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HomeMy WebLinkAbout2024-053 - Final Supplemental for The Related Bristol Specific Plan ProjectRESOLUTION NO. 2024-053 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA ANA (1) CERTIFYING THE FINAL SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FOR THE RELATED BRISTOL SPECIFIC PLAN PROJECT (SCH NO.2020029087), (2) ADOPTING ENVIRONMENTAL FINDINGS OF FACT AND A STATEMENT OF OVERRIDING CONSIDERATIONS FOR THE PROJECT PURSUANT TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT, AND (3) ADOPTING THE MITIGATION MONITORING AND REPORTING PROGRAM WHEREAS, in April 2022, the City of Santa Ana ("City") certified the General Plan Update ("GPU") Final Environmental Impact Report ("FEIR") (SCH No. 2020029087) and adopted its GPU; and WHEREAS, the GPU Land Use Element guides development by designating land uses, evaluates the potential environmental effects associated with implementation of the GPU, and addresses appropriate and feasible mitigation measures that would minimize or eliminate these impacts; and WHEREAS, the Related Bristol Specific Plan Project ("Project") site is located within the GPU South Bristol Street Focus Area and is consistent with the GPU land use designation; and WHEREAS, the Project entails, among other things, (1) demolition of the existing sixteen (16) structures on the Project Site; (2) the establishment of a new Related Bristol Specific Plan (SP No. 5) and a change of zone for the Project Site to the new Related Bristol Specific Plan (SP No. 5) designation; (3) redevelopment of the Project Site into 3,750 residential units, up to 350,000 square feet of commercial space, 250 hotel rooms, and 200 senior care units, including 6,520 onsite parking spaces, and 13.1 acres of onsite open space; and (4) approval of Vesting Tentative Tract Map ("VTTM") No. 2023-01; and WHEREAS, the City determined that a supplemental EIR ("SEIR") to the GPU FEIR is required to evaluate the potential of the Project to result in new or substantially greater environmental impacts than previously identified in the GPU FEIR, and therefore did not prepare an initial study in accordance with State CEQA Guidelines Section 15063(a); and WHEREAS, pursuant to Section 21067 of the Public Resources Code, and State CEQA Guidelines Section 15367, the City of Santa Ana is the lead agency for the Project; and Resolution No. 2024-053 Page 1 of 7 WHEREAS, pursuant to State CEQA Guidelines Section 15082, on March 17, 2023, the City sent to the Office of Planning and Research and each responsible and trustee agency a Notice of Preparation ("NOP"), which was also published in the Orange County Register, a newspaper of general circulation in the City of Santa Ana, stating that an environmental impact report would be prepared; and WHEREAS, twenty (20) comment letters were received in response to the NOP; and WHEREAS, pursuant to Public Resources Code Section 21083.9 and State CEQA Guidelines Sections 15082(c) and 15083, the City held a duly noticed scoping meeting on March 30, 2023, to solicit comments on the scope of the environmental review of the proposed project, and ten (10) written comments were received; and WHEREAS, a Draft Supplemental Environmental Impact Report (`Draft EIR") (SCH No. 2020029087) was prepared for the Project addressing comments received in response to the Notice of Preparation and evaluating the proposed Project's potentially significant environmental impacts; and WHEREAS, the Draft EIR determined that mitigation measures were required to mitigate impacts to a less than significant level for the following resource areas: air quality, cultural resources, geology and soils, greenhouse gas emissions, hazards and hazardous material, noise, and tribal cultural resources; and WHEREAS, the Draft EIR further concluded that despite the incorporation of all feasible mitigation measures, the proposed Project would nonetheless result in significant and unavoidable impacts relating to air quality and parks and recreation; and WHEREAS, in accordance with State CEQA Guidelines section 15085, a Notice of Completion was prepared and filed with the Office of Planning and Research on July 6, 2023; and WHEREAS, as required by State CEQA Guidelines section 15087(a), the City provided Notice of Availability of the Draft EIR to the public at the same time that the City sent Notice of Completion to the Office of Planning and Research, on July 6, 2023; and WHEREAS, during the public comment period, copies of the Draft EIR and technical appendices were available for review and inspection at City Hall, on the City's website, and at the City of Santa Ana Public Library; and WHEREAS, consistent with State CEQA Guidelines Section 15087(e), the Draft EIR was circulated for at least a 45-day public review and comment period from July 6, 2023, to August 21, 2023; and Resolution No. 2024-053 Page 2 of 7 WHEREAS, during the public review and comment period, the City consulted with and requested comments from all responsible and