce the risk of 

soil erosion and polluted discharge, as discussed above. 

4.1.3 Air Quality 

This section identifies the impacts to air quality that would result from the development of the 

Proposed Action described in Section 2.0. Impacts are measured against the environmental 

baseline presented in Section 3.3. Cumulative impacts are identified in Section 4.3. Air quality 

mitigation measures are presented in Section 5.3. 

Evaluation Criteria 

For the purpose of evaluating the Proposed Action’s contribution to regional air quality, a 

conformity review was conducted to evaluate whether conformity determination requirements 

would apply to a Proposed Action under NEPA air quality guidelines (40 CFR 93.153). The four 

steps in the review process are identified below: 

• Determine whether the Proposed Action causes emissions of criteria air 

pollutants (CAPs). 

• Determine whether the emissions of a criteria pollutant or its precursor (i.e. 

nitrogen oxides [NOx] and reactive organic gases [ROG] for ozone [O3]) would 

occur in a non-attainment or maintenance area for that CAP. 
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Final Environmental Assessment 4-4

• Determine whether the federal action is exempt from the conformity 

requirement as per 40 CFR 93.153 (c)(2)-(e). 

• Estimate the total emissions of the pollutants of concern from the Proposed 

Action and compare the estimates to the de minimus threshold of 40 CFR 

93.153 (b)(1) and (2) and to the non-attainment or maintenance area’s 

emissions inventory for each CAP. 

If the Proposed Action does not emit pollutants or is exempt under 40 CFR 93.153 (c)(2)-(e), or 

if the affected air basin is in attainment for all criteria pollutants, no further action is necessary. 

Otherwise, the proposed project’s estimated emissions must be compared to the de minimus

thresholds set forth in 40 CFR 93.153 (b)(1) and (2). If project emissions are greater than or 

equal to the de minimus threshold, a conformity determination must be performed. If the project 

emissions are less than de minimus thresholds, then the Proposed Action is considered to 

conform to the applicable SIP and a significant adverse effect to air quality would not occur. 

Construction Impacts 

Construction of Proposed Action would generate criteria air pollutants through operation of 

construction equipment and worker trips. Construction emissions were estimated using Urban 

Emissions version 9.2.4 (URBEMIS 9.2.4) and are shown in Table 4-1. URBEMIS 9.2.4 output 

files are included in Appendix J. 

Table 4-1: Unmitigated Construction Emissions – Proposed Action 

Construction Year 

Criteria Pollutants 

ROG NOx 

tons per year 

2011 0.23 1.82 

2012 0.43 0.18 

Maximum Years Emissions 0.43 1.82

Conformity de minimus Levels 100 100 

Exceedance of Levels No No

Source: URBEMIS 2007 (refer to Appendix J). 

As shown in Table 4-1, estimated ozone precursor (NOx and ROG) emissions from construction 

activities do not exceed the conformity de minimus levels or the Federal Class I Area prevention 

of significant deterioration (PSD) threshold of 250 tons per year (refer to Federal Class I Areas in 

Section 3.4). Therefore, construction emissions from the proposed project would result in NOx 

and ROG emissions less than conformity de minimus levels; therefore, significant adverse 

effects to air quality would not result from construction of the Proposed Action. 

Construction of the Proposed Action would involve ground disturbing activities including 

grading, excavation, stockpiling, and backfilling. These activities would generate fugitive dust 

emissions which may be transported offsite. BMPs are provided in Section 2.1 for dust control 

to ensure adverse effects to air quality from fugitive dust would not occur. 
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San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 4-5

Operation Impacts 

Trip Generation Rate and Trip Distribution 

Trip generation rates were based on data from the Traffic Impact Analysis (TIA) provided as 

Appendix H. The TIA provides a trip generation rate of 40 trips per 1,000 square feet of 

specialty retail/strip commercial space, 160 trips per 1,000 square feet of restaurant space, and 

160 trips per vehicle fueling station. These trip generation rates are consistent with the Institute 

of Traffic Engineers, Trip Generation Manual, 2008. Trip reduction due to pass-by trips were 

included (refer to TIA, Appendix H). The increase in vehicle trips with the implementation of 

proposed project is 4,168 trips per day. The trip distribution is provided in the TIA (Appendix 

H). 

Operational Emissions 

Operational emissions would primarily be comprised of indirect vehicular emissions associated 

with traffic generated by the project. The URBEMIS 9.2.4, 2007 (URBEMIS) air quality 

modeling program was used to estimate operational project emissions from average daily trips as 

well as other emissions that may be generated on-site (Appendix J). Table 4-2 summarizes 

emissions for area sources (boilers, heating and air conditioning units, kitchen stove, etc.) and 

mobile sources (vehicular) emissions and compares them to de minimus levels. 

Table 4-2: Unmitigated Operation Emissions - Proposed Action 

Criteria Pollutants 

ROG NOx 

tons per year 

Area Source 0.11 0.08 

Mobile Source 4.10 5.36 

TOTAL OPERATIONAL 4.21 5.44

Conformity de minimus Levels 100 100 

Exceedance of Levels No No

N/A = Not Applicable; de minimus levels are not applicable due to attainment 

status (refer to Section 3.4). 

Source: URBEMIS 2007.

As shown in Table 4-2, estimated emissions from operational activities do not exceed the 

conformity de minimus levels. A formal conformity determination is not required. Therefore, 

implementation of the Proposed Action would not result in NOx and ROG emissions in 

exceedance of conformity de minimus levels. Therefore, the Proposed Action would not result 

in significant adverse effects associated with emission of criteria air pollutants. 

Carbon Monoxide 

Implementation of the proposed project would result in emissions of carbon monoxide (CO) 

primarily as a result of increased motor vehicle traffic. Because CO disperses rapidly with 

increased distance from the source, emissions of CO are considered localized pollutants of 

concern rather than regional pollutants, and can be evaluated with Hot Spot analysis, in 

accordance with the Transportation Project-Level Carbon Monoxide Protocol (UC Davis, 1997). 
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Final Environmental Assessment 4-6

No intersections within the study area would operate at LOS E or F, after recommended 

mitigation (Appendix H). Therefore, the proposed project would not create or contribute to a 

CO “hot spot” as a result of idling vehicles from traffic delays and unacceptable traffic 

operations. 

Hazardous Air Pollutants/Toxic Air Contaminants 

Diesel particulate matter (DPM) is the main Toxic Air Contaminant (TAC) of concern during 

construction and operation phases of the Proposed Project (note the EPA has not designated 

DPM as a Hazardous Air Pollutant [HAP]). Construction would include grading, soil hauling, 

demolition, paving, and building activities. These activities utilize heavy equipment, which use 

diesel fuel and emit DPM. DPM emissions during operation would also be emitted from diesel 

vehicles used by delivery services. 

Land uses surrounding the project site include commercial uses with scattered residences. The 

nearest sensitive receptor is located 170 feet from the project site. Due to the distance of the 

nearest sensitive receptor, topography, rapid dissipation rate of DPM, and short-term nature of 

construction activities, the Proposed Action would not expose sensitive receptors to substantial 

concentrations of DPM. Therefore, the Proposed Action emissions of DPM would not create 

significant adverse effects. 

Climate Change 

Climate change is expected to result in global impacts, such as more erratic weather patterns, 

more frequent droughts, and rising sea level. Climate change is also expected to cause regional 

and local impacts, such as a reduction of snow pack in the mountain regions, increased drought 

periods, reduced water tables, increased seawater intrusion, and a reduction or reconfiguration of 

the coast line in California. 

Methodology 

Two recent federal court decisions (Massachusetts v. Environmental Protection Agency, U.S., 

1275 S.Ct. 1438, 1462 [2007] and Center for Biological Diversity v. National Highway Safety 

Administration, 508 F.3d 508 [9th Cir. 2007]), the passage of California Assembly Bill 32 (AB 

32), CEQ draft Guidance, and scientific consensus have resulted in general guidance regarding 

appropriate GHG analysis (Section 3.4). 

The CEQ has issued draft guidance for evaluating project-level climate change impacts under 

NEPA, which it is currently in the process of finalizing. The CEQ NEPA Guidance requires that 

a project’s GHG emissions be quantified and an analysis conducted, particularly if the project is 

projected to directly emit greater than 25,000 metric tons (MT) per year of Carbon Dioxide 

(CO2). Although the Proposed Project would not directly emit greater than 25,000 MT per year 

of CO2, a full climate change analysis is included below. 
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San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 4-7

Carbon Dioxide Equivalent 

Carbon dioxide equivalent (CO2e) is a method by which GHGs other than CO2 are converted to a 

CO2-like emission value based on a heat-capturing ratio. As shown in Table 4-3, CO2 is used as 

the base and is given a value of one. CH4 has the ability to capture 21 times more heat than CO2; 

therefore, CH4 is given a CO2e value of 21. Emissions are multiplied by the CO2e value to 

achieve one GHG emission value. By providing a common measurement, CO2e provides a 

means for presenting the relative overall effectiveness of emission reduction measures for 

various GHGs in reducing project contributions to global climate change. 

Table 4-3: Greenhouse gas CO2 EQUIVALENT

Gas CO2e Value 

CO2 1 

CH4 21

N2O 310

HFCs/PFCs1 6,500

SF6

1 23,900

Notes: CO2e = Carbon dioxide equivalent 

1 High-global warming potential pollutants 

CH4 = methane, N2O = nitrous oxide 

HFCs/PFCs = hydroflourocarbons/perflourocarbons 

SF6 = sulfur hexafluoride 

Source: IPCC, 2007 

Emission Estimates 

Development of the proposed project would result in an increase in GHG emissions related to 

mobile sources (trips generated), area sources (components of the Proposed Action that directly 

emit GHG), and indirect sources related to electricity, wastewater processing, and water 

transport. Based on the Proposed Action’s GHG emissions (see below under Emission 

Estimates), it was determined that specific climate change impacts could not be attributed to the 

proposed development. As such, project impacts are most appropriately addressed in terms of 

the incremental contribution to a global cumulative impact. This approach is consistent with the 

view articulated by the Intergovernmental Panel on Climate (IPCC) Change Fourth Assessment 

Report (IPCC, 2007). According to the IPCC, “difficulties remain in attributing temperature on 

smaller than continental scales and over time scales of less than 50 years. Attribution at these 

scales, with limited exceptions, has not yet been established (IPCC, 2007).” 

EPA and CARB approved URBEMIS 9.2.4 emissions modeling software was used to estimate 

area, construction, and mobile emissions. CH4 and N2O emissions from mobile sources were 

estimated using emission factors from the Local Government Operations Protocols (LGOP, 

2008) and converted to CO2e. Indirect emissions, which include electricity use, water 

conveyance, and wastewater treatment, were estimated using LGOP emission factors. The 

proposed project construction activities would emit 198.60 metric tons (MT) of CO2e and were 

amortized over 30 years and added to operational emissions. Table 4-4 estimates the proposed 

project’s direct GHG emissions at 80.08 MT of CO2e per year. Table 4-4 estimates the proposed 

project would result in indirect emissions of 5,473.40 MT of CO2e per year. 
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San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 4-8

Direct and indirect CO2e emissions would be well below the CEQ reporting standard. As noted 

in Section 3.4.2, both the state and federal governments have recently enacted measures that 

would reduce emissions from mobile sources, the primary component of the project’s indirect 

GHG emissions. Therefore, no significant adverse cumulative effects associated with climate 

change would occur. 

Table 4-4: Proposed Action Project Related GHG Emissions

Alternative A GHGs 

CO2e 

Emissions 

(ST) 

Conversion 

Factor 

(ST/MT) 

GHG 

Emissions in 

CO2e (MT) 

Direct 

Amortized 

Construction CO2 7.28 0.91 6.62 

Area CO2 80.72 0.91 73.46 

Indirect 

Mobile CO2 5,699.40 0.91 5,186.45 

Mobile CH4/N2O 65.00 0.91 59.15 

Electricity Usage CO2 214.37 

Electricity Usage CH4/N2O 1.89 

Water Conveyance CO2e 4.20 

Water Conveyance CH4/N2O 0.04 

Wastewater Treatment CO2e 7.24 

Wastewater 

Treatment CH4/N2O 0.06 

Total Project-Related GHG Emissions 5,553.48 

ST = short tons; MT = metric tons; CO2e = carbon dioxide equivalent 

Source: URBEMIS, 2007; LGOP, 2008. 

4.1.4 Biological Resources 

For the purposes of this assessment, special status has been defined to include those species that 

are listed as endangered or threatened under the FESA (or formally proposed for, or candidates 

for, listing). 

Although unlikely, the ruderal/disturbed areas within the Site may provide marginal habitat for 

San Diego thornmint, thread‐leaved brodiaea, San Diego button celery, and Stephens’ kangaroo 

rat even though their preferred soil and habitat types do not occur within the project site. None 

of these species were observed within the project site during the December 18, 2008 and July 20, 

2010 biological surveys. Despite the low likelihood that the proposed project would result in 

adverse effects to these species given the high level of disturbance and the lack of preferred 

habitat, precautionary measures are provided in Section 5.4. With the proposed mitigation, the 

Proposed Action is not likely to adversely affect federally listed special status species. 

Construction of the proposed project has the potential to disturb nest sites for federal protected 

migratory birds and other birds of prey. With implementation of the mitigation measures 
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San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 4-9

identified in Section 5.4, the Proposed Action would not result in significant adverse effects to 

migratory bird species and other birds of prey. 

4.1.5 Cultural Resources 

The surface survey of the Site resulted in the location of two isolated artifacts, that have not been 

previously evaluated for NRHP eligibility. The isolates are not considered significant and 

therefore not eligible for the NRHP; see Appendix G for evaluation. No historic properties were 

identified within the Site. In a letter dated February 5, 2010, the State Historic Preservation 

Officer concurred with the BIA’s determination of No Historic Properties Affected (Appendix 

G). There is a moderately high potential for unanticipated buried prehistoric archaeological 

resources within the Site based on the identification of an isolated artifact within rodent back 

dirt. Because the Site contains potential for buried prehistoric archaeological sites that may be 

eligible for nomination to the NRHP and California Register, construction monitoring of the 

property is recommended as mitigation in Section 5.0. 

Construction monitoring would include significance evaluation and data recovery of any 

unanticipated discoveries. If cultural resources are discovered during construction activities, all 

work activities would cease, and the findings would be evaluated by a qualified archeologist, 

including a BIA archaeologist. Further, the Tribe would be immediately notified of all cultural 

discoveries. These actions are required under 36 CFR § 800.13: Post-Review Discoveries. 

Since there are no known cultural resources at the Site, and since any potential findings would be 

evaluated under applicable regulations, it is not anticipated that the Proposed Action would 

adversely effect cultural resources at the Site. 

4.1.6 Socioeconomic Conditions/Environmental Justice 

The Proposed Action would include the construction of a new retail plaza at the Site. The 

addition of these retail facilities would have a positive impact on current socioeconomic 

conditions within the area. New jobs for members of the Tribe would be created at the Site, and 

the Tribe would benefit from the revenues created from the Proposed Action. These revenues 

could then be used by the Tribe to invest in health and welfare programs to improve the overall 

well being of Tribe members. 

Fiscal Analysis 

There is a common misconception that operations on land held in trust do not generate fiscal 

benefits beyond tribal governments. This is because tribes, as sovereign governments, do not 

pay corporate income taxes on revenue or property taxes on tribal land; tribal members that both 

live and work on a Reservation do not pay state income taxes; and state and/or local sales/excise 

taxes are not collected on purchases by tribal members on reservations. However, taxes are paid 

in all other circumstances, including: purchases made by non-tribal members, income taxes paid 

by non-tribal members or members that live off of the reservation, and all indirect and induced 

activity generated during operation. As such, federal, state, and local governments typically 

experience substantial fiscal benefits from tribal business operations. 

As stated in Section 3.6, the total annual property tax for the 2009-2010 fiscal year was 
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San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 4-10

approximately $1,778 for the Site. The Proposed Action would result in the entire area of the 

parcel at the Project Site to be transferred into trust status for the Tribe. Therefore, the entire 

taxable value of the parcel, or approximately $1,778 in annual property tax, would be lost. In the 

2008-2009 fiscal year, approximately $4.4 billion in property taxes was paid to the San Diego 

County Tax collector (CSCO, 2009). Therefore, the tax owed to the county for the subject 

property parcel was approximately .00004 percent of the county’s total tax revenue. The 

approximate 0.00004 percent loss in property taxes is considered diminutive and would not be 

anticipated to result in an adverse physical environmental effect. Additionally, effects due to the 

loss of state and federal tax revenues as a result of transferring the land into trust would be offset 

by increased local, state and federal tax revenues resulting from construction and operation of the 

Project. As such, an adverse impact to tax revenues would not occur. 

Crime 

The Proposed Action would introduce an increased number of patrons and employees into the 

community on a daily basis. As a result, criminal incidents may increase in the project area, 

particularly at the Site, as with any other development of this size. However, increased tax 

revenues resulting from the Proposed Action would assist in off-setting the cost for increased 

demand for law enforcement services. Additionally, the Tribe has an existing agreement with 

the San Diego County Sheriff’s Department for law enforcement services on the Tribe’s 

Reservation that would be extended to include the project site. As stated in Section 5.6, the 

Tribe agrees to adopt ordinances governing the sale and use of alcohol on the Site, as well as 

prohibiting loitering and other suspicious behavior on the Site. With implementation of the 

mitigation measures recommended in Section 5.6, the Proposed Action would not result in 

significant adverse effects associated with crime. 

Environmental Justice For Minority And Low Income Populations 

An “Environmental Justice” analysis is required as part of NEPA compliance for the proposed 

project. This environmental justice analysis was prepared using guidance form the President’s 

Council on Environmental Quality for compliance with Executive order 12898. The intent of 

this evaluation is to determine whether the No-Action or Project Alternatives would impose 

“disproportionately high and adverse human health or environmental effects of its programs, 

policies, and activities on minority populations and low-income populations in the United States 

and its territories...” 

The proposed project has been sited in a residential/commercial area. The proposed project 

would not disproportionately impose air quality impacts on any segment of the population. It is 

unlikely that any plant or animal species of specific concern or used for subsistence by a 

minority or low-income population would be disproportionately impacted. 

Increased traffic generated by the proposed project would not adversely impact any minority or 

low-income populations. Lighting and visual effects of the proposed project would not 

disproportionately impact any specific population segment. No minority of low-income area is 

located within view of the proposed project. 
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San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 4-11

The construction of the proposed retail plaza would serve the Tribe by creating much needed 

jobs and revenue, which would be beneficial to a minority population. No adverse health or 

environmental impacts to low-income and minority populations are projected to occur as a result 

of the proposed project. Rather, the effect on low-income and minority populations would be 

positive. The proposed project would have no negative effect with regards to environmental 

justice for adjacent and close-proximity residents. 

4.1.7 Transportation and Circulation 

This section describes construction, buildout, and cumulative transportation conditions in the 

vicinity of the project site. A Traffic Impact Analysis (Appendix H) was conducted by Linscott, 

Law and Greenspan (LLG) in August, 2010. The results of the analysis are summarized below. 

Evaluation Criteria 

Intersections 

The following criteria have been utilized to evaluate potential traffic effects from the project 

alternatives. This criteria is based on San Diego County’s “Guidelines for Determining 

Significance”, effective June 30, 2009 and modified February 19, 2010. 

Traffic volume increases from public or private projects that result in one or more of the 

following criteria will have a significant traffic volume or level of service (LOS) traffic impact 

on a signalized intersection: 

• The additional or redistributed ADT generated by the proposed project will significantly 

increase congestion on a signalized intersection currently operating at LOS E or LOS F, 

or will cause a signalized intersection to operate at a LOS E or LOS F. 

Traffic volume increases from public or private projects that result in one or more of the 

following criteria will have a significant traffic volume or LOS traffic impact on a un-signalized 

intersection: 

• The additional or redistributed ADT generated by the proposed project will add 21 or 

more peak hour trips to a critical movement of an unsignalized intersection, and cause an 

unsignalized intersection to operate below LOS D, or 

• The additional or redistributed ADT generated by the proposed project will add 21 or 

more peak hour trips to a critical movement of an unsignalized intersection currently 

operating at LOS E, or 

• The additional or redistributed ADT generated by the proposed project will add 6 or more 

peak hour trips to a critical movement of an unsignalized intersection, and cause the 

unsignalized intersection to operate at LOS F, or 

• The additional or redistributed ADT generated by the proposed project will add 6 or more 

peak hour trips to a critical movement of an unsignalized intersection currently operating 

at LOS F, or 

• Based upon an evaluation of existing accident rates, the signal priority list, intersection 

geometrics, proximity of adjacent driveways, sight distance or other factors, it is found 
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San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 4-12

that the generation rate is less than those specified above, and would significantly impact 

the operations of the intersection. 

Roadways 

New development must provide improvements or other measures to mitigate traffic impacts to 

avoid: 

• Reduction in LOS below C for on-site Circulation Element roads; 

• Reduction in LOS below D for off-site and on-site abutting Circulation Element roads; 

and 

• "Significantly impacting congestion" on roads that operate at LOS E or F. If impacts 

cannot be mitigated, the project cannot be approved unless a statement of overriding 

findings is made pursuant to the State CEQA Guidelines. The PFE, however, does not 

include specific guidelines for determining the amount of additional traffic that would 

“significantly impact congestion” on such roads. 

• The additional or redistributed ADT generated by the proposed land development project 

will cause on-site Circulation Element Roads to operate below LOS C during peak traffic 

hours during peak traffic hours. 

• The additional or redistributed ADT generated by the proposed project will significantly 

increase congestion on a Circulation Element Road or State Highway currently operating 

at LOS E or LOS F, or will cause a Circulation Element Road or State Highway to 

operate at a LOS E or LOS F as a result of the proposed project. 

• The additional or redistributed ADT generated by the proposed project will cause a 

residential street to exceed its design capacity. 

Construction Traffic Impacts 

Impacts resulting from the construction of the Proposed Action would be temporary in nature. 

Traffic impacts from construction activities for the proposed project would be concentrated on 

Valley Center, School Bus, and Wohlford Lake Roads in the immediate vicinity of the Project 

Site, as the focus of construction activity would be occurring at the project site. Traffic-related 

construction impacts typically experienced may include traffic delays, one-way traffic control, 

temporary road closures, and traffic detours. 

The Proposed Action will require that approximately two material supply trucks per day would 

deliver materials to the project site. Given the scope of the project and the time line of 

construction (approximately 10 months) an estimated 20 workers would be at the project site at 

any one time. Therefore, an estimated 44 one-way trips per day would be generated by 

construction of the proposed project, which is far less than the 4,078 trips generated during 

buildout. Therefore, significant adverse effects would not occur from construction traffic. 

Trip Generation Rate and Trip Distribution 

The trip generation rate was determined using the following steps: 
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San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 4-13

• San Diego Association of Governments (SANDAG) trip generation rates taken from the 

(Not so) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region, 

April 2002, were used for the project land uses. 

• Total project trips were calculated using the SANDAG rates to obtain the total trips 

generated by the project site. 

• As previously mentioned, a portion of project trips will not be new to the street system, 

but will be captured from trips already on the street system. These trips are termed “passby” trips and are assumed to be already on the roadways for another purpose. 

• Primary trips are trips assumed to be new to the street system. The primary trips are 

calculated by subtracting the pass-by trips from the total project trips. 

The project trip generation and pass-by rates are summarized in Table 4-5. 

Table 4-5: Trip Generation 

Land Use Size 

PassBy 

(%) 

ADTs AM Peak Hour PM Peak Hour 

Rate Volume In Out Total In Out Total 

Specialty 

Retail 27.6 KSF 10 40/KSF 994 18 11 29 45 45 90 

Restaurant 8.8 KSF 12 160/KSF 1,240 51 51 102 57 34 91 

Gasoline 

w/Food Mart 12 VFS 28 160/VFS 2,048 81 81 162 50 50 100 

Total Trips Generated 4,078 150 143 293 152 129 281 

ADT = average daily trips 

Source: TIA, 2010 (Appendix H). 

The project traffic was distributed and assigned to the street system based on the project’s 

proximity to state highways and arterials, and the locations of existing and proposed residential 

communities. Figures 7–1 and 7-2 in the TIA (Appendix H) show the project traffic distribution 

and the primary project traffic assignment. 

Peak Hour Intersection Effects 

Traffic volumes with the addition of traffic from the proposed project are provided in the TIA 

(Appendix H). Table 4-6 summarizes the LOS at each study intersection. Traffic increases 

from the Proposed Action would change the LOS of one intersection from an acceptable level to 

an unacceptable level. The following intersection would operate at an LOS F in the am peak 

hour with the implementation of the Proposed Action: 

• Valley Center Road/Street “A” 

Therefore, a potentially significant impact to the local intersection would result. A mitigation 

measure is included within Section 5.7 to reduce this impact to a less-than-significant level. 
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Final Environmental Assessment 4-14

Peak Hour Roadway Segment Effects 

Table 4-7 summarizes the LOS at each study roadway segment. Traffic increases from the 

Proposed Action would change the LOS of one roadway segment from an acceptable level to an 

unacceptable level. The following segment would operate at an LOS E with the implementation 

of the proposed project: 

• Valley Center Road, Lake Wohlford Road (N.) to Cole Grade Road 

Therefore, a potentially significant impact to the local roadway segment would result. A 

mitigation measure is included within Section 5.7 to reduce this impact to a less than significant 

level. 

Table 4-6: Intersection Level of Service 

No. Intersection Control 

Type Peak Hour 

Existing + 

Project 

2030 + Project 

Delay LOS Delay LOS 

1 Valley Center Road/ 

Cole Grade Road Signal AM PM 

32.7 

33.5 

C 

C 

53.3 

53.6 

D 

D 

2 Valley Center Road/ 

Street “A” TWSC AM PM 

53.6 

34.4 

F 

D 

>100 

>100 

F 

F 

3 

Valley Center 

Road/Relocated School 

Bus Road 

Inbound 

Only 

PM 

AM 

9.0 

0.0 

A 

- 

10.6 

0.0 

B 

- 

4 

Valley Center 

Road/Lake Wohlford 

Road (N.) 

Signal 

AM 

PM 

24.5 

26.8 

C 

C 

33.2 

43.3 

C 

D 

5 Lake Wohlford Road 

(N.)/School Bus Road TWSC AM PM 

15.9 

10.5 

C 

B 

28.4 

12.2 

D 

B 

6 Lake Wohlford Road 

(N.)/Wood Valley Road AWSC AM PM 

12.3 

11.7 

B 

B 

33.0 

29.7 

D 

D 

7 Lake Wohlford Road 

(N.)/ Project Access TWSC AM PM 

11.3 

10.7 

B 

B 

13.8 

12.6 

B 

B 

8 Valley Center 

Road/Lilac Road Signal AM PM 

15.0 

13.7 

B 

B 

34.9 

34.7 

C 

C 

9 

Valley Center 

Road/Woods Valley 

Road 

Signal 

AM 

PM 

16.1 

17.9 

B 

B 

19.8 

24.0 

B 

C 

ADT = average daily trips; LOS = Level of Service 

Source: TIA, 2010 (Appendix H). 

2030 Peak Hour Roadway Segment Effects 

Table 4-7 summarizes the LOS at each study roadway segment. Traffic increases from the 

Proposed Action would contribute to an unacceptable LOS at seven roadway segments in the 

cumulative year 2030. It should be noted that these roadway segments would operate at 

unacceptable levels without the addition of project traffic. Cumulative year 2030 existing 
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Final Environmental Assessment 4-15

Table 4-7: Street Segment Level of Service 

Street Segments Capacity

(LOS E) 

Existing + 

Project 2030 + Project 

ADT LOS ADT LOS

Valley Center Road 

Lake Wohlford Rd (N.) to Cole 

Grade Road 16,200 13,220 E 15,040 E 

 Cole Grade Road to Lilac Road 37,000 23,770 B 41,860 F 

 Lilac Road to Woods Valley Road 37,000 24,550 B 41,450 F 

Woods Valley Road to Lake 

Wohlford Road (S.) 37,000 25,300 C 36,370 E 

Lake Wohlford Road (N.) 

Valley Center Road to Woods Valley 

Road 16,200 10,650 D 15,230 E 

 Woods Valley Road to Guejito Road 16,200 6,590 C 13,620 E 

Woods Valley Road 

Valley Center Road to Lake 

Wohlford Road (N.) 16,200 2,740 B 5,290 C 

Cole Grade Road 

 Valley Center Road to Fruitvale Road 19,000 12,720 D 31,490 F 

ADT = average daily trips; LOS = Level of Service 

Source: TIA, 2010 (Appendix H). 

roadway segment volumes and LOS are provided in the TIA (Appendix H - Attachment 1). The 

following roadway segments would operate at an LOS E under cumulative traffic conditions: 

• Valley Center Road, Lake Wohlford Road (N.) to Cole Grade Road. Project related 

traffic constitute approximately 14% of the traffic on this segment under cumulative 

conditions. 

• Valley Center Road, Cole Grade Road to Lilac Road. Project related traffic constitute 

approximately 2% of the traffic on this segment under cumulative conditions. 

• Valley Center Road, Lilac Road to Wood Valley Road. Project related traffic constitute 

approximately 1% of the traffic on this segment under cumulative conditions. 

• Valley Center Road, Wood Valley Road to Lake Wohlford Road (N.). Project related 

traffic constitute approximately 1% of the traffic on this segment under cumulative 

conditions. 

• Lake Wohlford Road (N.), Valley Center Road to Wodds Valley Road. Project related 

traffic constitute approximately 8% of the traffic on this segment under cumulative 

conditions. 

• Lake Wohlford Road (N.), Wodds Valley Road to Guejito Road. Project related traffic 

constitute approximately 5% of the traffic on this segment under cumulative conditions. 

• Cole Grade Road, Valley Center Road to Fruitvale Road. Project related traffic constitute 

approximately 2% of the traffic on this segment under cumulative conditions. 

Therefore, a potentially significant impact to these local roadway segments would result. 
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Final Environmental Assessment 4-16

Mitigation measures are included within Section 5.7 to reduce impacts to a less-than-significant 

level. 

4.1.8 Land Use 

Land Use Jurisdiction 

NEPA requires an assessment of a project’s effect on adopted land use plans as well as plans that 

have been formally proposed and are being actively pursued by officials of the jurisdiction. 

Accordingly, the Proposed Project’s consistency with adopted and proposed land use regulations 

is assessed below. 

At this time, the project site is currently under County jurisdiction; once the Federal government 

acquires the property in trust for the Tribe, the parcels will not be subject to County land use 

regulations. Only tribal land use regulations are applicable on trust lands. The Tribal 

Government relies upon the Tribal Council, the governing body of the Tribal Government, to 

guide and regulate land use on Tribal lands. 

The Tribal Government desires to work cooperatively with local and State authorities on matters 

related to land use. Therefore, as stated in Section 2.0, the Tribe intends to develop the property 

in a manner reasonably consistent with Valley Center’s adopted design guidelines and 

ordinances. 

Consistency with County Land Use and Zoning designations 

The commercial nature of the Proposed Action is not consistent with the existing San Diego 

County zoning designation of Special Purpose-Parking (S86) for the project site. Although 

commercial land uses proposed by the project and those allowed under the surrounding land use 

designations would be generally compatible, potential impacts could result from the 

inconsistency with the project site’s current zoning designation, specifically associated with 

increased vehicle trip generation and public use of the area. Mitigation measures identified in 

Section 5 relating to traffic, noise, air quality, public services, and aesthetics would reduce 

environmental impacts associated with the project’s inconsistency with adopted San Diego 

County land use designations to less than significant. 

Agriculture 

There are no lands under a Williamson Act contract or in agricultural uses on the Project Site. 

Additionally the soils underlain the project site are not designated as State Significant soils or 

Prime Farmlands soils by the FMMP (DOC, 2009). Therefore, construction of the proposed 

retail plaza would not result in any significant adverse effect to agricultural resources. 

4.1.9 Public Services 

Water Supply 

The proposed retail plaza would utilize the existing on-site VCMWD water meter at the Site 

which was installed, and will be maintained and monitored by the Valley Center Municipal 
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Final Environmental Assessment 4-17

Water District (VCMWD). While the project would constitute an increase in usage of water 

resources, the projected increase would not impact the local water supply in the near term. 

VCMWD has provided a Will Serve letter for the project (Appendix B), indicating facilities to 

serve the project are reasonably expected to be available within the next five years based on the 

capital facility plans of the VCMWD. However, the letter notes that given hydrologic, legal, and 

regulatory conditions importing supplies from the State Water Project and Colorado River, there 

is a possibility that VCMWD may not have capacity to serve the project in the future. 

In the event that the VCMWD is no longer able to serve the development, groundwater and 

privately purchased water will be investigated as a potential potable water source. A discussion 

of the potential effects of the Proposed Action to groundwater resources in the area is provided in 

Section 4.1.2. Mitigation measures to reduce the potential adverse effects to groundwater 

resources are provided in Section 5.0. After mitigation, the project would not result in 

significant adverse effects associated with water supply. Should the use of groundwater 

resources as a potable water source for the Proposed Project be found infeasible, potable water 

will be purchased and trucked through a private supplier to the project site. The private purchase 

of potable water would not adversely impact public services. 

Wastewater Service 

As described in Section 2.1, wastewater would be collected onsite in an underground septic 

storage tank. The tank would be evacuated as needed and the wastewater trucked to the Valley 

View Casino wastewater treatment plant for treatment and disposal. The proposed project would 

not impact municipal or private wastewater facilities in the area. 

