PLANNING COMMISSION MEETING DATE:
MAY 19, 2025
SUBJECT:
Title
ARMORLITE LOFTS - REQUEST ENTITLEMENTS FOR A MIXED-USE DEVELOPMENT CONSISTING OF 165 RESIDENTIAL UNITS (APARTMENTS) AND 5,600 SQUARE FEET OF COMMERCIAL SPACE.
LOCATION/APN:
0 ARMORLITE DRIVE / APN: 219-162-62-00
CASE NUMBER:
ENVIRONMENTAL IMPACT REPORT (EIR 24-003), SPECIFIC PLAN (SP 23-0001), GENERAL PLAN AMENDMENT (GPA 23-0002), REZONE (R 23-0001), SITE DEVELOPMENT PLAN (SDP 23-0003), AND CONDITIONAL USE PERMIT (CUP 23-0002)
Body
Recommendation
Recommend to the City Council APPROVAL of the following in the order set forth below:
1. APPROVE Resolution PC 25-5162 to certify the Environmental Impact Report (EIR 24-0003);
2. APPROVE Resolution PC 25-5159 for a Specific Plan (SP 23-0001) to adopt the Armorlite Lofts Specific Plan;
3. APPROVE Resolution PC 25-5160 for a General Plan Amendment (GPA 23-0002) to change the General Plan land use designation of the 2.44-acre project site from Public Institutional (PI) to Specific Plan Area (SPA);
4. APPROVE Resolution PC 25-5161 for a Rezone (R 23-0001) to rezone the 2.44-acre project site from Public Institutional (PI) to Specific Plan Area (SPA);
5. APPROVE Resolution PC 25-5157 for a Site Development Plan (SDP 23-0003) to allow the construction of a mixed-use project consisting of 165 apartments and 5,600 square feet of commercial space; and
6. APPROVE Resolution PC 25-5158 for a Conditional Use Permit (CUP 23-0002) for the temporary use of a rock crusher during site grading.
Body
Introduction
The applicant is requesting approval of a mixed-use development consisting of 165 residential apartments units and 5,600 square feet of commercial space on a 2.44-acre vacant site located on the north side of Armorlite Drive approximately 180 feet east of Las Posas Road. A total of 17 of the 165 apartments will be dedicated as affordable housing units, available to very low-income households. The proposed project consists of a single five-story building (four stories over ground level parking) with 5,600 square feet of ground floor commercial space on Armorlite Drive.
Discussion
The project site is a 2.44-acre vacant lot, with urban development on all sides, with the exception of the North County Transit District (NCTD) Sprinter railroad right-of-way located to the north. The project site was subdivided from the adjacent Pacific Bell (AT&T) property to the west in 2022 (TPM20-0002) and continues to have a General Plan and zoning designation Public Institutional, to allow the expansion of the existing telecommunications facility on Las Posas Road. The project site was sold by Pacific Bell to the applicant, who filed this application on June 15, 2023 to develop the site.
The project site is located on Armorlite Drive and bordered to the west by a quick-service restaurant and the Pacific Bell/AT&T facility. To the south and east of the project site is the Palomar Station and Davia Village (The Marc) multifamily and mixed-use developments, as well as light industrial uses. The NCTD Sprinter station is located within a quarter mile, and both Innovation and Mission Sports public parks are located 0.14 and 0.28 miles from the project site.