trustee agencies, other regulatory agencies, and others pursuant to State CEQA Guidelines section 15086; and WHEREAS, the City received sixteen (16) written comment letters on the Draft EIR; and WHEREAS, pursuant to Public Resources Code section 21092.5, the City provided copies of its responses to commenting public agencies at least ten (10) days prior to the City's consideration of the Final EIR, on August 1, 2024; and WHEREAS, on August 1, 2024, the City released the Final EIR; and WHEREAS, the Final EIR consists of the Draft EIR, all technical appendices prepared in support thereof; all documents incorporated by reference, all written comments letters received on the Draft EIR, written responses to all written comments letters and verbal comments received on the Draft EIR, revisions to the Draft EIR and technical appendices, the Mitigation Monitoring and Reporting Program, and Statement of Overriding Considerations; and WHEREAS, on August 12, 2024, the Planning Commission conducted the public hearing to consider the Draft EIR and the Project, and solicited comments on the document. After hearing all relevant testimony from staff, the public and the City's consultant team, the Planning Commission voted to recommend that the City Council certify the EIR for the Project, adopt the Findings of Fact, the Statement of Overriding Considerations, and the Mitigation Monitoring and Reporting Program, and approve the Project; and WHEREAS, on September 17, 2024, the City Council held a duly noticed public hearing to consider the Final EIR and the Project, at which hearing members of the public were afforded an opportunity to comment and the Project was fully considered, after which the item was continued to the regularly -scheduled City Council meeting of October 1, 2024; and WHEREAS, all potentially significant adverse environmental impacts were sufficiently analyzed in the Final EIR; and WHEREAS, as contained herein, the City has endeavored in good faith to set forth the basis for its decision and recommendations on the Project; and WHEREAS, all of the requirements of the Public Resources Code and the CEQA Guidelines have been satisfied by the City in connection with the preparation of the Final EIR, which is sufficiently detailed so that all of the potentially significant environmental effects of the Project have been adequately evaluated; and Resolution No. 2024-053 Page 3 of 7 WHEREAS, the Final EIR prepared in connection with the Project sufficiently J analyzes the Project's potentially significant environmental impacts, and the Final EIR y analyzes a range of feasible alternatives to address whether these effects can be reduced to a level of less than significant; and WHEREAS, the City has made certain findings of fact, as set forth in Exhibit A to this Resolution, attached hereto and incorporated herein, based upon the oral and written evidence presented to it as a whole and the entirety of the administrative record for the Project, which are incorporated herein by this reference; and WHEREAS, the City finds that the Project's environmental topics that would result in no impact, as identified in the Final EIR, are described in Section II of the Findings of Fact, attached hereto as Exhibit A; and WHEREAS, the City finds that the Project's environmental impacts that are less than significant without implementation of project -specific mitigation measures, as identified in the Final EIR, are described in Section III of the Findings of Fact, attached hereto as Exhibit A; and WHEREAS, the City finds that the Project's impacts that, without mitigation, would result in significant adverse impacts, and that upon implementation of the mitigation measures provided in the Final EIR, would be considered less than significant, are described in Section IV of the Findings of Fact, attached hereto as Exhibit A; and WHEREAS, the City finds that the Project's impacts that, even with mitigation measures, would remain significant and unavoidable are described in Section V of the Findings of Fact, attached hereto as Exhibit A; and WHEREAS, the cumulative impacts of the Project identified in the EIR and set forth herein, are described in Section VI of the Findings of Fact, attached hereto as Exhibit A; and WHEREAS, the potential significant irreversible environmental changes that would result from the proposed Project are described in Section VII of the Findings of Fact, attached hereto as Exhibit A; and WHEREAS, the existence of any growth -inducing impacts and commitment of resources resulting from the proposed Project are described in Section VIII of the Findings of Fact, attached hereto as Exhibit A; and WHEREAS, the City finds that the reasonable alternatives to the Project are described in Section Ix of the Findings of Fact, attached hereto as Exhibit A; and WHEREAS, the Statement of Overriding Considerations that indicates the benefits of the Project outweigh the unavoidable significant environmental effects is described in Section x of the Findings of Fact, attached