Solid Waste 

Construction-related waste would be generated at the Site during the construction of the 

proposed facilities. However, since the construction period would be temporary, and since the 

contractor would institute the use of BMPs, these impacts would be small. Solid waste and 

recycling from operation of the proposed retail plaza would be collected by EDCO Recycling 

and Waste Collection or a similar provider to accommodate the increased service needs 

associated with the Proposed Action. 

Waste disposal activities are anticipated to occur at the Sycamore Landfill, which accepts a 

permitted total of 3,965 tons per day (tpd) (Calrecycle, 2010). Waste generated from Proposed 

Action would be approximately 0.1 percent of the daily waste stream and would represent a 

negligible addition to the landfill. Therefore, construction and operation of the Proposed Action 

would not result in any significant adverse effect to the solid waste stream. 

Electricity, Natural Gas, and Telecommunications 

Existing electrical and telephone infrastructure facilities are currently located near the Site. The 

Tribe would coordinate with Pacific Gas & Electric, Cox Communications, and an internet 

broadband company of their choosing regarding the extension of services to the Site. No 

significant adverse effects to utility providers would occur from the Proposed Action. 
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Final Environmental Assessment 4-18

Law Enforcement 

Under Public Law 280, 18 U.S.C. 1162, the State of California and other local law enforcement 

agencies have criminal enforcement authority on Tribal lands. San Diego County Sheriff’s 

Department would provide law enforcement services to the Site through existing agreements 

with the Tribe. The proposed retail plaza would result in a negligible increase in demands on the 

Department. Calls for service would not be disproportionate to other residential or commercial 

development; therefore the Proposed Action would not result in any significant adverse effect to 

law enforcement services 

Fire Protection and Emergency Services 

Construction-related impacts include the potential fire threat associated with equipment and 

vehicles coming into contact with wild land areas. Construction vehicles and equipment such as 

welder, torches, and grinders may accidentally spark and ignite vegetation or building materials. 

The increased risk of fire during the construction of the proposed facilities would be similar to 

that found at other construction sites. Standard construction and operational measures would be 

included within day-to-day work activities. These measures would lessen the chance of an 

accidental fire at the Site. 

Current International Fire Codes would be adhered to in relation to fire safety and the Tribe 

would cooperate with the fire district by allowing routine inspections. Use of the Site for 

commercial purposes would create additional demand for fire protection, and require more 

frequent responses from local fire-fighting agencies, including the San Pasqual Reservation Fire 

Department. The Tribe currently provides fire protection in the area together with the Valley 

Center Fire Department and Calfire. The scale of development would not create significant 

demands on local fire authorities; therefore the Proposed Action would not result in any 

significant adverse effect to fire protection services. 

Increased emergency calls to 911 as a result of the proposed project may result in delays in 

response times or result in the need for ambulances to be dispatched from more distant locations. 

However, given the scale of the proposed project, implementation of off-site traffic 

improvements, and the availability of emergency services in the area, the projected increase in 

emergency medical services would not result in any significant adverse effects to emergency 

services providers. 

4.1.10 Noise 

This section identifies the noise impacts that would result from the development of the Proposed 

Action described in Section 2.0. Impacts are measured against the environmental baseline 

presented in Section 3.10. Cumulative impacts are identified in Section 4.3. 

Construction Noise 

Grading and construction activities associated with the Proposed Action would be intermittent 

and temporary in nature. The closest sensitive noise receptors that would be exposed to noise 

during project construction are the adjacent school and residence, the nearest of which is 

approximately 170 feet southeast of the project site (refer to Section 3.10). 
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Final Environmental Assessment 4-19

Construction noise levels at and near the project site would fluctuate depending on the particular 

type, number, and duration of uses of various pieces of construction equipment. Constructionrelated material haul trips have the potential to raise ambient noise levels along haul routes, 

depending on the number of haul trips made and types of vehicles used. 

During construction approximately 40 worker trips per day would occur, based on the scope of 

the Proposed Action. It is conservatively estimated that 2 material supply truck trips would 

occur during construction. Because trucks are louder than passenger cars a passenger car 

equivalence (PCE) multiplier of 10 cars per truck was used. Therefore, the total passenger car 

equivalence trips per day would be 60. The existing traffic volume on Valley Center Road and 

Wohlford Road, adjacent to the project site is 14,900 and 8,970 vehicles per day, respectively. 

Construction trips would not double the existing traffic volume; therefore, the ambient noise 

level would not audible increase (Caltrans, 2009). 

Table 4-8 shows typical stationary point source noise levels at 50 feet during different 

construction stages. 

Table 4-8: Typical Construction Noise Levels 

Construction Phase Noise Level at 50 feet (dBA) 

Ground Clearing 84 

Excavation 89 

Foundations 78 

Erection 85 

Finishing 89 

Source: Federal Highway Administration, 2006 

Stationary point sources of noise attenuate (lessen) at a rate of 0 to 10 dBA per doubling of 

distance from the source, depending on environmental conditions (i.e., atmospheric conditions, 

topography and type of ground surfaces, noise barriers, etc.) (Caltrans, 2009). An attenuation 

factor of 6 dBA per doubling of distance is appropriate given the topography, buildings, and 

ground cover on and in the vicinity of the Project Site (i.e. few trees and brush). The maximum 

construction noise at the Project Site would be 89 dBA at 50 feet. Using an attenuation factor of 

6 dBA the noise level at the nearest sensitive noise receptor, a residence, would be 

approximately 75 dBA, which is greater than the Federal Noise Abatement Criteria of 67 dBA 

for outdoor activity areas of residences and schools (Table 3-10). 

Mitigation measures provided in Section 5.11 would reduce noise impacts due to construction to 

less than significant. These measures would ensure construction activities would be limited to 

daytime hours, and would require that a soundwall be installed prior to construction to attenuate 

construction noise levels to the extent feasible. Additionally, construction equipment would be 

equipped with adequate mufflers and staging areas would be located as far away from sensitive 

receptors as possible. Therefore, because construction activities would be short-term, 

intermittent, temporary, and the sound wall would attenuate construction noise levels below 

federal noise standards, no significant adverse effects associated with construction noise would 

occur. 
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Final Environmental Assessment 4-20

Vibration 

Construction activities would consist of using earthmoving equipment shown in Table 4-9, 

which can produce detectable or damaging levels of vibration at nearby sensitive land uses, 

primarily depending on the distance between the source and the nearby sensitive land use. 

Generally, physical damage is only an issue when construction requires the use of equipment 

with high vibration levels (i.e., compactors, large dozers, etc) and occurs within 25 to 100 feet of 

an existing structure. Table 4-9 provides estimated construction vibration levels at a reference 

distance of 50 feet and at 170 feet (distance to nearest sensitive receptor). The predicted Peak 

Particle Velocity (PPV) levels are below the significance threshold of 0.5 PPV for structures and 

0.1 PPV for annoyance of people (Caltrans, 2004). This would be a less-than-significant impact. 

Table 4-9: Reference and Predicted PPV from Construction 

Equipment 

Reference PPV at 50 feet Predicted PPV at 170 

feet 

Inches per Second Inches per Second 

Large bulldozer 0.089 0.017 

Excavator 0.089 0.017 

Compactor 0.170 0.031 

Scaper 0.089 0.017 

Loaded trucks 0.076 0.014 

Small bulldozer 0.003 0.00054 

Note: PPF was predicted using the equation PPV predicted = PPVref*(Dref/Dsource)^1.4 

Source: Caltrans, 2004 

Operation Noise 

The following identifies potential impacts from project-related noise sources, such as traffic, 

heating ventilation and air conditioning (HVAC) systems, parking lot, and deliveries. 

Traffic 

The level of traffic noise depends on three things: l) the volume of the traffic, 2) the speed of the 

traffic, and 3) the number of trucks in the flow of the traffic. It is not anticipated that speed in 

the vicinity of the Project Site or the mix of trucks in the traffic would change during the 

operational phase; however, with the implementation of the project, traffic volumes would 

increase on local roadways. 

The existing primary source of noise in the area is traffic on adjacent roadways. As discussed 

above the existing traffic volume on Valley Center Road and Lake Wohlford Road are 

approximately 15,000 and 9,000 vehicles per day, respectively (TIA, Appendix H). The 

Proposed Project would add 4,168 vehicles per day to local roadways. The added traffic would 

not double the existing volume of traffic (refer to Appendix H). Project-related traffic would 

therefore cause an increase in the ambient noise level of less than 3 dBA. Given the nature of the 

area surrounding the project site and the surrounding topography, the existing ambient noise 
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San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 4-21

level is estimated to be 65 dBA (EPA, 1974). Therefore, an increase of less than 1.5 dBA would 

result in an ambient noise level of no more than 66.5 dBA. The ambient noise level would be 

less than the Federal Noise Abatement Criteria of 67 dBA (refer to Table 3-10). Therefore, there 

would be a less-than-significant effect due to traffic noise. 

 

Vibration and Other Noise Sources 

Commercial uses would bring the possibility of noise due to operations of roof-mounted air 

handling units associated with building heating, ventilation, and air conditioning (HVAC) 

equipment and noise from loading docks, and the parking lot. 

The noise levels produced by HVAC systems vary with the capacities of the units, as well as 

with individual unit design. In this case, given the distance to the nearest sensitive noise 

receptor, noise from roof mounted HVAC equipment would not be audible. Therefore, there 

would be a less-than-significant effect due to HVAC noise. 

Idling trucks due to product delivery at the proposed project site has the potential to emit noise of 

85 dBA at 50 feet from the source (Caltrans, 2009). A sound wall would be constructed around 

the project site perimeter as recommended in mitigation indentified in Section 5.11. The sound 

wall is expected to attenuate noise levels by 8 dBA. Using the attenuation value of 6 dBA per 

doubling of distance (refer to construction analysis above) the ambient noise level at the nearest 

sensitive noise receptor (170 feet from the Project Site) would be approximately 64 dBA; 

therefore, a less-than-significant effect due to loading dock noise would occur. 

Parking lot noise would be mainly due to idling vehicles, opening and closing doors, and 

conversation. Worst case parking lot noise would be similar in intensity to loading dock noise. 

As shown above, the resulting noise level at the nearest sensitive noise receptor would be 64 

dBA, which is less than the Federal Noise Abatement Criteria of 67 dBA (Table 3-10). 

Therefore, a less-than-significant adverse effect from parking lot noise would occur. 

4.1.11 Hazardous Materials 

The Phase I Site Assessment conducted by GreenWave in April, 2009 at the project site did not 

identify any hazardous materials on site or within a distance that would affect the proposed 

project. 

During the construction period, it is possible that hazardous materials, such as solvents, paint, 

and adhesives would be brought, stored, and used on site. As with any liquid and solid, during 

handling and transfer from one container to another, the potential for an accidental release exists. 

Depending on the relative hazard of the material, if a spill were to occur of significant quantity, 

the accidental release could pose both a hazard to construction employees as well as to the 

environment. Construction BMPs limit and often eliminate the impact of such accidental 

releases. Since contact with stormwater during construction is the primary means of transporting 

these contaminants offsite, appropriate BMPs for this impact are included in the construction 

stormwater BMPs in Section 5.2. With the implementation of these BMPs and compliance with 

federal laws relating to the handling of hazardous materials, no adverse affects associated with 

the accidental release would occur during construction. 
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San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 4-22

During operation no hazardous materials would be handled, stored, or disposed of in reportable 

quantities on the project site, and no hazardous waste in reportable quantities would be generated 

by the operation of the project components. Therefore no adverse effects would occur associated 

with the handling, storage, generation, and disposal of hazardous materials. 

Although certain petroleum products are potentially hazardous under the ignitibility standard 

(flashpoint below 140 °F according to 40 CFR 261), they are exempt under many hazardous 

materials laws and are regulated under separate laws than all other hazardous materials. The 

proposed gas station would be equipped with underground storage tanks filled with petroleum 

products including gasoline and possibly diesel fuel. There is a potential for releases from 

storage and dispensing equipment at the proposed gas station. Spills and overfills result mainly 

from bad filling practices. Also unprotected steel tanks and piping can corrode and release 

product thorough holes caused by corrosion of the metal tank or piping. Material released 

through spills, overfills and leaks has the potential to contaminate stormwater runoff, or enter the 

surrounding groundwater through direct spilling or leaking into the surrounding soil. 

As stated in Section 3.11, the project would comply with the provisions of 40 CFR Part 280, 

including Part 280.20 Performance Standards for new UST systems, which includes 

requirements for tank design, the installation and maintenance of leak detection and prevention 

systems, and spill and overfill controls to minimize the risk of release of petroleum into the 

environment. The standards are therefore protective of both public health and the environment 

(including soil and groundwater) through the prevention of accidental release which could lead 

to soil and groundwater contamination. 

Mitigation measures to ensure proper operation of the gas station in compliance with 40 CFR 

280 are listed in Section 5.2. Compliance with the provisions of 40 CFR Part 280 would ensure 

that the impacts to public safety and environmental quality from accidental release of petroleum 

products, fire, explosion, and vapor intrusion hazards are minimized. Therefore, no significant 

adverse effects associated with the operation of the gas station would occur. 

4.1.12 Visual Resources 

The overall Interim VRM Class scenic quality rating for the Site is Class IV. The BLM assigns 

the following management strategy to Class IV resources: “to provide for management activities 

which require major modifications of the existing character of the landscape. The level of 

change to the characteristic landscape can be high. These management activities may dominate 

the view and be the major focus of viewer attention. However, every attempt should be made to 

minimize the impact of these activities through careful location, minimal disturbance, and 

repeating the basic elements.” Several developments currently exist within the area including the 

San Diego Sheriff’s office, Valley Center Middle School, Allstate Insurance Company, and 

Ridgeview Church. A retail plaza would not constitute a major modification to the landscape. 

Additionally, the Tribe intends to develop the subject property in a manner reasonably consistent 

with the existing Valley Center Design Guidelines. Since the proposed Tribal facilities would 

not constitute a significant change to the current visual and scenic resources at the Site, and since 

the Site qualifies as a VRM Class IV, impacts from the Proposed Action are anticipated to be 

small. The Proposed Action is situated in a low-lying area with surrounding residential 

developments that do not offer significant visual features. As the retail plaza would be a 
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San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 4-23

relatively small-scale building, its presence would not constitute a significant adverse effect to 

the overall scenic quality. 

The project would introduce a new source of lighting and glare on the subject property, however 

mitigation has been included in Section 5.0 to comply with standards of the San Diego County 

Dark Skies Ordinance [(Title 5, Div.9, Sections 59.101-59.113 of the County Code of Regulatory 

Ordinances) as added by Ordinance No 6900, effective January 18, 1985, and amended July 17, 

1986 by Ordinance No. 7155 and April 20, 2005 by Ordinance No. 9716.] and reduce off-site 

light emissions. After mitigation, the Proposed Action would not result in any significant 

adverse effects associated with night time lighting. 

4.1.13 Public Safety and Health 

The Tribe would observe all established construction practices during development of the Site, 

including use of the International Building Code. 

A Phase I Environmental Site Assessment was completed for the Site on April 2, 2009, and 

revealed no evidence of recognized environmental conditions in connection with the Site and 

further revealed no evidence of recognized environmental conditions associated with nearby 

properties. A recognized environmental condition is “the presence or likely presence of any 

hazardous substances or petroleum products on a property under conditions that indicate an 

existing release, a past release, or a material threat of a release of any hazardous substances or 

petroleum products into structures on the property or into the ground, ground water, or surface 

water of the property” (ASTM, 2006). 

Operation of the proposed restaurant would comply with federal food handling and sanitary 

codes. 

Construction and operation of the proposed gas station is required to comply with all federal 

regulations that are applicable. Refer to the analysis in Section 4.1.11 for further discussion of 

public health and safety issues. 

4.2 No Action Alternative 

4.2.1 Land Resources 

Under the No Action Alternative, the property would be developed with a parking lot on the 

eastern half of the site, consistent with Site Plan 06-004. Negligible impacts to topography 

would occur due to the relatively flat topography of the site. Compliance with Regional Water 

Quality Control Board (RWQCB) and County regulations would ensure adverse effects due to 

erosion would not occur. 

4.2.2 Water Resources 

Under the No Action Alternative, the project site would remain as a parking lot for the Valley 

View Casino, and there would be no change to the use of water resources at the Site. As the 

eastern portion of the site would be developed as a parking lot under the No Action Alternative, 
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San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 4-24

stormwater run-off rates would increase. During construction activities, contamination of 

stormwater runoff would be prevented through compliance with provisions for coverage under 

California’s NPDES Construction Stormwater General Permit (2009-0009-DWQ). There would 

be no significant adverse effects to water resources beyond those experienced under its current 

pattern of use as a parking lot. 

4.2.3 Air Quality 

The No-Action Alternative would result in the continued use of the project site as a parking lot 

for the Valley View Casino and air quality impacts would remain unchanged. There would be 

no additional adverse effects to air quality beyond those experienced under its current pattern of 

use as a parking lot. 

4.2.4 Biological Resources 

Under the No-Action Alternative, the existing paved parking lot will be expanded to cover the 

remainder of the eastern half of the site. Since the footprint of the proposed parking lot is similar 

to the Proposed Action, the potential for impacts to biological resources would be similar. 

4.2.5 Cultural Resources 

Under the No-Action Alternative, the existing paved parking lot will be expanded to cover the 

remainder of the eastern half of the site. Compliance with federal regulations would ensure that 

there would be negligable effects on potentially existing cultural resources at the site. 

4.2.6 Socioeconomic Conditions 

Under the No-Action Alternative, there would be no added source of revenue for the Tribe at the 

project site. The project site would continue to be utilized as a parking lot for the Valley View 

Casino, and the Tribe would need to look to other ventures in order to generate the needed funds. 

There would be no effects (positive or negative) to current socioeconomic conditions. 

4.2.7 Noise 

Under the No-Action Alternative, there will be temporary noise disturbance from the 

construction of the parking lot. However, there will not be new noise influences aside from the 

existing traffic. There would be no additional adverse effects to the affected environment. 

4.2.8 Visual and Scenic Resources 

Under the No-Action Alternative, the parking lot will be developed consistent to Site Plan 06-

004, which includes stipulations for landscaping and lighting. Compliance with these 

stipulations and the Valley Center design guidelines would prevent adverse effects to visual and 

scenic resources. 

4.2.9 Transportation and Circulation 

The No-Action Alternative would result in the continued use of the project site for parking and 
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San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 4-25

traffic patterns and volumes would remain virtually unchanged. 

4.2.10 Public Services 

Under the No-Action Alternative, the parking lot will be developed consistent with Site Plan 06-

004, which includes stipulations for water supply and wastewater disposal. Law enforcement 

and fire protection would be provided by the appropriate local agency, the San Diego County 

Sheriff’s Department and the Valley Center Fire Protection District, respectively. There would 

be no additional adverse effects to the affected environment due to existing public service 

infrastructure and location of public service providers. 

4.2.11 Hazardous Materials 

The No-Action Alternative does not involve the use, storage, or disposal of any hazardous 

material or hazardous waste. During construction activities, contamination of stormwater runoff 

from hazardous materials would be prevented through compliance with the provisions for 

coverage under California’s NPDES Construction Stormwater General Permit (2009-0009-

DWQ). During operation, the site would be required to comply with all state, county, and local 

standards governing the use of hazardous materials. Therefore adverse effects would not occur. 

4.3 Cumulative effects 

The Council on Environmental Quality (CEQ) National Environmental Policy Act (NEPA) 

regulations, as amended (40 CFR Parts 1500-1508) define cumulative effects as “the impact on 

the environment that results from the incremental impact of the action when added to other past, 

present, and reasonably foreseeable future actions regardless of what agency (Federal or nonFederal) or person undertakes such other actions.” Cumulative impacts can result from 

individually minor but collectively significant actions taking place over a period of time. 

The cumulative analysis assumes growth in the region from build-out of the San Diego County 

General Plan and Valley Center Community Plan, as well as reasonably foreseeable projects. 

Projects that were considered within this analysis include, but were not limited to: 

• The Hoag Major Use Permit; 

• The Hidden Meadows Residential Subdivision; and 

• The Garcia Residential Subdivision. 

4.3.1 Land Resources 

Potential cumulative impacts to land resources (topography, soils, seismicity, and mineral 

resources) are site specific and related to measures required to ensure proper design for site 

conditions. The Proposed Action would not contribute to significant adverse cumulative effects 

to land resources. 

4.3.2 Water Resources 

The Proposed Action is required to comply with the Clean Water Act as it relates to stormwater 

and point-source discharges under an NPDES permit. Compliance with USEPA stormwater 
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Final Environmental Assessment 4-26

pollution prevention requirements will prevent off-site development, in combination with 

development associated with the proposed project, from causing cumulatively significant 

stormwater related impacts. 

Disposal of wastewater effluent would be required to meet Federal standards. Since all 

wastewater would be managed by the Tribe and local authorities, there would not be a significant 

impact from project related wastewater discharge. 

4.3.3 Air Quality 

Cumulative impacts to the air basin are addressed within the requirements of the Clean Air Act 

and the General Conformity Rule. Using the significance thresholds of the General Conformity 

Rule, the Proposed Action does not reach the de minimus levels required for Federal conformity 

and would not result in changes to the basin’s air quality designation. Project operational 

emissions are either traffic or gas station related. Primary contaminant emissions for both of 

these sources are ozone precursors. Since the San Diego region is in attainment for ozone, the 

presence of added emissions from the Proposed Action at the Site would contribute small 

cumulative impacts to the overall regional air quality over time. Potential cumulative effects 

associated with greenhouse gas emissions and climate change are addressed in Section 4.1.3. 

4.3.4 Biological Resources 

The Proposed Action has the potential to adversely affect nest sites for federally protected 

migratory birds and other birds of prey. Although unlikely, the ruderal/disturbed areas still 

provide marginal habitat for San Diego thornmint, thread‐leaved brodiaea, San Diego button 

celery, and Stephens’ kangaroo rat even though their preferred soil and grassland habitat types 

do not occur within the Site. Despite the low likelihood that the Proposed Action would result in 

adverse effects to these species given the high level of disturbance and the lack of preferred 

habitat, mitigation has been provided to ensure that the Proposed Action would not result in 

adverse effects to these federal listed species in Section 5.0. With mitigation, the Proposed 

Action would not contribute to cumulative adverse effects associated with biological resources. 

4.3.5 Cultural Resources 

Protection measures for potential impacts to unknown cultural resources are included in Section 

5.0. Similar measures are required for all development in San Diego County to comply with 

County policies, NEPA, and CEQA. No cumulative adverse effects to cultural resources would 

occur as a result of the Proposed Action. 

4.3.6 Socioeconomic Conditions/ Environmental Justice 

The Proposed Action would contribute important socioeconomic benefits to the Tribe through 

the addition of new jobs and revenue that would continue to benefit the Tribe in the foreseeable 

future. The Proposed Action is not anticipated to result in significant adverse effects on 

environmental justice. The Proposed Action would create job opportunities, as well as services 

for the local area. Additionally, as discussed in Section 4.1.6, substantial fiscal benefits would 

be experienced by federal, state, and local governments. As such, the Proposed Action is 
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San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 4-27

anticipated to result in an overall tax revenue increase despite the loss of property tax revenues. 

Therefore, since the overall fiscal impact for federal, state, and local governments would be 

anticipated to increase, an adverse cumulative fiscal effect would not occur. No adverse 

cumulative effects to socioeconomic conditions or environmental justice would occur as a result 

of the Proposed Action. 

4.3.7 Transportation and Circulation 

The Proposed Action, when added to the projected cumulative local traffic flow increases would 

have a small cumulative impact on some of the surrounding intersections and street segments. 

The details of these potential impacts are discussed in Section 4. Mitigation measures discussed 

in Section 5 would lessen the project-generated traffic impacts. With implementation of these 

mitigation measures, the project would not contribute to adverse cumulative effects to the local 

traffic network. 

4.3.8 Land Use 

If taken into Federal trust, the project site would not be subject to County land use jurisdiction. 

Any changes to area resource use patterns off-site would be attributable solely to City/County 

policies. The Proposed Action would not contribute to significant adverse effects associated 

with land use. 

4.3.9 Agriculture 

The retention or development of agricultural land is largely a policy consideration for 

governmental entities. Prime and unique agricultural lands are considered a limited and valuable 

resource. Potential impacts to these lands must therefore be analyzed according to NEPA and 

the FPPA. All land uses in the region are subject to approval by local government entities. The 

project site does not contain prime, unique, or state/local important farmland not is it in 

agricultural production. Cumulatively significant adverse effects to agricultural land would not 

occur. 

4.3.10 Public Services 

The project site would utilize the local municipal water supply and a private wastewater system. 

Additionally, the facilities would hook up to an existing local electrical grid. Law enforcement 

services would be provided by the San Diego County Sheriff’s Department and fire protection 

services provided by the San Pasqual Reservation Fire Department. 

The VCMWD provided a Will Serve letter for the project, and all other cumulative development 

in the region would need to obtain the same agreement in order to connect to the VCMWD 

system. The VCMWD is capable of requiring conservation measures of its users and ensuring 

the water supply stability for residents and businesses through the requirements of these Will 

Serve agreements. Mitigation measures are provided in Section 5.0 to ensure the project does 

not result in significant adverse cumulative effects associated with water supply service. 

Therefore, projects would be prevented from using public water supply if the VCMWD could 
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San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 4-28

not supply them. There is no potential for cumulative effects from the project to wastewater 

treatment, since a private wastewater system would be used except during unusual peak periods. 

All future uses in the County will be subject to approval by local governments which will allow 

the County to control the rate of growth so that sufficient public services are available. While 

Tribal development is not subject to County approval, the Tribe has agreements with local 

service providers for compensation of services. Therefore, the Proposed Action would not 

contribute towards adverse cumulative effects to public services. 

4.3.11 Noise 

Generally, noise increases as areas are developed. The proposed project would increase noise 

levels through increased traffic and operational activities. However, the proposed project would 

not generate a level of traffic that would exceed acceptable outdoor noise standards. Some 

evening traffic may occur but would be insignificant. Therefore, traffic noise would not be a 

significant impact to surrounding residences, because the proposed facilities would operate and a 

majority of traffic would occur during normal business hours. The Proposed Action would not 

contribute towards significant adverse cumulative effects associated with noise. 

4.3.12 Hazardous Materials 

Cumulative effects associated with hazardous materials may include an increased risk of 

exposure of the public and the environment from the increased use, storage, and disposal of 

hazardous materials associated with the Proposed Action and cumulative developments. All new 

developments would be required to adhere to State and municipal regulations in the delivery, 

handling, and storage of hazardous materials, thereby reducing the risk of accidental exposure to 

the public’s health and welfare. Therefore, with the mitigation measures in Section 5.0 and 

compliance with federal regulations, the Proposed Action would not contribute to cumulative 

effects associated with hazardous materials. 

4.3.13 Visual Resources 

Since the project site is located in a largely developed residential low-lying area that does not 

offer significant visual features, and since the Proposed Action would be a small-scale 

commercial building, its presence would not significantly adversely effect the overall cumulative 

scenic quality of the area. 

 
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Final Environmental Assessment 5-1

Section 5 Mitigation Measures 

5.1 Land Resources 

No mitigation is required for the Proposed Action. 

5.2 Water Resources 

The following mitigation measures area recommended for the Proposed Action: 

Wastewater Treatment and Disposal 

No mitigation is required for the Proposed Action. 

Groundwater Supply 

The following mitigation is provided in the event that VCMWD capacity cannot serve the 

Proposed Action in the future and groundwater must be explored as a supplemental or 

replacement water supply; 

• A groundwater feasibility study shall be prepared which, at a minimum, characterizes the 

existing water table, determines groundwater levels and flow directions in the vicinity, 

estimates available supply, calculates the impact of the Proposed Action on nearby water 

supply wells, and recommends appropriate conservation measures to avoid impacting 

ongoing beneficial uses of groundwater and to preserve the water supply for the future of 

the Proposed Action. Conservation measures may include, but are not limited to: 

o Inclusion of high efficiency toilets and low flow faucets. 

o Irrigation systems shall avoid overspray and runoff and shall be operated at no 

more than 80 percent of the reference evapotranspiration. 

o Irrigation controllers shall be automatic and self-adjusting to account for changes 

in the weather. 

o Commercial refrigeration shall be air-cooled or closed looped if water cooled. 

o Ice-machines shall be air-cooled or use no more than 25 gallons of water per 100 

pounds of ice and be equipped with a recirculating cooling unit. 

Should the groundwater feasibility study find that the Proposed Action would have an 

unmitigateable adverse impact on nearby supply wells, groundwater would no longer be 

considered as a potable water source, and potable water would be purchased and trucked 

through private suppliers to the site. 

Water Quality 

As required and enforced by the EPA under the Clean Water Act, prior to construction a SWPPP 

shall be prepared that addresses water quality impacts associated with construction and on-going 

operations of the project. Permanent water quality maintenance features shall be incorporated 

into the project design and operation. Water quality control measures identified in the SWPPP 

shall include, but not be limited to the following: 
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Construction Activities 

• Existing vegetation shall be retained where possible. To the extent feasible, grading 

activities shall be limited to the immediate area required for construction. 

• Temporary vegetation erosion control measures (such as silt fences, staked straw bales, 

and temporary revegetation) shall be employed for disturbed areas and stockpiled soil. 

• No disturbed surfaces shall be left without erosion control measures in place during the 

winter and spring months. Construction activities shall be limited to the non-rainy season 

(May-October). 

• Sediment shall be retained onsite by a system of sediment basins, swales, or other 

appropriate measures. 

• A spill prevention plan shall be developed which shall identify proper storage, collection, 

and disposal measures for potential pollutants (such as fuel storage tanks, paints, and 

adhesives) used onsite, as well as the proper procedures for cleaning up and reporting of 

any spills. 

• Potentially hazardous materials shall be stored away from drainages and containment 

berms shall be constructed to prevent spilled materials from reaching water bodies. 

• Vehicles and equipment used during construction shall be provided proper and timely 

maintenance to reduce potential for mechanical breakdowns leading to a spill of materials 

into water bodies. Maintenance and fueling shall be conducted in an area that meets the 

criteria set forth in the spill prevention plan 

Operation Measures 

The following mitigation measures shall be implemented to minimize impacts to water quality 

from stormwater runoff: 

• All storm drains shall be equipped with silt and grease traps to remove oils, debris, and 

other pollutants. Storm drain inlets shall also be labeled “No Dumping-Drains to Rivers 

and Streams.” 

• The parking lot shall be designed to allow stormwater runoff to be directed toward 

vegetative filter strips to help control sediment. 

• Gasoline and diesel refueling/ dispensing sites should be contoured to drain into oil/water 

catchment basins. 

The following mitigation measures shall be implemented to minimize impacts to water quality 

form leaks of gasoline and/or diesel storage tanks as required by Federal regulations for 

underground storage tanks contained in 40 CFR Part 280 and enforced by the EPA. To prevent 

leaks of fuel from the gas station storage tanks and dispensing stations, the gas station shall be 

designed and constructed in accordance with all Federal regulations governing gasoline 

operations. Specific design, construction and operation practices shall include the following to 

prevent spills, overfills, and corrosion: 

• The gas station shall be equipped with catchment basins of sufficient size to contain mall 

spills. As a minimum, the basin shall be large enough to contain what may spill when the 

delivery hose is uncoupled form the fill pipe. Any spilled fuel shall be removed and 

disposed of immediately. 
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Final Environmental Assessment 5-3

• Gas station attendants and delivery personnel shall follow industry standard filling 

practices such as American Institute recommended Practice 1007, “Loading and 

Unloading of MC306/DOT 406 Cargo Motor vehicles.” Filling practices shall include 

provisions that ensure that the volume available in the tank is greater than the volume of 

product to be transferred to the tank before the transfer is made; and that the transfer 

operation is monitored constantly to prevent overfilling and spilling. 

• Gasoline storage tanks shall be equipped with overfill protection such as automatic 

shutoff devices, overfill alarms or ball and float valves. 

• Gasoline storage tanks shall be constructed to meet Federal corrosion performance 

standards. 

• Gasoline storage tanks shall be periodically inspected to ensure that the tank is 

structurally sound and free of corrosion or holes. Frequency of inspections shall be 

consistent with Federal requirements. 

• The tanks shall be equipped with leak detection systems to provide early detection of 

leaks from the tanks and dispensing equipment. 

Implementation of the above measures would reduce the impacts on water resources to less than 

significant. 

5.3 Air Quality 

BMPs discussed in Section 2.1 would minimize dust emissions from the Proposed Action. No 

further mitigation is required for the Proposed Action. 

5.4 Biological Resources 

The following precautionary measures will be implemented under the Proposed Action to ensure 

adverse effects to San Diego thornmint, thread-leaved brodiaea, and San Diego button celery are 

avoided: 

• A focused botanical survey will be conducted by a qualified botanist during the blooming 

periods for these species prior to commencement of construction activities within the 

ruderal/disturbed areas. One botanical survey may be conducted in April, May, or June 

to satisfy the bloom periods for these species. A letter report will be completed following 

the preconstruction survey to document the results. Should no species be observed, then 

no additional precautionary measures would be required. 

• Should any of the federal listed plants be observed during the focused botanical survey, 

the biologist would contact the Tribe within one day of the survey to report the findings. 

A ten-foot buffer would be established around the species using construction flagging 

prior to commencement of construction activities. 

