Land Evaluation and Site Assessment

Land Evaluation C and Site Assessment

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3111 Manchester Avenue

Land Evaluation and Site Assessment

Prepared for:

Greystar 444 South Cedros Avenue Solana Beach, CA 92075

Prepared by:

AUGUST 2018 LAND EVALUATION AND SITE ASSESSMENT

3111 MANCHESTER AVENUE

Prepared for

Greystar 444 South Cedros Avenue, Suite 172 Solana Beach, CA 92075

Prepared by:

Birdseye Planning Group, LLC 1354 York Drive Vista, California 92084

August 2018 3111 Manchester Avenue, Encinitas Land Evaluation and Site Assessment

3111 Manchester Avenue City of Encinitas, California

LAND EVALUATION AND SITE ASSESSMENT

Table of Contents Page

Project Description ...... 1 LESA Evaluation ...... 3 Land Evaluation ...... 3 Site Assessment Factors ...... 4 Conclusion ...... 7 References ...... 10

List of Figures Figure 1: Project Location ...... 2 Figure 2: Zone of Influence ...... 7

List of Tables Table 1 ‐ Land Capability Classification (LCC) and Storie Index Score ...... 5 Table 2 ‐ Project Size Score ...... 5 Table 3 ‐ Water Resource Availability ...... 5 Table 4 ‐ Surrounding Agricultural Land ...... 6 Table 5 ‐ Final LESA Score Sheet Summary ...... 8

Greystar i 3111 Manchester Avenue, Encinitas Land Evaluation and Site Assessment

3111 Manchester Avenue Encinitas, California

LAND EVALUATION AND SITE ASSESSMENT

This report is an evaluation of potential impacts to agricultural land associated with a proposal to construct and operate a senior care facility on a 15‐acre site located at 3111 Manchester Avenue in the City of Encinitas. This report has been prepared by Birdseye Planning Group (BPG) under contract to Greystar as part of the due diligence process conducted for the proposed project.

Land Evaluation and Site Assessment (LESA) is a term used to define an approach for rating the relative quality of land resources based upon specific measurable features. The LESA system is a point‐based approach composed of six factors. Two Land Evaluation factors are based upon soil resource quality. Four Site Assessment factors rate the value of the land for agricultural purposes based on the size of the site, water resource availability, surrounding agricultural lands and surrounding protected resource lands. Each factor is separately rated on a 100‐point scale and then weighted relative to one another and combined, resulting in a single numeric score with a maximum attainable score of 100 points. It is this project score that becomes the basis for a determination of a project’s potential significance, based upon a range of established scoring thresholds (Department of Conservation, 1997).

Appendix G of the California Environmental Quality Act (CEQA) Guidelines identifies the California Agricultural LESA Model as an optional method for assessing impacts to agriculture and farmland associated with development projects.

PROJECT DESCRIPTION/SETTING

The applicant proposes to construct a 194‐unit senior care facility with 16 affordable work for housing units on a 15 gross‐acre site located at 3111 Manchester Avenue in the City of Encinitas, California. The proposed site is zoned Rural Residential (RR) 2 and is located in the coastal zone. The project location is shown in Figure 1. The site has historically been used for agricultural production, primarily strawberries and Asian vegetables. The proposed senior care facility is allowed on the site per current zoning provided a major use permit is approved. The City of Encinitas has indicated a LESA is required to evaluate the potential for significant or adverse impacts associated with the loss of agricultural land. If so, mitigation may include the purchase of coastal agricultural land that has been set aside for production in perpetuity. Greystar is currently in the due diligence phase of the project and has requested preparation of a LESA to determine whether impacts caused by the project would require mitigation.

Greystar 1 Project Site

Figure 1—Project Site 3111 Manchester Avenue, Encinitas Land Evaluation and Site Assessment

LESA EVALUATION

The site was evaluated using the California LESA Model to rate the project site relative to the evaluation/assessment factors referenced above to identify whether the proposed project would meet the threshold criteria as a significant impact to Agricultural Resources under the CEQA Guidelines. The factors used to perform the LESA evaluation are described as follows:

LAND EVALUATION The Land Evaluation portion of the LESA Model focuses on two main components that are separately rated:

1. Land Capability Classification Rating: The Land Capability Classification (LCC) indicates the suitability of soils for most kinds of crops. Soils are rated from Class I to Class VIII. Soils having the fewest limitations receive the highest rating.