hereto as Exhibit A; and Resolution No. 2024-053 Page 4 of 7 WHEREAS, all the mitigation measures identified in the Final EIR and necessary to reduce the potentially significant impacts of the Project to a level of less than significant are set forth in the Mitigation Monitoring and Reporting Program ("MMRP"), attached hereto as Exhibit B; and WHEREAS, prior to taking action, the City has heard, been presented with, reviewed, and considered all of the information and data in the administrative record, including but not limited to the Final EIR and all oral and written evidence presented to it during all meetings and hearings; and WHEREAS, the Final EIR reflects the independent judgment of the City and is deemed adequate for purposes of making decisions on the merits of the Project; and WHEREAS, no comments made in the public hearing conducted by City Council and no additional information submitted to the City Council have produced substantial new information requiring recirculation of the Final EIR or additional environmental review of the project under Public Resources Code Section 21092.1 and State CEQA Guidelines Section 15088.5; and WHEREAS, all other legal prerequisites to the adoption of this Resolution have occu rred . NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Santa Ana as follows: Section 1. The above recitals are true and incorporated herein by reference. Section 2. The City Council hereby finds that it has been presented with the Final EIR, which it has reviewed and considered, and further finds that the Final EIR is an accurate and objective statement that has been completed in full compliance with CEQA and the State CEQA Guidelines, and that the Final EIR reflects the independent judgment and analysis of the City, acting as lead agency for the Project. Section 3. The City Council declares that no evidence of new significant impacts or any new information of "substantial importance," as defined by State CEQA Guidelines Section 15088.5, has been received by the City after circulation of the Final EIR that would require recirculation of the Final EIR. Section 4. The City Council hereby: A. Certifies the Final EIR based on the entirety of the record of proceedings. B. Adopts the Findings of Fact and Statement of Overriding Considerations, attached hereto and incorporated herein as Exhibit A, after balancing the significant and unavoidable air quality and parks and recreation impacts of the proposed Project against the benefits of the proposed Project. Resolution No. 2024-053 Page 5 of 7 C. Adopts the MMRP attached hereto and incorporated herein as Exhibit B, consistent with Public Resources Code Section 21081.6; makes implementation of the mitigation measures in the MMRP a condition of approval of the Project; and finds that in the event of any inconsistencies between the mitigation measures set forth herein and the MMRP, the MMRP shall control. D. Directs City staff to cause a Notice of Determination to be filed and posted with the County of Orange Registrar-Recorder/County Clerk and the State Clearinghouse within five working days of the City Council's final project approval. Section 5. The documents and materials associated with this Resolution that constitute the record of proceedings on which these findings are based are located at Santa Ana City Hall, 20 Civic Center Plaza, Santa Ana, CA 92701. The Planning Manager is the custodian of records for the record of proceedings. This information is provided pursuant to Public Resources Code section 21081.6. Section 6. This Resolution shall take effect immediately upon its adoption by the City Council, and the City Clerk shall attest to and certify the vote adopting this Resolution. ADOPTED this 1st day of October, 2024 by the following vote: APPROVED AS TO FORM: Sonia R. Carvalho, City Attorney Laura A. Rossini Chief Assistant City Attorney Resolution No. 2024-053 Page 6 of 7 AYES: Councilmembers Amezcua, Bacerra, Hernandez, Lopez Penaloza, Vazquez (6) _ .._. NOES: Councilmembers None 0 ABSTAIN: Councilmembers Phan 1 ) -- recusal ._ ABSENT: Councilmembers None 0 CERTIFICATE OF ATTESTATION AND ORIGINALITY I, JENNIFER L. HALL, City Clerk, do hereby attest to and certify the attached Resolution No. 2024-053 to be the original resolution adopted by the City Council of the City of Santa Ana on October 1, 2024. Date: '-� Resolution No. 2024-053 Page 7of7 EXHIBIT A FINDINGS OF FACT CEQA FINDINGS OF FACT FOR THE RELATED BRISTOL !'MIXED -USE PROJECT SANTA ANA, CALIFORNIA STATE CLEARINGHOUSE NO.2020029087 CITY OF SANTA ANA DP NO. 2022-31 Public Resources Code section 21002 states that "public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects[.]" Section 21002 further states that the procedures required by CEQA "are intended to assist public agencies in systematically identifying both the significant effects of proposed projects and the feasible alternatives or feasible mitigation measures which would avoid or substantially lessen such significant effects." Agencies demonstrate