The following precautionary measures will be implemented under the Proposed Action to ensure 

adverse effects to Stephens’ kangaroo rat are avoided: 

• A species sensitivity training program will be established. This program will be designed 

to educate construction personnel about the mitigation measures required for the 

execution of the project. All construction personnel will attend the sensitivity training 

that will provide instruction on identification, status, and detailed protocol of the actions 
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San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 5-4

that should be taken in the event that this species is encountered onsite during 

construction activities. The construction personnel will sign a sheet documenting 

attendance at the training. A qualified biologist will prepare a letter report within 30 days 

following the training to document the results of the preconstruction survey and training. 

The letter report will be submitted to the Tribe for its records. 

• A preconstruction survey will be conducted for Stephens’ kangaroo rat not more than 14 

days prior to construction activities occurring within the ruderal/disturbed areas. Should 

the biologist observe Stephens’ kangaroo rat within the project site, consultation with the 

USFWS would be initiated within 24 hours of the survey. No work would commence 

until the USFWS authorizes the commencement of such work. 

• If the construction crew observes Stephens’ kangaroo rat within the construction area, all 

construction activities will immediately cease. The construction crew will contact the 

biologist within 24 hours of the sighting. The biologist will consult with the USFWS 

within 24 hours of notification. No work would commence until the USFWS authorizes 

the commencement of such work. 

The following mitigation measures will be implemented under the Proposed Action to avoid 

potential adverse effects to migratory birds and other birds of prey: 

• If construction begins during the nesting season for raptors and other migratory birds 

(between February and October), a qualified biologist will conduct a preconstruction 

survey for active nests within 250 feet of the project site no more than 14 days prior to 

construction. If no active nests are found, then no further mitigation is necessary. 

• If any active nests are located in the project parcels, a 100-foot diameter buffer zone will 

be established around the nest to maximum extent practicable. A biologist should 

monitor nests weekly during construction to evaluate potential nesting disturbance caused 

by construction activities. The boundary of the buffer will be marked with yellow 

caution tape, surveyor’s flagging, pin flags, stakes, etc. The buffer zone will be 

maintained until the end of the breeding season or until the young have fledged. No 

construction activities should occur within 100 feet of a nest tree while young are in the 

nest. The biological monitor will have the authority to stop construction if construction 

results in evidence of potential nest abandonment. The caution tape, surveyor’s flagging, 

pin flags, stakes, etc., may be removed when a biologist, whose qualifications are 

acceptable to approval agency staff, confirms that the nest(s) is no longer occupied and 

all young have fledged. 

• If an active nest occurs in a tree scheduled for removal or during demolition of an 

existing structure, the species of nesting bird will be determined to identify whether the 

species is protected under the MBTA. The nest tree will be preserved until the USFWS 

is contacted to obtain guidance on alternative buffers based on the species requirements. 

5.5 Cultural Resources 

The following mitigation measures shall be implemented during construction to minimize the 

potential impacts associated with inadvertent discovery of cultural resources: 

• The NHPA as amended, applies due to the federal action of bringing the Site into Trust, 

as well as 36 CFR § 800. These laws require the following: 
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Final Environmental Assessment 5-5

o If human remains are discovered or suspected, work shall halt in that area and 

procedures set forth in 36 CFR § 800.13 shall be followed. 

o Once in Federal trust, and in the event of any inadvertent discovery, all such finds 

shall be subject to the implementing regulations under 36 CFR § 800.13. 

o Implementation of the above protective measures would reduce the impacts on 

cultural resources to less than significant. 

• It is recommended that a qualified archaeologist and Native American Monitor be present 

during all ground disturbing activity. 

5.6 Socioeconomic Conditions/ Environmental Justice 

The following mitigation measures shall be implemented under the Proposed Action to minimize 

potential impacts associated with crime: 

• The Tribe shall adopt an ordinance governing the sale and use of alcohol at the site; 

including, but not limited to, the prohibition of the sale of alcohol to minors less than 21 

years of age, as well as the prohibition of public drinking and/or intoxication at the site. 

• The Tribe shall adopt an ordinance prohibiting loitering and suspicious behavior on site. 

5.7 Transportation and Circulation 

Design Phase 

Project redesign is recommended to align the internal driveway to the western parking lot further 

south along Street A, opposite the access point to the eastern parking lot. 

Opening Year Mitigation 

The following mitigation measures are recommended to reduce potential traffic impacts to less 

than significant in the buildout year. It should be noted that without the jurisdiction to 

implement off-site mitigation measures, the only feasible mitigation available to the Tribe is to 

provide funding for recommended roadway and intersection improvements. Therefore the Tribe 

would contribute funding for the following improvements: 

• Valley Center Road/ Street “A” intersection: Restripe Valley Center Road to provide a 

westbound left-turn lane with 150-feet of storage and a 90-foot bay taper and an 

eastbound dedicated right-turn lane. Provide two outbound (northbound) lanes on Street 

“A”, one left-turn lane and one right-turn lane with an overlap phase. Conduct an annual 

traffic count at the Valley Center Road/ Street “A” intersection as part of a monitoring 

program of the intersection to determine when signal warrants are met. Install the traffic 

signal once warrants are met. 

• Valley Center Road between Lake Wohlford Road (N.) and Cole Grade Road: Provide 

the intersection improvements listed above and in addition, provide a westbound left-turn 

only lane at the Valley Center Road/Molly Anne Court intersection (entering into Citrus 

Point Subdivision). These capacity improvements along the impacted portion of Valley 

Center Road would directly improve traffic flow and is a proportional improvement to 

the amount of traffic the project adds to the segment. The provision of dedicated left-turn 
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San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 5-6

lanes will enable left-turn vehicles to not need to stop in Valley Center Road through 

traffic to make their turn. This is advantageous due to high speeds on Valley Center 

Road. 

Cumulative Mitigation 

Without the jurisdiction to implement off-site mitigation measures, the only feasible mitigation 

available to the Tribe is to provide funding for recommended roadway improvements. Various 

study roadway segments would operate in the cumulative year (2030) under unacceptable 

conditions without the Project. Therefore, the Tribe would contribute a share of the required 

funding proportionate to the level of impact associated with the trips added by the Project (a “fair 

share” calculated according to Caltrans guidelines). The following mitigation measures are 

recommended to reduce potential traffic impacts to less than significant in the cumulative year 

2030: 

• Implement buildout mitigation measures provided above. 

• Valley Center Road between Cole Grade Road and Lake Wohlford Road (S.): 

Payment into the County Traffic Impact Fee Program would mitigate the cumulative 

impact on this roadway to below a level of significance (County of San Diego, 2008). 

• Lake Wohlford Road (N.) between Valley Center Road and Guejito Road: Payment 

into the County Traffic Impact Fee Program would mitigate the cumulative impact on 

this roadway to below a level of significance (County of San Diego, 2008). 

• Cole Grade Road between Valley Center Road and Fruitvale Road: Payment into the 

County Traffic Impact Fee Program would mitigate the cumulative impact on this 

roadway to below a level of significance (County of San Diego, 2008). 

5.8 Land Use 

No mitigation is required for the Proposed Action. 

5.9 Agriculture 

No mitigation is required for the Proposed Action. 

5.10 Public Services 

The following mitigation measures will be required by Valley Center Municipal Water District 

as conditions of approval for the provision of water supplies to the Proposed Project: 

• Residents of the property will be required to participate in any future water conservation 

measures that may be adopted by the District. 

• The project shall be subject to the District’s Administrative Code including but not 

limited to Article 160 regarding Water Service, Article 190 Developer Project 

Requirements, Article 175 regarding Recycled Water, and Article 230 regarding Water 

Supply Shortage Conditions. 
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Final Environmental Assessment 5-7

5.11 Noise 

The following mitigation measures shall be implemented to achieve the federal noise abatement 

criteria of 67 dBA for exterior areas of nearby sensitive receptors: 

 Construction shall be limited to between the hours of 7am and 7pm Monday through 

Saturday. 

 During construction, stationary equipment and staging areas shall be located as far as 

practical from noise sensitive receptors. 

 All construction vehicles or equipment, fixed or mobile, shall be equipped with properly 

operating and maintained mufflers and acoustical shields or shrouds, in accordance with 

manufacturers’ recommendations. 

 The general contractors for all construction activities shall provide a contact number for 

citizen complaints and a methodology for dealing with such complaints such as 

designating a noise disturbance coordinator. This noise disturbance coordinator shall 

receive all public complaints about construction-related noise and vibration, shall be 

responsible for determining the cause of the complaint, and shall implement any feasible 

measures to be taken to alleviate the problem. 

 A sound wall shall be constructed along the southern border of the Site prior to other 

improvements on the site to greatly reduce noise impacts to the adjacent Valley Center 

School and residences. The height, length, placement, and construction of the sound wall 

shall be designed to reduce noise level from construction and operation to below the 

federal standard at nearby sensitive noise receptors. The sound wall shall be of at least 

eight feet in height to provide an attenuation level of 8 dBA, as noise attenuates at 

approximately one dBA per vertical foot (Caltrans, 2009). 

5.12 Hazardous Materials 

Mitigation is provided in Section 5.2, Water Resources to minimize impacts to stormwater from 

hazardous materials handling during construction activities. 

Impacts during operation from the handling of petroleum products would be regulated by EPA 

under 40 CFR 280. No mitigation is required. 

5.13 Visual Resources 

In order to reduce effects associated with lighting and glare the following mitigation measures 

are recommended: 

1. The Proposed Action should employ only shielded low-pressure sodium cutoff light 

fixtures, which will conform to San Diego County Dark Sky Ordinance. 

2. The Proposed pole lights should be 25 ft. in height, which allows them to be placed on 

the interior of proposed parking lot facilities. This measure reduces the amount of 
Summary of Environmental Impacts 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 5-8

light spillage onto the adjacent property, including Valley Center and Lake Wohlford 

Roads. 

Table 5-1: Summary of Environmental Impacts 

Land Resources

Proposed Action Alternative No-Action Alternative 

SMALL Impact NO Impact 

Water Resources ( surface and ground, quality, use, rights)

Proposed Action Alternative No-Action Alternative 

SMALL Impact NO Impact 

Air (quality/ achievement, visibility)

Proposed Action Alternative No-Action Alternative 

MODERATE Impact SMALL Impact 

Living Resources ( wildlife, vegetation, ecosystems, and agriculture)

Proposed Action Alternative No-Action Alternative 

SMALL Impact NO Impact 

Cultural Resources

Proposed Action Alternative No-Action Alternative 

NO Impact NO Impact 

Socioeconomic Conditions

Proposed Action Alternative No-Action Alternative 

MODERATE Impact NO Impact 

Noise

Proposed Action Alternative No-Action Alternative 

MODERATE Impact NO Impact 

Visual and Scenic Resources

Proposed Action Alternative No-Action Alternative 

SMALL Impact NO Impact 

Traffic Analysis 

Proposed Action Alternative No-Action Alternative 

SMALL Impact NO Impact 
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San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 6-1

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Western San Diego Metropolitan Area. California Division of Mines and Geology, 

Bulletin 200. 

Kroeber, A. L. 1925. Handbook of the Indians of California. Bureau of American Ethnology 

Bulletin 78. Smithsonian Institute, Washington. Reprinted in 1976 by Drover 

Publications, New York. 

Lemm, J. M. 2006. Field Guide to Amphibians and Reptiles of the San Diego Region. California 

Natural History Guides No. 89. University of California Press, Berkeley, CA. 344 pp. 

Lightner, J. 2006. San Diego County Native Plants. San Diego Flora, San Diego, CA. 320 pp. 

Local Government Operation Protocol (LGOP), 2008. LGOP for the Quantification and 

Reporting of Greenhouse Gas Emissions Inventories, Version 1.0, 2008. Available 

online at: http://www.climateregistry.org/resources/docs/protocols/industry/localgov/lgo_protocol_september2008.pdf. Accessed on March 15, 2010. 

Luomala, Katherine. 1976. Flexibility in Sib Affiliation among the Diegueño. In Native 

Californians: A Theoretical Retrospective, edited by L. J. Bean, and T. C. Blackburn, pp. 

245-270. Ballena Press, Socorro, New Mexico. 

Mayer, K. E. and W. F. Laudenslayer, Jr. (eds.). 1988. A Guide to Wildlife Habitats of 

California. 

Mooney, H. A. 1977. Southern coastal scrub. In: Barbour, M. G. and J. Major (eds.). Terrestrial 

Vegetation of California. John Wiley and Sons, New York, NY. pp. 471-490. 

Munz, P. A. 1974. A Flora of Southern California. University of California Press, Berkeley, CA. 

1086 pp 

Moratto, M. J. 1984. California Archaeology. Academic Press, Inc. 

National Park Service (NPS), 1990. NPS-28: Cultural Resource Management Guidelines. 

Washington, D.C. 

Norwood, Rick. 1980. The Cultural Resources of San Dieguito Estates. Unpublished report on 

file at the South Coastal Information Center, San Diego State University, San Diego, 

California. 

Peet, Mary Rockwood. 1949. San Pasqual: A Crack in the Hills. The Highland Press. Culver 

City, California. 

Phillips, George Harwood. 1975. Chiefs and Challengers. University of California Press. Los 

Angeles, California. 

Pigniolo, Andrew, R., Davidson, Elizabeth. Cultural Resource Inventory of a 9 Acre Parcel For 

the Fee-To-Trust and Tribal Improvement Project. December, 2009. 
References 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 6-5

Private Settlement Agreement between the San Pasqual band of Mission Indians and San Pasqual 

Economic Development Agency, and the San Diego County Air pollution Control 

District. 2009 

Public Law 100-675-102 Statute 4000. “San Luis Rey Indian Water Rights Settlement Act.” 

November 17, 1988 

Remeika, Paul and Lowell Lindsay. 1992. Geology of Anza-Borrego: Edge of Creation. Sunbelt 

Publications, Inc. San Diego, California. 

Rensch, Hero E. 1975. The Indian Place Names of Rancho Cuyamaca. Acoma Books, Ramona, 

California. 

Rogers, Malcolm J. 1945. An Outline of Yuman Prehistory. Southwestern Journal of 

Anthropology, 1(2):157-198. 

Rogers, Thomas H. 1992. Geologic Map of California: San Diego-El Centro Sheet. Division of 

Mines and Geology. Sacramento 

Rustvold, Marjorie M. 1983. San Pasqual Valley: Rancheria to Greenbelt. Unpublished Master’s 

Thesis. Social Sciences Department. San Diego State University. 

San Diego Air Pollution Control District. Available at:http://www.sdapcd.org/index.html. 

Accessed December, 10, 2009. 

San Diego County, 2009. Guidelines for Determining Significance and Report Format and 

Content Requirements Dark Skies and Glare. Electronic Document, http://www.co.sandiego.ca.us/dplu/docs/Dark_Skies_Guidelines.pdf, Accessed August 12, 2010. 

San Diego County, 2010. Dan McAllister: San Diego County Treasury-Tax Collector. Property 

Tax Information. Available online at: 

https://www.sdctreastax.com/ebpp3/%285ke20y552sikwc45dmener2m%29/Start.aspx. 

Accessed August 12, 2010. 

San Diego County, 1979. San Diego County General Plan. Available online at 

http://www.sdcounty.ca.gov/dplu/general plan.html. Accessed August 2, 2010. 

San Diego County Sheriff’s Department (SDCSD), 2010. Personal communication with 

Lieutenant Brislin. August 15, 2010. 

San Pasqual Reservation Fire Department (San Pasqual FD), 2010. Staffing and Station 

Information. Available online: http://sprfd.com/index.html. Accessed August 15, 2010. 

Shackley, M. Steven. 1984. Archaeological Investigations in the Western Colorado Desert: A 

Socioecological Approach, Vol. 1. Wirth Environmental Services, A Division of Dames 

& Moore, San Diego. 

Shipek, Florence. 1982. The Kamia. In APS/SDG&E Interconnection Project: Native American 

Cultural Resources, edited by Clyde Woods, pp. 21-33. Wirth Associates, Inc., San 

Diego. 
References 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 6-6

Small, A. 1974. The Birds of California. Winchester Press, New York, NY. 310 pp. 

Spier, Leslie. 1923. Southern Diegueño Customs. University of California Publications in 

American Archaeology and Ethnology 20:292-358. 

State of California Department of Conservation-Williamson Act. Available at: 

http://www.conservation.ca.gov/. Accessed April 9, 2010 

State of California Department of Finance. Available at: http://www.dof.ca.gov/. Accessed 

November 9, 2009 

State of California, Department of Parks and Recreation. 1976. California Inventory of Historic 

Resources. Department of Parks and Recreation, Sacramento, California. 

State of California, Resources Agency, Department of Fish and Game, Sacramento, CA. 166pp. 

True, D.L. 1966. Archaeological Differentiation of Shoshonean and Yuman Speaking Groups in 

Southern California. Unpublished Ph.D. dissertation, Department of Anthropology, 

University of California, Los Angeles. 

True, D.L. 1970. Investigation of a Late Prehistoric Complex in Cuyamaca Rancho State Park, 

San Diego County, California. 1970 Archaeological Survey Monograph, Department of 

Anthropology, University of California, Los Angeles. 

University of California at Davis (UCD), 1997. Transportation Project-Level Carbon Monoxide 

Protocol, Revised December, 1997. 

Urban Emissions (URBEMIS), 2007. Area, mobile, and construction emissions model, 2007. 

Available online at: http://www.urbemis.com/. Viewed July 2010. 

U.S. Census, 2000. American Fact Finder. Available at: http://www.factfinder.census.gov. 

Accessed November 10, 2009 

U.S. Department of the Interior-Bureau of Land Management. Manual H-8410-1-Visual 

Resource Inventory. Available at: http://www.blm.gov/nstc/VRM/8410.html. Accessed 

on August 3, 2009. 

U.S. Environmental Protection Agency (EPA). National Ambient Air Quality Standards. 

Available at: http://www.epa.gov/air/criteria.html. Accessed November 20, 2009. 

EPA. 1999. Publication 832-F-99-006 Stormwater Technology Fact Sheet: Vegetated Swales. 

Available at: http://www.epa.gov/npdes/pubs/vegswale.pdf. Accessed July 2010. 

United States Department of the Interior-Bureau of Indian Affairs. National Environmental 

Policy Act Handbook 59 IAM 3-H. May, 2005. 

Willey, G. R., and P. Phillips. 1958. Method and Theory in American Archaeology. University 

of Chicago Press. 
References 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 6-7

Valley Center Community Plan, San Diego County General Plan, Amended April 17, 2002. 

Available at: http://www.vccpg.org. Accessed September 10, 2009. 

Valley Center Municipal Water District. Email Communication. December 15, 2009
Preparers 

San Pasqual 9 Acre Fee‐to‐Trust August 2010 

Final Environmental Assessment 7-1

Section 7 List of Preparers 

7.1 Lead Agency 

United States Department of Interior – Bureau of Indian Affairs 

John Rydzik, Chief, Division of Environmental, Cultural Resource Management and Safety, 

Pacific Regional Office 

Patrick O’Mallan, Environmental Protection Specialist, Pacific Regional Office 

7.2 Preparers of Final Environmental Assessment 

Analytical Environmental Services (AES) 

Project Director, David Zweig 

Project Manager, Ryan Lee, AICP 

Deputy Project Manager, Bibiana Alvarez 

AES Technical Staff: 

Peter Bontadelli 

Kelly Buja 

Clint Cole 

Dana Hirschberg 

Glenn Mayfield 

Melinda McCrary 

Erin Quinn 

David Sawyer 

Ashley Wells 
Appendix A Publication Notice 

 



California Home Tuesday, July 13, 2010 

 OPR Home > CEQAnet Home > CEQAnet Query > Search Results > Document Description 

San Pasqual Band of Diegueno Mission Indians - 9 Acre Development 

 

SCH Number: 2010054003 

Document Type: EA - Environmental Assessment 

Project Lead Agency: Bureau of Indian Affairs 

Project Description

The Tribe intends to build a small shopping plaza with at least one retail tenant, a restaurant and a gas station. 

Contact Information

Primary Contact: 

Patrick O'Mallan 

U.S. Bureau of Indian Affairs 

916-978-6044 

2800 Cottage Way 

Sacramento, CA 95825 

Project Location

County: San Diego 

City: 

Region: 

Cross Streets: Lake Wohlford Road and Valley Center Road 

Latitude/Longitude: 

Parcel No: 189-051-02 

Township: 11S 

Range: 1W 

Section: 15 

Base: SBB&M 

Other Location Info: City/Nearest Community: Valley Center 

Proximity To

Highways: 15 

Airports: 

Railways: 

Waterways: Lake Wohlford 

Schools: Valley Center Middle 

Land Use: 

Development Type

Commercial 

Local Action

Other Action 

Project Issues

Aesthetic/Visual, Agricultural Land, Air Quality, Archaeologic-Historic, Biological Resources, Drainage/Absorption, Economics/Jobs, Geologic/Seismic, 

Noise, Public Services, Schools/Universities, Sewer Capacity, Soil Erosion/Compaction/Grading, Solid Waste, Toxic/Hazardous, Traffic/Circulation, 

Water Quality, Vegetation, Water Supply, Wetland/Riparian, Growth Inducing, Landuse, Cumulative Effects 

Reviewing Agencies (Agencies in Bold Type submitted comment letters to the State Clearinghouse) 

Resources Agency; Department of Conservation; Department of Parks and Recreation; Department of Water Resources; California Highway Patrol; 

Caltrans, District 11; Caltrans, Division of Transportation Planning; Health and Human Services Agency; Air Resources Board; Office of Emergency 

Services; State Water Resources Control Board; Regional Water Quality Control Board, Region 9; Native American Heritage Commission; Other 

CEQAnet - San Pasqual Band of Diegueno Mission Indians - 9 Acre Development Page 1 of 2

http://www.ceqanet.ca.gov/DocDescription.asp?DocPK=642534 7/13/2010
Agency(ies); Other - Public Comments; Department of Fish and Game, Region 5 

Date Received: 5/10/2010 Start of Review: 5/10/2010 End of Review: 6/8/2010 

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Appendix B VCMWD Will Serve Letter 

 


Appendix C Grading/Drainage Plan 
STORMWATER RUNOFF/DRAINAGE ASSESSMENT

9-ACRE SITE, VALLEY CENTER, CA 

FEE-TO-TRUST 

 [DRAFT]

San Pasqual Indian Reservation, 

San Diego County, California 

September 5, 2009 

Applicant: 

San Pasqual Band of Indians 

27458 North Lake Wohlford Road 

Valley Center, CA 92082 

Lead Agency: 

Bureau of Indian Affairs 

Southern California Agency 

1451 Research Park Drive, Suite 100 

Riverside, CA 92507 

Prepared By: 

GreenWave Environmental Consulting, Inc. 

600 Queen Street, Suite 2909 

Honolulu, HI 96813 
Table of Contents 

1.0 INTRODUCTION ............................................................................................................................ 1

1.1 Assessment Purpose & References............................................................................................... 1

1.2 Applicable Regulations................................................................................................................. 1

2.0 EXISTING HYDROGEOLOGIC CONDITIONS ........................................................................... 2

2.1 Location ....................................................................................................................................... 2

2.2 Topography ................................................................................................................................... 4

2.3 Geologic Setting............................................................................................................................ 4

2.3 Soil Types ..................................................................................................................................... 5

2.4 Soil Hydrological Classification ................................................................................................... 6

2.6 Groundwater ................................................................................................................................. 6

2.8 Climate & Precipitation ................................................................................................................ 7

2.9 Flood Zone Designations.............................................................................................................. 8

3.0 STORMWATER & RUNOFF CONSEQUENCES ......................................................................... 9

3.1 Drainage Areas............................................................................................................................. 9

3.2 Rational Method Runoff Calculations ........................................................................................ 11

3.3 Proposed Action & Potential Consequences.............................................................................. 12

4.0 MITIGATION MEASURES/BEST MANAGEMENT PRACTICES ........................................... 14

4.1 Site Control Measures................................................................................................................. 14

 List of Figures 

Figure 1 – Map of Site Location..................................................................................................... 3

Figure 2 – Aerial View of Site Location......................................................................................... 3

Figure 3 - Site Topographical Map................................................................................................. 4

Figure 4 - Site Soil Map.................................................................................................................. 5

Figure 5 – Well Data Map .............................................................................................................. 7

Figure 6 - FEMA Flood Zone Map & Approximate Site Boundary............................................... 8

Figure 7 – Runoff into Southwest Site Corner................................................................................ 9

Figure 8 – Site Drainage Areas..................................................................................................... 10
List of Tables 

Table 1 – Soil Map Units................................................................................................................ 5

Table 2 – Ground Water Level, Well Data ..................................................................................... 7

Table 3 – Example Peak Discharge Calculation, Current Site Conditions................................... 12

Table 4 – Example Peak Discharge Calculation, Fully Completed Site Development................ 12

Appendices 

Appendix A – United States Geological Survey - Rodriguez Quadrangle Map 

Appendix B – San Pasqual Reservation Geology Map 

Appendix C – United States Department of Agriculture (USDA) – Custom Soil Resource Report 

Appendix D – Lake Wohlford Hourly Precipitation Data 

Appendix E – VHB Drainage Photos 

Appendix F – Rational Equation Chart 

Appendix G – Planned Development - Site Plan 
1

1.0 INTRODUCTION 

1.1 Assessment Purpose & References 

This Stormwater Runoff/Drainage Assessment was conducted in support of an Environmental 

Assessment (EA) which addresses the current environmental conditions and future consequences 

associated with a proposed action by the San Pasqual Band of Mission Indians. The proposed 

action consists of the transfer of a 9 acre site into federal trust status for the San Pasqual Band of 

Mission Indians and the subsequent site development. Please refer to the EA document for 

specific details on the site setting and discussion/analysis of project alternatives, impact 

avoidance, and mitigation measures. 

This report is one of several additional technical studies and analysis requested by the U.S. 

Department of Interior, Bureau of Indian Affairs (BIA). The purpose of this report is to provide 

a description of existing site conditions as well as potential impacts of surface water runoff from 

the proposed action. Subject matter detailed in this document includes current hydrogeologic 

conditions, applicable regulations, site/nearby surface water bodies, runoff calculations and 

mitigation measures. This report specifically covers the potential of sedimentation from 

increased runoff water as result of proposed action on the site; runoff transports of potential 

chemical pollutants from site operations are not addressed. 

The following documents/sources were reviewed in the preparation of this document: 

• “Aggregate Resource Investigation for Selected Area of the San Pasqual Band of Mission 

Indians Reservation, Valley Center, California”, M.S. Thesis, Eric Bergstrom 2005 

• “Draft Environmental Assessment (EA), 9 Acre Site, San Pasqual Band of Indians, Valley 

Center California”, GreenWave Environmental Consulting Inc. , August 2009 

• “Phase I Environmental Site Assessment Report (ESA), 9 Acre Site”, GreenWave 

Environmental Consulting Inc. , April 2009 

• “Preliminary Drainage Analysis for Valley View Casino Expansion Project”, Hamada 

Engineering, February 2003 

• Site Visit Photographs, Mr. Doug DeBerry, Ecologist/Biologist, Vanasse Hangen Brustlin, 

Inc. (VHB), site visit on 17 December 2008 after a major rainfall event. 

• “Water Quality Control Plan for the San Diego Basin”, California Regional Water Quality 

Control Board, San Diego Region, 1994-2008 (living document) 

1.2 Applicable Regulations 

The EA document addresses the overall regulatory context for the site activities. This 

stormwater/runoff drainage assessment has been prepared for BIA. The BIA is the federal 

agency charged with reviewing and approving tribal applications pursuant to Section 151 of Title 

25 of the Code of Federal Regulations to take land into federal trust status. For the purposes of 

this stormwater runoff/drainage assessment, the following regulations from federal, state and 

county levels may affect the proposed actions at the site: 
2

Environmental Protection Agency (EPA) 

The Safe Drinking Water Act (SDWA) was originally passed by Congress in 1974 to protect 

public health by regulating the nation's public drinking water supply. The law was amended in 

1986 and 1996 and requires many actions to protect drinking water and its sources: rivers, lakes, 

reservoirs, springs, and ground water wells. 

The Clean Water Act (CWA) is the primary federal law in the United States governing water 

pollution. The CWA requires a National Pollutant Discharge Elimination System (NPDES) 

permit for all point source discharges into the waters of the United States, as described in Section 

402 of the CWA. Since the site does not have drainage into any water bodies; an NPDES permit 

or SWPPP or stormwater management program is not required. 

State of California 

The State of California has authority to administer the NPDES program if required. According 

to the EPA, even when a state receives NPDES authorization, EPA continues to issue NPDES 

permits on tribal lands. Regardless, the site does not require an NPDES permit. 

County of San Diego 

The San Diego County Flood Control District (FCD) was first formed in 1966 by an Act of the 

State Legislature to focus primarily on flood control issues in the Unincorporated County of San 

Diego. In 1985, the FCD Act was modified to include the protection of watercourses, watershed 

management, and water quality. For the tribal lands affected by the proposed action, the FCD is 

authorized under its charter to: “Operate outside of its jurisdiction to assist with watershed 

issues within the County of San Diego and in counties and nations with watersheds that drain 

into the District’s jurisdiction.” 

2.0 EXISTING HYDROGEOLOGIC CONDITIONS 

2.1 Location 

The 9 acre site is located in the unincorporated area of San Diego County known as Valley 

Center, about 11 miles northeast of Escondido. It located less than two miles from the 

boundaries of the Tribe’s reservation. The location in relation to the boundaries of the Tribe’s 

reservation can be found at Figure 1. An aerial view of the site can be found at Figure 2. The 9 

acre site parcel is roughly rectangular in dimension, the short axis of which lies parallel to Lake 

Wohlford Road along the eastern property boundary. The long axis of the property lies parallel 

to Valley Center Road along the northern property boundary. South of the site parcel is the 

Valley Center Middle School and a vacant lot lies to the west. 
3

Figure 1 – Map of Site Location 

Figure 2 – Aerial View of Site Location 
4

2.2 Topography 

Overall the site is flat plateau as displayed by the 1997 United States Geological Survey (USGS) 

Topographic Map of the area which is included in Appendix A. The site has a very slight slope 

with a down gradient from east to west as shown in Figure 3 below. The east boundary has an 

elevation of approximately 1,527 feet above mean sea level (MSL) while the west boundary is 

approximately 1,500 feet MSL. The east boundary is at the cusp of a saddle which descends to 

the east into the Paradise Creek drainage. Overall the site is part of a large plateau in the Valley 

Center area. 

Figure 3 - Site Topographical Map 

2.3 Geologic Setting 

The 9 acre site is located in the Peninsula Range of San Diego, California. The geologic history 

of the area generally consists of Pre-Cretaceous metasedimentary rocks intruded by Mesozoic 

granitic plutons. The granitic rocks are identified as the Peninsular Ranges Batholith, a 

composite mass of Cretaceous age rocks emplaced through plutonic intrusion between 122 and 

98 million years ago. Following emplacement, a period of uplift, tilting, and erosion ensued, 

leading to the present day topography. Exposure of various rock types has led to erratic 

weathering and occasionally steep cliffs. Along with the surrounding nearby area, the proposed 

site consists of alluvium from erosion of the hills near the plateau. A 2005 geological map of the 

entire San Pasqual Reservation was developed for a previous study of the area by Eric Bergstrom 

and has been included in Appendix B. The north side of geological map begins in the hills 

approximately two miles south of the site. Although the map does not cover the actual site, due 

to close proximity of the map, the geology of the site area is very similar.
5

2.3 Soil Types 

The soils within the site are composed of two main associations as designated by the United 

States Department of Agriculture (USDA): the Fallbrook sandy loam and Visalia sandy loam. 

The 9 acre site has approximately equal amounts of these two soil types. The Visalia series 

consists of moderately well drained, very deep sandy loams derived from granitic alluvium. The 

Fallbrook sandy loam is very similar but includes more fine grain size materials. Both of these 

soils are on alluvial fans and flood plains that have slopes of 0 to 15 percent. The soils are used 

to grow avocados, citrus, walnut orchards, truck crops, irrigated pasture, field crops, tomatoes, 

flowers, and nursery stock. 

Figure 4 displays the site soil map. Table 1 has the corresponding soil type descriptions and 

levels of soil occurrence at the site. Appendix C contains a USDA custom soil resource report 

for the site area created using their website. 

Figure 4 - Site Soil Map 

Table 1 – Soil Map Units 

9 Acre Site 

Map Unit Symbol Map Unit Name Acres Percent 

FaC2 Fallbrook sandy loam 4.7 52% 

VaB Visalia sandy loam 4.3 48% 
6

2.4 Soil Hydrological Classification 

Hydrologic soil groups are based on estimates of runoff potential. Soils are assigned to one of 

four groups according to the rate of water infiltration when the soils are not protected by 

vegetation, are thoroughly wet, and receive precipitation from long-duration storms. The lowest 

to highest runoff potential runs from group A to D respectively. Both of the site soils are 

classified in the soil hydrologic group B as described below according to the USDA 

classification. 

Soil drainage class refers to the frequency and duration of wet periods under conditions similar 

to those under which the soil formed. Alterations of the water regime by human activities, either 

through drainage or irrigation, are not a consideration unless they have significantly changed the 

morphology of the soil. Seven classes of natural soil drainage are recognized: excessively 

drained, somewhat excessively drained, well drained, moderately well drained, somewhat poorly 

drained, poorly drained, and very poorly drained. Both of the site soils are classified as “well 

drained” as defined below according to the USDA classification. 