Specific Plan (SP 23-0001)
The project proposes developing the site through the adoption of the Armorlite Lofts Specific Plan. The plan will serve as the primary land use policy and regulatory document for the 2.44-acre project site during both the development phase of the project and ongoing use of the site. Below, Table 1 compares the existing development standards of the Public Intuitional Zone to the proposed Specific Plan:
|
Table 1: Comparative Development Standards |
|
Development Standard |
Existing P-I Zone |
Proposed Armorlite Lofts Specific Plan |
|
Residential Density |
N/A |
45 du/ac 1 |
|
FAR Max. |
3.0 2 |
2.3 |
|
Building Height Max. |
3 stories / 45 feet |
5 stories / 65 feet |
|
Front Setback |
10 feet |
10 feet |
|
Interior Setback |
5 feet |
5 feet |
|
Rear |
N/A |
10 feet |
|
Footnotes: 1. Base density used for density bonus calculations, 67.6 du/ac with density bonus units 2. Per General Plan Table 2-3 (San Marcos General Plan Land Use Designations) |
The proposed project includes 17 reserved affordable units onsite, or 15% of the 110 units allowed under the base density of the Specific Plan (45 du/ac). The Specific Plan implements the principles of State of California’s Density Bonus law Government Code Section 65915-65918, in that it provides for a 50% density bonus for the Very-Low Income targeted affordable household units. The density bonus allowance increases the total number of units to 165 (inclusive of the 17 affordable units), or a density of 67.6 du/ac. Since the Specific Plan provides development standards specific to the development, no concessions have been requested, as allowed under State Density Bonus Law.
General Plan Amendment/Rezone (GPA 23-0002)/ (R 23-0001)
The current General Plan Land Use and Zoning designation for the 2.44-acre project site is Public Institutional (PI). The purpose and intent of the Public Institutional designation is to allow for the development and operation of public uses, such as schools, parks, police and fire stations, and public and private utilities. The site's designation as Public Institutional originated from its prior intended use as an expansion area for the adjacent telecommunications facility. As previously mentioned, Pacific Bell/AT&T determined this land was no longer needed to support its facilities and subdivided this portion of the property into a separate lot in 2022.
The project includes both a General Plan Amendment and Rezone, to change the designation of the property from Public Institutional to Specific Plan area, to implement the Armorlite Lofts Specific Plan. The proposed General Plan Amendment and Rezone are considered consistent with the Goals and Objectives of the General Plan, in that project will promote the following:
• Ensure land use diversity and balanced development that encourage an efficient and responsible relationship between land use, transit, open space, and areas of environmental sensitivity (LU-1).
• Encourage integration of high-quality and sustainable development through the establishment of development standards and land use patterns that encourage long-term environmental sustainability (LU-2).
• Develop land use patterns that are compatible with and support a variety of mobility opportunities and choices (L-U3).
• Promote community design that produces a distinctive, high-quality built environment with forms and character that create memorable places and enrich community life (LU-5).
• Direct and sustain growth and expansion in areas of San Marcos that can support a concentration of a variety of uses that are particularly suitable for multimodal transportation and infrastructure expansion and improvements (LU-7).
• Ensure that existing and future development is adequately serviced by infrastructure and public services (LU-8).
Site Development Plan (SDP 23-0003)
Under a Site Development Plan (SDP), the project design is reviewed for compliance with the design guidelines and the Armorlite Lofts Specific Plan and other applicable regulatory provisions.
The Armorlite Lofts building is designed in a contemporary architectural style, incorporating clean lines, modern materials, and a varied massing intended to reduce the perceived scale of the structure, particularly from Armorlite Drive, where the building will have a primarily single-story appearance, with the structure gaining height internally, away from the road. The five-story building includes features such as articulated facades, balconies, large windows, and integrated landscaping to provide visual interest and enhance pedestrian interaction along Armorlite Drive. The design utilizes a combination of stucco, metal accents, and glass materials in a neutral color palette, with the intent of providing a cohesive and context-sensitive development that complements surrounding uses. The project’s 165 units will consist of a mix of one-bedroom/one-bathroom and two-bedroom/two-bathroom floor plans, with unit sizes ranging from approximately 620 to 1,020 square feet. Each unit will include private open space in the form of a balcony or deck ranging in size from 55 to 82 square feet.
The project includes approximately 34,894 square feet of outdoor and 2,050 square feet of indoor common open space for recreational use by residents. Several recreational amenities designed in an urban style will be provided on the upper building levels and will include a pool, spa, bocce ball court, barbeque areas, fire pits, and seating areas. Additional multi-age recreational features are incorporated to support a variety of resident needs. Private open space is provided through individual unit balconies or decks, while common recreational spaces are centrally located to promote accessibility and community interaction. Landscaping, pedestrian pathways, and site furnishings are integrated throughout the open space areas to enhance the overall livability of the development. A dog park on the west side of the building and passive recreation space in the northeast corner of the project will also be provided.