compliance with section 21002's mandate by adopting findings before approving projects for which EIRs are required. (See Pub. Resources Code, § 21081, subd. (a); State CEQA Guidelines § 15091, subd. (a).) The approving agency must make written findings for each significant environmental effect identified in an EIR for a proposed project and must reach at least one of three permissible conclusions. • The first possible finding is that "[c]hanges or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effect as identified in the final EIR." (State CEQA Guidelines § 15091, subd. (a)( I ).) • The second permissible finding is that "[s]uch changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding" and that "[s]uch changes have been adopted by such other agency or can and should be adopted by such other agency." (State CEQA Guidelines § 15091, subd. (a)(2).) • The third potential conclusion is that "[s]pecific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR." (State CEQA Guidelines § 15091, subd. (a)(3).) Agencies must not adopt a project with significant environmental impacts if feasible alternatives or mitigation measures would substantially lessen the significant impacts. Public Resources Code section 21061.1 defines "feasible" to mean "capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social and technological factors." State CEQA Guidelines section 15364 adds "legal" considerations as another indicium of feasibility (See also Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 565). Project objectives also inform the determination of "feasibility." (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 401, 417.) Further, "`feasibility' under CEQA encompasses `desirability' to the extent that desirability is based on a reasonable balancing of the relevant economic, environmental, social, and technological factors." (1d.; see also Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 715.) An agency need not, however, adopt infeasible mitigation measures or alternatives (State CEQA Guidelines § 15091, subds. (a), (b)). Further, environmental impacts that are less than significant do not require the imposition of mitigation measures (Leonoff v. Monterey County Board of Supervisors (1990) 222 Cal.App.3d 1337, 1347). Notably, section 21002 requires an agency to "substantially lessen or avoid" significant adverse environmental impacts. Thus, mitigation measures that "substantially lessen" significant environmental impacts, even if not completely avoided, satisfy section 21002's mandate. (Laurel Hills Homeowners Assn. v. City Council (1978) 83 Cal.App.3d 515, 521 ("CEQA does not mandate the choice of the environmentally best feasible project if through the imposition of feasible mitigation measures alone the appropriate public agency has reduced environmental damage from a project to an acceptable level"); Las Virgenes Homeowners Federation, Inc. Y. County of Los Angeles (1986) 177 Cal.App.3d 300, 309 ("[flhere is no requirement that adverse impacts of a project be avoided completely or reduced to a level of insignificance ... if such would render the Project unfeasible"). CEQA requires that the lead agency adopt mitigation measures or alternatives, where feasible, to substantially lessen or avoid significant environmental impacts that would otherwise occur. Project modification or alternatives are not required, however, where such changes are infeasible or where the responsibility for modifying the Project lies with some other agency. (State CEQA Guidelines § 15091, subds. (a), (b)-) The California Supreme Court has stated, "[t]he wisdom of approving ... any development project, a delicate task which requires a balancing of interests, is necessarily left to the sound discretion of the local officials and their constituents who are responsible for such decisions. The law as we interpret and apply it simply requires that those decisions be informed, and therefore balanced." (Citizens of Goleta Valley v. Board of Supervisors, supra, 52 Ca1.3d at p. 57b). The City of Santa Ana has determined that based on all the evidence presented, including, but not limited to, the Final EIR, written and oral testimony given at meetings and hearings on the Project, and submission of testimony from the public, organizations and regulatory agencies, the following environmental impacts associated with the Project are: (1) less than significant and do not require mitigation; (2) potentially significant and each of these impacts would be avoided or reduced to a level of insignificance through the identified mitigation measures; or (3) significant and cannot be fully mitigated to a level of less than significant but will be substantially lessened to the extent feasible by the identified mitigation measures. +CrrT1r)KI ENVIRONMENTAL REVIEW AND PUBLIC PARTICIPATION The Final Supplemental EIR includes the Draft Supplemental Environmental Impact Report (EIR) dated July 2023, written comments on the Draft Supplemental EIR that were received during the public review period, written