• Hydrologic Group B: Soils having a moderate infiltration rate when thoroughly wet. 

These consist chiefly of moderately deep or deep, moderately well drained or well 

drained soils that have moderately fine texture to moderately coarse texture. These soils 

have a moderate rate of water transmission. 

• Well drained: Water is removed from the soil readily but not rapidly. Internal free water 

occurrence commonly is deep or very deep; annual duration is not specified. Water is 

available to plants throughout most of the growing season in humid regions. Wetness 

does not inhibit growth of roots for significant periods during most growing seasons. The 

soils are mainly free of the deep to redoximorphic features that are related to wetness. 

Based on the existing hydrologic soil group B and “well drained” drainage class, exposed soil on 

the site has a moderate potential for runoff and erosion in extreme precipitation events. 

2.6 Groundwater 

Numerous wells have been drilled in the site area of Valley Central. Five wells have been drilled 

at locations on or very near the 9 acre site as shown below in Figure 5. The ground water level 

data for these wells was reported and archived to the Water Data Library, California Department 

of Water Resources. Table 2 displays the ground water level depths which have been 

consistently reported at less than 100 feet below the ground surface. The shallow ground water 

level is consistent with the flat basin topography of the area. The well ground water level data 

below may be slightly different now as all of the data was recorded in 1966-1967. For the Phase 

I Environmental Assessment of the site, Greenwave Consulting found no information available 

regarding the status of the wells. Contact with the respective state and federal agencies did not 

yield any information. 
7

Table 2 – Ground Water Level, Well Data 

Figure 5 – Well Data Map 

2.7 Surface Water Bodies

The site area does not have any permanent surface water bodies. Based on a review of aerial 

photographs, there is an intermittent drainage channel and possibly a settling basin in the vacant 

lot to the west of the site. From the photos, vegetation, and regional climate pattern, the channel 

appears to flow solely during and after heavy rainfall events. The potential settling basin is an 

oval feature in the adjoining vacant lot sized approximately 30 feet by 60 feet. 

2.8 Climate & Precipitation

The proposed site area has a semiarid climate with warm dry summers and mild winters. The 

average annual precipitation is approximately 15 inches resulting in a borderline arid climate. 

Rainfall is strongly concentrated in the cooler half of the year, particularly December through 

State Well Number Water Surface 

Elevation MSL

11S01W15D001S 1481 

11S01W10N002S 1481 

11S01W10N001S 1490 

11S01W15C003S 1482 

11S01W10P001S 1462 
8

March. The summer months are virtually rainless. Rainfall amounts are highly variable from 

year to year and from month to month. 

A nearby rain gauge for the site is located at Lake Wohlford. The station was in operation from 

1948 to 1992. As part of a study by the National Climatic Data Center, Hourly Precipitation 

Data (HPD) rainfall event statistics for this station were computed based on recordings made of 

rainfall and time. The HPD statistics were generated through a process of computer statistical 

analysis of the station precipitation data in 2003. A data documentation paper on the process and 

the HPD statistical results for Lake Wohlford are located in Appendix D. A cursory review of 

the data shows that the station recorded precipitation values of 4-7 inches within a 24 hour period 

several times in the station operating period. The data displays these levels of precipitation 

occurring at least once if not multiple times every decade from 1940s-1980s. The large rainfall 

values are almost exclusively during the winter months. The highest value noted in the data is 

12.1 inches over 23.5 hours in the early months of 1969. This peak value is collaborated by a 

nearby Escondido rain gauge station recording 7.7 inches over 16 hours during the same time 

frame. 

2.9 Flood Zone Designations 

A Flood Insurance Rate Map (FIRM) displays the floodplains in a town or area. Such maps are 

used for town planning, the insurance industry, and by individuals. It is the official map showing 

Federal Emergency Management Agency (FEMA) delineations of both special hazard areas and 

the risk premium zones. 

The entire site is designated as Zone X as shown in Figure 6. FEMA describes Zone X as an 

area determined to be outside the 500-year floodplain. According to FEMA, for Zone X areas, 

flood insurance is available to all property owners and renters as long as the community 

participates in the National Flood Insurance Program. 

Figure 6 - FEMA Flood Zone Map & Approximate Site Boundary 
9

3.0 STORMWATER & RUNOFF CONSEQUENCES  

3.1 Drainage Areas 

There are no municipal storm drains on or in the vicinity of the site. The only stormwater 

infrastructure on the property at this time besides the roads, curbs and gutters is the culvert at the 

south boundary of the site. This culvert runs under the “school bus” road easement acting as a 

conduit for water from the eastern portion of the property to the western portion. A review of the 

high definition aerial and ground photos of the site shows stormwater draining to a low area in 

the southwest corner of the property. Much of the water appears to settle on the site; any 

remaining runoff appears to exit the property into a small wooded area. Some runoff flow may 

also drain towards the western site boundary into a channel which possibly flows into a small 

settling basin in the adjoining parcel. Please refer to Figure 8 below for drainage patterns 

inferred from the photos. 

Appendix E contains photos of the site drainage areas after a significant winter rainfall. The 

photos were taken by Mr. Doug DeBerry, an Ecologist/Biologist from Vanasse Hangen Brustlin 

Inc. on 17 December 2008. As shown in one of the photos in Figure 7 below, the site drainage 

flow affects the southwest corner of the site with occasional minor flooding of the area. Also of 

note in the Appendix E photos, the Valley Center and North Lake Wohlford roads on the north 

and east boundaries, do not have curbs or gutter features. These raised roadbeds do have some 

stabilization structures and vegetation growth to protect from runoff erosion. The “school bus” 

road easement does have sidewalk, curb and gutter features draining runoff into the 

aforementioned culvert into the southwestern corner of the site. 

 

Figure 7 – Runoff into Southwest Site Corner 
Figure 8 – Site Drainage Areas
11

3.2 Rational Method Runoff Calculations 

The rational equation is the simplest method to determine peak discharge from drainage basin 

runoff. The basic equation and units for the rational method are below: 

Rational Method Equation: Q=CIA 

Q = Peak discharge (cubic feet per second or CFS) 

C = Rational method runoff coefficient 

I = Rainfall intensity (inches/hour) 

A = Drainage area (acres) 

The rational method runoff coefficient (C) is a function of the soil or exposed material type and 

slope. The coefficient is the least precise unit in the equation and is subject to some individual 

judgment based on the site attributes. Appendix F contains a chart from the book Hydrologic 

Analysis and Design with runoff coefficients (C) versus hydrological soil group and slope range. 

For the calculations below, the following runoff coefficients were used. For the current and 

future site open space use (lawns, fields, future development areas) the chart has a C=.14 value 

using the parameters of: hydrological unit B, open space land use, slope at 0-2%, and a stormrecurrence interval 25 years or greater. For the current and future site developments, two 

different values were used. For paved parking lots and streets, the chart has a C=.95 value using 

the parameters of: parking land use, slope at 0-2%, and a storm-recurrence interval 25 years or 

greater. For the various buildings, the chart has a C=.89 value using the parameters of: 

commercial use, slope at 0-2%, and a storm-recurrence interval 25 years or greater. 

The rainfall intensity for this area was determined using isopluvial maps in the NOAA Atlas 2, 

Volume XI-California in Region 3. For average rainfall intensity (I) frequency, the following 

site values were provided by a previous runoff calculation by Summit Engineering for a 

proposed casino: 2 year frequency = .46 inches/hour, 10 year frequency = 2.16 inches/hour and 

100 year frequency = 2.88 inches/hour 

The drainage area values are used for the example runoff calculations below total (9) acres for 

the site parcel size. The area amount has been split into estimates of acreage under different site 

uses with resultant runoff coefficient values. 

The rational method calculations in Table 3 & 4 below are simple examples for the current site 

conditions and fully completed future development as shown on the site plan. The acreage 

values for each use (C Value) in the tables below are very rough estimates based on approximate 

measurements of aerial photos and the development site plan. Additional calculations with the 

rational method will be required to compute exact peak runoff for specific site configurations 

such as construction, partial development or changes to the final development plan. Regardless 

of the approximate nature, the runoff value calculations show a result of flows more than 

doubling in the change from current site conditions to completed development plans. 
12

Table 3 – Example Peak Discharge Calculation, Current Site Conditions 

2 Year 

Frequency (cfs)

10 Year 

Frequency (cfs)

100 Year 

Frequency (cfs)

~6 Acres @ C=.14 

(Open Space) .4 1.8 2.4 

~3 Acres @ C=.89 

(Parking Lot & Road) 1.2 5.8 7.7 

TOTAL SITE RUNOFF 1.6 7.6 10.1 

Table 4 – Example Peak Discharge Calculation, Fully Completed Site Development 

2 Year 

Frequency (cfs)

10 Year 

Frequency (cfs)

100 Year 

Frequency (cfs)

~1 Acre @ C=.14 

(Lawn/Landscaping) .1 .3 .4 

~3 Acres @ C=.89 

(Commercial Buildings) 1.2 5.8 7.7 

~5 Acres @ C=.95 

(Parking Lot & Road) 2.2 10.2 13.7 

TOTAL SITE RUNOFF 3.5 16.3 21.8 

3.3 Proposed Action & Potential Consequences 

The proposed action consists of the transfer of the site into federal trust status for the San 

Pasqual Band of Mission Indians and the subsequent development of a portion of the site into a 

small shopping plaza. The site is currently partially used as a parking lot. Approximately 50 

percent of the site is either paved or covered with gravel, and the remaining 50 percent exists as a 

vacant lot. The parking facility will continue to be used as additional employee parking for the 

Valley View Casino and as storage and maintenance for buses. The Tribe intends to build a 

small shopping plaza on the site in the future. The shopping plaza is expected to contain at least 

one retail tenant, a restaurant and a gas station. A site plan by Howard Parcell Company for the 

fully completed future development is located in Appendix G. 

The proposed site activities will result in changes to the hydrogeologic environment. There are 

different periods to consider for the proposed action: construction of the planned developments, 

subsequent development operation and planned future development. 

The removal of vegetation will be necessary during construction of the development or any 

future development. Vegetation acts as a binder to hold in soil and rock materials during 

precipitation events. Additionally, rock and soil materials may be transported or temporarily 
13

stockpiled on the site. The change in the landscape will have an effect on the rate and volume of 

runoff and sediment load in a direct relationship to the exposed rock materials. Based on the 

existing hydrologic soil group B and “well drained” drainage class, the site has a moderate 

potential for runoff in extreme precipitation events. Additionally, the very flat site topography 

should limit sediment transport. Never the less, the fine grain size materials of the site soils do 

have the potential for erosion and sediment transport. Without appropriate erosion control 

practices, the excavation and construction activities in the proposed development could 

contribute to increased sedimentation and runoff flow to the intermittent streams on and 

bordering the site. The increase in sediment load may lead to channel aggradation in the site 

drainages. Changes could affect the channel hydraulic attributes and subsequent watercourse 

direction or flood behavior. 

The change in the site from partially to fully developed will have a large effect on the runoff 

levels from the site. The building roofs, entry roads and parking lot materials have a very low 

water absorption capability. While past precipitation events may have been absorbed by site 

soils, development will result in increased runoff flows. As shown in the rational method 

calculations in the earlier section, the runoff could be expected to approximately double in the 

change from partial to complete site development. The runoff will flow down to the low sections 

of the site which include the current culvert/drainage channel, the southwestern corner of the site 

and a general east-west and north-south down gradients. The site development will increase the 

chance of flooding on the site and in neighboring parcels. 

 

Although, not covered in detail for the scope of this report, changes in the runoff and sediment 

levels may lead to an increased transport of chemical constituents due to leakage or spills from 

the development including the buildings, roadways and parking lots. Although industrial use is 

not planned, the development will likely have maintenance areas with potential containments 

especially the shopping center and gas station. 
14

4.0 MITIGATION MEASURES/BEST MANAGEMENT 

PRACTICES 

4.1 Site Control Measures 

The most important element of mitigation for stormwater runoff and drainage is a detailed plan 

along with the resources and personnel to implement, monitor and adjust site prevention 

measures. As mentioned earlier, there are different phases of the project for consideration 

including development design/construction, operation and future development. The following 

best management practices (BMPs) are recommended taking in account general principals as 

well as site specific attributes. Some practices may only be applicable to one phase of the project 

such as construction. 

1.) On-site Control 

An on-site manager should be assigned oversight of the stormwater runoff/drainage 

program. The manager should be based near the development and have a direct line of 

control with the personnel working onsite. The manager will be responsible for 

overseeing the implementation of mitigation measures, monitoring of runoff 

quality/volumes, and adjusting the program as necessary. In depth familiarity with the 

regulations and plans including BMPs will be required. Through standard operating 

procedures, signage and training, all appropriate site workers (construction or 

maintenance) should have basic knowledge of the stormwater runoff mitigation practices 

and contact information for the manager. During the construction phase, the stormwater 

runoff/drainage program management role may be assigned to a site supervisor or general 

compliance/quality control officer. After completion of the development, the role might 

be assigned to the lead property manager or head of site maintenance. As well as onsite 

conditions, the manager should also be active in monitoring the drainages downhill from 

the parcel. Offsite monitoring should be completed as possible with the permission of 

respective land owners. The amount of effort required in implementing the stormwater 

runoff/drainage program will vary depending on the time of year. The very pronounced 

winter precipitation pattern should be accounted for in mitigation materials preparation, 

monitoring and site operations planning. 

 

2.) Construction & Future Development Mitigation Measures

The construction on the site should be planned to proceed in an order of operations to 

minimize the amount of exposed bare ground. Vegetation should be preserved as 

possible and landscaping activities conducted as soon as possible after excavation is 

complete for an area. For all the intrusive site activities that expose sediment to runoff, 

the following list of mitigation measures should be called upon in combination together 

depending on the situation and conditions. In addition to construction activities, these 

mitigation measures could be useful preventative measures for flood control measures 

during large storms. Note that all water control devices below should be regularly 

maintained or checked to ensure their continued effectiveness and to protect from 

unexpected catastrophic failure. 

 
15

• Silt fence: A silt fence is a temporary linear sediment barrier of permeable fabric 

designed to intercept and slow the flow of sediment-laden sheet flow runoff. 

• Gravel bag barrier: A gravel bag barrier is a temporary linear sediment barrier 

consisting of stacked gravel bags, designed to intercept and slow the flow of 

sediment-laden sheet flow runoff. 

• Straw bale barrier: A straw bale barrier is a temporary linear sediment barrier 

consisting of straw bales, designed to intercept and slow sediment-laden sheet 

flow runoff. 

• Fiber rolls: Fiber rolls (sediment logs or wattles), composed of bio-degradable 

fibers stuffed in a photo-degradable open weave netting, are designed to reduce 

sediment runoff from disturbed sediment into the storm drain system or 

watercourses. Fiber rolls are porous and allow water to filter through fibers and 

trap sediment, increase filtration rates, slow runoff, and reduce sheet and rill 

erosion. 

• Drop inlet sediment barrier: A drop inlet sediment barrier is a temporary barrier 

placed at an inlet of drainage areas. The sediment barrier may be constructed of 

stone, concrete block, straw bales, or silt fence material, and gravel. These 

barriers will prevent sediment from entering the storm drainages during 

operations. Sediment-laden runoff is ponded before entering the inlet to the 

drainage, thus allowing some sediment to fall out of suspension. 

• Settling Basin A settling basin is a land depression created for sediment-laden 

runoff to settle before entering drainages outside the site. Very fine particles from 

the runoff are removed by means of gravity. The turbid water enters the basin at 

one end and the cleaner water is taken out at the other end. 

3.) Construction Stockpiles 

Stockpiles of rock materials created during excavation or building foundation 

preparation are of special concern for sediment transport during runoff events. A 

stockpile should be covered when it is not being worked. A system will need to be 

devised to protect the stockpiles during precipitation events. Stockpiles of fine gravel 

and concrete sand are especially of concern. Protection of stockpiles is a year-round 

requirement. The following practices are recommended: 

• Secure all stockpiles with waterproof covers before all predicted large 

precipitation events. 

• Locate stockpiles away from concentrated flows of stormwater, drainage courses, 

and inlets. 

• Protect all stockpiles from stormwater runoff using temporary perimeter sediment 

barriers during precipitation events. 
16

4.) Development Design

Careful consideration of stormwater drainage will need to be a part of the site 

development design. The current intermittent culvert flow through the site and increased 

runoff from the site development will need to be routed and mitigated. Taking in 

consideration the east-west & north-south site slope and current runoff path, the south 

boundary area may present a logical location for a main site drainage channel. The 

channel could be directed behind the planned shopping center and along the planned reoriented route of the “school bus” road easement. Building roof and parking lot 

drainages could be designed to feed into this central drainage. 

During partial site development phases, open space areas could be used as settling basins 

where intermittent runoff is routed from the drainage channel. These locations would 

need to be built below the rest of the site grade and designed for water settling with an 

appropriate underlay of porous materials. The southwest corner of the site is currently a 

settling area for intermittent runoff. Due to almost complete development of the site 

footprint, the final site design does not allow for significant runoff settling basins. One 

possible solution could be the construction of a subsurface settling tank. Overall, the site 

drainage design should account for all of the facilities and potential future development. 

A discussion may need to take place with owners of the down gradient vacant parcel 

regarding current and future runoff levels. 

5.) Site Development Maintenance

The site developments will need to be maintained properly to reduce the chance of 

uncontrolled runoff. The building drainage systems, roadways, channels and settling 

areas will need to be kept clear of debris and checked for structural integrity on a regular 

basis. Blockages or leaks may result in runoff being directed into unplanned routes 

resulting in site erosion or flooding of buildings. 

 

6.) Monitoring

Constant site monitoring will reduce the chance of sediment discharge or excess runoff 

from the site. Monitoring should include regular inspections of the site for compliance 

with stormwater runoff mitigation practices and preparation. During the winter months, 

when high precipitation events occur, weather predictions should be monitored to predict 

runoff events. Site activities may need to be changed or rescheduled for large storms. 

For example, construction excavation or use southern western parking area might be 

stopped for incoming weather systems. The weather monitoring should allow early 

enough warning of runoff events to prepare for site mitigation measures. A portable 

turbidity monitor could also be used during any site excavation for baseline and 

stormwater runoff measurements from the intermittent drainage from the site. Combined 

with 24 hour precipitation from local weather stations, the turbidity amounts can be 

gauged to establish a baseline for the area. Any spikes in turbidity should be investigated 

for the point source on the site.            
Appendix D Biological Resource Reports (2009 

Biological Assessment and 2010 Biological Technical 

Memorandum) 
2009 Biological Assessment 
Submitted to:  

San Pasqual Band of Mission Indians

c/o: GreenWave Solutions, Inc.

attn: Mr. Anthony W. Silvia, Esq.

2223 Avenida de la Playa, Suite 100

La Jolla, CA 92037

Submitted by:

Vanasse Hangen Brustlin, Inc.

Senior Scientist:  

Douglas A. DeBerry, Ph.D., PWS, PWD

351 McLaws Circle, Suite 3   

Williamsburg, VA 23185

FEBRUARY 2009

Biological Assessment 

San Pasqual 9‐Acre Parcel 

San Diego County, California 
This page is intentionally left blank. 
San Pasqual Biological Assessment  

9‐Acre Parcel

February 2009

   

Page 1 of 9

Introduction

Vanasse Hangen Brustlin, Inc. (VHB) completed a Biological Assessment (BA) of a 9‐acre parcel near

Valley Center, San Diego County, California.  The parcel is located at the intersection of Lake Wohlford

Road (east boundary) and Valley Center Road (north boundary) (see attached Location Map).  The Valley

Center Middle School campus lies immediately to the south.  At current, the 9‐acre parcel is used, in

part, as a parking lot – the remaining acreage is in a periodically‐mowed ‘vacant lot’ condition with an

amalgam of ruderal grasses and forbs.

VHB has undertaken this study at the request of GreenWave Solutions, Inc. (GreenWave) on behalf of

the San Pasqual Band of Mission Indian Tribe (Tribe).  The Tribe currently owns the subject property in

fee simple and desires to take the land into trust.  GreenWave is preparing an environmental

assessment for use by the Bureau of Indian Affairs in deciding whether to take the property into trust.  

The proposed use for the site is a mixed‐use retail development.   

The purpose for VHB’s study is twofold: 1) to document extant biological conditions within the parcel

boundary in satisfaction of National Environmental Policy Act reporting conventions; and, 2) to evaluate

the potential effects of a proposed land use change on federally listed threatened or endangered

species that could be present on the property.  The format of this report follows general BA guidelines

published by the U.S. Fish and Wildlife Service and the National Marine Fisheries Service under Section 7

of the Endangered Species Act (16 U.S.C. 1530‐1544), as well as the 1998 ‘Endangered Species Act

Consultation Handbook’ jointly published by both agencies (USFWS and NMFS 1998).  The conclusions

derived herein are based on the professional opinion of VHB’s senior scientist Douglas A. DeBerry, Ph.D.,

PWS, PWD, who is a specialist in rare species inventory and habitat assessment.

Proposed Action

The Tribe proposes to use this 9‐acre parcel for development of a retail strip‐mall, fast‐food restaurant,

and gas station.  It is our understanding that a plan‐of‐development (POD), including engineering

drawings and specifications, has not been prepared for the proposed land use.  However, such a site

development will presumably include soil disturbance and cut/fill grading or import of non‐native

substrate materials for site pad preparation.  For the purposes of this BA, it is assumed that all 9 acres of

the site area will be disturbed in this manner.

Study Methods

VHB conducted a site visit on December 18, 2008 to review and document current site conditions.  An

extensive literature review had been completed prior to the site visit to give proper context for

community and habitat observations.  Information on threatened and endangered species known to  
Location Map

San Pasqual Indian Reservation

9-Acre Parcel

San Diego County, California

Study Limits

0 2,000 4,000 ft.

Source: USGS 7.5 minute Rodriguez Mountain, CA Quadrangle
San Pasqual Biological Assessment  

9‐Acre Parcel

February 2009

   

Page 3 of 9

occur in San Diego County was extracted from the U.S. Fish and Wildlife Service Carlsbad Regional Office

(http://www.fws.gov/carlsbad/TEspecies.html) as well as database information available from the

California Department of Fish and Game (http://www.dfg.ca.gov/).  Vegetation communities were

described in accordance with the classification summaries provided in Barbour and Major (1977),

Lightner (2006), and the California Department of Fish and Game (2008).  Structure and physiognomic

characteristics of the vegetation assemblages onsite were compared with regionally‐relevant

descriptions in Hanes (1977), Mooney (1977), Griffin (1977), Gray (1982), and Keeley (1989).  Plant

species identification was based on Munz (1974), Hickman (1993), Stuart and Sawyer (2001), and

Lightner (2006).  Wildlife information was extracted from various resources, including Small (1974),

Mayer and Laudenslayer (1988), Jameson and Peeters (1988), and Lemm (2006).

Listed Species

Table 1 lists all species with a federal status under the Endangered Species Act that have been known to

occur in San Diego County.  This information is based on a database query from the U.S. Fish and

Wildlife Service Carlsbad Regional Office (http://www.fws.gov/carlsbad/).  Also included is a reference

to the typical habitat type for each species based on a review of the various technical resources noted

above, as well as database information available from Calflora (http://www.calflora.org/), the California

Department of Fish and Game (http://www.dfg.ca.gov/), the US Fish and Wildlife Service

(http://www.fws.gov/), and NatureServe Explorer (http://www.natureserve.org/explorer/).   

Site Description

Vegetation:  The ca. 9‐acre parcel is roughly rectangular in dimension, the long axis of which lies parallel

to Valley Center Road.  Approximately the eastern half is an existing parking lot, a portion of which is

paved; the western half is in a periodically‐maintained condition marked by colonization of ruderal

(weedy) plants.  Common species include Bermuda grass (Cynodon dactylon), black mustard (Brassica

nigra), eastern Mohave buckwheat (Eriogonum fasciculatum), telegraph weed (Heterotheca

grandiflora), and Clearwater cryptantha (Cryptantha intermedia).  A narrow zone of vegetation on

disturbed soils occurs along the parking lot perimeter.  This narrow zone is dominated by a variety of

colonizing ruderals, including prickly Russian thistle (Salsola oleraceus), eastern Mohave buckwheat,

Clearwater cryptantha, telegraph weed, narrowleaf plantain (Plantago lanceolata), smooth cat’s ear

(Hypochaeris glabra), common dandelion (Taraxacum officinale), black mustard, coastal sagebrush

(Artemesia californica), and common deerweed (Lotus scoparius).  Occasional landscape ornamentals

were observed along the southern perimeter of the lot, including oleander (Nerium oleander cultivar),

California sycamore (Platanus racemosa cultivar), and an unidentified fan palm.

Wildlife:  No wildlife species were observed utilizing the property during this site review.

   
Table 1. US Fish and Wildlife Service: List of Federally Threatened or Endangered Species for San Diego County, Californi

[Source: Carlsbad Fish and Wildlife Office; http://www.fws.gov/carlsbad/TEspecies.html][Accessed February 2009]

Scientific Name Common Name Status Habita

PLANTS

Acanthomintha ilicifolia San Diego thornmint T coastal sage scrub, chaparral, native grasslanAmbrosia pumila San Diego ambrosia E openings in sage scrub, river terraces, open gArctostaphylos glandulosa subsp. crassifolia Del Mar manzanita E southern maritime chaparralAstragalus magdalenae var. peirsonii Peirson's milk‐vetch T Algodones dunesAstragalus tener var. titi coastal dunes milk‐vetch E coastal dunes near surf zoneBaccharis vanessae Encinitas baccharis T southern maritime chaparralBerberis nevinii Nevin's barberry E chaparralBrodiaea filifolia thread‐leaved brodiaea T alkali grasslands on hillsides, floodplains (NW Chorizanthe orcuttiana Orcutt's spineflower E coastal chaparral openingsCordylanthus maritimus subsp. maritimus salt marsh bird's beak E salt marshes, intertidal brackish zonesDeinandra (=Hemizonia) conjugens Otay tarplant T grasslands, open coastal sage scrub, maritime Eryngium aristulatum var. parishii San Diego b l utton celery E vernal l poo sFremontodendron mexicanum Mexican flannelbush E southern mixed chaparralHazardia orcuttii Orcutt's hazardia C coastal sage scrub, mixed chaparral, southern Monardella linoides subsp. viminea willowy monardella E drainages/floodplains in coastal sage scrub or Navarretia fossalis spreading navarretia T vernal pools, clay flats, various hydric alkali hOrcuttia californica California Orcutt grass E vernal poolsPhacelia stellaris Brand's phacelia C coastal dunes and sandy washes in Diegan saPoa atropurpurea San Bernardino bluegrass E edges of moist meadows at 5000‐7500 feetPogogyne abramsii San Diego mesa mint E vernals pools, chemise chaparral, coastal sage Pogogyne nudiuscula Otay mesa mint E vernals pools on Otay Mesa (SW SD County)Rorippa gambellii Gambel's watercress E lake margins and slow‐flowing streams, brack

FISH

Cyprinodon macularius desert pupfish E seeps and slow moving streams in Salton Sink 

Eucyclogobius newberryi tidewater goby E small coastal lagoons, lower reaches of streamGasterosteus aculeatus williamsoni unarmored threespine stickleback E San Felipe Creek (introduced population)Oncorhynchus mykiss southern steelhead E streams, rivers, lakes, reservoirs (partially ana

AMPHIBIANS

Bufo californicus (=B. microscaphus c. ) arroyo toad (a. southwestern t.) E washes, streams, arroyos, and adjacent uplan

Rana aurora draytoni California red‐legged frog T vicinity of pools or other bodies of water
Table 1. US Fish and Wildlife Service: List of Federally Threatened or Endangered Species for San Diego County, Californi

[Source: Carlsbad Fish and Wildlife Office; http://www.fws.gov/carlsbad/TEspecies.html][Accessed February 2009]

Scientific Name Common Name Status Habita

BIRDS

Brachyramphus marmoratus marbled murrelet T near shore areas, estuaries, soundsCharadrius alexandrinus nivosus western snowy plover T beaches, dry mud flats, sandy shores of riversCharadrius montanus mountain plover W* high plains/shortgrass prairie, tablelands, ranCoccyzus americanus yellow‐billed cuckoo C dense riparian woodlandsEmpidonax traillii extimus southwestern willow flycatcher E willow thicketsGymnogyps californianus California condor E mountain and foothill rangeland and forestHaliaeetus leucocephalus bald eagle PDM various habitats near large bodies of waterPelecanus occidentalis brown pelican E offshore islands, emergent rocks, sand spits, Phoebastria albatrus short‐tailed albatross E pelagic; ground nesting sites variousPolioptila californica californica coastal California gnatcatcher T* coastal sage scrubRallus longirostris levipes light‐footed clapper rail E coastal wetlandsS l ternu a (S ) = terna) antillarum b i rown C lif i California least tern E bare or sparsel d y vegetated flat substrates neaVireo bellii pusillus least Bell's vireo E dense, willow‐dominated riparian areas with 

MAMMALS

Dipodomys stephensi Stephens' kangaroo rat E annual grassland with sparse perennial veget

Enhydra lutris nereis southern sea otter T/X* coastal waters near shoreOvis canadensis peninsular bighorn sheep E eastern slopes of Sierra NevadaPerognathus longimembris pacificus Pacific pocket mouse E shrubland, chaparral

INVERTEBRATES

Branchinecta sandiegonensis San Diego fairy shrimp E Southern California coastal vernal pools

Euphydryas editha quino Quino checkerspot butterfly E chaparral, coastal sage scrubPyrgus ruralis lagunae Laguna Mountains skipper E Mt. Palomar and Laguna MountainsStreptocephalus woottoni Riverside fairy shrimp E vernal poolsStatus: E = Federally endangered; T = Federally threatened; C = Federal candidate for listing; P = proposed; PDM = subject to post delisting mon

X: experimental population; W = withdrawn
Table 2. Partial Checklist of Vascular Plant Species

San Pasqual Indian Reservation: 9‐Acre Parcel

December 18, 2008

Scientific Name Common Name Family

Achnatherum P. Beauv. needlegrass Poaceae

Ambrosia psilostachya DC. Cuman ragweed Asteraceae

Artemisia californica Less. coastal sagebrush Asteraceae

Brassica nigra (L.) W.D.J. Koch black mustard Brassicaceae

Cryptantha intermedia (A. Gray) Greene Clearwater cryptantha Boraginaceae

Cynodon dactylon (L.) Pers. Bermudagrass Poaceae

Eriogonum fasciculatum Benth. Eastern Mojave buckwheat Polygonaceae

Gutierrezia microcephala (DC.) A. Gray threadleaf snakeweed Asteraceae

Heterotheca grandiflora Nutt. telegraphweed Asteraceae

Hypochaeris glabra L. smooth cat's ear Asteraceae

Lactuca serriola L. prickly lettuce Asteraceae

Lolium perenne L. ssp. multiflorum (Lam.)

Husnot

Italian ryegrass Poaceae

Lotus scoparius ( ) Nutt. Ottley common deerweed Fabaceae

Nerium oleander L. (cultivar) oleander Apocynaceae

Phleum pratense L. timothy Poaceae

Plantago lanceolata L. narrowleaf plantain Plantaginaceae

Platanus racemosa Nutt. (cultivar) California sycamore Platanaceae

Poa L. bluegrass Poaceae

Salsola tragus L. prickly Russian thistle Chenopodiaceae

Sonchus oleraceus L. common sowthistle Asteraceae

Taraxacum officinale F.H. Wigg. common dandelion Asteraceae
San Pasqual Biological Assessment  

9‐Acre Parcel

February 2009

   

Page 7 of 9

Effects of Proposed Action on Listed Species and/or Critical Habitat

Though there are some 49 federally‐listed plant and animal species occurring in San Diego County (see

Table 1), our review indicates that potential habitat for any such species is completely lacking on this

property.  The lack of habitat for federally‐listed species is attributed to the various anthropogenic

activities that have occurred, or are currently undertaken, to maintain this property for previous or

current land uses.  Such activities appear to have included: soil disturbance, compaction, and grading;

importing non‐native materials such as gravel and asphalt for the current land use (parking lot); and,

periodic maintenance of vegetation in vacant areas by mowing or other mechanical means.  Other

habitat‐limiting factors include adjacent development (school site, major road intersection, adjacent

community structures, residential buildings, etc.), colonization by aggressive ruderals and/or non‐native

species, and the ongoing pattern of automotive traffic on and adjacent to the site.  Finally, there is no

previously‐recorded evidence of federally‐listed species or critical habitat on the parcel.  Therefore,

taking all above‐referenced factors into consideration, the proposed land use change is not anticipated

to present a threat to the continued existence of any federally‐listed threatened or endangered species

or critical habitat thereto.

Conclusions

In light of the existing conditions documented during site reconnaissance of December 2008, detailed

review of the extant literature including database information on federally‐listed resources within San

Diego County, and information provided by GreenWave, it is VHB’s professional opinion that no effect or

incidental take is anticipated through the development of this 9‐acre parcel as proposed.   

Recommendations for Further Action

Given the overall lack of potential for this site to support federally‐listed threatened or endangered

species, no further studies are recommended at this time.

  
San Pasqual Biological Assessment  

9‐Acre Parcel

February 2009

   

Page 8 of 9

References Cited

Barbour, M. G. and J. Major (eds.). 1977. Terrestrial Vegetation of California. John Wiley and Sons, New

York, NY. 1002 pp.