2. Storie Index Rating: The Storie Index provides a numeric rating (based upon a 100‐point scale) of the relative degree of suitability or value of a given soil for intensive agriculture use. This rating is based upon soil characteristics only.

According to the United States Department of Agriculture survey, Corralitos loamy‐sand (CsC) (5‐9% slopes) is the soil type on the portion of the site used for agricultural production. This soil is a Capability Class III‐s soil with a Storie Index rating of 61 (Dudek, 2013). According to the Natural Resources Conservation Service (NRCS), Class III soils have severe limitations which minimizes the selection of plants, requires special conservation practices or both. Thus, Class III soils are not Prime soils under the California Department of Conservation (CDC) or the USDA’s definitions, unless they are irrigated. The CDC Farmland Mapping and Monitoring Program has classified the site as Prime, if irrigated.

The LESA Model assigns ratings to each land capability class and multiplies that number by the proportion of the project area that contains each soil class to find the Land Capability Classification score. This analysis assumes the entire 15 acres is Corralitos loamy sand. A Storie Index score is calculated by multiplying the proportion of the project within each soil type by the soil type’s Storie Index rating. Table 1 provides a summary of the Land Evaluation (LE) scores. The final LE and Site Assessment (SA) scores are entered into the Final LESA Score Sheet as shown in Table 5, later in this report. In this case, Class III‐s soils have a LCC Rating of 60 (California Department of Conservation 1997). Because 100% of the site has Class III‐s soils and Storie Index of 61, the LCC and Storie scores are 60 and 61, respectively.

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SITE ASSESSMENT FACTORS The California LESA Model includes the following four Site Assessment factors that are separately rated:

 Project Size Rating TABLE 1 Land Capability Classification (LCC) and Storie Index Score A B C D E F G H Soils Acres Proportion LCC LCC LCC Storie Storie of Project Rating Score Index Score Area Corralitos loamy 15 100% III-s 60 60 61 61 sand (5-9% slope) TOTALS 15 100% 60 61 Source: California Department of Conservation, 1997

 Water Resources Availability Rating  Surrounding Agricultural Land Rating  Surrounding Protected Resource Land Rating

A. Project Size Rating The project size rating recognizes the role that farm size plays in the viability of commercial agricultural operations. In general, larger farming operations provide greater flexibility in farm management and marketing decisions. Further, they tend to have a greater economic impact through direct employment and upon supporting industries that include farm equipment operators, fertilizer/pesticide vendors and food processors (California Department of Conservation, 1997).

To define agricultural productivity, the size of the farming operation is considered as well as the proportion of different quality lands comprising the total acreage. Lands with higher quality soils facilitate greater management and cropping flexibility and have the potential to provide higher economic return per acre unit than land with lower quality soils. Thus, rather than rely upon a single acreage figure in the Project Size rating, the project is divided into three acreage groupings based upon possible LCC ratings. Under the Project Size rating, relatively fewer acres of high quality soils are required to achieve a maximum Project Size score. Alternatively, a maximum score on lesser quality soils could also achieve a maximum Project Size score. Table 2 summarizes the Project Size score for the proposed project. As shown, the 15-acre site has Class III-s soils with a corresponding Project Size score of 10.

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B. Water Resources Availability Rating The Water Resource Availability Rating is based upon the availability of water sources that supply the subject property and then determining whether restrictions in supply are likely to take place in years characterized as periods of drought and non‐drought.

The 15‐acre site is served by the Olivenhain Municipal Water District. As referenced, without water for irrigation purposes, the soils would not achieve a Prime Class III rating. For the TABLE 2 Project Size Score LCC CLASS I-II LCC CLASS III LCC CLASS IV-VIII Total Acres 0 15 0 Project Size Scores 0 10 0 Source: California Department of Conservation, 1997 purpose of this discussion, it is assumed an uninterrupted supply of water is available for irrigation. Thus, the site was given the highest Water Resource Availability Rating given the consistent water delivery. The project site has no known physical or economic restrictions that could alter water resource supply during either drought or non‐drought years. Table 3 summarizes the Water Resources Availability score.