responses to those comments and changes to the Draft Supplemental EIR, and the Final Supplemental EIR Errata making minor corrections and revisions to the Final Supplemental EIR. In conformance with CEQA and the State CEQA Guidelines, the City of Santa Ana conducted an extensive environmental review of the Related Bristol Mixed -Use Project: • The City of Santa Ana concluded that a Supplemental EIR should be prepared, and the Notice of Preparation (NOP) was released for a 30-day public review period from March 17, 2023, through April 17, 2023. The NOP was posted at the Orange County Clerk's Office on March 16, 2023. The notice was published in the Orange County Register, a newspaper of general circulation. Under CEQA, a Lead Agency may proceed directly with preparation of the EIR without preparation of an Initial Study if it is clear that an EIR will be required (State CEQA Guidelines Section 15060[d]). The City of Santa Ana has made such a determination for this Project and has not prepared an Initial Study. • Completion of a scoping process, in which the public was invited by the City of Santa Ana to participate. The scoping meeting for the Supplemental EIR was held on March 30, 2023 at 5:30 p.m. at the McFadden Institute of Technology located at 2701 South Raitt Street in Santa Ana. The notice of a public scoping meeting was included in the NOP distributed on March 17, 2023. • Preparation of a Draft Supplemental EIR by the City of Santa Ana, which was made available for a 45-day public review period (July 6, 2023 through August 21, 20232023). The Notice of Availability (NOA) for the Draft Supplemental EIR was sent to all persons, agencies and organizations on the interest list interested persons, published in the July 6, 2023 Orange County Register, and posted at the Orange County Clerk's Office and the State Clearinghouse (SCH) at the Governor's Office of Planning and Research (OPR) on July 61 2023. Copies of the Draft Supplemental EIR were made available for public review at the City of Santa Ana, Planning Division Counter, located at 20 Civic Center Plaza, M-20, Santa Ana, CA 92701, and the City of Santa Ana Public Library, located at 26 Civic Center Plaza, Santa Ana, CA 92701. The Draft Supplemental EIR was also available for review and download via the following City website location: https:,//www.santa-ana.org/related- california-bristol-specific-plan. • The Final Supplemental EIR contains comments on the Draft Supplemental EIR, responses to those comments, revisions to the Draft Supplemental EIR, if any, and appended documents. The Final Supplemental EIR was released for a 10-day agency review period prior to certification of the Final Supplemental EIR. • Pursuant to CEQA Guidelines Section 15095, staff is directed as follows: ay copy of the Final Supplemental EIR and CEQA Findings of Fact shall be retained in the Project files; b) copy of the Final Supplemental EIR and CEQA Findings of Fact shall be provided to the Project applicant who is responsible for providing copy of same to all CEQA "responsible" agencies. SECTION II RESOLUTION REGARDING ENVIRONMENTAL TOPIC AREAS WITH NO IMPACT Based upon the Supplemental EIR prepared for the Project, the City determined that the Project would have no impact or a less than significant impact on the following environmental topic areas and that no further, detailed analysis of these topics was required in the Supplemental EIR: • Aesthetics • Agriculture and Forestry Resources • Biological Resources • Mineral Resources • Wildfire The evidence in support of the finding that the Project will not have a significant impact on these environmental topic areas are set forth in the Draft EIR which is incorporated by reference (Supplemental Draft EIR, pp. 5.16-7 to 5.16-12). Based upon the Supplemental EIR prepared for the Project, the City determined that the Project would have no impact on the following environmental topic areas: A. Cultural Resources Impact Finding: The Project would not cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5 (Draft Supplemental EIR at p. 5.2- 9). Facts in Support of Findings: The Project site does not contain any historical resources. As described in the Historical Resource Assessment that was prepared for the Project site (included as Appendix D of the Draft Supplemental EIR), 16 of the existing buildings onsite were constructed more than 45 years ago. None of the buildings were identified as meeting any historic resource criterion and do not meet the definition of a historic resource pursuant to CEQA or the City of Santa Ana. Overall, the site does not include any historic resources and implementation of the proposed Project would not impact a historic resource. Therefore, Project impacts would be less than those disclosed in the GPU FEIR, which were determined to be significant and unavoidable despite inclusion of mitigation (Draft Supplemental EIR at pp. 5.2-9 through 5.2-14). B. Energy Impact Finding: The Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency (Draft