Open Space/Landscaping
Private landscaping will be designed to complement the contemporary architectural style and urban character of the development. The planting of approximately 67 trees throughout the site is proposed, including species such as Crape Myrtle, Western Redbud, Palo Verde, and Brisbane Box, selected for their drought tolerance, seasonal interest, and compatibility with the local climate. Landscape design integrates a mix of native and drought-tolerant shrubs, grasses, and groundcovers, including species like Deer Grass, Cleveland Sage, and California Fuchsia, consistent with the City’s Water Efficient Landscape Ordinance (WELO) requirements. Trees and plantings are strategically placed to define building edges, shade pedestrian pathways, and enhance recreational spaces, with particular attention to the central open space areas, pool deck, and pedestrian paseo. Planters at the podium level and integrated landscaping along Armorlite Drive will contribute to the project’s urban form while supporting sustainability, aesthetic quality, and long-term maintenance objectives.
Parking/Circulation
Onsite circulation for the project is designed to prioritize pedestrian, bicycle, and vehicular access within a compact, transit-oriented environment. The project provides direct vehicular access from Armorlite Drive, with secondary emergency access provided through the Pacific Bell/AT&T property driveway onto Las Posas Road. This secondary access will require the relocation of an existing trash enclosure on the Pacific Bell/AT&T property and the installation of automatic electric gates that will enable unrestricted access during emergencies.
As seen in Tables 2 and 3 below, a total of 247 residential and 17 commercial parking spaces are required with a total of 254 parking spaces provided onsite through a combination of open/surface parking, tuck-under parking, and ground-floor covered parking areas. Of the 254 spaces, approximately 247 spaces are allocated for residential use and 7 spaces are reserved for commercial use. Additionally, 10 residential spaces will be available for shared daytime commercial use, while commercial spaces will accommodate overnight residential parking. Consistent with the City’s Climate Action Plan (CAP), the project is required to reduce the total parking provided by 27%, due to its proximity (within one-half mile) to the Sprinter rail station. A total of 51 tandem parking spaces will be provided, with tandem spaces assigned to a single residential unit. Bicycle parking will be accommodated within individual units and an enclosed bike storage area is located within the parking garage.
|
Table 2: Residential Parking Requirements |
|
|
Land Use |
Qty. |
Ratio |
Total Required Parking |
|
1 Bedroom Units |
93 |
1.5 spaces / unit |
140 |
|
2 Bedroom Unites |
72 |
2 spaces / unit |
144 |
|
Guest |
165 |
1 space / 3 units |
55 |
|
Subtotal: |
339 |
|
CAP Reduction (27%): |
-92 |
|
Total Required Residential Parking: |
247 spaces |
|
Table 3: Commercial Parking Requirements |
|
|
Land Use |
Qty. |
Ratio |
Total Required Parking |
|
Commercial Parking |
5,600 sq.ft. |
1 space / 1,000 sq.ft. |
23 |
|
CAP Reduction (27%): |
-6 |
|
Total Required Commercial Parking: |
17 spaces 1 |
|
Footnote: 1. 10 residential parking spaces will be shared with commercial uses during daytime hours and commercial parking spaces will be shared with residential uses overnight. |
To comply with CAP and California Green Building Standards Code (CALGreen) requirements, the project will provide 13 electric vehicle (EV) charging spaces, along with an additional 25 EV-ready spaces and 62 EV-capable spaces.
Conditional Use Permit (CUP 23-0002)
A Conditional Use Permit is included to allow for the temporary use of a rock crusher onsite during grading. The use of an onsite rock crusher allows the project to process rock material onsite for reuse as fill or base material for construction. This approach minimizes export volumes, reduces construction traffic and associated emissions, and helps maintain construction efficiency. The Conditional Use Permit contains conditions of approval to mitigate potential impacts from the use of the rock crusher onsite, such as requirements for placement and limits on the time of use (7:00 am to 4:30 pm).