C. Surrounding Agricultural Land Rating The Surrounding Agricultural Land Rating is designed to provide a measurement of the level of agricultural land use within the Zone of Influence (ZOI) of the subject parcel. The “Zone of Influence” is defined as land within one-quarter mile from the subject project boundary. Parcels that are intersected by the 0.25-mile buffer are included in their entirety. Based upon the percentage of agricultural land in the ZOI, the project site is assigned a Surrounding

Table 3 Water Resource Availability Water Source Proportion Water Weighted of Project Availability Availability Area Score Score Olivenhain 100% 100 100 Municipal Water District Total Water 100 Resource Score Source: California Department of Conservation, 1997; BPG, LLC., 2017

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Agricultural Land score. The LESA Model rates the potential significance of the conversion of an agricultural parcel that has a large proportion of surrounding land in agricultural production more highly than one that has a relatively small percentage of surrounding land in agricultural production (California Department of Conservation, 1997).

Land on three sides of the site are developed (or under development); and thus, are not use for agricultural purposes. Land to the west is under development by the California Department of Transportation for transit/transportation-related purposes. Mira Costa College is located adjacent to and east of the site. Manchester Avenue and the San Elijo Lagoon are located to the south. This area is preserved for conservation purposes; and thus, is not developed or used for agricultural production. Steep slopes and residential areas are located north of the site. Figure 2 depicts the ZOI within 0.25 miles of the project site boundary. Per the LESA Instruction Guide, because less than 40% of the surrounding land is used for agricultural production, the Surrounding Agricultural Land Score for the proposed project is zero as shown in Table 4.

Table 4 Surrounding Agricultural Lands Total Acres in Acres of Percent in Percent Surrounding Surrounding Acreage Agricultural Protected Agriculture Protected Agricultural Protected within Production Resource Resources Land Score Resource “Zone of Land Land Land Score Influence” 260 0 43* 0% 19% 0 0 Source: Department of Conservation, 1997 *- Approximately 43 acres (19%) within the San Elijo Ecological Reserve are located in the 230-acre ZOI.

D. Surrounding Protected Resource Land Rating The Surrounding Protected Resource Land Rating is an extension of the Surrounding Agricultural Land Rating, and is scored in a similar manner. Protected resource lands are those lands with long-term use restrictions that are compatible with or supportive of agricultural uses of land. Included among them are the following: • Williamson Act contracted land;

• Publicly owned lands maintained as park, forest, or watershed resources; and

• Lands with agricultural, wildlife habitat, open space, or other natural resource easements that restrict the conversion of such land to urban or industrial uses.

Land located north of the site is undeveloped slope located adjacent to existing residential development. While these areas are undeveloped and contain some habitat, they are zoned Residential (R) 3 and not considered protected. As referenced, the San Elijo Ecological Preserve is located south of the site across Manchester Avenue. Approximately 43 acres are located within 0.25 miles of the site. This area comprises approximately 19% of the total acreage in the ZOI (260 acres). Per the LESA Instruction Guide, because less than 40% of the surrounding land is protected, the Surrounding Protected Resource Land Rating score is zero. Greystar 6 Project Site

Zone of Influence

Figure 2—Zone of Influence 3111 Manchester Avenue, Encinitas Land Evaluation and Site Assessment

CONCLUSION The LESA Model is weighted so that one‐half of the total score is derived from the LE and one‐ half from the SA. As shown in Table 5, the LE subscore is 30.25, while the SA subscore is 16.5. The final LESA score is 46.75. As provided Section IV or the LESA Instruction Manual, a final LESA score between 40 and 59 is considered significant only if both the LE and SA sub‐scores are each greater than or equal to 20 points. In this case, the LE subscore is greater than 20 points (30.25); however, the SA subscore is less than 20 (16.50). Thus, the project would have a less than significant impact on agricultural resources. No mitigation for agricultural impacts would be required should the project be developed as proposed.