Supplemental EIR at p. 5.3-13). Facts in Support of Findings: The proposed Project would be required to meet the CCR Title 24 energy efficiency standards in effect during permitting of the Project. The City's administration of the CCR Title 24 requirements includes review of design components and energy conservation measures that occurs during the permitting process, which ensures that all requirements are met. In addition, the Project would not conflict with or obstruct Opportunities to use renewable energy, such as solar energy. Redevelopment of the site would not result in obstruction of opportunities for use of renewable energy. In addition, Draft Supplemental EIR Section 5.5, Greenhouse Gas Emissions, Mitigation Measure GHG-1 requires installation of solar panels or other source of renewable electricity generation onsite to the maximum roof area available. Mitigation Measure GHG-2 requires the proposed Project to meet 2022 CALGreen Tier 2 voluntary energy efficiency standards, which surpass the building code energy efficiency requirements, and Mitigation Measure GHG-5 requires the proposed Project to install Energy Star certified or of equivalent energy efficient appliances in all residential units. Thus, the proposed Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency, and impacts would not occur. This is consistent with the findings of the GPU FEIR, which determined that implementation of the City's GPU would not interfere with any plan for renewable energy or energy efficiency, and that no impacts would occur (Draft Supplemental EIR at pp. 5.3-13 through 5.3-15). C. Geology and Soils Impact Finding: The Project would not expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault. (Draft Supplemental EIR at p. 5.4-9). Facts in Support of Findings: The Project site is not located within an Alquist-Priolo Earthquake Fault Zone and no active faults are known to cross the site. The closest known active faults are associated with the San Joaquin Hills Fault, located approximately 1.3 miles northeast from the site; the Newport -Inglewood Fault Zone, approximately 4.1 miles southwest of the site (Appendix G to the Draft Supplemental EIR). The San Joaquin Hills fault does not rupture at the ground surface. Because no known faults exist on the site, the proposed Project would not expose people or structures to potential substantial adverse effects from rupture of a known earthquake fault that is delineated on an Alquist-Priolo Earthquake Fault Zoning Map or other evidence of a fault, and no impacts would occur. Therefore, impacts related to Project buildout of the site would be consistent with the impact conclusions set forth in the GPU FEIR, which determined that impacts related to surface rupture of a fault would be less than significant (Draft Supplemental EIR at p. 5.4-9). Impact Finding: The Project would not expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving landslides (Draft Supplemental EIR at p. 5.4-10). Facts in Support of Findings: The proposed Project site is located in a seismically active region subject to strong ground shaking. However, as described previously, the Geotechnical Report (included as Appendix G to the Draft Supplemental EIR) describes that the Project site is generally level and no hills or slopes are adjacent to the site. In addition, the site is not within a seismically induced landslide hazard zone area and is not considered potentially susceptible to seismically - induced slope instability. Thus, the Project site is not located within or adjacent to an earthquake - induced landslide area, and the proposed Project would not expose people or structures to substantial adverse effects involving landslides, and impacts related to landslides would not occur. Therefore, impacts related to Project buildout of the site would be consistent with the impact conclusions set forth in the GPU FEIR, which determined that impacts related to landslides would be less than significant (Draft Supplemental EIR at p. 5.4-10). Impact Finding: The Project would not have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater (Draft Supplemental EIR at 5.4-13). Facts in Support of Findings: The Project site is currently connected to the City's sewer system. As detailed in Draft Supplemental EIR Chapter 3.0, Project Description, the Project would install a new onsite sewer system that would connect to the existing 78-inch sewer in Sunflower Avenue. The proposed Project would not use septic tanks or alternative wastewater disposal systems. As a result, no impacts related to septic tanks or alternative wastewater disposal systems would occur from implementation of the proposed Project. Therefore, impacts related to Project buildout of the site would be less than the impact conclusions set forth in the GPU FEIR, which determined that impacts related to septic tanks would be less than significant (Draft Supplemental EIR at 5.4-13). D. Hazards and Hazardous Materials Impact Finding: The Project would not be located on a site that