Ordinance Number 1119URGENCY ORDINANCE NO. 1119
AN INTERIM ORDINANCE OF THE CITY COUNCIL OF THE
CITY OF SAN JUAN CAPISTRANO EXTENDING
URGENCY ORDINANCE NO. 1116 PROHIBITING NEW
COMMERCIAL BATTERY ENERGY STORAGE SYSTEMS
WITHIN THE CITY OF SAN JUAN CAPISTRANO,
ADOPTED AS AN URGENCY MEASURE; AND FINDING
THE ACTION TO BE EXEMPT FROM CEQA
WHEREAS, the City of San Juan Capistrano, California (“City”) is a municipal
corporation, duly organized under the constitution and laws of the State of California; and
WHEREAS, in general, a Battery Energy Storage Systems (“BESS”) facility
collects energy from the grid, stores it, and then discharges that energy later to provide
electricity or other grid services when needed, typically at times of high demand; and
WHEREAS, Engie North America (“Applicant”) is proposing to construct a BESS
facility on land currently owned by Saddleback Church located at the northern end of the
city; and
WHEREAS, in December 2021, the City received entitlement applications and a
letter of intent from the Applicant requesting to establish a BESS facility within the Planned
Community (“PC”) District zoning designation; and
WHEREAS, the PC District zoning designation allows uses and structures
permitted within the city subject to the approval of a Comprehensive Development Plan
(“CDP”) consistent with the General Plan, pursuant to San Juan Capistrano Municipal
Code (“Municipal Code”) Section 9-3.315(b). In the absence of an approved CDP, the PC
District zoning designation allows identified interim uses pursuant to Municipal Code
Section 9-3.315(c) subject to the development standards for the Agri-Business District,
pursuant to Municipal Code Section 9-3.315(e)(3); and
WHEREAS, the Planning Director has the authority and responsibility to review
uses not listed in the Municipal Code and permit such proposed unlisted use if it falls
within the purpose and intent of the base district, is of a comparable nature to the principal,
accessory, or conditional uses set forth in the base district, is not listed in the base district,
and will not be detrimental to property in the vicinity of such use pursuant to Municipal
Code Section 9-3.203; and
WHEREAS, on April 29, 2022, the Development Services Director determined that
a BESS facility cannot be accommodated by an unlisted use determination under
Municipal Code Section 9-3.203 as the required findings could not be met. As such, the
preparation and approval by the City Council of a CDP would be required to allow the
proposed use; and
WHEREAS, in September 2022, Saddleback Church submitted a request for the
City Council to initiate a Rezone study to establish a CDP that would govern the
Ordinance No. 1119 May 7, 2024
2
approximately 161-acre Saddleback Church Rancho Capistrano property. On November
1, 2022, the City Council denied the initiation of a Rezone study to create the proposed
CDP; and
WHEREAS, the City’s current Zoning Regulations do not contain criteria
specifically for BESS facilities; and
WHEREAS, pursuant to Assembly Bill 205, an applicant proposing to build a
qualifying energy facility may file an “opt-in application for certification” at the California
Energy Commission (“CEC”) and the CEC’s permitting authority over the proposed
project is “in lieu of any permit, certificate, or similar document required by a state, local,
or regional agency, or federal agency, to the extent permitted by federal law, for those
facilities”; and
WHEREAS, in reviewing so-called opt-in projects, the CEC functions as the Lead
Agency for purposes of California Environmental Quality Act (“CEQA”) review and must
make certain findings in certifying an opt-in project; and
WHEREAS, in early 2023, Applicant opted to pursue a State approval process
through the CEC, as opposed to seeking local approval through the City Council, and in
February 2024, the Applicant formally withdrew its City applications; and
WHEREAS, in a letter dated April 18, 2024, the CEC provided notice to the City of
the CEC’s receipt of an opt-in application for the Compass Battery Energy Storage project
(24-OPT-02) (the “Opt-In Notice”). The application seeks to construct, own, and operate
an approximately 250-megawatt (“MW”) BESS in the City of San Juan Capistrano. The
BESS would be capable of storing up to 250 MW of electricity for four hours (up to 1,000
MW hours). The project would be composed of lithium-iron phosphate batteries, or similar
technology batteries, inverters, medium voltage transformers, a switchyard, a collector
substation, and other associated equipment to interconnect into the existing San Diego
Gas & Electric (“SDG&E”) Trabuco to Capistrano 138-kilovolt transmission line located
approximately 500 feet from the project site and approximately 90 feet from the project
property. The project would connect to the SDG&E electric transmission system via a
proposed loop-in transmission line that would be constructed to transfer power to and
from the proposed project. The loop-in transmission line would be supported by the
replacement of two existing transmission poles and construction of one new transmission
pole. Electric energy would be transferred from the existing power grid to the project
batteries for storage and from the project batteries to the power grid when additional
electricity is needed. No off-site transmission upgrades are required for the full capacity
of the project, and an interconnection agreement with SDG&E and the California