Environmental Review
In accordance with the California Environmental Quality Act (CEQA), an Environmental Impact Report (EIR) 24-003 (SCH No. 2024020372) (Attachment D) was prepared for the proposed project.
A Scoping Meeting was conducted on February 15, 2024, and a Draft EIR was prepared to analyze potential environmental impacts of the project and three alternatives, including a reduced development footprint (14 units), a reduced intensity (80 units / 5,600 square feet commercial), and a “no project” scenario. The Draft EIR analysis identified potential project impacts in the following four areas: Biological Resources, Cultural Resources, Noise, and Tribal Cultural Resources. Although impacts to these areas were identified, the EIR includes mitigation measures that reduce the impacts to less than significant. These impacts are discussed in detail in the EIR and are summarized below:
Biological Resources
The project would result in impacts to biological resources primarily through the disturbance of approximately 2.25 acres of onsite habitat, including 2.13 acres of Diegan coastal sage scrub and 0.12 acres of non-native grassland. The project also has the potential to impact nesting birds protected under the Migratory Bird Treaty Act and California Fish and Game Code during construction activities such as tree and vegetation removal. In addition, indirect impacts to sensitive species could occur from dust, lighting, noise, and the introduction of invasive plant species. To mitigate these impacts, the project will implement measures including pre-construction nesting bird surveys, habitat restoration or mitigation to offset habitat loss, and construction best management practices to control dust, trash, and invasive species. With implementation of these mitigation measures, impacts to biological resources would be reduced to a less-than-significant level.
Cultural/Tribal Cultural Resources (combined study areas)
The project site is located in an area with documented cultural resources, including the recorded archaeological site SDI-5633. Although no new cultural resources were identified during updated surveys, there remains a potential for uncovering previously unidentified archaeological resources during grading and construction activities. In addition, through consultation with local Native American tribes under AB 52 and SB 18, the project includes mitigation measures requiring:
• Pre-construction cultural resources sensitivity training, monitoring by qualified archaeologists and Native American representatives during ground-disturbing activities;
• Procedures for evaluating and properly treating any discoveries (including the onsite repatriation);
• Integration of transplanted white sage plant specimens into the project landscaping;
• An agreement among the applicant and Rincon Band of Luiseño Indians (Rincon) for the contribution of funds for the preparation of an ethnographic study by the tribe; and
• Placement of an onsite land acknowledgment marker, approved by the Rincon Band of Luiseño Indians, prior to building occupancy.
With implementation of these mitigation measures, impacts to cultural and tribal cultural resources would be reduced to a less-than-significant level.
Noise
Construction activities associated with grading, excavation, rock drilling, and temporary rock crushing, have the potential to generate noise levels that could exceed the City's construction noise standards, particularly at nearby multi-family residential and commercial properties. Specifically, rock drilling and rock crushing operations could temporarily exceed the applicable thresholds if equipment is staged too close to property lines. To mitigate these impacts, the project will implement measures including minimum setback distances for construction equipment, the location and orientation of the rock crushing equipment, restrictions on construction hours, and, if necessary, installation of temporary noise barriers. Operational noise associated with project-generated traffic, mechanical equipment, and residential activities was analyzed and determined to comply with City noise standards. With the implementation of identified mitigation measures, all temporary and operational noise impacts would be reduced to a less-than-significant level.
The Draft EIR was circulated for 45-day public review from January 10, 2025 to February 24, 2025. During the comment period, four comment letters were received from: the California Department of Fish and Wildlife, the California Public Utilities Commission (CPUC), San Diego County Archaeological Society (SDCAS), and Lozeau Drury on behalf of Supporters Alliance for Environmental Responsibility (SAFER).