is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, create a significant hazard to the public or the environment (Draft Supplemental EIR at p. 5.6-26). Facts in Support of Findings: The Phase I Environmental Site Assessment (included as Appendix J to the Draft Supplemental EIR) that was conducted database searches to determine if the Project area or any nearby properties are identified as currently having hazardous materials. The record searches determined that although the site has a history of various uses and identified as previously generating hazardous wastes and clean-up activities, the Project site is not located on or near by a site which is included on a list of hazardous materials sites pursuant to Government Code Section 65962.5. As a result, impacts related to hazards from being located on or adjacent to a hazardous materials site would not occur from implementation of the proposed Project (Draft Supplemental EIR at p. 5.6-26). Impact Finding: The Project would not expose people or structures either directly or indirectly to a significant risk of loss, injury, or death involving wildfires (Draft Supplemental EIR at p. 5.6-29). Facts in Support of Findings: The Project site is located within an urban developed area and is not located within an identified wildland fire hazard area and is not an area where residences are intermixed with wildlands. In addition, implementation of the proposed Project would be required to adhere to the following chapters of the City's Municipal Code to reduce potential fire hazards: Chapter 8.2 Uniform Building Code, Chapter 8.4 Uniform Mechanical Code, Chapter 8.5 National Electric Code, and Chapter 14 City of Santa Ana Fire Code. Additionally, the Project would be in compliance with any further guidelines from the Orange County Fire Authority (OCFA) related to fire prevention and is subject to permit approval by the City's Building Division. Therefore, the proposed Project would not expose people or structures to a significant risk of loss, injury, or death from wildfires and no impacts would occur (Draft Supplemental EIR at p. 5.6-29). E. Hydrology and Water Quality Impact Finding: The Project is not in a flood hazard, tsunami, or seiche zone that could risk release of pollutants due to Project inundation (Draft Supplemental EIR at p. 5.7-17). Facts in Support of Findings: The FEMA FIRM for the Project area (06059CO279J) shows that the Project site is located within "Zone X," which is an area of minimal flood hazard potential outside of the 0.2 percent annual chance flood. Thus, the Project site is not located within a flood hazard area that could be inundated with flood flows and result in release of pollutants. Impacts related to flood hazards and pollutants would not occur from the Project. The Project site is over 5.9 miles from the Pacific Ocean, and outside of the Tsunami Hazard Zone identified by the California Department of Conservation. Thus, the Project site would not be inundated by a tsunami that could result in the release of pollutants, and impacts would not occur. Additionally, because the Project site is not within the vicinity of a water body, it is not at risk for seiche flood hazards. Therefore, the release of pollutants on the Project site resulting from a seiche inundation would not occur (Draft Supplemental EIR at p. 5.7-17). F. Land Use and Plannin Impact Finding: The Project would not physically divide an established community (Draft Supplemental EIR at p. 5.8-19). Facts in Support of Findings: The Project site has long been developed with a shopping center that includes 16 commercial buildings with surface parking areas, vehicle circulation drives, and ornamental landscaping. The Project site is surrounded by and well connected to roadways. Areas in all directions are developed with commercial and residential uses. The proposed Project would demolish the existing development and related infrastructure on the site and provide a new mixed -use development with up to 3,750 multi -family residential units; up to 350,000 SF of commercial uses; a 250-room hotel; a senior living/continuum of care use with up to 200 units; and approximately 13.1 acres of common open space. The proposed Project would change the site from a partially underutilized shopping center to a residential and commercial mixed -use community with open space and gathering spaces, consistent with the DC-5 designation for development of transit -oriented high density urban villages. In addition, the proposed Project would not change roadways in a manner that would inhibit access or install any infrastructure that would result in physical division. The Specific Plan includes development of new onsite roadways and installation of new onsite infrastructure that would connect to existing roadways and infrastructure that are adjacent to the site. Thus, the proposed Project would not result in impacts related to physical division of an established community. This is consistent with the findings of the GPU FEIR, which determined