Independent System Operator has been executed. Following the construction of the
switchyard by Applicant, ownership and operations would transfer to SDG&E; and
WHEREAS, this action by the Applicant to file the application with the CEC
increases the urgency for the City to evaluate if, how, and where commercial BESS
facilities can be accommodated safely within the city; and
Ordinance No. 1119 May 7, 2024
3
WHEREAS, once CEC deems the application complete, CEC will be under a 270-
day period to certify the project; and
WHEREAS, while the Applicant’s proposed project may no longer require local
entitlement approvals, there remain significant public safety-related concerns that must
be analyzed prior to any BESS project moving forward within the city; and
WHEREAS, there have been several fires at BESS facilities both in California and
nationwide while the proposed location is near established residential neighborhoods in
San Juan Capistrano and downslope of several hundred homes in Laguna Niguel; and
WHEREAS, should a fire occur at the proposed BESS site adjacent to Trabuco
Creek, an environmentally sensitive watercourse that flows to the ocean, fire
extinguishing compounds used to combat the fire (either from the ground or air) would
have the potential of entering the creek and significantly impairing water quality and native
flora and fauna; and
WHEREAS, Senate Bill 38 (“SB 38”) requires every BESS facility in California to
coordinate with local emergency management agencies, unified program agencies, and
local first responders to develop an emergency response and emergency action plan for
the facility to protect surrounding residents, neighboring properties, emergency
responders, and the environment, and submit said plan to the county and the city where
the facility is located; and
WHEREAS, SB 38 recognizes the many hazards that BESS facilities create, as it
provides that the mandated emergency response and action plan may consider
responses to potential offsite impacts, such as poor air quality, threats to municipal water
supplies and water runoff, and threats to natural waterways. The plan may also include
procedures related to shelter-in-place orders and road closure notifications; and
WHEREAS, California Government Code Section 65858 provides that, without
following the procedures otherwise required prior to the adoption of a zoning ordinance,
an urgency measure in the form of an interim ordinance may be adopted by a four-fifths
vote of the City Council to protect the public from a current and immediate threat to the
public health, safety, or welfare resulting from a contemplated zoning proposal; and
WHEREAS, Government Code Section 65868 further provides that such an
urgency measure shall be effective for only forty-five days following its adoption, but may
be extended beyond the initial forty-five day period, following compliance with that
Section, for an additional ten months and fifteen days and subsequently for an additional
twelve months; and
WHEREAS, at its April 2, 2024, City Council meeting, staff’s findings demonstrated
that the potential for development of new commercial BESS facilities within the city
without adequate land use policies and standards in place to implement SB 38 and to
prevent potentially catastrophic interference with nearby communities presents a current
and immediate threat to the public’s safety and welfare, and the approval of use permits,
building permits, or other applicable entitlements for such uses would threaten public
Ordinance No. 1119 May 7, 2024
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safety and welfare; and
WHEREAS, at its April 2, 2024, meeting, the City Council voted to approve an
interim ordinance prohibiting new commercial battery energy storage systems within the
city, unless a use permit was approved prior to April 2, 2024, based upon a need for the
immediate preservation of the public health, safety, and welfare as set forth herein, for an
initial period of forty-five days while staff researched and selected the best recommended
course of action to address the safety-related concerns regarding BESS facilities
(“Urgency Ordinance No. 1116”); and
WHEREAS, the temporary prohibition on BESS facilities is scheduled to expire on
May 17, 2024; and
WHEREAS, staff has issued a written report to the City Council on the progress of
its study along with measures taken to alleviate the condition that led to the adoption of
Urgency Ordinance No. 1116; and
WHEREAS, City staff is still in the process of conducting research to understand
the impacts of BESS facilities and uses on community welfare and explore potential
amendments to the City’s Municipal Code and General Plan in relation to BESS facilities;
and
WHEREAS, staff remains concerned that the absence of adequate land use
policies and standards to address BESS facilities, including those necessary to implement
SB 38 and prevent potentially catastrophic impacts to nearby residents and environmental
resources, poses a current and immediate threat to the public’s safety and welfare; and
WHEREAS, in light of the significant safety risks associated with BESS facilities,
City staff seeks additional time to further investigate these issues, formulate
recommendations for City Council consideration, and explore adjustments to the City’s
General Plan and Zoning Regulations to mitigate the safety risks associated with BESS
facilities.