California Department of Fish and Game. 2008. The Vegetation Classification and Mapping Program,

VegCAMP. Website accessed December 10, 2008. (http://www.dfg.ca.gov/biogeodata/vegcamp/).

Gray, J. T. 1982. Community structure and productivity in Ceanothus chaparral and coastal sage scrub of

Southern California. Ecological Monographs 52:415‐434.

Griffin, J. R. 1977. Oak woodland. In: Barbour, M. G. and J. Major (eds.). Terrestrial Vegetation of

California. John Wiley and Sons, New York, NY. pp. 383‐416.

Guthrie, D. A. 1974. Suburban bird populations in Southern California. American Midland Naturalist

92:461‐466.

Hanes, T. L. 1977. California chaparral. In: Barbour, M. G. and J. Major (eds.). Terrestrial Vegetation of

California. John Wiley and Sons, New York, NY. pp. 417‐469.

Hickman, J. C. (ed.). 1993. The Jepson Manual: Higher Plants of California. University of California Press,

Berkeley, CA. 1424 pp.

Jameson, E. W., Jr. and H. J. Peeters. 1988. California Mammals. California Natural History Guides No.

52. University of California Press, Berkeley, CA. 403 pp.

Keeley, S. E. (ed.). 1989. The California Chaparral: Paradigms Reexamined. Science Series Publication No.

34. Natural History Museum of Los Angeles County, Los Angeles, CA.

Lemm, J. M. 2006. Field Guide to Amphibians and Reptiles of the San Diego Region. California Natural

History Guides No. 89. University of California Press, Berkeley, CA. 344 pp.

Lightner, J. 2006. San Diego County Native Plants. San Diego Flora, San Diego, CA. 320 pp.

Mayer, K. E. and W. F. Laudenslayer, Jr. (eds.). 1988. A Guide to Wildlife Habitats of California. State of

California, Resources Agency, Department of Fish and Game, Sacramento, CA. 166 pp.

Mooney, H. A. 1977. Southern coastal scrub. In: Barbour, M. G. and J. Major (eds.). Terrestrial

Vegetation of California. John Wiley and Sons, New York, NY. pp. 471‐490.

Munz, P. A. 1974. A Flora of Southern California. University of California Press, Berkeley, CA. 1086 pp.

Small, A. 1974. The Birds of California. Winchester Press, New York, NY. 310 pp.
San Pasqual Biological Assessment  

9‐Acre Parcel

February 2009

   

Page 9 of 9

Stuart, J. D. and J. O. Sawyer. 2001. Trees and Shrubs of California. California Natural History Guides No.

62. University of California Press, Berkeley, CA. 468 pp.

U.S. Fish and Wildlife Service and National Marine Fisheries Service. 1998. Endangered Species Act

Consultation Handbook: Procedures for Conducting Section 7 Consultations and Conferences.

Washington, D.C. http://www.fws.gov/endangered/consultations/s7hndbk/s7hndbk.htm
Representative Photographs – San Pasqual 9‐Acre Parcel Biological Assessment

December 18, 2008 – Page 1 of 4

Photograph 1: Typical view of gravel parking area near the center of the parcel.

Photograph 2: Maintained ‘vacant lot’ portion of the parcel (western half).
Representative Photographs – San Pasqual 9‐Acre Parcel Biological Assessment

December 18, 2008 – Page 2 of 4

Photograph 3: Landscaping along southern parcel boundary.

Photograph 4: Ruderal vegetation colonizing on a fallow strip along Lake Wohlford Road.
Representative Photographs – San Pasqual 9‐Acre Parcel Biological Assessment

December 18, 2008 – Page 3 of 4

Photograph 5: Asphalt portion of parking lot near northern parcel boundary.

Photograph 6: Narrow zone of ruderals along Valley Center Road.
Representative Photographs – San Pasqual 9‐Acre Parcel Biological Assessment

December 18, 2008 – Page 4 of 4

Photograph 7: Field portion of parcel along Valley Center Road.

Photograph 8: View of field portion of parcel from southwestern corner.
2010 Biological Technical Memorandum 
Analytical Environmental Services San Pasqual 9-Acre Project Site 

August 2010 Technical Memorandum 

1

Biological Assessment Technical Memorandum 

for the 

San Pasqual Nine-Acre Fee-To-Trust Project 

San Diego County, California 

August 2010 

Purpose 

This Biological Assessment (BA) technical memorandum (memo) has been prepared to supplement the 

results of a BA prepared by Vanasse Hangen Brustlin, Inc. (2009), for the San Pasqual proposed nine-acre 

fee-to-trust project, in San Diego County, California (Figure 1). The results of the 2009 BA were based 

on a survey conducted during the winter and were used to support findings in the draft Environmental 

Assessment (EA) for the proposed project (Analytical Environmental Services (AES), 2010). San Diego 

County expressed concern that sensitive plants and wildlife are less likely to be present during winter 

surveys in a comment letter dated June 4, 2010 submitted on the Draft EA. The purpose of this memo is 

to document biological resources observed during a July 20, 2010 biological survey of the project site. 

Project Location 

The approximately nine-acre project site (Assessor’s Parcel Number 189-051-02) is located in Valley 

Center, California, on the southwest corner of Valley Center Road and North Lake Wohlford Road. The 

project site is located in Section 15 of Township 11 South, Range 1 West, on the Rodriguez MT, 

California U.S. Geological Survey (USGS) 7.5-Minute Topographic Quadrangle (quad), San Bernardino 

Baseline & Meridian (Figure 2). 

Project Description 

The proposed project consists of two main components: (1) placing one parcel consisting of 9.08 acres 

into Federal trust status, and (2) development of a portion of the project site into a small shopping plaza.

Methodology 

Information on biological resources in the vicinity of the project site was obtained from the following 

sources: the U.S. Fish and Wildlife Service (USFWS) list of federal listed special status species known to 

occur within San Diego County and surrounding counties (updated March 1, 2010) (Attachment 1); a 

CNDDB map of special status species within a five-mile radius of the project site (CDFG, 2001); the 

2009 BA for the project site (Vanasse Hangen Brustlin, Inc., 2009); and the July 20, 2010 biological 

survey of the project site conducted by AES. 
PROJECT

SITE

Figure 1

Regional Location

SOURCE: Street Map World, 2009; AES 2010

 San Diego County

0 5 10

Miles

SCALE

San Pasqual Band 9-acre Fee-to-Trust and Retail Plaza Project Biological Resources Letter / 209543
PROJECT

SITE

VALLEY VIEW

CASINO

Valley Center Rd

Lake Wohlford Rd

Woods Valley Rd

LEGEND

0 1,000 2,000

Feet

San Pasqual Band 9-acre Fee-to-Trust and Retail Plaza Project Biological Resources Letter / 209543

9-Acre Site

Figure 2

Site and Vicinity

SOURCE: “Rodriguez MT, CA” USGS 7.5 Minute Topographic Quadrangle, T11S, R1W, Sections 15; San Bernardino Baseline & Meridian; AES, 2010
San Pasqual 9-Acre Project Site 

August 2010 Technical Memorandum 

4

Field Survey and Analysis 

AES biologist Kelly Buja, M.S., conducted a biological survey and an informal delineation of the project 

site on July 20, 2010. The biological survey consisted of evaluating biological communities and 

documenting potential habitat for federal listed species with the potential to occur within the project site. 

Lists of plants and wildlife observed in the project site are in Attachment 2. The delineation consisted of 

mapping wetland and waterway features occurring within the project site. 

Environmental Setting

The project site is relatively flat with elevations that range from 1,505 feet in the west to 1,530 feet in the 

east. The average annual temperature within this region ranges from approximately 52 to 77 degrees 

Fahrenheit. The project site falls within Climate Zones 20 through 21 “Ocean-Influenced Southwestern 

California.” Specifically, the climate regimes of the area are more typical of Climate Zone 21, oceaninfluenced thermal belts, where steeper slopes drain cold air currents and frosts are rare. The regional 

geology is within the Peninsular Ranges (PR) geomorphic province, which includes mainland 

southwestern California exclusive of the coastal region and areas immediately south of the Transverse 

Ranges. The PR geomorphic province is a component of the Southwestern California (SW) geological 

region, which occurs within the greater California Floristic Province (Ca-FP). 

Soil Types 

The project site is comprised of two soil types: Visalia sandy loam (VaB), 2 to 5 percent slopes; and 

Fallbrook sandy loam (FaC2), 5 to 9 percent slopes, eroded. 

Habitat Types

Habitat types in the project site include ruderal/disturbed areas, developed areas, and a roadside ditch. 

The habitat map is in Figure 3. 

Ruderal/Disturbed 

Approximately half of the project site is comprised of ruderal/disturbed areas. The ruderal/disturbed 

areas include dirt roads and ornamental trees and nonnative species on disturbed land. Dominant 

vegetation in the ruderal/disturbed areas of the project site includes Bermuda grass (Cynodon dactylon), 

black mustard (Brassica nigra), narrowleaf plantain (Plantago lanceolata), soft chess (Bromus 

hordeaceus), smooth cat’s ear (Hypochaeris glabra), common dandelion (Taraxacum officinale), coastal 

sagebrush (Artemesia californica), common deerweed (Lotus scoparius), common purslane (Portulaca 

oleracea), puncture vine (Tribulus terrestris), alfalfa (Medicago sativa), Cooper’s goldenbush 

(Ericameria cooperi), ragweed (Ambrosia sp.), Mexican palo verde (Parkinsonia aculeate), and 

California buckwheat (Eriogonum fasciculatum). Ornamental trees include an isolated palm 

(Washingtonia sp.) and peppertree (Schinus sp.). 

Developed 

Approximately half of the project site is developed. The developed areas include paved roads and a 

paved parking lot. 
School Bus Rd

Lake Wohlford Rd Thundernut Ln

Valley Center Rd

Figure 3

Habitat Map

SOURCE: Aerial Express aerial photograph, 11/2009; AES, 2010

0 60 120

Feet

San Pasqual Band 9-acre Fee-to-Trust and Retail Plaza Project Biological Resources Letter / 209543

9-Acre Site

Culvert

Roadside Ditch

Developed

Ruderal/Disturbed

LEGEND
San Pasqual 9-Acre Project Site 

August 2010 Technical Memorandum 

6

Roadside Ditch 

A roadside ditch occurs on the south-central portion of the project site. Water within the approximately 

one-foot wide roadside ditch flows west, is culverted beneath a paved road, continues for approximately 

20 feet in an approximately five-foot wide channel, and ponds water where it abruptly loses its defined 

bed and banks at its terminus with a dirt road. No vegetation was observed within the roadside ditch on 

the east side of the culverts during the July 2010 survey. The roadside ditch to the west of the culverts 

was sparsely vegetated at the time of the July 2010 survey of the project site. Vegetation observed in the 

bed and along the banks of the roadside ditch includes Bermuda grass, ragweed, narrowleaf plantain, 

puncture vine, and panic grass (Panicum capillare). 

Potential Waters of the U.S. 

An informal wetland delineation was conducted within the project site in conjunction with the July 20, 

2010 biological survey. One roadside ditch occurs within the project site (Figure 3). The roadside ditch 

was excavated wholly in uplands and does not carry a relatively permanent flow of water as the manmade 

ditch only receives water from surrounding ruderal/disturbed and developed areas and through direct 

precipitation. The roadside ditch does not have a hydrologic connection with a waters of the U.S. because 

water within the roadside ditch does not flow off of the project site. In accordance with RGL 07-01, the 

roadside ditch is not considered a potentially jurisdictional feature. No potentially jurisdictional features 

occur within the project site. 

Results 

Federal Listed Species with the Potential to Occur in the Project Site 

For the purposes of this assessment, special status has been defined to include those species that are listed 

as endangered or threatened under the FESA (or formally proposed for, or candidates for, listing). A 

summary of regionally occurring federal listed species in the vicinity of the project site based on the 

USFWS file data, a description of habitat requirements, and a rationale as to whether the species has the 

potential to occur within the project site is provided in Attachment 3. Presence of species or their habitat 

was evaluated during the July 2010 biological survey. Species without the potential to occur in the 

project site are not further discussed. A five-mile radius map for state and federal listed special status 

species is provided as Figure 4. The project site does not occur within designated critical habitat for any 

federal listed species. The project site does not occur within the boundaries of the MHCP (Figure 5).

Federal Listed Plants 

San Diego Thornmint (Acanthomintha ilicifolia) 

Federal Status – Threatened 

This species is an annual herb found usually on clay soils in chaparral, coastal scrub, valley and foothill 

grassland, and vernal pools from 10 to 960 meters. The blooming period is from April through June. 

This species is known from San Diego and Baja California (CNPS, 2010). There is one CNDDB record 

for San Diego thornmint within five miles of the project site. The record is from 1990 and is 

approximately 2.5 miles southwest of the project site (CNDDB record number: 49). The record states 
PROJECT

SITE

8 3

16

16

14

9

2

2

1

12 3

4

3

2

13

5

2

15

11

2

10

7

6

2

2

2

9

5

9

76

Valley

Center R

Cole Grade Rd

d

Lilac Rd

Lake Wohlford Rd

Woods Valley Rd

Grade Rd

Valley

Center Rd

SPECIAL STATUS SPECIES DATA

San Pasqual Band 9-acre Fee-to-Trust and Retail Plaza Project Biological Resources Letter / 209543

1 - arroyo chub

2 - arroyo toad

3 - coast horned lizard

4 - coastal California gnatcatcher

5 - coastal whiptail

6 - least Bell's vireo

7 - northwestern San Diego pocket mouse

8 - orangethroat whiptail

9 - Orcutt's brodiaea

10 - pallid bat

11 - pocketed free-tailed bat

12 - Rainbow manzanita

13 - Ramona horkelia

14 - Stephens' kangaroo rat

15 - two-striped garter snake

16 - western pond turtle

Figure 4

CNDDB 5-Mile Radius Map

SOURCE: California Natural Diversity Database, 7/2010; “Rodriguez MT, CA” USGS 7.5 Minute Topographic Quadrangle, T11S, R1W, Sections 15; San Bernardino Baseline &

 Meridian; AES, 2010

9-Acre Site 5-Mile Radius CNDDB Occurrences

0 4,000 8,000

Feet
SOURCE: SANDAG, 2003; AES, 2010

PROJECT SIT
San Pasqual 9-Acre Project Site 

August 2010 Technical Memorandum 

9

that the seed and soil were transplanted to the project site outside its native habitat and range. Although 

the species is usually found on clay soils within valley and foothill grassland, the sandy loam soils within 

the weedy vegetation of the ruderal/disturbed areas may provide marginal habitat for this species. This 

species was not observed during the July 20, 2010 biological survey. Because the July 20, 2010 

biological survey of the project site was conducted outside the evident and identifiable period for this 

species, it may have been present and not detected. San Diego thornmint has a low potential to occur 

within the project site. 

Thread‐Leaved Brodiaea (Brodiaea filifolia) 

Federal Status – Threatened 

This species is usually found on clay soils within chaparral, occasionally in openings, cismontane 

woodland, coastal scrub, playas, valley and foothill grassland, and vernal pools from 25 to 1,219 meters. 

The blooming period is from March through June (CNPS, 2010). There are no documented CNDDB 

records for thread‐leaved brodiaea within five miles of the project site. Although the species is usually 

found on clay soils within valley and foothill grassland, the sandy loam soils within the weedy vegetation 

of the ruderal/disturbed areas may provide marginal habitat for this species. This species was not 

observed during the July 20, 2010 biological survey. Because the July 20, 2010 biological survey of the 

project site was conducted outside the evident and identifiable period for this species, it may have been 

present and not detected. Thread-leaved brodiaea has a low potential to occur within the project site. 

San Diego Button Celery (Eryngium aristulatum var. parishii) 

Federal Status – Endangered 

This species is an annual to perennial herb usually found in mesic vernal pools, valley and foothill 

grassland, and coastal scrub from 20 to 620 meters. The blooming period is from April through June 

(CNPS, 2010). There are no CNDDB records for San Diego button celery within five miles of the project 

site. Although the species is usually found on clay soils and within valley and foothill grassland, the 

sandy loam soils within the weedy vegetation of the ruderal/disturbed areas may provide marginal habitat 

for this species. This species was not observed during the July 20, 2010 biological survey. Because the 

July 20, 2010 biological survey of the project site was conducted outside the evident and identifiable 

period for this species, it may have been present and not detected. San Diego button celery has a low 

potential to occur within the project site. 

Federal Listed Wildlife 

Stephens’ Kangaroo Rat (Dipodomys stephensi) 

Federal Status: Endangered

Stephens’ kangaroo rat is found in sagebrush and grassy patches on sandy or gravelly soils. Stephens’ 

kangaroo rat is known from the San Jisinto Valley of San Diego, Riverside, and San Bernardino counties 

(Jameson and Peeters, 2004). There are three documented CNDDB records for Stephens’ kangaroo rat 

within five miles of the project site. The nearest CNDDB record that is presumed extant is from 2004 and 

is approximately 2.6 miles northeast of the project site (occurrence number: 226). The record states that 
San Pasqual 9-Acre Project Site 

August 2010 Technical Memorandum 

10

100 individuals were trapped in 73 locations in native grasslands, elevated areas, well drained hillsides, 

ridges, saddles, trails, dirt roadways, and adjacent lands in a trapping study (CDFG, 2003). Although the 

species is usually found in sagebrush habitat types, the weedy vegetation of the ruderal/disturbed areas 

may provide marginal habitat for this species. However, given that the project site is highly disturbed and 

is surrounded by development, it is unlikely that this species would occur within the project site. This 

species was not observed during the biological survey of the project site. Although unlikely, this species 

has a low potential to occur within the project site. 

Migratory Birds and Birds of Prey 

The Migratory Bird Treaty Act (MBTA) of 1918 (16 U.S.C. 703-711) protects migratory birds by making 

it unlawful to take, possess, buy, sell, purchase, or barter any migratory bird listed in 50 CFR 10 including 

feathers or other parts, nests, eggs, or products, except as allowed by implementing regulations (50 CFR 

21). No birds were observed nesting during the July 20, 2010 biological survey of the project site. 

Migratory birds and other birds of prey have the potential to nest within the ornamental shrubs and trees 

within the project site. 

Summary of Findings and Recommendations 

The proposed project has the potential to adversely affect nest sites for federal protected migratory birds 

and other birds of prey. Although unlikely, the ruderal/disturbed areas still provide marginal habitat for 

San Diego thornmint, thread‐leaved brodiaea, San Diego button celery, and Stephens’ kangaroo rat even 

though their preferred soil and habitat types do not occur within the project site. None of these species 

were observed within the project site during the July 20, 2010 biological survey. Despite the low 

likelihood that the proposed project would result in adverse effects to these species given the high level of 

disturbance and the lack of preferred habitat, precautionary mitigation may be implemented to ensure that 

the proposed project would not result in adverse effects to these federal listed species. 
San Pasqual 9-Acre Project Site 

August 2010 Technical Memorandum 

11

References 

Analytical Environmental Services (AES). 2010. Environmental Assessment for the San Pasqual 9-Acre 

Project Site, San Diego, California. 

California Department of Fish and Game (CDFG), 2003. RareFind 3 Version 3.1.0, California Natural 

Diversity Data Base. Fresno, California. Accessed on August 12, 2010. 

California Native Plant Society (CNPS), 2010. Inventory of Rare and Endangered Plants. Online edition, 

v6-05c. California Native Plant Society. Fresno, California. Accessed from: 

http://www.cnps.org/inventory. Accessed on August 10, 2010. 

Cornell Lab of Ornithology, 2009. The Birds of North America. Accessed from: 

http://bna.birds.cornell.edu/BNA. Accessed on August 10, 2010. 

County of San Diego, 2003. North County Multiple Habitat Conservation Program. Environment; Open 

Space/Habitat Preservation. Prepared by Sandbag. Approved in 2004. 

Ehrlich, P. R., D. S. Dobkin, and D. Wheye, 1992. Birds in Jeopardy: the Imperiled and Extinct Birds of 

the United States and Canada, Including Hawaii and Puerto Rico. Stanford University Press, 

Stanford, California. 259 pp.

Eriksen, C. and D. Belk, 1999. Fairy Shrimps of California’s Puddles, Pools, and Playas. Mad River 

Press, Inc. Eureka, California. 

Jameson, E.W., Jr. and H.J. Peeters, 2004. Mammals of California, rev. ed. University of California 

Press, Berkeley, California. 

Matthews, J.R. and C.J. Moseley (eds.), 1990. The Official World Wildlife Fund Guide to Endangered 

Species of North America. Volume 1. Plants, Mammals. xxiii + pp 1-560 + 33 pp. Appendix + 6 

pp. glossary + 16 pp. index. Volume 2. Birds, Reptiles, Amphibians, Fishes, Mussels, 

Crustaceans, Snails, Insects, and Arachnids. xiii + pp. 561-1180. Beacham Publications, Inc., 

Washington, D.C.

NatureServe, 2009. NatureServe Explorer: An Online Encyclopedia of Life [Web Application]. Version 

7.1. NatureServe, Arlington, Virginia. Available at: http://www.natureserve.org/explorer. 

Accessed on August 10, 2010. 

U.S. Fish and Wildlife Service (USFWS), 1994. Determination of Endangered Status for the Pacific 

Pocket Mouse. Federal Register 59(188): 49752-49764. September 29, 1994. 

Vanasse Hangen Brustlin, Inc., 2009. Biological Assessment for the San Pasqual 9-Acre Project Site, San 

Diego, California. 

Preparers 

Analytical Environmental Services 

1801 7th Street, Suite 100 

Sacramento, California 95811 

Phone: (916) 447-3479 

Fax: (916) 447-1665 


 

Attachment 1: U. S. Fish and Wildlife Service (USFWS) list of federal listed special-status species known to occur within San Diego County 

and surrounding counties (USFWS, 2010) 

Scientific Name Common Name Taxon Abbrev. Lead OfficeFed. 

Status CH R.P. 5yr Rev LA O SB Riv SD Imp Listing Fed Reg Date Listed

PLANTS

Acanthoscyphus (Oxytheca) parishii 

var. goodmaniana [1] Cushenbury oxytheca ACPAGO CFWO E f-02 D2 2009 X 59:43652 24-Aug-94

Acanthomintha ilicifolia San Diego thornmint ACIL CFWO T f-08 2009 X 63:54937 13-Oct-98

Acmispon (Lotus) dendroideus var. 

traskiae

San Clemente Island 

lotus LODETR CFWO E F 84 2007 X 42:40682 11-Aug-77

Allium munzii Munz's onion ALMU CFWO E f-05 2009 X 63:54975 13-Oct-98

Ambrosia pumila San Diego ambrosia AMPU CFWO E p-09 in prep. X X 67:44372 2-Jul-02

Arctostaphylos glandulosa subsp. 

crassifolia Del Mar manzanita ARGLCR CFWO E in prep. X 61:52370 7-Oct-96

Arenaria paludicola marsh sandwort ARPA VFWO E F 98 2008 X X 58:41378 3-Aug-93

Arenaria ursina Bear Valley sandwort ARUR CFWO T f-07 2008 X 63:49006 14-Sep-98

Astragalus albens Cushenbury milk-vetchASAL CFWO E f-02 D2 2009 X 59:43652 24-Aug-94

Astragalus brauntonii Braunton's milk-vetch ASBR VFWO E f-06 F 99 2009 X X X 62:4172 29-Jan-97

Astragalus lentiginosus var. coachellaeCoachella Valley milkvetch ASLECO CFWO E f-05 2009 X 63:53596 6-Oct-98

Astragalus magdalenae var. peirsonii Peirson's milk-vetch ASMAPE CFWO T f-08 2008 X 63:53596 6-Oct-98

Astragalus pycnostachyus var. 

lanosissimus

Ventura marsh milkvetch ASPYLA VFWO E f-04 in prep. X X 66:27901 21-May-01

Astragalus tener var. titi coastal dunes milkvetch ASTETI VFWO E D 2009 X X 63:43100 12-Aug-98

Astragalus tricarinatus triple-ribbed milkvetch ASTR CFWO E 2009 X X 63:53596 6-Oct-98

Atriplex coronata var. notatior San Jacinto Valley 

crownscale ATCONO CFWO E f-05 2008 X 63:54975 13-Oct-98

Baccharis vanessae Encinitas baccharis BAVA CFWO T in prep. X 61:52370 7-Oct-96

Berberis nevinii Nevin's barberry BENE CFWO E f-08 2009 X X X X 63:54956 13-Oct-98

Brodiaea filifolia thread-leaved brodiaea BRFI CFWO T pr-09 2009 X X X X X 63:54975 13-Oct-98

Castilleja cinerea ash-gray Indian 

paintbrush CACI CFWO T f-07 2008 X 63:49006 14-Sep-98

Castilleja grisea San Clemente Island 

Indian paintbrush CAGR CFWO E F 84 2007 X 42:40682 11-Aug-77

Ceanothus ophiochilus Vail Lake ceanothus CEOP CFWO T f-07 2008 X 63:54956 13-Oct-98

Cercocarpus traskiae Catalina Island 

mountain-mahogany CETR CFWO E 2007 X 62:42692 8-Aug-97
Chloropyron maritimum 

(Cordylanthus maritimus) var. 

maritimum (subsp. maritimus) [1]

salt marsh bird's beak CHMAMA CFWOE F 85 2009XXX 43:44809 28-Sep-78

Chorizanthe orcuttiana Orcutt's spineflower CHOR CFWOE 2008X 61:523707-Oct-96

Chorizanthe parryi var. fernandina San Fernando Valley 

spineflower CHPAFE VFWO

CXXX 64:57533 25-Oct-99

Deinandra (Hemizonia) conjugens [1] Otay tarplant DECO CFWOTf-02 F 04 2009X 63:54937 13-Oct-98

Delphinium variegatum subsp. 

kinkiense

San Clemente Island 

larkspur DEVAKI CFWO

E F 84 2008X 42:40682 11-Aug-77

Dodecahema (Centrostegia) leptoceras 

[1]

slender-horned 

spineflower DOLE CFWO

E in prep.XXX 52:36265 28-Sep-87

Dudleya cymosa subsp. ovatifolia Santa Monica 

Mountains dudleya DUCYOV VFWO

T F 99 in prep.XX 62:4172 29-Jan-97

Dudleya stolonifera Laguna Beach live

-

forever DUST CFWO

T in prep.X 63:54937 13-Oct-98

Eriastrum densifolium subsp. 

sanctorum

Santa Ana River 

woolly-star ERDESA CFWO

E in prep.XXX 52:36265 28-Sep-87

Erigeron parishii Parish's daisy ERPA CFWOTf-02 D2 2009XX 59:43652 24-Aug-94

Eriogonum kennedyi var. 

austromontanum

southern mountain wild 

buckwheat ERKEAU CFWO

Tf-07 2008X 63:49006 14-Sep-98

Eriogonum ovalifolium var. vineum Cushenbury buckwheatEROVVI CFWOEf-02 D2 2009X 59:43652 24-Aug-94

Eryngium aristulatum var. parishii San Diego button 

celery ERARPA CFWO

E F 98 in prep.XX 58:413843-Aug-93

Fremontodendron mexicanum Mexican flannelbush FRME CFWOEf-07 2009X 63:54956 13-Oct-98

Hazardia orcuttii Orcutt's hazardia HOAR CFWOCX 69:248764-May-04

Helianthemum greenei Island rush-rose HEGR VFWOT F 00 in prep.X 62:40954 31-Jul-97

Lithophragma maximum San Clemente Island 

woodland star LIMA CFWO

E F 84 2007X 62:426928-Aug-97

Malacothamnus clementinus San Clemente Island 

bush mallow MACL CFWO

E F 84 2007X 42:40682 11-Aug-77

Monardella linoides subsp. viminea willowy monardella MOLIVI CFWOEf-06 2008X 63:54937 13-Oct-98

Navarretia fossalis spreading navarretia NAFO CFWOTf-05 F 98 2009XXX 63:54975 13-Oct-98

Orcuttia californica California Orcutt grass ORCA CFWOE F 98 in prep.XXX 58:413843-Aug-93

Pentachaeta lyonii Lyon's pentachaeta PELY VFWOE F 99 2008X 62:4172 29-Jan-97

Phacelia stellaris Brand's phacelia PHST CFWOCXXX 69:248764-May-04

Physaria (Lesquerella) kingii subsp. 

bernardina [1]

San Bernardino 

Mountains bladderpod PHKIBE CFWO

Ef-02 D2 2009X 59:43652 24-Aug-94

Poa atropurpurea San Bernardino 

bluegrass POAT CFWO

Ef-08 2008XX 63:49006 14-Sep-98

Pogogyne abramsii San Diego mesa mint POAB CFWOE F 98 in prep.X 43:44809 28-Sep-78

Pogogyne nudiuscula Otay mesa mint PONU CFWOE F 98 in prep.X 58:413843-Aug-93

Rorippa gambellii Gambel's watercress ROGA VFWOE F 98 in prep.XXXX 58:413783-Aug-93

Sibara filifola Santa Cruz Island rock

-

cress

SIFI CFWOE 2006X 62:426928-Aug-97

Sidalcea pedata pedate checker-mallow SIPE CFWOE F 98 in prep.X 49:34497 31-Aug-84
Taraxacum californicum California taraxacum TACA CFWO E f-08 2008 X 63:49006 14-Sep-98

Thelypodium stenopetalum slender-petaled 

mustard THST CFWO E F 98 in prep. X 49:34497 31-Aug-84

Trichostema austromontanum subsp. 

compactum Hidden Lake bluecurls TRAUCO CFWO T np-07 2006 X 63:49006 14-Sep-98

Verbesina dissita big-leaved crown beardVEDI CFWO T in prep. X 61:52370 7-Oct-96

INVERTEBRATES

Branchinecta lynchi vernal pool fairy 

shrimp VPFS SAC T f-03 2007 X 59:48153 19-Sep-94

Branchinecta sandiegonensis San Diego fairy shrimp SDFS CFWO E fr-07 F 98 2008 X X 62:4925 3-Feb-97

Dinacoma caseyi Casey's June beetle CJB CFWO pE p-09 X 74:32857 9-Jul-09

Euphilotes battoides allyni El Segundo blue 

butterfly ESB CFWO E F 98 2008 X 41:22041 1-Jun-76

Euphydryas editha quino Quino checkerspot 

butterfly QCB CFWO E fr-09 F 03 2009 X X X X 62:2313 16-Jan-97

Glaucopsyche lygdamus 

palosverdesensis

Palos Verdes blue 

butterfly PVB CFWO E f-80 F 84 2008 X 45:44939 2-Jul-80

Pyrgus ruralis lagunae Laguna Mountains 

skipper LMS CFWO E f-06 2007 X 62:2313 16-Jan-97

Rhaphiomidas terminatus abdominalis Delhi Sands flowerloving fly DSF CFWO E F 97 2008 X X 58:49887 23-Sep-93

Streptocephalus woottoni Riverside fairy shrimp RFS CFWO E f-05 F 98 2008 X X X X 58:41391 3-Aug-93

FISH

Catostomus santaanae Santa Ana sucker SAS CFWO T pr-09 in prep X X X X 65:19686 12-Apr-00

Cyprinodon macularius desert pupfish R02 E f-86 F 93 X X X 51:10850 31-Mar-86

Eucyclogobius newberryi tidewater goby TWG VFWO E fr-08 D 04 2007 X X 59:5494 4-Feb-94

Gasterosteus aculeatus williamsoni unarmored threespine 

stickleback VFWO E p-80 F 85 2009 X X X 35:16047 13-Oct-70

Gila bicolor mohavensis Mohave tui chub VFWO E F 84 2009 X 35:16047 13-Oct-70

Gila elegans bonytail chub R06 E f-94 F 90 X X X 45:27713 23-Apr-80

Oncorhynchus mykiss southern steelhead (So 

Cal DPS) R09 E X X X 71:833 5-Jan-06

Ptychocheilus lucius Colorado squawfish R06 E f-94 F 91 X X X 50:30194 24-Jul-85

Xyrauchen texanus razorback sucker R06 E f-94 X X X 56:54967 23-Oct-91

AMPHIBIANS

Anaxyrus californicus (B. 

microscaphus c.) [1]

arroyo toad (a. 

southwestern t.) ARTO VFWO E pr-09 F 99 2009 X X X X X 59:64866 16-Dec-94

Batrachoseps aridus desert slender 

salamander DSS CFWO E F 82 2009 X 38:14678 4-Jun-73

Rana draytoni California red-legged 

frog CRLF SAC T pr-08 F 02 X X X X X 61:25832 23-May-96

Rana muscosa (So Cal DPS) mountain yellowlegged frog MYLF CFWO E f-06 X X X 67:44382 2-Jul-02
REPTILES

Gopherus agassizii desert tortoise DETO T f-94 F 94 X X X 55:12191 2-Apr-90

Phrynosoma mcallii flat-tailed horned lizardFTHL CFWO pT X X X 58:62624 29-Nov-93

Uma inornata Coachella Valley 

fringe-toed lizard CVFTL CFWO T f-80 F 85 in prep. X 45:63812 25-Sep-80

Xantusia riversiana island night lizard INL CFWO T F 84 2006 X 42:40685 11-Aug-77

BIRDS

Amphispiza belli clementeae San Clemente sage 

sparrow

SCSS CFWO T F 84 2009 X 42:40685 11-Aug-77

Brachyramphus marmoratus marbled murrelet MAMU POR T pr-08 F 97 X X 57:45337 1-Oct-92

Charadrius alexandrinus nivosus western snowy plover WSP SAC T fr-05 D 01 2006 X X X 58:12874 5-Mar-93

Coccyzus americanus yellow-billed cuckoo YBCU SAC C X X X X X X 66:38611 25-Jul-01

Empidonax traillii extimus southwestern willow 

flycatcher SWFL R02 E fr-05 D X X X X X X 60:10715 27-Feb-95

Gymnogyps californianus California condor CACO VFO E F 96 X X X 61:54057 16-Oct-96

Haliaeetus leucocephalus bald eagle BAEA R03 PDM F 86 X X X X X X 60:36010 12-Jul-95

Lanius ludovicianus mearnsi San Clemente 

loggerhead shrike SCLS CFWO E F 84 2009 X 42:40685 11-Aug-77

Pelecanus occidentalis brown pelican BRPE VFWO PDM pde-08 F 83 2007 X X X X X X 50:4945 4-Feb-85

Phoebastria albatrus short-tailed albatross STAL JFO E X X X 65:46643 31-Jul-00

Polioptila californica californica coastal California 

gnatcatcher CAGN CFWO T fr-07 in prep. X X X X X 58:16757 30-Mar-93

Rallus longirostris levipes light-footed clapper railLFCR CFWO E F 85 2009 X X X 35:16047 13-Oct-70

Rallus longirostris yumanensis Yuma clapper rail YUCR R02 E X X X 32:4001 11-Mar-67

Sternula (Sterna) antillarum browni

[1] California least tern CLT CFWO E F 85 2006 X X X X X 35:8495 2-Jun-70

Vireo bellii pusillus least Bell's vireo LBV CFWO E fr-94 D 98 2006 X X X X X X 51:16482 2-May-86

MAMMALS

Dipodomys merriami parvus San Bernardino 

kangaroo rat SBKR CFWO E fr-08 2009 X X X 63:51005 24-Sep-98

Dipodomys stephensi Stephens' kangaroo rat SKR CFWO E D 97 in prep. X X X 53:38469 30-Sep-88

Enhydra lutris nereis southern sea otter SSO VFO T/X* D 00 X X X 52:29780 11-Aug-87

Ovis canadensis nelsoni Peninsular bighorn 

sheep PBS CFWO E fr-09 F 00 in prep. X X X 63:13134 18-Mar-98

Perognathus longimembris pacificus Pacific pocket mouse PPM CFWO E F 98 in prep. X X X 59:49752 29-Sep-94

Spermophilus tereticaudus chlorus Palm Springs ground 

squirrel CFWO C X 64:57534 25-Oct-99

Urocyon littoralis catalinae Santa Catalina Island 

fox CAIF CFWO E D-05 X 69:10335 5-Mar-04

Status: E = Federally endangered; T = Federally threatened; C = Federal candidate for listing; P = proposed; PDM=subject to post delisting monitoring

XN: Experimental population; * southern 
sea otter first listed as threatened Jan. 14, 

1977 42:2968

CH = Critical Habitat: p = Proposed; f = Designated; np=Not Prudent; pr = Proposed Revised; fr = Final Revised; W* = proposal withdrawn

RP = Recovery Plan: F= Final, D= Draft

County Reported: LA = Los Angeles; O = Orange; SB = San Bernardino; Riv = Riverside; SD = San Diego; Imp = Imperial

Note: Santa Catalina Isl. and San Clemente 

Isl. Are in L.A. County

[1] Name under which the species was listed is in parentheses. This form should be cited at least in the beginning of a document, otherwise use the current name throughout.