TABLE 5 Final LESA Score Sheet Summary Factor Rating (0-100 Factor Weighting (Total Weighted Factor Rating Points) = 1.00) Land Evaluation (LE)

1. Land Capability 60 0.25 15 Classification (LCC Rating) 2. Storie Index Rating 61 0.25 15.25

Land Evaluation Subscore 30.25

Site Assessment (SA)

1. Project Size Rating 10 0.15 1.5

2. Water Resource 100 0.15 15 Availability Rating 3. Surrounding 0 0.15 0 Agricultural Land Rating 4. Surrounding 0 0.05 0 Protected Resource Lands Rating Site Assessment Subscore 16.50

TOTAL 46.75

Source: California Department of Conservation, 1997

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Coastal Agricultural Resources

The California Coastal Act has specific language and standards applicable to agricultural lands. Coastal Act Section 30241states that farmland within the Coastal Zone must meet any of the following to be designated as Prime: 1) have a NRCS soil classification of Class I or II; 2) have a Storie Index Rating of 80 through 100; 3) have the ability to support livestock, at least one animal unit per acre as defined by the USDA; or 4) have been planted with fruit or nut bearing trees, vines, bushes or crops that have a nonbearing period of fewer than five years and that will normally return during the commercial bearing period on an annual basis from the production of unprocessed agricultural plant production not less than $200 per acre.

As referenced herein, soils on the site are Class III and Prime only if irrigated. The Storie Index Ratio is less than 80 (i.e., 61). Corralitos loamy sand is not suitable for livestock grazing nor has grazing occurred on the site. The parcel is used to cultivate perennial strawberries and Asian vegetables. Based on these characteristics, the property does not meet the Prime agricultural land criteria described above.

In cases where land does not meet the definition of Prime per Section 30241, Section 30242 of the Coastal Act applies. This section addresses lands suitable for agricultural use and limits conversions of such lands to non‐agricultural uses unless continued agricultural use is not feasible or the conversion would preserve prime agricultural land or concentrate development consistent with Section 30250. Any permitted conversion of agricultural land pursuant to Section 30242 must be compatible with continued agricultural use on surrounding lands.

The project site is the only remaining parcel of agricultural land in the area and is zoned for development. As referenced herein, conversion of the site from agricultural land to a developed parcel would not be considered a significant impact to agricultural land under Appendix G of the CEQA Guidelines. This is due in part to the fact that all surrounding land is developed or in an ecological preserve. While continued use of the site for agricultural purposes may be feasible, the site is zoned RR‐2 and the proposed project is permitted on the site provided a major use permit is approved. Based on existing zoning, the site is not intended to remain in agricultural production. Per Section 30250, new development should be located within, contiguous with, or in proximity to, existing developed areas able to accommodate it or in other areas with adequate public services and where it will not have significant adverse effects, either individually or cumulatively, on coastal resources. Conversion of the proposed site would allow development of the proposed project contiguous to the Caltrans facility to the west and Mira Costa College to the east on the north side of Manchester Avenue. Conversion of the site to a senior care facility would not impact agricultural production on other suitable parcels. No remaining agricultural land exists in proximity to the site; thus, the preservation of prime agricultural land in another location is not applicable. Based on these findings, conversion of the site from agricultural use to a senior care facility would not conflict with the Coastal Act or cause an adverse impact to coastal agricultural lands or coastal resources. Greystar 9 3111 Manchester Avenue, Encinitas Land Evaluation and Site Assessment

REFERENCES

California Department of Conservation, California Agricultural Land Evaluation and Site Assessment Model, Instruction Manual, 1997.

Dudek and Associates, Inc., Agricultural Viability Analysis for the Manchester Property in Encinitas and the Cannon Road Property in Carlsbad, California for the North Coast Corridor Public Works Plan/Transportation and Resource Enhancement Program, September 2013.

United States Department of Agriculture, Web Soil Survey, 2017. Accessed October 31, 2017. https://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm

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