NOW, THEREFORE, the City Council of the City of San Juan Capistrano does
ordain as follows:
Section 1. The recitals above are each incorporated by reference and adopted as
findings by the City Council.
Section 2. This Interim Ordinance is not subject to the CEQA (Public Resources
Code §21000, et seq.) pursuant to CEQA Guidelines (Cal. Code Regs., tit. 14, §15000 et
seq.) Section 15060(c)(2) [activity will not result in a direct or reasonably foreseeable
indirect physical change in the environment]. Here, this Interim Ordinance is merely
extending the current prohibition on certain projects from proceeding for a period of time
during which the City will study the potential development. As a result, this Interim
Ordinance will not result in a direct or reasonably foreseeable indirect physical change in
the environment. Further, the 10-Day Report merely describes actions previously taken
to alleviate the conditions which led to the adoption of Urgency Ordinance No. 1116.
Ordinance No. 1119 May 7, 2024
5
Alternatively, this Interim Ordinance is exempt from CEQA under CEQA Guidelines
Sections 15061(b)(3) [it can be seen with certainty that there is no possibility the activity
in question may have a significant effect on the environment], and, in the alternative,
15307 [Class 7 categorical exemption for regulatory activity to assure the protection of
natural resources], and, in the alternative, 15308 [Class 8 categorical exemption for
regulatory activity to assure the protection of the environment]. Here, this Interim
Ordinance will extend the current prohibition on certain projects from being able to
proceed for a period of time during which the City will study the potential development.
This activity is meant to assure the protection of the environment and natural resources
by studying the hazards associated with BESS facilities, such as unique fire and explosion
hazards, for potential development of zoning regulations for BESS facilities. Currently,
there are no commercial BESS facilities in the city. This Project merely preserves the
status quo. Further, the 10-Day Report merely describes actions previously taken to
alleviate the conditions which led to the adoption of Urgency Ordinance No. 1116.
Alternatively, this Interim Ordinance is exempt from CEQA pursuant to Public
Resources Code Section 21080(b)(4) and CEQA Guidelines Section 15269(c) because
it prevents a clear and imminent danger that requires immediate action to prevent or
mitigate the loss of, or damage to, life, health, property, and essential public services.
Here, this Interim Ordinance will extend the current prohibition on certain projects from
being able to proceed for a period of time during which the City will study the potential
development. This activity is meant to prevent or mitigate the loss of, or damage to, life,
health, property, and essential public services by studying the hazards associated with
BESS facilities, such as unique fire and explosion hazards, for potential development of
zoning regulations for BESS facilities. Further, the 10-Day Report merely describes
actions previously taken to alleviate the conditions which led to the adoption of Urgency
Ordinance No. 1116.
Section 3. This Interim Ordinance is urgently needed for the immediate
preservation of the public health, safety, and welfare based on the findings of this Interim
Ordinance and corresponding action report. This Interim Ordinance shall take effect
immediately upon adoption.
Section 4. Urgency Ordinance No. 1116 is hereby extended for ten months and
fifteen days, unless earlier repealed by the City Council or extended in accordance with
the provisions set forth in California Government Code Section 65858.
Section 5. No use permit, variance, building permit, business license, or any other
entitlement for use shall be approved or issued for the establishment, construction, or
operation of a commercial BESS facility for any location or property within the City of San
Juan Capistrano, unless a use permit was approved prior to April 2, 2024, authorizing the
establishment, construction, and operation of the commercial BESS facility, in which case
the commercial BESS facility may continue in operation as approved but may not be
replaced or modified in any manner that would require revision or amendment to the use
permit under the City’s Zoning Regulations. As used in this ordinance, the term
“commercial” means the use of a BESS facility to provide electricity to third parties, for
consideration.