March 1, 2010

ATTACHMENT 2 

Plants Observed Within 

the 

Nine-Acre San Pasqual Project Site 

July 20, 2010 

 (*) Asterisk indicates a non-native sp. 

 (+) Plus indicates cultivated or ornamental sp. 

San Pasqual 9-Acre Project Site 

August 2010 Technical Memorandum 

1

Family Scientific Name Common Name *

Anacardiaceae Schinus sp. Pepper tree I

Arecaceae Washingtonia sp. Fan palm --

Asteraceae Ambrosia sp. Ragweed

Asteraceae Artemisia californica California sagebrush N

Asteraceae Ericameria cooperi Cooper’s goldenbush N

Asteraceae Grindelia sp. Gumplant --

Asteraceae Helianthus sp. Sunflower N

Asteraceae Hypochaeris glabra Smooth cat's ear I

Asteraceae Lactuca serriola Prickly lettuce I

Brassicaceae Brassica nigra Black mustard I

Brassicaceae Brassica sp. --

Chenopodiaceae Salsola tragus Russian thistle I

Euphorbiaceae Eremocarpus setigerus Dove weed; Turkey 

mullein

N

Fabaceae Lotus scoparius California broom N

Fabaceae Medicago sativa Alfalfa I

Fabaceae Parkinsonia aculeate Mexican Palo Verde N

Fabaceae Trifolium variegatum Clover N

Fabaceae Vicia villosa ssp. villosa Hairy vetch I

Hydrophyllaceae Phacelia californica N

Onagraceae Epilobium canum Zauschneria N

Plantaginaceae Plantago lanceolata English plantain I

Poaceae Avena fatua Wild oat I

Poaceae Bromus diandrus Ripgut grass I

Poaceae Bromus hordeaceus Soft brome I

Poaceae Bromus tectorum Cheat grass I

Poaceae Bromus tectorum Cheat grass I

Poaceae Cynodon dactylon Bermuda grass I

Poaceae Cynosurus echinatus Hedgehog dogtail I

Poaceae Lolium multiflorum Italian ryegrass I

Poaceae Panicum capillare Witchgrass N

Poaceae Phalaris sp. --

Poaceae Vulpia sp. --

Polygonaceae Eriogonum fasciculatum var. fasciculatum California buckwheat N

Polygonaceae Rumex crispus Curly dock I

Portulacaceae Portulaca oleracea Common purslane I

Zygophyllaceae Tribulus terrestris Puncture vine I
San Pasqual 9-Acre Project Site 

August 2010 Technical Memorandum 

2

Wildlife Observed Within 

the 

Nine-Acre San Pasqual Project Site 

July 20, 2010 

SCIENTIFIC NAME COMMON NAME

BIRDS*

Cathartes aura Turkey vulture

Corvus brachyrhynchos American crow

Hirundo rustica Barn swallow

Mimus polyglottos Northern mockingbird

Sturnella neglecta Western meadowlark 

ANIMALS

Sceloporus occidentalis ( Western fence lizard

Spermophyllis beecheyi California ground squirrel

Sylvilagus audubonii Audubon’s cottontail

All birds were observed foraging within the project site. No birds were observed nesting. 

Analytical Environmental Services 1 San Pasqual 9-Acre Project Site 

August 2010 Technical Memorandum

Attachment 3

REGIONALLY OCCURRING FEDERALLY THREATENED OR ENDANGERED SPECIES FOR SAN DIEGO 

COUNTY, CALIFORNIA 

Species Status Habitat Potential To Occur Within Project Site

PLANTS

Acanthomintha ilicifolia 

San Diego thornmint

T Clay soils within coastal sage scrub, chaparral, native 

grassland, and vernal pools. Blooms April through 

June (CNPS, 2010).

Yes. See text.

Ambrosia pumila San 

Diego ambrosia

E Often in disturbed areas, sometimes alkaline, in 

chaparral, coastal scrub, native grasslands, and vernal 

pools. Blooms April through October (CNPS, 2010).

Yes. However, the July 20, 2010 biological 

survey was conducted within the evident and 

identifiable blooming period for this species. 

This species was not observed within the 

project site. This species does not occur 

within the project site.

Arctostaphylos 

glandulosa subsp. 

crassifolia 

Del Mar manzanita

E Often found in sandy, maritime areas in chaparral. 

Blooms December through June (CNPS, 2010).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Astragalus magdalenae 

var. peirsonii 

Peirson's milk‐vetch

T Found in desert dunes. Blooms December through 

April (CNPS, 2010).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Astragalus tener var. titi 

coastal dunes 

milk‐vetch

E Often vernally mesic areas of coastal bluff scrub, 

occasionally in sandy soils, coastal dunes, and coastal 

prairie. Blooms March through May (CNPS, 2010).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Baccharis vanessae 

Encinitas baccharis

T Usually found on sandstone soils within cismontane 

woodland and chaparral, occasionally maritime 

influenced. Blooms August through November 

(CNPS, 2010). 

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Berberis nevinii 

Nevin's barberry

E Usually found on sandy or gravelly soils within 

chaparral, cismontane woodland, coastal scrub, and 

riparian scrub. Blooms March through June (CNPS, 

2010).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Brodiaea filifolia

thread‐leaved brodiaea

T Usually found on clay soils within chaparral, 

occasionally in openings, cismontane woodland, 

coastal scrub, playas, valley and foothill grassland, 

and vernal pools. Blooms March through June 

(CNPS, 2010).

Yes. See text.

Chorizanthe orcuttiana 

Orcutt's spineflower

E Usually in sandy openings of closed-cone coniferous 

forest, chaparral that is occasionally maritime, and 

coastal scrub. Blooms March through May (CNPS, 

2010). 

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Cordylanthus maritimus 

subsp. maritimus 

salt marsh bird's beak

E Found in coastal dunes and marshes and swamps, 

occasionally in coastal salt. Blooms May through 

October (CNPS, 2010).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Deinandra 

(=Hemizonia) 

conjugens 

Otay tarplant

T Usually found in clay soils within coastal scrub and 

valley and foothill grassland from 82 to 984 feet (25 

to 300 meters). Blooms May through June (CNPS, 

2010). 

No. The project site occurs more than 500 feet 

outside of the known elevational range. 

Eryngium aristulatum 

var. parishii 

San Diego button celery

E Usually found in mesic vernal pools, valley and 

foothill grassland, and coastal scrub. Blooms April 

through June (CNPS, 2010).

Yes. See text.

Fremontodendron 

mexicanum 

Mexican flannelbush

E Usually found on gabbroic, metavolcanic, or 

serpentinite substrate in closed-cone coniferous forest, 

chaparral, and montane woodland. Blooms March 

through June (CNPS, 2010).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Hazardia orcuttii 

Orcutt's hazardia

C Often found on clay soils in coastal scrub and 

chaparral, which is occasionally maritime. Blooms 80 

to 85 meters (CNPS, 2010).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Monardella linoides 

ssp. viminea 

willowy monardella

E Usually found in alluvial ephemeral washes in 

chaparral, coastal scrub, and riparian forest, scrub, 

and woodland. Blooms June through August (CNPS, 

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.
Analytical Environmental Services 2 San Pasqual 9-Acre Project Site 

August 2010 Technical Memorandum

Species Status Habitat Potential To Occur Within Project Site

2010).

Navarretia fossalis

spreading navarretia

T Found in vernal pools, chenopod scrub, marshes and 

swamps, occasionally in assorted shallow freshwater, 

and playas. Blooms April through June (CNPS, 

2010). 

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Orcuttia californica

California Orcutt grass

E Found in vernal pools. Blooms April through August 

(CNPS, 2010).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Phacelia stellaris 

Brand's phacelia

C Found in coastal dunes and sandy washes in Diegan 

sage scrub (CNPS, 2010).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Poa atropurpurea 

San Bernardino 

bluegrass

E Usually found in mesic areas along meadows and 

seeps at 5,000 to 7,500 feet (1,360 to 2,455 meters). 

Blooms May through July (CNPS, 2010).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Pogogyne abramsii 

San Diego mesa mint

E Found in vernal pools. Blooms March through July 

(CNPS, 2010).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Pogogyne nudiuscula 

Otay mesa mint

E Found in vernal pools. Blooms May through July 

(CNPS, 2010).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Rorippa gambellii 

Gambel's watercress

E Occasionally found freshwater or brackish water in 

marshes and swamps. Blooms April through October 

(CNPS, 2010)..

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

FISH

Cyprinodon macularius

desert pupfish

E Found in seeps and slow moving streams in Salton 

Sink basin.

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Eucyclogobius 

newberryi 

tidewater goby

E Found in small coastal lagoons, lower reaches of 

streams and upper portions of bays.

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Gasterosteus aculeatus 

williamsoni 

unarmored threespine 

stickleback

E Clear, slow-flowing streams with sand or mud 

substrate, water temperature less than 24 °C, and 

abundant aquatic vegetation; occurs in deeper pools 

with slow current or, in stronger currents, behind 

obstructions. Lack of turbidity is a requirement. 

Juveniles congregate in backwaters among aquatic 

plants (Matthews and Moseley, 1990). Known from 

Los Angeles, San Bernardino, San Diego, Santa 

Barbara, Ventura counties (NatureServe, 2009).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Oncorhynchus mykiss 

southern steelhead

E Found in cool, clear, fast-flowing permanent streams 

and rivers with riffles and ample cover from riparian 

vegetation or overhanging banks. Spawning occurs in 

streams with pool and riffle complexes. Requires 

cold water and gravelly streambed to breed (Moyle, 

2002).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

AMPHIBIANS

Bufo californicus (=B. 

microscaphus c. )

arroyo toad

E Found in washes, arroyos, and streams with low and 

moderate gradients and pools. Upland habitat 

includes adjacent desert, shrubland/chaparral, and 

woodland – hardwood. Inhabits sandy banks in 

riparian woodlands (willow, cottonwood, sycamore, 

and/or coast live oak). Adults obtain shelter by 

burrowing into sandy soil and may occur up to 2 km 

from the streams used for breeding, but most often 

within 0.5 km of the streams. Adults are nocturnal 

except during the breeding season and are active at 

temperatures from 71.6 to 95°F (NatureServe, 2009).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Rana aurora draytoni 

California red‐legged 

frog

T Found in permanent and temporary pools of streams, 

marshes, and ponds with dense grassy and/or shrubby 

vegetation from 0 to 1,500 meters (NatureServe, 

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.
Analytical Environmental Services 3 San Pasqual 9-Acre Project Site 

August 2010 Technical Memorandum

Species Status Habitat Potential To Occur Within Project Site

2009).

BIRDS

Brachyramphus 

marmoratus

marbled murrelet

T Found in near shore areas, estuaries, sounds. No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Charadrius 

alexandrinus nivosus

western snowy plover

T Found in beaches, dry mud flats, sandy shores of

rivers, lakes, ponds.

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Charadrius montanus

mountain plover

W* Found in xeric tablelands with sparse, low vegetation. No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Coccyzus americanus 

yellow‐billed cuckoo

C Found in dense riparian woodlands. No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Empidonax traillii 

extimus 

southwestern willow 

flycatcher

E Found in willow thickets. No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Gymnogyps 

californianus

California condor

E Inhabits a wide range of habitats with relatively open 

areas and adequate food supplies. Topographic relief 

is also required to provide uplift for takeoff and flight.

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Haliaeetus 

leucocephalus

bald eagle

PDM Found in various habitats near large bodies of water. No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Pelecanus occidentalis 

brown pelican

E Found in offshore islands, emergent rocks, sand spits, 

sand bars.

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Phoebastria albatrus

short‐tailed albatross

E Found in pelagic; ground nesting project sites various. No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Polioptila californica 

californica 

coastal California 

gnatcatcher

T* Found in coastal sage scrub. No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Rallus longirostris 

levipes 

light‐footed clapper rail

E Found in coastal wetlands. No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Sternula (=Sterna) 

antillarum browni 

California least tern

E Nests on open, flat beaches along lagoon or estuary 

margins; sometimes on mud or sand flats a distance 

from the ocean or on artificial islands created from 

dredge spoils (Ehrlich et al. 1992). Breeds along the 

Pacific coast from central California to southern Baja 

California (NatureServe, 2009).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Vireo bellii pusillus

least Bell's vireo

E Occupies dense, low, shrubby vegetation, early 

successional stages in riparian area, brushy fields, 

young second-growth forest or woodland, scrub oak, 

coastal chaparral, and mesquite brushlands. Usually 

found near water, in riparian areas and thickets along 

dry intermittent streams. The most critical structural 

component is a dense shrub layer for breeding from 

0.6 to 3 meters above ground (Cornell Lab of 

Ornithology, 2010).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

MAMMALS

Dipodomys stephensi 

Stephens' kangaroo rat

E Found in sagebrush and grassy patches on sandy or 

gravelly soils (Jameson and Peeters, 2004). 

Yes. See text.

Enhydra lutris nereis

southern sea otter

T/X* Found in coastal waters near shore. No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Ovis canadensis 

peninsular bighorn 

E Found in eastern slopes of Sierra Nevada. No. The project site does not contain habitat 

for this species. This species does not occur 
Analytical Environmental Services 4 San Pasqual 9-Acre Project Site 

August 2010 Technical Memorandum

Species Status Habitat Potential To Occur Within Project Site

sheep within the project site.

Perognathus 

longimembris pacificus 

Pacific pocket mouse

E Found in shrublands with firm sandy soil: fine-grain, 

sandy substrates in the immediate vicinity of the 

ocean; coastal strand, coastal dunes, river alluvium, 

and coastal sage scrub growing on marine terraces 

(USFWS 1994).

No. The project site does not contain habitat 

and is outside the geographical range for this 

species. This species does not occur within 

the project site.

INVERTEBRATES

Branchinecta 

sandiegonensis

San Diego fairy shrimp

E Found in Southern California coastal vernal pools 

(Eriksen and Belk, 1999).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Euphydryas editha 

quino

Quino checkerspot 

butterfly

E Found in open chaparral, juniper woodland, chaparral 

and coastal sage scrub, and native grassland with host 

plants Plantago erecta and Plantago hookeriana var. 

californica (NatureServe, 2009).

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Pyrgus ruralis lagunae 

Laguna Mountains 

skipper

E Found usually in wet montane meadows up to 1,800 

meters in yellow pine forests. Females lay their eggs 

on the understory of its host plant, Cleveland's 

horkelia (Horkelia clevelandii) (NatureServe, 2009). 

No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Streptocephalus 

woottoni

Riverside fairy shrimp

E Found in vernal pools (Eriksen and Belk, 1999). No. The project site does not contain habitat 

for this species. This species does not occur 

within the project site.

Source: USFWS, 2010; AES, 2010.
Appendix E United States Fish & Wildlife Services Data 

File 
 

Attachment 1: U. S. Fish and Wildlife Service (USFWS) list of federal listed special-status species known to occur within San Diego County 

and surrounding counties (USFWS, 2010) 

Scientific Name Common Name Taxon Abbrev. Lead OfficeFed. 

Status CH R.P. 5yr Rev LA O SB Riv SD Imp Listing Fed Reg Date Listed

PLANTS

Acanthoscyphus (Oxytheca) parishii 

var. goodmaniana [1] Cushenbury oxytheca ACPAGO CFWO E f-02 D2 2009 X 59:43652 24-Aug-94

Acanthomintha ilicifolia San Diego thornmint ACIL CFWO T f-08 2009 X 63:54937 13-Oct-98

Acmispon (Lotus) dendroideus var. 

traskiae

San Clemente Island 

lotus LODETR CFWO E F 84 2007 X 42:40682 11-Aug-77

Allium munzii Munz's onion ALMU CFWO E f-05 2009 X 63:54975 13-Oct-98

Ambrosia pumila San Diego ambrosia AMPU CFWO E p-09 in prep. X X 67:44372 2-Jul-02

Arctostaphylos glandulosa subsp. 

crassifolia Del Mar manzanita ARGLCR CFWO E in prep. X 61:52370 7-Oct-96

Arenaria paludicola marsh sandwort ARPA VFWO E F 98 2008 X X 58:41378 3-Aug-93

Arenaria ursina Bear Valley sandwort ARUR CFWO T f-07 2008 X 63:49006 14-Sep-98

Astragalus albens Cushenbury milk-vetchASAL CFWO E f-02 D2 2009 X 59:43652 24-Aug-94

Astragalus brauntonii Braunton's milk-vetch ASBR VFWO E f-06 F 99 2009 X X X 62:4172 29-Jan-97

Astragalus lentiginosus var. coachellaeCoachella Valley milkvetch ASLECO CFWO E f-05 2009 X 63:53596 6-Oct-98

Astragalus magdalenae var. peirsonii Peirson's milk-vetch ASMAPE CFWO T f-08 2008 X 63:53596 6-Oct-98

Astragalus pycnostachyus var. 

lanosissimus

Ventura marsh milkvetch ASPYLA VFWO E f-04 in prep. X X 66:27901 21-May-01

Astragalus tener var. titi coastal dunes milkvetch ASTETI VFWO E D 2009 X X 63:43100 12-Aug-98

Astragalus tricarinatus triple-ribbed milkvetch ASTR CFWO E 2009 X X 63:53596 6-Oct-98

Atriplex coronata var. notatior San Jacinto Valley 

crownscale ATCONO CFWO E f-05 2008 X 63:54975 13-Oct-98

Baccharis vanessae Encinitas baccharis BAVA CFWO T in prep. X 61:52370 7-Oct-96

Berberis nevinii Nevin's barberry BENE CFWO E f-08 2009 X X X X 63:54956 13-Oct-98

Brodiaea filifolia thread-leaved brodiaea BRFI CFWO T pr-09 2009 X X X X X 63:54975 13-Oct-98

Castilleja cinerea ash-gray Indian 

paintbrush CACI CFWO T f-07 2008 X 63:49006 14-Sep-98

Castilleja grisea San Clemente Island 

Indian paintbrush CAGR CFWO E F 84 2007 X 42:40682 11-Aug-77

Ceanothus ophiochilus Vail Lake ceanothus CEOP CFWO T f-07 2008 X 63:54956 13-Oct-98

Cercocarpus traskiae Catalina Island 

mountain-mahogany CETR CFWO E 2007 X 62:42692 8-Aug-97
Chloropyron maritimum 

(Cordylanthus maritimus) var. 

maritimum (subsp. maritimus) [1]

salt marsh bird's beak CHMAMA CFWOE F 85 2009XXX 43:44809 28-Sep-78

Chorizanthe orcuttiana Orcutt's spineflower CHOR CFWOE 2008X 61:523707-Oct-96

Chorizanthe parryi var. fernandina San Fernando Valley 

spineflower CHPAFE VFWO

CXXX 64:57533 25-Oct-99

Deinandra (Hemizonia) conjugens [1] Otay tarplant DECO CFWOTf-02 F 04 2009X 63:54937 13-Oct-98

Delphinium variegatum subsp. 

kinkiense

San Clemente Island 

larkspur DEVAKI CFWO

E F 84 2008X 42:40682 11-Aug-77

Dodecahema (Centrostegia) leptoceras 

[1]

slender-horned 

spineflower DOLE CFWO

E in prep.XXX 52:36265 28-Sep-87

Dudleya cymosa subsp. ovatifolia Santa Monica 

Mountains dudleya DUCYOV VFWO

T F 99 in prep.XX 62:4172 29-Jan-97

Dudleya stolonifera Laguna Beach live

-

forever DUST CFWO

T in prep.X 63:54937 13-Oct-98

Eriastrum densifolium subsp. 

sanctorum

Santa Ana River 

woolly-star ERDESA CFWO

E in prep.XXX 52:36265 28-Sep-87

Erigeron parishii Parish's daisy ERPA CFWOTf-02 D2 2009XX 59:43652 24-Aug-94

Eriogonum kennedyi var. 

austromontanum

southern mountain wild 

buckwheat ERKEAU CFWO

Tf-07 2008X 63:49006 14-Sep-98

Eriogonum ovalifolium var. vineum Cushenbury buckwheatEROVVI CFWOEf-02 D2 2009X 59:43652 24-Aug-94

Eryngium aristulatum var. parishii San Diego button 

celery ERARPA CFWO

E F 98 in prep.XX 58:413843-Aug-93

Fremontodendron mexicanum Mexican flannelbush FRME CFWOEf-07 2009X 63:54956 13-Oct-98

Hazardia orcuttii Orcutt's hazardia HOAR CFWOCX 69:248764-May-04

Helianthemum greenei Island rush-rose HEGR VFWOT F 00 in prep.X 62:40954 31-Jul-97

Lithophragma maximum San Clemente Island 

woodland star LIMA CFWO

E F 84 2007X 62:426928-Aug-97

Malacothamnus clementinus San Clemente Island 

bush mallow MACL CFWO

E F 84 2007X 42:40682 11-Aug-77

Monardella linoides subsp. viminea willowy monardella MOLIVI CFWOEf-06 2008X 63:54937 13-Oct-98

Navarretia fossalis spreading navarretia NAFO CFWOTf-05 F 98 2009XXX 63:54975 13-Oct-98

Orcuttia californica California Orcutt grass ORCA CFWOE F 98 in prep.XXX 58:413843-Aug-93

Pentachaeta lyonii Lyon's pentachaeta PELY VFWOE F 99 2008X 62:4172 29-Jan-97

Phacelia stellaris Brand's phacelia PHST CFWOCXXX 69:248764-May-04

Physaria (Lesquerella) kingii subsp. 

bernardina [1]

San Bernardino 

Mountains bladderpod PHKIBE CFWO

Ef-02 D2 2009X 59:43652 24-Aug-94

Poa atropurpurea San Bernardino 

bluegrass POAT CFWO

Ef-08 2008XX 63:49006 14-Sep-98

Pogogyne abramsii San Diego mesa mint POAB CFWOE F 98 in prep.X 43:44809 28-Sep-78

Pogogyne nudiuscula Otay mesa mint PONU CFWOE F 98 in prep.X 58:413843-Aug-93

Rorippa gambellii Gambel's watercress ROGA VFWOE F 98 in prep.XXXX 58:413783-Aug-93

Sibara filifola Santa Cruz Island rock

-

cress

SIFI CFWOE 2006X 62:426928-Aug-97

Sidalcea pedata pedate checker-mallow SIPE CFWOE F 98 in prep.X 49:34497 31-Aug-84
Taraxacum californicum California taraxacum TACA CFWO E f-08 2008 X 63:49006 14-Sep-98

Thelypodium stenopetalum slender-petaled 

mustard THST CFWO E F 98 in prep. X 49:34497 31-Aug-84

Trichostema austromontanum subsp. 

compactum Hidden Lake bluecurls TRAUCO CFWO T np-07 2006 X 63:49006 14-Sep-98

Verbesina dissita big-leaved crown beardVEDI CFWO T in prep. X 61:52370 7-Oct-96

INVERTEBRATES

Branchinecta lynchi vernal pool fairy 

shrimp VPFS SAC T f-03 2007 X 59:48153 19-Sep-94

Branchinecta sandiegonensis San Diego fairy shrimp SDFS CFWO E fr-07 F 98 2008 X X 62:4925 3-Feb-97

Dinacoma caseyi Casey's June beetle CJB CFWO pE p-09 X 74:32857 9-Jul-09

Euphilotes battoides allyni El Segundo blue 

butterfly ESB CFWO E F 98 2008 X 41:22041 1-Jun-76

Euphydryas editha quino Quino checkerspot 

butterfly QCB CFWO E fr-09 F 03 2009 X X X X 62:2313 16-Jan-97

Glaucopsyche lygdamus 

palosverdesensis

Palos Verdes blue 

butterfly PVB CFWO E f-80 F 84 2008 X 45:44939 2-Jul-80

Pyrgus ruralis lagunae Laguna Mountains 

skipper LMS CFWO E f-06 2007 X 62:2313 16-Jan-97

Rhaphiomidas terminatus abdominalis Delhi Sands flowerloving fly DSF CFWO E F 97 2008 X X 58:49887 23-Sep-93

Streptocephalus woottoni Riverside fairy shrimp RFS CFWO E f-05 F 98 2008 X X X X 58:41391 3-Aug-93

FISH

Catostomus santaanae Santa Ana sucker SAS CFWO T pr-09 in prep X X X X 65:19686 12-Apr-00

Cyprinodon macularius desert pupfish R02 E f-86 F 93 X X X 51:10850 31-Mar-86

Eucyclogobius newberryi tidewater goby TWG VFWO E fr-08 D 04 2007 X X 59:5494 4-Feb-94

Gasterosteus aculeatus williamsoni unarmored threespine 

stickleback VFWO E p-80 F 85 2009 X X X 35:16047 13-Oct-70

Gila bicolor mohavensis Mohave tui chub VFWO E F 84 2009 X 35:16047 13-Oct-70

Gila elegans bonytail chub R06 E f-94 F 90 X X X 45:27713 23-Apr-80

Oncorhynchus mykiss southern steelhead (So 

Cal DPS) R09 E X X X 71:833 5-Jan-06

Ptychocheilus lucius Colorado squawfish R06 E f-94 F 91 X X X 50:30194 24-Jul-85

Xyrauchen texanus razorback sucker R06 E f-94 X X X 56:54967 23-Oct-91

AMPHIBIANS

Anaxyrus californicus (B. 

microscaphus c.) [1]

arroyo toad (a. 

southwestern t.) ARTO VFWO E pr-09 F 99 2009 X X X X X 59:64866 16-Dec-94

Batrachoseps aridus desert slender 

salamander DSS CFWO E F 82 2009 X 38:14678 4-Jun-73

Rana draytoni California red-legged 

frog CRLF SAC T pr-08 F 02 X X X X X 61:25832 23-May-96

Rana muscosa (So Cal DPS) mountain yellowlegged frog MYLF CFWO E f-06 X X X 67:44382 2-Jul-02
REPTILES

Gopherus agassizii desert tortoise DETO T f-94 F 94 X X X 55:12191 2-Apr-90

Phrynosoma mcallii flat-tailed horned lizardFTHL CFWO pT X X X 58:62624 29-Nov-93

Uma inornata Coachella Valley 

fringe-toed lizard CVFTL CFWO T f-80 F 85 in prep. X 45:63812 25-Sep-80

Xantusia riversiana island night lizard INL CFWO T F 84 2006 X 42:40685 11-Aug-77

BIRDS

Amphispiza belli clementeae San Clemente sage 

sparrow

SCSS CFWO T F 84 2009 X 42:40685 11-Aug-77

Brachyramphus marmoratus marbled murrelet MAMU POR T pr-08 F 97 X X 57:45337 1-Oct-92

Charadrius alexandrinus nivosus western snowy plover WSP SAC T fr-05 D 01 2006 X X X 58:12874 5-Mar-93

Coccyzus americanus yellow-billed cuckoo YBCU SAC C X X X X X X 66:38611 25-Jul-01

Empidonax traillii extimus southwestern willow 

flycatcher SWFL R02 E fr-05 D X X X X X X 60:10715 27-Feb-95

Gymnogyps californianus California condor CACO VFO E F 96 X X X 61:54057 16-Oct-96

Haliaeetus leucocephalus bald eagle BAEA R03 PDM F 86 X X X X X X 60:36010 12-Jul-95

Lanius ludovicianus mearnsi San Clemente 

loggerhead shrike SCLS CFWO E F 84 2009 X 42:40685 11-Aug-77

Pelecanus occidentalis brown pelican BRPE VFWO PDM pde-08 F 83 2007 X X X X X X 50:4945 4-Feb-85

Phoebastria albatrus short-tailed albatross STAL JFO E X X X 65:46643 31-Jul-00

Polioptila californica californica coastal California 

gnatcatcher CAGN CFWO T fr-07 in prep. X X X X X 58:16757 30-Mar-93

Rallus longirostris levipes light-footed clapper railLFCR CFWO E F 85 2009 X X X 35:16047 13-Oct-70

Rallus longirostris yumanensis Yuma clapper rail YUCR R02 E X X X 32:4001 11-Mar-67

Sternula (Sterna) antillarum browni

[1] California least tern CLT CFWO E F 85 2006 X X X X X 35:8495 2-Jun-70

Vireo bellii pusillus least Bell's vireo LBV CFWO E fr-94 D 98 2006 X X X X X X 51:16482 2-May-86

MAMMALS

Dipodomys merriami parvus San Bernardino 

kangaroo rat SBKR CFWO E fr-08 2009 X X X 63:51005 24-Sep-98

Dipodomys stephensi Stephens' kangaroo rat SKR CFWO E D 97 in prep. X X X 53:38469 30-Sep-88

Enhydra lutris nereis southern sea otter SSO VFO T/X* D 00 X X X 52:29780 11-Aug-87

Ovis canadensis nelsoni Peninsular bighorn 

sheep PBS CFWO E fr-09 F 00 in prep. X X X 63:13134 18-Mar-98

Perognathus longimembris pacificus Pacific pocket mouse PPM CFWO E F 98 in prep. X X X 59:49752 29-Sep-94

Spermophilus tereticaudus chlorus Palm Springs ground 

squirrel CFWO C X 64:57534 25-Oct-99

Urocyon littoralis catalinae Santa Catalina Island 

fox CAIF CFWO E D-05 X 69:10335 5-Mar-04

Status: E = Federally endangered; T = Federally threatened; C = Federal candidate for listing; P = proposed; PDM=subject to post delisting monitoring

XN: Experimental population; * southern 
sea otter first listed as threatened Jan. 14, 

1977 42:2968

CH = Critical Habitat: p = Proposed; f = Designated; np=Not Prudent; pr = Proposed Revised; fr = Final Revised; W* = proposal withdrawn

RP = Recovery Plan: F= Final, D= Draft

County Reported: LA = Los Angeles; O = Orange; SB = San Bernardino; Riv = Riverside; SD = San Diego; Imp = Imperial

Note: Santa Catalina Isl. and San Clemente 

Isl. Are in L.A. County

[1] Name under which the species was listed is in parentheses. This form should be cited at least in the beginning of a document, otherwise use the current name throughout.