California Department of Fish and Wildlife
Comments raised concerns about the project's potential impacts on sensitive species, including the Crotch’s Bumble Bee and Pocket Mouse species. In response, the EIR was updated to include additional mitigation measures, such as pre-construction surveys during the bumble bee nesting period and acknowledgment that an Incidental Take Permit could be required if the species is detected. Regarding pocket mouse species, due to the site's isolated, urbanized condition and lack of observed small mammal activity, impacts to these species are unlikely.
CDFW also commented on mitigation ratios for habitat impacts, recommending consideration of the site's ecological value. Given the site’s urban setting and limited biological function the mitigation ratios proposed of 1:1 for Diegan coastal sage scrub and 0.5:1 for non-native grassland are sufficient. Additional comments on cumulative biological impacts, vernal pool resources, and coastal California gnatcatcher surveys were addressed by clarifying the absence of vernal pool resources onsite, the low likelihood of sensitive species presence, and the existing mitigation measures for nesting birds. The Final EIR includes minor revisions to biological monitoring and reporting requirements, incorporated CDFW's recommended clarifications, and confirmed that a Mitigation Monitoring and Reporting Program (MMRP) has been prepared. Other administrative comments regarding California Natural Diversity Database data submission, payment of filing fees, and reference materials were noted and addressed appropriately. Overall, the Final EIR fully responds to CDFW’s input.
California Public Utilities Commission
The CPUC submitted comments related to the project’s proximity to the adjacent SPRINTER rail line and pedestrian crossing. The CPUC comment mistakenly referenced receipt of a Notice of Preparation (NOP), although the City had sent a Notice of Availability at that stage. The CPUC did not submit comments during the original NOP review period. While the CPUC indicated that rail safety improvements may be necessary due to development adjacent to the active rail line, the project design addresses this concern through installation of perimeter fencing, including a 5-foot split-face block wall along the northern boundary adjacent to the rail corridor and tubular steel fencing along the east and west boundaries. The EIR concluded that there are no direct pedestrian connections from the project site to the rail corridor, and pedestrian access to the Palomar College SPRINTER Station will occur via established sidewalks along Armorlite Drive and Las Posas Road. No new environmental issues were raised, and no further response or changes to the EIR were warranted.
San Diego County Archaeological Society (SDCAS)
SDCAS comments addressed the potential for the project to encounter non-tribal cultural resources and a request that the mitigation measures be expanded to include non-tribal cultural resources. Mitigation measure MM-TCR-1 has been revised to note that all non-tribal artifacts collected by the archaeologist shall also be subject to curation during any grading operations.
Lozeau Drury on behalf of Supporters Alliance for Environmental Responsibility (SAFER)
Lozeau Drury LLP, on behalf of the Supporters Alliance for Environmental Responsibility (SAFER), submitted a comment letter on the Draft EIR for the Armorlite Lofts project. The comments generally assert that “the Draft EIR fails as an informational document and does not implement all feasible mitigation measures,” however, the letter does not identify any specific deficiencies related to any specific environmental topics, mitigation measures, or sections of the Draft EIR and follow-up requests for clarification on these comments were not returned. As discussed in the Draft EIR, all potentially significant impacts have been mitigated to less-than-significant levels, and no additional mitigation is required. The commenter also reserved the right to supplement their comments during Final EIR review and at future public hearings. No further response or revisions to the EIR were necessary because the letter did not raise any specific issues concerning the adequacy of the environmental analysis. Additionally, at the time of the preparation of this staff report, no additional comments on behalf of SAFER have been submitted.
Fiscal Impact
Fiscal and Economic Impact Reports were prepared for the project and are provided as Attachment F. These reports compare the land use change from Public Institutional to Specific Plan Area (for the Armorlite Lofts Specific Plan). For the purposes of the fiscal and economic analyses, the reports compare the project (“proposed plan”), consisting of 165 residential units and 5,600 square feet of commercial space, with development of the site consistent with the existing Public Institutional zoning (“approved plan”). Under the "approved plan" scenario, a conceptual 160,000-square-foot data center was assumed, maximizing the site's development and employment potential.