Ordinance No. 1119 May 7, 2024
6
Section 6. The penalties for land use violations that are prescribed in Section 9-
1.201 of the Municipal Code shall apply to violations of the provisions of this Interim
Ordinance.
Section 7. If any provision of this ordinance or its application to any person or
circumstance is held to be invalid, such invalidity has no effect on the other provisions or
applications of the ordinance that can be given effect without the invalid provision or
application, and to this extent, the provisions of this resolution are severable. The City
Council declares that it would have adopted this resolution irrespective of the invalidity of
any portion thereof.
Section 8. The City Council hereby directs staff to prepare, execute, and file with
the County of Orange Clerk a notice of exemption within five (5) working days of the
adoption of this Ordinance.
Section 9. The Custodian of Records for this Interim Ordinance is the City Clerk
and the records compromising the administrative record for this Interim Ordinance are
located at 32400 Paseo Adelanto, San Juan Capistrano, CA 92675.
PASSED, APPROVED AND ADOPTED by the City Council of San Juan Capistrano,
California, at a regular meeting of the City Council held on the 7th day of May, 2024.
City of San Juan Capistrano
________________________________
SERGIO FARIAS, MAYOR
ATTEST:
________________________________
CHRISTY JAKL, ACTING CITY CLERK
Ordinance No. 1119 May 7, 2024
7
STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss.
CITY OF SAN JUAN CAPISTRANO )
I, CHRISTY JAKL, Acting City Clerk of the City of San Juan Capistrano, do hereby certify
that the foregoing is a true and correct copy of Urgency Ordinance No. 1119 was duly
adopted and passed at the Regular Meeting of the City Council on the 7th day of May
2024 by the following vote, to wit:
AYES: COUNCIL MEMBERS: Taylor, Campbell, Hart and Mayor Farias
NOES COUNCIL MEMBERS: None
ABSENT: COUNCIL MEMBERS: Mayor Pro Tem Bourne
_____________________________________
CHRISTY JAKL, ACTING CITY CLERK
STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss AFFIDAVIT OF POSTING
CITY OF SAN JUAN CAPISTRANO )
I, CHRISTY JAKL, declare as follows:
That I am the duly appointed and qualified City Clerk of the City of San Juan Capistrano;
That in compliance with State laws, Government Code section 36933(1) of the State of
California, on the 2nd day of May 2024, at least 5 days prior to the adoption of the
ordinance, I caused to be posted a certified copy of the proposed ordinance entitled:
AN INTERIM ORDINANCE OF THE CITY COUNCIL OF THE CITY OF
SAN JUAN CAPISTRANO EXTENDING URGENCY ORDINANCE NO.
1116 PROHIBITING NEW COMMERCIAL BATTERY ENERGY STORAGE
SYSTEMS WITHIN THE CITY OF SAN JUAN CAPISTRANO, ADOPTED
AS AN URGENCY MEASURE; AND FINDING THE ACTION TO BE
EXEMPT FROM CEQA
This document was posted in the Office of the City Clerk
________________________________
CHRISTY JAKL, ACTING CITY CLERK
San Juan Capistrano, California
Ordinance No. 1119 May 7, 2024
8
STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss AFFIDAVIT OF POSTING
CITY OF SAN JUAN CAPISTRANO )
I, CHRISTY JAKL, declare as follows:
That I am the duly appointed and qualified City Clerk of the City of San Juan Capistrano;
that in compliance with State laws, Government Code section 36933(1) of the State of
California.
On the 8th day of May 2024, I caused to be posted a certified copy of Urgency Ordinance
No. 1119, adopted by the City Council on May 7, 2024, entitled:
AN INTERIM ORDINANCE OF THE CITY COUNCIL OF THE CITY OF
SAN JUAN CAPISTRANO EXTENDING URGENCY ORDINANCE NO.
1116 PROHIBITING NEW COMMERCIAL BATTERY ENERGY STORAGE
SYSTEMS WITHIN THE CITY OF SAN JUAN CAPISTRANO, ADOPTED
AS AN URGENCY MEASURE; AND FINDING THE ACTION TO BE
EXEMPT FROM CEQA
This document was posted in the Office of the City Clerk
________________________________
CHRISTY JAKL, ACTING CITY CLERK
San Juan Capistrano, California