March 1, 2010
Appendix F Cultural Resource Inventory – 

(Confidential Information Bound Under Separate 

Cover) 
Appendix G Supplemental Cultural Resources 

Information (SHPO Concurrence Letter and Cultural 

Resources Report Addendum) 
SHPO Concurrence Letter 


Cultural Resources Report Addendum 
August 2010 1 San Pasqual Band Fee-to-Trust and Retail Plaza Project 

Cultural Resources Addendum

Addendum to Cultural Resources Study for 

San Pasqual Band of Mission Indians 9-acre Fee-to-Trust and Retail Plaza 

Project, San Diego County, California 

DATE: August 3, 2010 

TO: Dan Hall, District Archaeologist, Pacific Regional Office, Bureau of Indian Affairs 

(BIA), Sacramento, CA. 

FROM: Analytical Environmental Services (AES), Sacramento, CA. 

SUBJECT: Addendum to the Cultural Resources Study for the San Pasqual Band of Mission Indians 

Fee-to-Trust and Retail Plaza Project, San Diego County, California 

1.0 EXECUTIVE SUMMARY 

This addendum to the Cultural Resources Inventory of a 9-acre Parcel (APN# 189-05-102) for the San 

Pasqual Fee-to-Trust and Tribal Improvement Project, San Pasqual, County of San Diego, California

(Laguna Mountain Environmental, 2009) has been prepared to address comments from San Diego County 

submitted on the Environmental Assessment related to the need to conduct further evaluation of two 

cultural resources encountered in the 9-acre fee-to-trust project area. The above referenced cultural 

resources study and addendum is intended to fulfill the requirements of Section 106 of the National 

Historic Preservation Act (NHPA) in support of the Environmental Assessment (EA). A project 

description and location; natural, cultural and ethnographic setting are provided in the above referenced 

document completed by Laguna Mountain Environmental (2009). Consist with the findings of the 

Cultural Resources Report, the resource evaluations in this addendum concluded that both isolated 

artifacts are not eligible for listing on the National Register of Historical Places (NRHP). Therefore, 

further consultation with the State Historic Preservation Officer (SHPO) in accordance with Section 106 

of NHPA is not required. 

2.0 RESOURCE EVALUATIONS 

A total of two cultural resources were encountered during the cultural resource investigation of the project 

area conducted by Laguna Environmental. Both resources are isolated flakes of Santiago Peak volcanic 

stoneand are designated SPP-I-1 and SPP-I-2. Descriptions of the artifacts can be found in the above 

referenced cultural resource study (Laguna Mountain Environmental, 2009). 

SPP-I-1

SPP-I-1 is an isolated flake made from Santiago Peak volcanic stone that dates to the prehistoric period.

Criteria A, B, and C are applicable primarily to cultural resources that date to the historical period. 

Criterion D addressed the data potential of the cultural resource; this criterion is applies to archaeological 

resources. 
August 2010 2 San Pasqual Band Fee-to-Trust and Retail Plaza Project 

Cultural Resources Addendum

SPP-I-1 is not associated with the broad patterns of our history and therefore is considered ineligible for 

inclusion under Criterion A of the NRHP. SPP-I-1 is not affiliated with the life of a person important to 

our past and, therefore, is not eligible for inclusion under Criterion B of the NRHP. SPP-I-1 does not 

represent the work of a master, possess high artistic qualities and/or embody distinctive characteristics of 

a period and therefore it is not eligible for inclusion on the NRHP under Criterion C. 

SPP-I-1 does not have the potential to yield important information regarding the prehistoric occupation of 

San Diego County. The flake does not possess any diagnostic features that would allow it to be identified 

as a specific type associated with a particular time period. The flake is manufactured of Santiago Peak 

Volcanic which is not a datable material. As such, a determination in regards to the age of the flake 

cannot be made. Also, the deposition of the artifact does not suggest it is associated with an intact buried 

cultural deposit. The artifact was encountered on the ground surface in an area that had been previously 

disturbed by the installation of utilities and construction of the parking area. Recordation has exhausted 

the data potential for this flake and it is not eligible for inclusion on the NRHP under Criterion D. 

SPP-I-2

SPP-I-2 is an isolated flake made from Santiago Peak volcanic stone that dates to the prehistoric period.

SPP-I-2 is not associated with the broad patterns of our history and is not eligible for inclusion under 

Criterion A of the NRHP. SPP-I-2 is not connected with the life of a person important to our past and is 

ineligible for inclusion under Criterion B of the NRHP. The flake does not represent the work of a 

master, possess artistic qualities and/or embody distinctive characteristics of a period and so it is not 

eligible for inclusion on the NRHP under Criteria C. 

SPP-I-2 does not have the potential to yield important information regarding the occupation of San Diego 

County. The flake does not exhibit temporally diagnostic features, nor was it manufactured from a 

datable material. The flake was recovered from the ground surface indicating that it is not associated with 

an intact subsurface cultural deposit. Recordation of the flake has exhausted the data potential of this 

flake and thus it is considered ineligible for listing on the NRHP under Criterion D. 

3.0 FINDINGS 

Two cultural resources, both described as isolated flakes (SPP-I-1 and SPP-I-2), were identified within 

the APE. Both cultural resources were evaluated and found ineligible for inclusion on the NRHP, which 

is consistent with the findings of the original Cultural Resources Study conducted by Laguna Mountain 

Environmental. SHPO concurrence on the results of the original cultural resources study was provided in 

a letter dated on February 22, 2010. Thus, the Section 106 of NHPA process is complete and no 

additional consultation with the SHPO is required. 
August 2010 3 San Pasqual Band Fee-to-Trust and Retail Plaza Project 

Cultural Resources Addendum

4.0 ADDITONAL REFERENCES 

AES

2010 Final Environmental Assessment, San Pasqual 9-Acre Fee-to-Trust and Retail Plaza Project, San 

Diego County, CA. Submitted to the San Pasqual Band of Band of Mission Indians, San Diego 

County, Ca. 

Laguna Mountain Environmental, Inc. 

2009 Cultural Resource Inventory of a 9-acre parcel (APN#189-05-102) for the San Pasqual Fee-toTrust and Tribal Improvement Project, San Pasqual, County of San Diego, California.

Submitted to Environet, Inc., Honolulu, Hawaii. 

National Park Service 

1990 National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation. 

Published 1990, revised for Internet 2002. Available online at: 

http://www.cr.nps.gov/nr/publications/bulletins/nrb15/. Site accessed August 2010. 
State of California  The Resources Agency Primary # 

DEPARTMENT OF PARKS AND RECREATION HRI# 

CONTINUATION SHEET Trinomial 

Page 1 of 1 *Resource Name or # (Assigned by recorder) SPP-I-1 (Temporary Number)

*Recorded by: M. McCrary, AES 1801 7th St., Ste. 100, Sacramento 95811 *Date:  Continuation Update 

Resource Description: 

This resource (SPP-I-1), described as an isolated flake, was identified and recorded as part of the San Pasqual 9-acre 

Fee-to-Trust and Retail Plaza Project, San Diego County, CA. Evaluations per the criteria of the National Register of 

Historical Places were completed at the request of San Diego County. This purpose of this update is to include the 

register evaluation as part of the resource record.

Resource Evaluation 

SPP-I-1 is not associated with the broad patterns of our history and therefore is considered ineligible for inclusion 

under Criterion A of the NRHP. SPP-I-1 is not affiliated with the life of a person important to our past and, therefore, 

is not eligible for inclusion under Criterion B of the NRHP. SPP-I-1 does not represent the work of a master, possess 

high artistic qualities and/or embody distinctive characteristics of a period and therefore it is not eligible for inclusion 

on the NRHP under Criterion C.

SPP-I-1 does not have the potential to yield important information regarding the prehistoric occupation of San Diego 

County. The flake does not possess any diagnostic features that would allow it to be identified as a specific type 

associated with a particular time period. The flake is manufactured of Santiago Peak volcanic stone, which is not a 

datable material. As such, a determination in regards to the age of the flake cannot be made. Also, the deposition of 

the artifact does not suggest it is associated with an intact buried cultural deposit. The artifact was encountered on the 

ground surface in an area that had been previously disturbed by the installation of utilities and construction of the 

parking area. Recordation has exhausted the data potential for this flake and it is not eligible for inclusion on the 

NRHP under Criterion D.

References:

AES

2010 Final Environmental Assessment, San Pasqual 9-Acre Fee-to-Trust and Retail Plaza Project, San Diego 

County, CA. Submitted to the San Pasqual Band of Band of Mission Indians, San Diego County, Ca. 

AES

2010 Cultural Resources Addendum, San Pasqual 9-Acre Fee-to-Trust and Retail Plaza Project, San Diego 

County, CA. Submitted to the San Pasqual Band of Band of Mission Indians, San Diego County, Ca. 

Laguna Mountain Environmental, Inc. 

2009 Cultural Resource Inventory of a 9-acre parcel (APN#189-05-102) for the San Pasqual Fee-to-Trust and 

Tribal Improvement Project, San Pasqual, County of San Diego, California. Submitted to Environet, Inc., 

Honolulu, Hawaii.

DPR 523L (1/95) *Required information 
State of California  The Resources Agency Primary # 

DEPARTMENT OF PARKS AND RECREATION HRI# 

CONTINUATION SHEET Trinomial 

Page 1 of 1 *Resource Name or # (Assigned by recorder) SPP-I-2 (Temporary Number)

*Recorded by: M. McCrary, AES 1801 7th St., Ste. 100, Sacramento 95811 *Date:  Continuation Update 

Resource Description:

This resource (SPP-I-2), described as an isolated flake, was identified and recorded as part of the San Pasqual 9-acre 

Fee-to-Trust and Retail Plaza Project, San Diego County, CA. Evaluations per the criteria of the National Register of 

Historical Places were completed at the request of San Diego County. This purpose of this update is to include the 

register evaluation as part of the resource record.

Resource Evaluation

SPP-I-2 is an isolated flake made from Santiago Peak volcanic stone that dates to the prehistoric period. 

SPP-I-2 is not associated with the broad patterns of our history and is not eligible for inclusion under 

Criterion A of the NRHP. SPP-I-2 is not connected with the life of a person important to our past and is 

ineligible for inclusion under Criterion B of the NRHP. The flake does not represent the work of a master, 

possess artistic qualities and/or embody distinctive characteristics of a period and so it is not eligible for 

inclusion on the NRHP under Criteria C.

SPP-I-2 does not have the potential to yield important information regarding the occupation of San Diego 

County. The flake does not exhibit temporally diagnostic features, nor was it manufactured from a datable 

material. The flake was recovered alone from the ground surface indicating that it is not associated with an 

intact subsurface cultural deposit. Recordation of the flake has exhausted the data potential of this flake and 

thus it is considered ineligible for listing on the NRHP under Criterion D.

References:

AES

2010 Final Environmental Assessment, San Pasqual 9-Acre Fee-to-Trust and Retail Plaza Project, San Diego 

County, CA. Submitted to the San Pasqual Band of Band of Mission Indians, San Diego County, Ca. 

AES

2010 Cultural Resources Addendum, San Pasqual 9-Acre Fee-to-Trust and Retail Plaza Project, San Diego 

County, CA. Submitted to the San Pasqual Band of Band of Mission Indians, San Diego County, Ca. 

Laguna Mountain Environmental, Inc. 

2009 Cultural Resource Inventory of a 9-acre parcel (APN#189-05-102) for the San Pasqual Fee-to-Trust and 

Tribal Improvement Project, San Pasqual, County of San Diego, California. Submitted to Environet, Inc., 

Honolulu, Hawaii.

DPR 523L (1/95) *Required information 
Appendix H Traffic Impact Analysis 
TRAFFIC IMPACT ANALYSIS

SAN PASQUAL 9-ACRE FEE-TO-TRUST &

RETAIL PLAZA PROJECT

County of San Diego, California 

August 5, 2010

LLG Ref. 3-10-1972 

Prepared by: Under the Supervision of:

 Cara Leone John Boarman, P.E. 

Transportation Planner II Principal 
LINSCOTT, LAW & GREENSPAN, engineers LLG Ref. 3-10-1972 

San Pasqual 9-Acre Fee-to-Trust & Retail Plaza Project 

N:\1972\Text\1972.9-Acre Report.Clean.doc

i

TABLE OF CONTENTS

SECTION PAGE

1.0 Introduction ................................................................................................................................ 1

2.0 Project Description .................................................................................................................... 2

2.1 Project Location .................................................................................................................. 2

2.2 Project Description .............................................................................................................. 2

2.3 Project Access ..................................................................................................................... 2

3.0 Existing Conditions .................................................................................................................... 7

3.1 Study Area .......................................................................................................................... 7

3.2 Existing Street Network ...................................................................................................... 8

3.3 Existing Traffic Volumes .................................................................................................... 9

4.0 Analysis Approach and Methodology .................................................................................... 12

4.1 Intersections ...................................................................................................................... 12

4.2 Street Segments ................................................................................................................. 12

5.0 Significance Criteria ................................................................................................................ 13

5.1 Road Segments .................................................................................................................. 13

5.2 Intersections ...................................................................................................................... 15

6.0 Analysis of Existing Conditions .............................................................................................. 17

6.1 Peak Hour Intersection Levels of Service ......................................................................... 17

6.2 Daily Street Segment Levels of Service ........................................................................... 18

7.0 Trip Generation/Distribution/Assignment ............................................................................ 19

7.1 Trip Generation ................................................................................................................. 19

7.2 Trip Distribution/Assignment ........................................................................................... 19

8.0 Analysis of Project Impacts ..................................................................................................... 24

8.1 Existing + Project Operations ........................................................................................... 24

8.1.1 Intersection Analysis ............................................................................................. 24

8.1.2 Segment Operations .............................................................................................. 24

8.2 Year 2030 (With Project) Operations ............................................................................... 24

8.2.1 Forecast Volumes.................................................................................................. 24

8.2.2 Intersection Analysis ............................................................................................. 24

8.2.3 Segment Operations .............................................................................................. 25

9.0 Congestion Management Program Compliance ................................................................... 29

10.0 Access and Other Issues .......................................................................................................... 30
LINSCOTT, LAW & GREENSPAN, engineers LLG Ref. 3-10-1972 

San Pasqual 9-Acre Fee-to-Trust & Retail Plaza Project 

N:\1972\Text\1972.9-Acre Report.Clean.doc

ii

10.1 Project Access ................................................................................................................... 30

10.2 Site Plan Assessment ........................................................................................................ 31

11.0 Impact Summary ..................................................................................................................... 33

11.1 Significance of Impacts..................................................................................................... 33

11.2 Mitigation Measures ......................................................................................................... 33

APPENDICES

APPENDIX 

A. Intersection and Segment Manual Count Sheets 

B. County of San Diego Roadway Classification Table 

C. Existing Intersection Analysis Worksheets 

D. Existing + Project Intersection Analysis Worksheets 

E. Year 2030 (With Project) Intersection Analysis Worksheets 
LINSCOTT, LAW & GREENSPAN, engineers LLG Ref. 3-10-1972 

San Pasqual 9-Acre Fee-to-Trust & Retail Plaza Project 

N:\1972\Text\1972.9-Acre Report.Clean.doc

iii

LIST OF FIGURES 

SECTION—FIGURE # PAGE

Figure 2–1 Vicinity Map ................................................................................................................. 4

Figure 2–2 Project Area Map .......................................................................................................... 5

Figure 2–3 Site Plan ........................................................................................................................ 6

Figure 3–1 Existing Conditions Diagram ...................................................................................... 10

Figure 3–2 Existing Traffic Volumes ............................................................................................ 11

Figure 7–1 Project Traffic Distribution ......................................................................................... 21

Figure 7–2 Project Traffic Volumes .............................................................................................. 22

Figure 7–3 Existing + Project Traffic Volumes ............................................................................ 23

Figure 8–1 Year 2030 (With Project) Traffic Volumes ................................................................ 28

Figure 10–1 Project Access Recommendations .............................................................................. 32

LIST OF TABLES

SECTION—TABLE # PAGE

Table 3–1 Existing Traffic Volumes .............................................................................................. 9

Table 5–1 Measures of Significant Project Impacts to Congestion on Circulation Element Road 

Segments Allowable Increases on Congested Road Segments ................................... 13

Table 5–2 Measures of Significant Project Impacts to Congestion on Intersections Allowable 

Increases on Congested Intersections ......................................................................... 16

Table 6–1 Existing Intersection Operations ................................................................................. 17

Table 6–2 Existing Street Segment Operations ........................................................................... 18

Table 7–1 Project Trip Generation ............................................................................................... 20

Table 8–1 Intersection Operations ............................................................................................... 26

Table 8–2 Street Segment Operations .......................................................................................... 27
LINSCOTT, LAW & GREENSPAN, engineers LLG Ref. 3-10-1972 

San Pasqual 9-Acre Fee-to-Trust & Retail Plaza Project 

N:\1972\Text\1972.9-Acre Report.Clean.doc

1

TRAFFIC IMPACT ANALYSIS

9-ACRE SAN PASQUAL PROJECT

County of San Diego, California 

August 5, 2010

1.0 INTRODUCTION

Linscott, Law, & Greenspan, Engineers (LLG) has been retained to prepare a traffic study for the 9-

Acre San Pasqual project located just north of the San Pasqual Band of Mission Indians Reservation. 

The Reservation is located approximately 11 miles northeast of Escondido in San Diego County, 

California. The purpose of this study is to assess the potential impacts to the local circulation system 

as a result of the proposed project. 

The project proposes to develop a 9-acre site to provide a gas station, drive-through restaurant, and a 

strip commercial/retail development. It also includes the relocation of an existing surface parking lot 

currently occupying the project site to the westerly adjacent parcel. A more detailed project 

description is presented in Section 2.0 of this report. 

The traffic analysis presented in this report includes the following: 

 Project Description 

 Existing Conditions Description 

 Analysis Approach and Methodology 

 Significance Criteria 

 Analysis of Existing Conditions 

 Trip Generation/Distribution/Assignment 

 Analysis of Potential Project Impacts 

 Congestion Management Compliance 

 Project Access Review 

 Summary and Conclusions 
LINSCOTT, LAW & GREENSPAN, engineers LLG Ref. 3-10-1972 

San Pasqual 9-Acre Fee-to-Trust & Retail Plaza Project 

N:\1972\Text\1972.9-Acre Report.Clean.doc

2

2.0 PROJECT DESCRIPTION

The following is a brief description of the project location, as well as operational characteristics that 

affect project traffic generation and regional distribution. 

2.1 Project Location 

The project is located just north of the San Pasqual Indian Reservation in the Community of Valley 

Center in the County of San Diego. The site is located on the southwest corner of the Valley Center 

Road/ Lake Wohlford Road (N.) intersection. 

Figure 2–1 shows the project vicinity, and Figure 2–2 is a more detailed project area map. 

2.2 Project Description 

The San Pasqual Band of Mission Indians proposes to develop a 9-acre site to provide a gas station, 

a restaurant, and a strip commercial/retail development. Additionally, the project proposes the 

relocation of an existing surface parking lot currently occupying the project site to the westerly 

adjacent parcel. 

Figure 2–3 shows the preliminary conceptual site plan. 

2.3 Project Access 

Access to the commercial portion of the project is proposed via an existing driveway on Valley 

Center Road at School Bus Road and at a proposed driveway along Lake Wohlford Road (N.). The 

Valley Center Road driveway will be full access and the driveway located on Lake Wohlford Road 

(N.) will be restricted to right-in/right-out only movements. A more detailed discussion of the project 

access is located in Section 10.0 of the report. 

Currently, school buses, shuttle buses and casino employee private vehicles utilize the Valley Center 

Road/ School Bus Road intersection. With the relocation of the existing surface parking lot, the 

Valley Center Road/ School Bus Road intersection is proposed to be relocated to the west of its 

current location. The existing Valley Center Road/ School Bus Road intersection will be modified to 

become the major access point to the site and is termed “Street A” in this study. The following is a 

detailed discussion of the existing and proposed access for these existing trips. 

Existing 

School buses currently use School Bus Road to drop-off students in the morning and pick them up in 

the afternoon on weekdays during the school year. The buses enter School Bus Road from Valley 

Center Road, pick-up and drop-off students at the sidewalk along the south side of the road within 

the west-to-east section of the School Bus Road, and exit onto Lake Wohlford Road (N.). 

Shuttle buses are currently used to transport casino employees. The shuttle buses make a right-turn 

onto School Bus Road (two-way portion) from Valley Center Road, make a left-turn into the existing 

parking lot, load or unload the employees at the shelters within the existing parking lot, return to 
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School Bus Road where they make a right-turn to exit the lot, and lastly turn right at Valley Center 

Road and head east toward Lake Wohlford Road (N.) where they make a right-turn to travel south 

toward the casino. It should be noted that the shuttle buses only utilize a short segment of School 

Bus Road (two-way portion) to ingress the parking lot. No left turns exiting the parking lot onto 

School Bus Road are allowed. 

Private vehicles driven by casino employees enter the parking lot from Valley Center Road by 

turning onto School Bus Road (two-way portion), and then make a left-turn into the existing parking 

lot. Vehicles exiting the parking lot make a right-turn onto School Bus Road and continue onto 

Valley Center Road to reach their destination. No left turns exiting the parking lot onto School Bus 

Road are allowed. 

With School Bus Road Realignment and Parking Relocation 

School buses will use the relocated School Bus Road. The buses will continue to enter School Bus 

Road from Valley Center Road and exit onto Lake Wohlford Road (N.). However, there will no 

longer be a portion of School Bus Road that operates as a two-lane roadway. 

Shuttle buses will continue to transport casino employees from Valley Center Road, however, they 

will no longer access School Bus Road and will instead utilize the project access (Street “A”) located 

along Valley Center Road. From the project access, they will now turn right into the relocated 

parking lot where they will load or unload the employees at the shuttle stops and then return to the 

project access where they make a left-turn to exit the lot, and lastly turn right at Valley Center Road 

and head east toward Lake Wohlford Road (N.) where they make right-turn to travel south toward 

the casino. 

Private vehicles driven by casino employees will enter the relocated parking lot from Valley Center 

Road, however they will no longer access School Bus Road and will instead utilize the project 

access (Street “A”) located along Valley Center Road. From the project access, they will now turn 

right into the relocated parking lot. Vehicles will now make a left-turn to exit the relocated parking 

lot and continue onto Valley Center Road to reach their destination. 



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3.0 EXISTING CONDITIONS

3.1 Study Area 

The study area was based on the criteria identified in the County of San Diego’s Report Format & 

Content Requirements: Transportation & Traffic, First Modification February 19, 2010. Based on 

the County’s criteria, “the scope of the full direct and cumulative traffic assessment shall include 

those roads and intersections that will receive 25 peak hour trips (2-way peak hour total).” Based on 

this criteria, the following intersections and segments included in the study area are listed below. 

Intersections: 

 Valley Center Road / Cole Grade Road 

 Valley Center Road / Lake Wohlford Road (N.) 

 Lake Wohlford Road (N.) / School Bus Road 

 Lake Wohlford Road (N.) / Woods Valley Road 

 Valley Center Road / Lilac Road 

 Valley Center Road / Woods Valley Road 

Segments 

Valley Center Road 

 Lake Wohlford Road to Cole Grade Road 

 Cole Grade Road to Lilac Road 

 Lilac Road to Woods Valley Road 

 Woods Valley Road to Lake Wohlford Road (S.) 

Lake Wohlford Road (N.) 

 Valley Center Road to Woods Valley Road 

 Woods Valley Road to Guejito Road 

Woods Valley Road 

 Valley Center Road to Lake Wohlford Road (N.) 

Cole Grade Road 

 Valley Center Road to Fruitvale Road 

The following is a discussion of the key roadways analyzed in the study area. The existing traffic 

data collection is also described in detail. 

Figure 3–1 depicts the existing conditions and geometry of the driveways and study area 

intersections. 
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3.2 Existing Street Network

Valley Center Road is classified on the Adopted County of San Diego Circulation Element as a 

Prime Arterial west/south of Cole Grade Road and as a Collector east/north of Cole Grade Road. On 

the General Plan (GP) Update, Valley Center Road is classified as a 4.1A Major Road Series from 

Woods Valley Road to Lilac Road, a 4.2A Boulevard Series from Lilac Road to Miller Road, a 4.2A 

Boulevard Sereies from Miller Road to Vesper Road and a 2.1D Community Collector Series from 

Vesper Road to Lake Wohlford Road. From north of Lake Wohlford Road (S.) to Cole Grade Road, 

Valley Center Road has recently been widened to major road standards (four-lane divided roadway 

with bike lanes). East of Cole Grade Road, Valley Center Road becomes a two-lane undivided 

roadway. Beginning at Sunset Road, Valley Center Road provides a two-way left-turn lane 

(TWLTL) continuing to Lake Wohlford Road (N.). The posted speed limit ranges from 45 to 60 mph 

with bus stops provided. Bike lanes are provided and curbside parking is prohibited for the entirety 

of the roadway. 

Lake Wohlford Road (North) is classified on the Adopted County of San Diego Circulation 

Element as a Collector. On the GP Update, Lake Wohlford Road (N.) is classified as a 2.2C Light 

Collector. Lake Wohlford Road (N.) is currently constructed as a two-lane undivided roadway. The 

posted speed limit within the project area varies between 45 to 50 mph. Curbside parking is 

generally prohibited, and no bike lanes or bus stops are provided. 

Woods Valley Road is classified on the Adopted County of San Diego Circulation Element as a 

Rural Collector. On the GP Update, Woods Valley Road is classified as a 2.2C Light Collector 

Series from Lake Wohlford Road to Oakmont Road and a 2.1D Community Collector Series from 

Oakmont Road to Valley Center Road. Woods Valley Road is currently constructed as a two-lane 

undivided roadway. Curb, gutter and sidewalks are not provided. The posted speed limit ranges 

from 40 to 45 mph in the project vicinity. 

Cole Grade Road is classified on the Adopted County of San Diego Circulation Element as a 

Collector. On the GP Update, Cole Grade Road is classified as a 4.2A Boulevard Series from Valley 

Center Road to Horse Creek Road. It is currently constructed as a two-lane road with a TWLTL 

within the study area. Curb and gutter are provided and sidewalks are not provided. The posted 

speed limit ranges from 45 to 50 mph. 

Lilac Road is classified on the Adopted County of San Diego Circulation Element as a Collector. 

On the GP Update, Lilac Road is classified as a 4.2A Boulevard Series from Valley Center Road to 

Betsworth Road. It is currently constructed as a two-lane undivided road. Curb, gutter and sidewalks 

are not provided. The posted speed limit ranges from 45 to 50 mph in the project vicinity. 

School Bus Road is an unclassified private roadway. It currently operates primarily as a one-way 

roadway with vehicles entering from Valley Center Road and exiting at Lake Wohlford Road (N.). 

Currently, school buses, casino shuttle buses and private vehicles driven by casino employees utilize 

School Bus Road. A small portion of School Bus Road between Valley Center Road and the parking 

lot driveway operates as a two-way roadway used for private casino employee vehicles and shuttle 
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service. The remainder of the roadway operates one-way and serves as a student pick-up zone for the 

middle school. 

3.3 Existing Traffic Volumes 

Peak hour intersection turning movement traffic counts and segment counts within the project area 

were conducted by LLG in July 2009 and July 2010. Traffic counts were conducted between 7:00 

AM and 9:00 AM and the highest hour of traffic within this period was utilized. Similarly, the 

highest hour of traffic between 4:00 PM and 6:00 PM was used in the analysis. Since school was not 

in session during the time of data collection, a 5% growth factor was used to forecast non-summer 

counts. This rate is based on a comparison of previous non-summer counts collected in the general 

vicinity of the project area to the data collected in July 2010. 

Table 3–1 is a summary of the most recent available average daily traffic volumes (ADTs). Figure 

3–2 shows the existing traffic volumes. Appendix A contains the manual count sheets. 

TABLE 3–1 

EXISTING TRAFFIC VOLUMES

Street Segment ADTa

Valley Center Road 

Lake Wohlford Road (N.) to Cole Grade Road 11,180 

Cole Grade Road to Lilac Road 22,910 

Lilac Road to Woods Valley Road 24,100 

Woods Valley Road to Lake Wohlford Road (S.) 24,930 

Lake Wohlford Road (N.) 

Valley Center Road to Woods Valley Road 9,420 

Woods Valley Road to Guejito Road 5,970 

Woods Valley Road 

Valley Center Road to Lake Wohlford Road (N.) 2,450 

Cole Grade Road 

Valley Center Road to Fruitvale Road 12,230 

Footnotes: 

a. Average Daily Traffic Volumes.


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4.0 ANALYSIS APPROACH AND METHODOLOGY

Level of service (LOS) is the term used to denote the different operating conditions which occur on a 

given roadway segment under various traffic volume loads. It is a qualitative measure used to 

describe a quantitative analysis taking into account factors such as roadway geometries, signal 

phasing, speed, travel delay, freedom to maneuver, and safety. Level of service provides an index to 

the operational qualities of a roadway segment or an intersection. Level of service designations 

range from A to F, with LOS A representing the best operating conditions and LOS F representing 

the worst operating conditions. Level of service designation is reported differently for signalized and 

unsignalized intersections, as well as for roadway segments. 

4.1 Intersections 

Signalized intersections were analyzed under AM and PM peak hour conditions. Average vehicle 

delay was determined utilizing the methodology found in Chapter 16 of the 2000 Highway Capacity 

Manual (HCM), with the assistance of the Traffix (version 8.0) computer software. The delay values 

(represented in seconds) were qualified with a corresponding intersection Level of Service (LOS). 

Unsignalized intersections were analyzed under AM and PM peak hour conditions. Average vehicle 

delay and Levels of Service (LOS) was determined based upon the procedures found in Chapter 17 

of the 2000 Highway Capacity Manual (HCM), with the assistance of the Traffix (version 8.0) 

computer software 

4.2 Street Segments 

Street segment analysis is based upon the comparison of daily traffic volumes (ADTs) to the County 

of San Diego’s Roadway Classification, Level of Service, and ADT Table. This table provides 

segment capacities for different street classifications, based on traffic volumes and roadway 

characteristics. The County of San Diego’s Roadway Classification, Level of Service, and ADT 

Table is attached in Appendix B. 
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5.0 SIGNIFICANCE CRITERIA

For the purpose of this traffic study, the following criterion was utilized to evaluate potential 

significant impacts and is based on the County’s documents “Guidelines for Determining 

Significance”, effective June 30, 2009 with a first modification effective February 19, 2010. 

5.1 Road Segments 

Pursuant to the County’s General Plan Public Facilities Element (PFE), new development must 

provide improvements or other measures to mitigate traffic impacts to avoid: 

a. Reduction in Level of Service (LOS) below "C" for on-site Circulation Element roads; 

b. Reduction in LOS below "D" for off-site and on-site abutting Circulation Element roads; and 

c. "Significantly impacting congestion" on roads that operate at LOS "E" or "F". If impacts 

cannot be mitigated, the project cannot be approved unless a statement of overriding findings 

is made pursuant to the State CEQA Guidelines. The PFE, however, does not include specific 

guidelines for determining the amount of additional traffic that would “significantly impact 

congestion” on such roads. 

The County has created the following guidelines to evaluate likely traffic impacts of a proposed 

project for road segments and intersections serving that project site, for purposes of determining 

whether the development would "significantly impact congestion" on the referenced LOS E and F 

roads. The guidelines are summarized in Table 5–1. The thresholds in Table 5–1 are based upon 

average operating conditions on County roadways. It should be noted that these thresholds only 

establish general guidelines, and that the specific project location must be taken into account in 

conducting an analysis of traffic impact from new development. 

TABLE 5–1 

MEASURES OF SIGNIFICANT PROJECT IMPACTS TO CONGESTION ON CIRCULATION ELEMENT 

ROAD SEGMENTS ALLOWABLE INCREASES ON CONGESTED ROAD SEGMENTS

Level of Service Two-Lane Road Four-Lane Road Six-Lane Road 

LOS E 200 ADT 400 ADT 600 ADT 

LOS F 100 ADT 200 ADT 300 ADT 

General Notes: 

1. By adding proposed project trips to all other trips from a list of projects, this same table must be used to determine if total 

cumulative impacts are significant. If cumulative impacts are found to be significant, each project that contributes additional trips 

must mitigate a share of the cumulative impacts. 

2. The County may also determine impacts have occurred on roads even when a project’s traffic or cumulative impacts do not trigger 

an unacceptable level of service, when such traffic uses a significant amount of remaining road capacity.
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On-site Circulation Element Roads—PFE, Transportation, Policy 1.1 states that “new development 

shall provide needed roadway expansion and improvements on-site to meet demand created by the 

development, and to maintain a Level of Service C on Circulation Element Roads during peak traffic 

hours”. Pursuant to this policy, a significant traffic impact would result if: 

 The additional or redistributed ADT generated by the proposed land development project 

will cause on-site Circulation Element Roads to operate below LOS C during peak traffic 

hours during peak traffic hours except within the Otay Ranch and Harmony Grove 

Village plans as specified in the PFE, Implementation Measure 1.1.2. 

Off-Site Circulation Element Roads—PFE, Transportation, Policy 1.1 also states that “new 

development shall provide off-site improvements designed to contribute to the overall achievement 

of a Level of Service D on Circulation Element Roads.” Implementation Measure 1.1.3 addressed 

projects that would significantly impact congestion on roads operating at LOS E or F. It states, “new 

development that would significantly impact congestion on roads operating at LOS E or F, either 

currently or as a result of the project, will be denied unless improvements are scheduled to attain an 

LOS to D or better or appropriate mitigation is provided.” The following significance guidelines 

define a method for evaluating whether or not increased traffic volumes generated or redistributed 

from a proposed project will “significantly impact congestion” on County roads, operating at LOS E 

or F, either currently or as a result of the project. 