The Fiscal Impact Report identifies potential recurring municipal revenues and costs to the City’s General Fund resulting from the proposed land use change. Revenue sources analyzed include property taxes, sales taxes, licenses, permits, and fines, while expenditures include public safety, public works maintenance, and administrative services. The Fiscal Impact Report estimates that the proposed project would result in a recurring fiscal surplus of $219 to the City’s General Fund, compared to a recurring surplus of $197,070 under the data center (“approved plan”) scenario, primarily due to the lower demand for City services associated with a non-residential use.
The Economic Impact Report identifies the general economic impacts of the proposed project. Major indicators evaluated include: gross receipts (direct output plus output generated by suppliers and employee spending), employment (direct on-site and indirect employment), and one-time construction impacts. The report estimates that recurring economic output would be approximately $4.46 million annually for the proposed project, compared to $40.73 million annually if developed as a data center. This difference is primarily related to employment opportunities, as the proposed mixed-use (primarily residential) project would generate negligible permanent jobs compared to an estimated 133 jobs for the conceptual 160,000-square-foot data center. One-time construction-related economic impacts are estimated at $66.33 million for the proposed project compared to $70 million for the data center scenario.
The project site has remained undeveloped under the current Public Institutional zoning designation. Pacific Bell/AT&T determined the site was no longer needed for expansion of its existing facility and subsequently sold it to the applicant. The fiscal and economic studies prepared for the project are conservative in nature and are required to reflect reasonable economic activity consistent with the site’s existing land use designation. While the Public Institutional zone permits other uses such as schools and parks, a data center was selected as the most reasonable alternative use for analysis, given the site's location and original purpose under the Public Institutional designation. However, due to the relatively small size of the parcel (2.44 acres) and current market conditions that favor residential development, it is unlikely that the site would be developed as a data center. Additionally, the development of the site with housing and onsite affordable units is the only viable development option that also meaningfully contributes to meeting the City’s and region’s ongoing need for a broader range of housing types and affordable housing opportunities.
Public Comment
The public notice mailing list for the project includes approximately 883 unique property owners and current occupants. A Notice of Application was mailed upon the submittal of the application, and no public comments were received in response. A joint notice of public workshop and scoping session for the project was also mailed, and the workshop-scoping session was conducted virtually on February 15, 2024; however, it was not attended by any members of the public. Other than the comment letters discussed in the Environmental Review section, no additional public comments on the project were received.
Attachment(s)
Resolutions:
1. Resolution PC 25-5162 (EIR 24-0003): Recommending that the City Council certify the Environmental Impact Report;
2. Resolution PC 25-5159 (SP 23-0001): Recommending that the City Council adopt the Armorlite Lofts Specific Plan;
3. Resolution PC 25-5160 (GPA 23-0002): Recommending that the City Council approve a General Plan Amendment to change the land use designation of the 2.44-acre project site from Public Institutional (PI) to Specific Plan Area (SPA);
4. Resolution PC 25-5161 (R 23-0001): Recommending that the City Council approve a Rezone of the 2.44-acre project site from Public Institutional (P-I) to Specific Plan Area (SPA);
5. Resolution PC 25-5157 (SDP 23-0003): Recommending that the City Council approve a Site Development Plan for a mixed-use project consisting of 165 apartments and 5,600 square feet of commercial space; and
6. Resolution PC 25-5158 (CUP 23-0002): Recommending that the City Council approve a Conditional Use Permit for the temporary use of a rock crusher during site grading.
Attachments:
A. Vicinity Map
B. Requested Entitlements
C. Site & Project Characteristics
D. Armorlite Lofts Specific Plan
E. Environmental Impact Report (EIR) 24-003
F. Fiscal and Economic Impact Analysis
G. Project Plans
Prepared by: Sean del Solar, Senior Planner
Reviewed by: Scott Nightingale, Principal Planner
Stephanie Kellar, P.E., Deputy City Engineer
Submitted by: Joseph Farace, Planning Division Director