Traffic volume increases from public or private projects that result in one or more of the following 

criteria will have a significant traffic volume or level of service impact on a road segment: 

 The additional or redistributed ADT generated by the proposed project will significantly 

increase congestion on a Circulation Element Road or State Highway currently operating 

at LOS E or LOS F, or will cause a Circulation Element Road or State Highway to 

operate at a LOS E or LOS F as a result of the proposed project as identified in Table 5–

1, or 

 The additional or redistributed ADT generated by the proposed project will cause a 

residential street to exceed its design capacity. 
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5.2 Intersections 

This section provides guidance for evaluating adverse environmental effects a project may have on 

signalized and unsignalized intersections. Table 5–2 summarizes significant project impacts for 

signalized and unsignalized intersections. 

Signalized Intersections—Traffic volume increases from public or private projects that result in one 

or more of the following criteria will have a significant traffic volume or level of service traffic 

impact on a signalized intersection: 

 The additional or redistributed ADT generated by the proposed project will significantly 

increase congestion on a signalized intersection currently operating at LOS E or LOS F, 

or will cause a signalized intersection to operate at a LOS E or LOS F as identified in 

Table 5–2. 

 Based upon an evaluation of existing accident rates, the signal priority list, intersection 

geometrics, proximity of adjacent driveways, sight distance or other factors, the project 

would significantly impact the operation of the intersection. 

Unsignalized Intersections—The operating parameters and conditions for unsignalized intersections 

differ dramatically from those of signalized intersections. Very small volume increases on one leg or 

turn and/or through movement of an unsignalized intersection can substantially affect the calculated 

delay for the entire intersection. Significance criteria for unsignalized intersections are based upon a 

minimum number of trips added to a critical movement at an unsignalized intersection. 

Traffic volume increases from public or private projects that result in one or more of the following 

criteria will have a significant traffic impact on an unsignalized intersection as listed in Table 5–2

and described as text below: 

 The additional or redistributed ADT generated by the proposed project will add 21 or 

more peak hour trips to a critical movement of an unsignalized intersection, and cause an 

unsignalized intersection to operate below LOS D, or 

 The additional or redistributed ADT generated by the proposed project will add 21 or 

more peak hour trips to a critical movement of an unsignalized intersection currently 

operating at LOS E, or 

 The additional or redistributed ADT generated by the proposed project will add 6 or more 

peak hour trips to a critical movement of an unsignalized intersection, and cause the 

unsignalized intersection to operate at LOS F, or 

 The additional or redistributed ADT generated by the proposed project will add 6 or more 

peak hour trips to a critical movement of an unsignalized intersection currently operating 

at LOS F, or 

 Based upon an evaluation of existing accident rates, the signal priority list, intersection 

geometrics, proximity of adjacent driveways, sight distance or other factors, it is found 

that the generation rate is less than those specified above, and would significantly impact 

the operations of the intersection. 
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TABLE 5–2 

MEASURES OF SIGNIFICANT PROJECT IMPACTS TO CONGESTION ON INTERSECTIONS

ALLOWABLE INCREASES ON CONGESTED INTERSECTIONS

Level of service Signalized Unsignalized 

LOS E Delay of 2 seconds or less 20 or less peak hour trips on a critical 

movement 

LOS F Delay of 1 second, or 5 or less peak hour 

trips on a critical movement 

5 or less peak hour trips on a critical 

movement 

General Notes: 

1. A critical movement is an intersection movement (right-turn, left-turn, through-movement) that experiences excessive queues,

which typically operate at LOS F. 

2. By adding proposed project trips to all other trips from a list of projects, these same tables are used to determine if total 

cumulative impacts are significant. If cumulative impacts are found to be significant, each project that contributes any trips must 

mitigate a share of the cumulative impacts. 

3. The County may also determine impacts have occurred on roads even when a project’s traffic or cumulative impacts do not 

trigger an unacceptable level of service, when such traffic uses a significant amount of remaining road capacity. 

4. For determining significance at signalized intersections with LOS F conditions, the analysis must evaluate both the delay and the 

number of trips on a critical movement, exceedance of either criteria result in a significant impact. 
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SIGNALIZED UNSIGNALIZED 

DELAY/LOS THRESHOLDS DELAY/LOS THRESHOLDS

Delay LOS Delay LOS 

0.0 < 10.0 A 0.0 < 10.0 A 

10.1 to 20.0 B 10.1 to 15.0 B 

20.1 to 35.0 C 15.1 to 25.0 C 

35.1 to 55.0 D 25.1 to 35.0 D 

55.1 to 80.0 E 35.1 to 50.0 E 

 > 80.1 F > 50.1 F 

6.0 ANALYSIS OF EXISTING CONDITIONS

The analysis of existing conditions includes the assessment of the study area intersection and street 

segments. 

6.1 Peak Hour Intersection Levels of Service 

Table 6–1 summarizes the existing intersection levels of service. As seen in Table 6–1, all 

intersections are calculated to operate at LOS C or better during both the AM and PM peak hours. 

Appendix C contains the existing intersection analysis worksheets. 

TABLE 6–1 

EXISTING INTERSECTION OPERATIONS

Intersection Control 

Type 

Peak 

Hour 

Existing 

Delaya LOSb

 

1. Valley Center Road/ Cole Grade Road Signal AM 32.2 C 

PM 32.9 C 

 

2. Valley Center Road/ School Bus Road TWSC c AM 20.3 C 

PM 13.1 B 

 

3. Valley Center Road/ Lake Wohlford Road (N.) Signal AM 23.3 C 

PM 26.0 C 

 

4. Lake Wohlford Road (N.)/ School Bus Road TWSC AM 14.6 B 

PM 10.2 B 

 

5. Lake Wohlford Road (N.)/ Woods Valley Road AWSC d AM 11.1 B 

PM 10.7 B 

 

6. Lake Wohlford Road (N.)/ Project Access TWSC AM DNE DNE 

PM DNE DNE 

 

7. Valley Center Road/ Lilac Road Signal AM 14.9 B 

PM 13.7 B 

 

8. Valley Center Road/ Woods Valley Road Signal AM 16.1 B 

PM 17.7 B 

Footnotes: 

a. Average delay expressed in seconds per vehicle. 

b. Level of Service. 

c. TWSC – Two-Way Stop Controlled intersection. 

d. AWSC – All-Way Stop Controlled intersection. 
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6.2 Daily Street Segment Levels of Service 

Table 6–2 summarizes the existing roadway segment level of service. As seen in Table 6–2, the 

segments are calculated to currently operate at LOS D or better except for the Valley Center Road 

segment between Lake Wohlford Road (N.) and Cole Grade Road which currently operates at LOS 

E. 

TABLE 6–2 

EXISTING STREET SEGMENT OPERATIONS

Street Segment Functional 

Classification 

Capacity 

(LOS E) a ADT b

 LOS c

Valley Center Road 

Lake Wohlford Road (N.) to Cole 

Grade Road Rural Collector 16,200 11,180 E 

Cole Grade Road to Lilac Road Major Road 37,000 22,910 B 

Lilac Road to Woods Valley Road Major Road 37,000 24,100 B 

Woods Valley Road to Lake Wohlford 

Road (S.) Major Road 37,000 24,930 C 

Lake Wohlford Road (N.) 

Valley Center Road to Woods Valley 

Road Rural Collector 16,200 9,420 D 

Woods Valley Road to Guejito Road Rural Collector 16,200 5,970 C 

Woods Valley Road 

Valley Center Road to Lake Wohlford 

Road (N.) Rural Collector 16,200 2,450 B 

Cole Grade Road 

Valley Center Road to Fruitvale Road Town Collector 19,000 12,230 D 

Footnotes: 

a. Capacities based on County of San Diego Roadway Classification Table. 

b. Average Daily Traffic Volumes. 

c. Level of Service. 
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7.0 TRIP GENERATION/DISTRIBUTION/ASSIGNMENT

Based on the preliminary conceptual site plan, the proposed project consists of specialty retail/strip 

commercial, restaurant, and gas station land uses. It also includes the relocation of an existing 

surface parking lot currently occupying the project site to the westerly adjacent parcel. It is expected 

that many of the trips will be trips not new to the street system, but instead captured from trips 

already on the system. These trips are termed “pass-by” trips. 

7.1 Trip Generation 

The project trip generation was determined using the following steps: 

1. San Diego Association of Governments (SANDAG) trip generation rates taken from the (Not 

so) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region, April 2002, 

were used for the project land uses.

2. Total project trips were calculated using the SANDAG rates to obtain the total trips 

generated by the project site. 

3. As previously mentioned, a portion of project trips will not be new to the street system, but 

will be captured from trips already on the street system. These trips are termed “pass-by” 

trips and are assumed to be already on the roadways for another purpose. 

4. Primary trips are trips assumed to be new to the street system. The primary trips are 

calculated by subtracting the pass-by trips from the total project trips. 

Commercial Development Trips

Based on the total commercial trip generation calculations, the proposed project is calculated to 

generate 5,072 ADT with 325 total trips during the AM peak hour (166 inbound / 159 outbound) and 

417 total trips during the PM peak hour (220 inbound / 197 outbound). 

Total Primary Commercial Trips

Based on SANDAG rates and pass-by percentages, the proposed project is calculated to generate 

approximately 4,078 primary daily trips with 293 primary trips during the AM peak hour (150 

inbound / 143 outbound) and 281 primary trips during the PM peak hour (152 inbound / 

129 outbound). These trips are new to the street system.

The total project trip generation is summarized in Table 7–1. 

7.2 Trip Distribution/Assignment 

The project traffic was distributed and assigned to the street system based on the project’s proximity 

to state highways and arterials, and the locations of existing and proposed residential communities. 

Figure 7–1 shows the project traffic distribution. Figure 7–2 shows the primary project traffic 

assignment. Figure 7–3 shows the existing + project traffic volumes. 
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TABLE 7–1 

PROJECT TRIP GENERATION 

Land Use Size 

Daily Trip Ends 

(ADTs) AM Peak Hour PM Peak Hour 

Ratea Volume % of 

ADT

In:Out Volume % of 

ADT 

In:Out Volume 

Split In Out Total Split In Out Total

Commercial Development 

Specialty Retail/Strip 

Commercial 27.6 KSF 40 /KSF 1,104 3% 6:4 20 13 33 9% 5:5 50 50 100 

Pass-by 10% (110) 10% 5:5 (2) (2) (4) 10% 5:5 (5) (5) (10)

Specialty Retail/Strip 

Commercial 

Primary Trips 

 994 — 18 11 29 — 45 45 90 

Restaurant 

Sit-Down, High Turnover 8.8 KSF 160 /KSF 1,408 8% 5:5 56 56 112 8% 6:4 68 45 113 

Pass-by 12% (168) 10% 5:5 (5) (5) (10) 20% 5:5 (11) (11) (22)

Restaurant 

Sit-Down, High Turnover 

Primary Trips 

 1,240 — 51 51 102 — 57 34 91 

Gasoline w/ Food Mart 12 VFS 160 /VFS 2,560 7% 5:5 90 90 180 8% 5:5 102 102 204 

Pass-by 28% (716) 10% 5:5 (9) (9) (18) 50% 5:5 (52) (52) (104)

Gasoline w/ Food Mart 

Primary Trips 2,048 — 81 81 162 — 50 50 100 

Total Commercial Trips 5,072 — 166 159 325 — 220 197 417 

Total Project Pass-by (994) — (16) (16) (32) — (68) (68) (136)

Total Primary Commercial Trips 4,078 — 150 143 293 — 152 129 281 

Footnotes: 

a. Trip rates and pass-by percentages are based on SANDAG’s (Not So) Brief Guide of Vehicular Traffic Generation Rates for the San Diego Region, April 2002.

General Notes: 

KSF = Thousand square feet 

VFS = Vehicle fueling stations



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8.0 ANALYSIS OF PROJECT IMPACTS

The following is a summary of the intersection and daily street segment operations for the NearTerm scenarios. The impacts of the proposed project traffic volumes are compared to the existing 

volumes to determine potential near-term significant direct impacts, based on the published 

significance criteria. Also presented are the Year 2030 forecasted volumes and operations from the 

General Plan (GP) Update traffic model, which were utilized to address potential cumulative project 

traffic impacts. Findings of significance are made at the conclusion of the report in Section 11.0. 

8.1 Existing + Project Operations 

8.1.1 Intersection Analysis 

Table 8–1 shows that with the addition of project traffic, the study area intersections are calculated 

to continue to operate at a LOS D or better during the AM and PM peak hours with the exception of 

the Valley Center Road/ Street “A” intersection which is calculated to operate at LOS F during the 

AM peak hour. 

Appendix D contains the existing + project intersection level of service analysis worksheets. 

8.1.2 Segment Operations 

Table 8–2 shows that with the addition of project traffic, the street segments are calculated to 

continue to operate at a LOS D or better except for the two-lane portion of Valley Center Road 

segment between Lake Wohlford Road (N.) and Cole Grade Road which continues to operate at 

LOS E. 

Based on the established significance criteria, significant direct impacts are calculated at the 

intersection of Valley Center Road and Street “A” and along the segment on Valley Center Road 

between Lake Wohlford Road (N.) and Cole Grade Road. 

8.2 Year 2030 (With Project) Operations 

8.2.1 Forecast Volumes 

Year 2030 traffic volumes are derived from the most recent version of the SANDAG Series 11 

County of San Diego GP Update traffic model, revised June 3, 2010, which includes land use and 

network changes consistent with the proposed GP Update. This includes the recent widening of 

Valley Center Road to four lanes. The GP Update traffic model ADTs were compared to existing 

ADTs in the study area. Future peak hour intersection turn volumes were calculated based on 

forecasted growth in ADT on the adjacent links. Project traffic was added to the Year 2030 volumes. 

Figure 8–1 shows the Year 2030 (With Project) traffic volumes. 

8.2.2 Intersection Analysis 

Table 8–1 shows that with the forecasted Year 2030 (With Project) traffic volumes the study area 

intersections are calculated to continue to operate at a LOS D or better except for the Valley Center 

Road/ Street “A” intersection which is forecasted to operate at LOS F during the AM and PM peak 

hours. 
LINSCOTT, LAW & GREENSPAN, engineers LLG Ref. 3-10-1972 

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Appendix E contains the Year 2030 (With Project) intersection level of service analysis worksheets. 

8.2.3 Segment Operations 

Table 8–2 shows that with the forecasted Year 2030 (With Project) traffic volumes the street 

segments are calculated to continue to operate at a LOS D or better except for the following: 

 Valley Center Road between Lake Wohlford Road and Cole Grade Road – LOS E 

 Valley Center Road between Cole Grade Road and Woods Valley Road – LOS F 

 Valley Center Road between Woods Valley Road and Lake Wohlford Road (S.) – LOS E 

 Lake Wohlford Road (N.) between Valley Center Road and Guejito Road – LOS E 

 Cole Grade Road between Valley Center Road and Fruitvale Road – LOS F 

Based on the established significance criteria, significant cumulative impacts are calculated at all of 

the study area locations forecasted to operate at LOS E/F conditions. 

 
LINSCOTT, LAW & GREENSPAN, engineers LLG Ref. 3-10-1972 

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26

SIGNALIZED UNSIGNALIZED 

DELAY/LOS THRESHOLDS DELAY/LOS THRESHOLDS 

Delay LOS Delay LOS 

0.0 < 10.0 A 0.0 < 10.0 A 

10.1 to 20.0 B 10.1 to 15.0 B 

20.1 to 35.0 C 15.1 to 25.0 C 

35.1 to 55.0 D 25.1 to 35.0 D 

55.1 to 80.0 E 35.1 to 50.0 E 

 > 80.1 F > 50.1 F 

TABLE 8–1 

INTERSECTION OPERATIONS

Intersection Control

Type 

Peak

Hour 

Existing Existing + Project Year 2030 

(With Project) 

Delaya LOSb Delay LOS ∆c Delay LOS 

 

1. Valley Center Road/ Cole Grade Road Signal AM 32.2 C 32.7 C — 53.3 D 

PM 32.9 C 33.5 C — 53.6 D 

 

2. Valley Center Road/ Street “A” TWSC d AM 20.3 C 53.6 F 265 >100 F 

PM 13.1 B 34.4 D 242 >100 F 

 

3. Valley Center Road/ Relocated School Bus 

Road 

Inbound 

Only 

AM DNE DNE 9.0 A — 10.6 B 

PM DNE DNE 0.0f — — 0.0f

 — 

 

4. Valley Center Road/ Lake Wohlford Road 

(N.) Signal 

AM 23.3 C 24.5 C — 33.2 C 

PM 26.0 C 26.8 C — 43.3 D 

 

5. Lake Wohlford Road (N.)/ School Bus Road TWSC AM 14.6 B 15.9 C — 28.4 D 

PM 10.2 B 10.5 B — 12.2 B 

 

6. Lake Wohlford Road (N.)/ Woods Valley 

Road AWSC e AM 11.1 B 12.3 B — 33.0 D 

PM 10.7 B 11.7 B — 29.7 D 

 

7. Lake Wohlford Road (N.)/ Project Access TWSC AM — — 11.3 B — 13.8 B 

PM — — 10.7 B — 12.6 B 

 

8. Valley Center Road/ Lilac Road Signal AM 14.9 B 15.0 B — 34.9 C 

PM 13.7 B 13.7 B — 34.7 C 

 

9. Valley Center Road/ Woods Valley Road Signal AM 16.1 B 16.1 B — 19.8 B 

PM 17.7 B 17.9 B — 24.0 C 

 

Footnotes: 

a. Average delay expressed in seconds per vehicle. 

b. Level of Service. 

c. “∆” denotes the project-induced increase in trips at the critical movement for potentially 

impacted intersections. 

d. TWSC – Two-Way Stop Controlled intersection. Minor street left turn delay is reported. 

e. AWSC –All-Way Stop Controlled intersection. 

f. No critical movements are reported during the PM peak hour on the Valley Center Road/ 

School Bus Road (Realigned) intersection, therefore no delay is shown. 

General Notes: 

Bold typeface and shading indicates a potential significant impact. 

DNE = Does Not Exist 
LINSCOTT, LAW & GREENSPAN, engineers LLG Ref. 3-10-1972 

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27

TABLE 8–2 

STREET SEGMENT OPERATIONS

Street Segment Capacity 

(LOS E) a

Existing Existing + 

Project 

Projectinduced 

increase

Year 2030 

(With Project) 

ADT b LOS c ADT LOS ADT LOS 

Valley Center Road 

Lake Wohlford Road (N.) to Cole 

Grade Road 16,200 11,180 E 13,220 E 2,040 15,040 E 

Cole Grade Road to Lilac Road 37,000 22,910 B 23,770 B 860 41,860 F 

Lilac Road to Woods Valley Road 37,000 24,100 B 24,550 B 450 41,450 F 

Woods Valley Road to Lake 

Wohlford Road (S.) 37,000 24,930 C 25,300 C 370 36,370 E 

Lake Wohlford Road (N.) 

Valley Center Road to Woods 

Valley Road 16,200 9,420 D 10,650 D 1,230 15,230 E 

Woods Valley Road to Guejito 

Road 16,200 5,970 C 6,590 C 620 13,620 E 

Woods Valley Road 

Valley Center Road to Lake 

Wohlford Road (N.) 16,200 2,450 B 2,740 B — 5,290 C 

Cole Grade Road 

Valley Center Road to Fruitvale 

Road 19,000 12,230 D 12,720 D 490 31,490 F 

Footnotes: 

a. Capacities based on County of San Diego Roadway Classification Table. 

b. Average Daily Traffic Volumes. 

c. Level of Service. 

General Notes: 

Bold typeface and shading indicates a significant impact. 

LINSCOTT, LAW & GREENSPAN, engineers LLG Ref. 3-10-1972 

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9.0 CONGESTION MANAGEMENT PROGRAM COMPLIANCE

The Congestion Management Program (CMP), adopted on November 22, 1991, is intended to link 

land use, transportation and air quality through level of service performance. The CMP requires an 

Enhanced CEQA Review for projects that are expected to generate more than 2,400 ADT or more 

than 200 peak hour trips. 

The SANDAG Congestion Management Program, Updated July 16, 2008 report contains a list of 

“CMP Arterials” that are to be analyzed if the project exceeds the above mentioned trip generation 

thresholds. Although the project generates more than the 2,400 ADT and 200 peak hour trips, none 

of the study area locations analyzed in this report are listed as CMP arterials, highways, or freeways. 

Therefore, a CMP analysis is not required of this project.
LINSCOTT, LAW & GREENSPAN, engineers LLG Ref. 3-10-1972 

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30

10.0 ACCESS AND OTHER ISSUES

10.1 Project Access 

Access to the commercial portion of the project is proposed via one full access driveway on Valley 

Center Road and one right-turn in/out only driveway on Lake Wohlford Road (N.). Based on a 

review of forecasted traffic volumes at the access points, the following geometry and traffic controls 

are recommended to facilitate adequate operations at each driveway. Figure 10–1 illustrates the 

project access recommendations. 

1. Valley Center Road/ Street “A”

Restripe Valley Center Road to provide a westbound left-turn lane with 150-feet of storage 

and a 90-foot bay taper and an eastbound dedicated right-turn lane. Provide two outbound 

(northbound) lanes on Street “A”, one left-turn lane and one right-turn lane with an overlap 

phase. Conduct an annual traffic count at the Valley Center Road/ Street “A” intersection as 

part of a monitoring program of the intersection to determine when signal warrants are met. 

Install the traffic signal once warrants are met. 

It should be noted that signalization of the Valley Center Road/ Street “A” intersection will 

likely not be needed until full buildout of the site and is dependent on tenant mix and trip 

generation. It is recommended that a monitoring system be implemented to identify the point 

at which a traffic signal is warranted. 

2. Lake Wohlford Road (N.)/ Project Access

Place the project driveway under stop-control. Signage shall be placed to restrict access to 

right-turn in/ right-turn out only. An exception to the 300-foot separation County standard 

between road intersections will be required. This exception is justified since access will be 

limited to right-in/right-out only at Lake Wohlford Road (N.) and peak hour traffic volume 

projections are low coming in and out of this driveway (see Figure 7–3). In addition, the 

signal on Lake Wohlford Road (N.) at Valley Center Road will provide gaps for vehicles 

exiting the site. Corner sight distance meeting County standards must be provided. 

At the relocated Valley Center Road/ School Bus Road intersection, the following is recommended 

to provide adequate operations: 

Provide a westbound left-turn lane with 130-feet of storage and a 90-foot bay taper and an 

eastbound dedicated right-turn lane on Valley Center Road. School Bus Road should be a 22-

foot wide one-way roadway with school buses entering along Valley Center Road and exiting 

along Lake Wohlford Road (N.). Ensure proper sight distance is met at the new location 

based on County standards. 
LINSCOTT, LAW & GREENSPAN, engineers LLG Ref. 3-10-1972 

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10.2 Site Plan Assessment 

The site plan dated March 24, 2009 (Figure 2–3) was evaluated for access and circulation issues. 

Based on this evaluation, LLG has the following recommendations. 

1. The one-way School Bus Road shall continue its current operations in which buses and 

vehicles enter from Valley Center Road and exit to Lake Wohlford Road (N.). 

2. Place the driveway to the west parking lot further south on Street “A” to be opposite the 

east parking lot access to provide for a four-legged intersection. 

LINSCOTT, LAW & GREENSPAN, engineers LLG Ref. 3-10-1972 

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11.0 IMPACT SUMMARY

The project is calculated to generate a total of 5,072 ADT with 325 total AM and 417 total PM peak 

hour trips. The effects of the proposed project traffic were measured at 9 intersections (including 

project access locations) and 8 street segments in the project area for direct project and cumulative 

impacts. 

11.1 Significance of Impacts 

The following is a description of the calculated significant impacts for the proposed project based on 

the County of San Diego “Guidelines for Determining Significance”, effective June 30, 2009 with a 

first modification effective February 19, 2010 along with recommendations for mitigation measures 

at the impacted locations. 

Direct and Cumulative Impacts 

1. Valley Center Road/ Street “A” intersection 

2. Valley Center Road segment between Lake Wohlford Road (N.) and Cole Grade Road 

3. Valley Center Road between Cole Grade Road and Lake Wohlford Road (S.) 

4. Lake Wohlford Road (N.) between Valley Center Road and Guejito Road 

5. Cole Grade Road between Valley Center Road and Fruitvale Road 

11.2 Mitigation Measures 

The following mitigation measures are recommended. 

Direct and Cumulative Mitigation 

1. Valley Center Road/ Street “A” intersection: Restripe Valley Center Road to provide a 

westbound left-turn lane with 150-feet of storage and a 90-foot bay taper and an eastbound 

dedicated right-turn lane. Provide two outbound (northbound) lanes on Street “A”, one leftturn lane and one right-turn lane with an overlap phase. Conduct an annual traffic count at 

the Valley Center Road/ Street “A” intersection as part of a monitoring program of the 

intersection to determine when signal warrants are met. Install the traffic signal once 

warrants are met. 

2. Valley Center Road between Lake Wohlford Road (N.) and Cole Grade Road: Provide 

the intersection improvements listed in Mitigation Measure #1 and in addition, provide a 

westbound left-turn only lane at the Valley Center Road/ Molly Anne Court intersection 

(entering into Citrus Point Subdivision). These capacity improvements along the impacted 

portion of Valley Center Road would directly improve traffic flow and is a proportional 

improvement to the amount of traffic the project adds to the segment. The provision of 

dedicated left-turn lanes will enable left-turn vehicles to not need to stop in Valley Center 

Road through traffic to make their turn. This is advantageous due to high speeds on Valley 
LINSCOTT, LAW & GREENSPAN, engineers LLG Ref. 3-10-1972 

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34

Center Road. These improvements would mitigate the significant direct and cumulative 

impacts.

3. Valley Center Road between Cole Grade Road and Lake Wohlford Road (S.): Payment 

into the County Traffic Impact Fee Program would mitigate the cumulative impact on this 

roadway to below a level of significance. 

4. Lake Wohlford Road (N.) between Valley Center Road and Guejito Road: Payment into 

the County Traffic Impact Fee Program would mitigate the cumulative impact on this 

roadway to below a level of significance.

5. Cole Grade Road between Valley Center Road and Fruitvale Road: Payment into the 

County Traffic Impact Fee Program would mitigate the cumulative impact on this roadway to 

below a level of significance.
3-10-1972 San Pasqual 9-Acre Fee-to-Trust & Retail Plaza Project 

Year 2030 Analysis 

N:\Projects\2009 AES Projects\209543 - San Pasqual Fee to Trust\9-acre EA\Traffic\Year 2030 Analysis (2).doc 

ATTACHMENT 1 

YEAR 2030 WITHOUT PROJECT

STREET SEGMENT OPERATIONS

Street Segment Capacity

(LOS E) a

Year 2030 

(Without Project)

ADT b LOS c

Valley Center Road

Lake Wohlford Road (N.) to Cole 

Grade Road 16,200 13,000 E

Cole Grade Road to Lilac Road 37,000 41,000 F

Lilac Road to Woods Valley Road 37,000 41,000 F

Woods Valley Road to Lake 

Wohlford Road (S.) 37,000 36,000 E

Lake Wohlford Road (N.)

Valley Center Road to Woods 

Valley Road 16,200 14,000 E

Woods Valley Road to Guejito 

Road 16,200 13,000 E

Woods Valley Road

Valley Center Road to Lake 

Wohlford Road (N.) 16,200 5,000 C

Cole Grade Road

Valley Center Road to Fruitvale 

Road 19,000 31,000 F

Footnotes:

a. Capacities based on County of San Diego Roadway Classification Table.

b. Average Daily Traffic Volumes.

c. Level of Service.
The appendices to this Traffic Impact Analysis are 

available upon request. 
Appendix I Bureau of Land Management 

Manual 8410 Visual Resources Inventory 
Appendix I: 

Bureau of Land Management Manual 8410 Visual Resources Inventory 

1.0 Introduction 

The Bureau of Land Management (BLM) developed a Manual (8410) for assessing the level of value of 

the Visual Resources for a specific parcel (BLM, 2007). This methodology was used to complete the 

analysis for the Scenic Quality Rating Summary in Section 3.13 Visual Resources. The methodology for 

2.0 Scenic Quality - Explanation of Rating Criteria 

The BLM established rating criteria for seven features that effect scenic quality of visual resources. 

These features are landform, vegetation, water, color, adjacent scenery, scarcity, and cultural 

modifications. 

Landform 

Topography becomes more interesting as it gets steeper or more massive, or more severely or universally 

sculptured. Outstanding landforms may be monumental, as the Grant Canyon, the Sawtooth Mountain 

Range in Idaho, the Wrangell Mountain Range in Alaska, or they may be exceedingly artistic and subtle 

as certain badlands, pinnacles, arches and other extraordinary formations. 

Vegetation 

Give primary consideration to the variety of patterns, forms, and textures created by plant life. Consider 

short-lived displays when they are known to be recurring or spectacular. Consider also small scale 

vegetational features which add striking and intriguing detail elements to the landscape (e.g. gnarled or 

windbeaten trees, and Joshua trees). 

Water 

That ingredient which adds movement or serenity to a scene. The degree to which water dominates the 

scene is the primary consideration in selecting the rating score. 

Color 

Consider the overall color(s) of the basic components of the landscape (e.g. soil, rock, vegetation, etc.) as 

they appear during the seasons or periods of high use. Key factors to use when UDWLQJ3FRORU ́DUHYDULHW\

contrast, and harmony. 

Adjacent Scenery 

Degree to which scenery outside the scenery unit being rated enhances the overall impression of the 

scenery within the rating unit. The distance which adjacent scenery will influence scenery within the 
rating unit will normally range from 0-5 miles, depending upon the characteristics of the topography, the 

vegetative cover, and other such factors. This factor is generally applied to units which would normally 

rate very low in score but the influence of the adjacent unit would enhance the visual quality and raise the 

score. 

Scarcity 

This factor provides an opportunity to give added importance to one or all of the scenic features that 

appear to be relatively unique or rare within one physiographic region. There may also be cases where a 

separate evaluation of each of the key factors does not give a true picture of the overall scenic quality of 

an area. Often it is a number of not so spectacular elements in the proper combination that produces the 

most pleasing and memorable scenery-the scarcity factor can be used to recognize this type of area and 

give it the added emphasis it needs. 

Cultural Modifications 

Cultural modifications in the landform/water, vegetation, and addition of structures should be considered 

and may detract from the scenery in the form of a negative intrusion or complement or improve the scenic 

quality of a unit. Rate accordingly. 

3.0 Scenic Quality Inventory and Evaluation Chart 

The BLM developed a Scenic Quality Inventory and Evaluation Chart, which provides rating criteria and 

associated scores to each of the features that comprise the scenic quality. The Inventory and Evaluation 

Chart is presented in Table 1, below. 

4.0 References 

Department of the Interior Bureau of Land Management. 2007. Manual 8410 ± Visual Resource 

Inventory. Electronic Document, http://www.blm.gov/nstc/VRM/8410.html, Accessed 

August 2010. 
Table 1: 

Scenic Quality Inventory and Evaluation Chart 

Key Factors Rating Criteria Score Rating Criteria Score Rating Criteria Score 

Landform High Vertical Relief as 

expressed in cliffs, spires, 

or massive rock outcrops, 

or severe surface 

variation or highly eroded 

formations including major 

badlands or dune 

systems; or detail features 

dominant and 

exceptionally striking 

5 Steep canyons, 

mesas, buttes, 

cinder cones, and 

drumlins; or variety 

in size and shape 

of landforms; or 

detail features 

which are 

interesting though 

not dominant or 

exceptional. 

3 Low rolling hills, 

foothills, or flat 

valley bottoms; or 

few or not 

interesting 

landscape features. 

1 

Vegetation A variety of vegetative 

types as expressed in 

interesting forms, 

textures, and patterns. 

5 Some variety of 

vegetation, but only 

one or two major 

types 

3 Little or no variety 

or contrast in 

vegetation. 

1 

Water Clean and clear 

appearing, still, or 

cascading white water, 

any of which are a 

dominant factor in the 

landscape. 

5 Flowing, or still, but 

not dominant in the 

landscape. 

3 Absent, or present, 

but not noticeable. 

0 

Color Rich color combinations, 

variety, or vivid color; or 

pleasing contrasts in the 

soil, rock, vegetation, 

water, or snow fields. 

5 Some intensity or 

variety in colors 

and contrasts of 

the soil, rock, and 

vegetation, but not 

a scenic element. 

3 Subtle color 

variations, contrast, 

or interest; 

generally mute 

tones. 

1 

Influence of 

Adjacent 

Scenery 

Adjacent scenery greatly 

enhances visual quality. 

3 Adjacent scenery 

moderately 

enhances overall 

visual quality. 

3 Adjacent scenery 

has little or no 

influence on overall 

visual quality. 

0 

Scarcity One of a kind, or 

unusually memorable, or 

very rare within the 

region. Consistent 

chance for exceptional 

wildlife or wildflower 

viewing, etc. 

*5+ Modifications add 

little or no visual 

variety to the area, 

and introduce no 

discordant 

elements. 

0 Modifications add 

variety but are very 

discordant and 

promote strong 

disharmony. 

-4 

* A rating of greater than 5 can be given but must be supported by written justification. 

Source: BLM, 2007 
Appendix J URBEMIS Files