that the GPU provides for infill redevelopment and would concentrate development in areas to take advantage of mass transit and provide mixed -use opportunities, and would not introduce any new development, roadways, or other infrastructure that would bisect existing communities or neighborhoods (Draft Supplemental EIR at pp. 5.8-19 through 5.8-20). G. Population and Housing Impact Finding: The Project would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere (Draft Supplemental EIR at p. 5.10- 1 1 ). Facts in Support of Findings: The Project site is currently developed with commercial retail buildings and there is no existing housing on the Project site. The proposed Project would implement new housing on the site, where none currently exists. Therefore, the proposed Project would not result in displacement of substantial numbers of people, such that construction of replacement housing elsewhere would be necessary. As a result, impacts would not occur and would be consistent with those identified in the GPU FEIR (Draft Supplemental EIR at p. 5.10-1 1 ). H. Utilities and Service Systems Impact Finding: The Project would comply with federal, State, and local statutes and regulations related to solid waste (Draft Supplemental EIR at p. 5.15-24). Facts in Support of Findings: All solid waste -generating activities within the City is subject to the requirements set forth in Section 5.408.1 of the 2016 California Green Building Standards Code that requires demolition and construction activities to recycle or reuse a minimum of 65 percent of the nonhazardous construction and demolition waste, and AB 341 that requires diversion of a minimum of 75 percent of operational solid waste. Also, the proposed senior/'continuum of care housing facility would be required to comply with the California Medical Waste Management Act for proper disposal of all medical waste, which would be ensured through the State's medical permitting process. Implementation of the proposed Project would be consistent with all state regulations, as ensured through the City's development project permitting process. Therefore, the proposed Project would comply with all solid waste statute and regulations; and impacts would not occur. Thus, the impacts of the proposed Project are less than those identified by the GPU FEIR, which determined that development would be required to implement regulations related to solid waste and that impacts would be less than significant (Draft Supplemental EIR at p. 5.15-24). This page was intentionally left blank. sFr_TinN III RESOLUTION REGARDING ENVIRONMENTAL IMPACTS NOT REQUIRING MITIGATION Section 15091 of the State CEQA Guidelines does not require specific findings to address environmental effects that an EIR identifies as "less than significant" where no mitigation is required. These findings will nevertheless fully account for all such effects identified in the Draft Supplemental EIR in this Section Ill. Thus, the City hereby finds that the following potential environmental impacts of the Project are less than significant and do not require the imposition of mitigation measures: A. Air Quality Impact Finding: The Project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people (Draft Supplemental EIR at p. 5.1-42). Facts in Support of Findings: The proposed Project would not emit other emissions, such as those generating objectionable odors, that would affect a substantial number of people. The type of facilities that are considered to result in other emissions, such as objectionable odors, include wastewater treatments plants, compost facilities, landfills, solid waste transfer stations, fiberglass manufacturing facilities, paint/coating operations (e.g., auto body shops), dairy farms, petroleum refineries, asphalt batch plants, chemical manufacturing, and food manufacturing facilities. The proposed Project would implement a new mixed -use development including residential, open space/recreation, retail, restaurant, and other commercial development. These land uses do not involve the types of uses that would emit objectionable odors affecting a substantial number of people. During construction, emissions from construction equipment, architectural coatings, and paving activities may generate odors. However, these odors would be temporary, intermittent in nature, and would not affect a substantial number of people. The noxious odors would be confined to the immediate vicinity of the construction equipment. Also, the short-term construction -related odors would cease upon the drying or hardening of the odor -producing materials. In addition, all Project -generated solid waste would be stored in covered containers and removed at regular intervals in compliance with solid waste regulations and would not generate objectionable odors. Therefore, impacts associated with other operation- and construction - generated emissions, such as odors, would be less than significant (Draft Supplemental EIR at pp. 5.1-42 through 5.1-43). B. Cultural Resources Impact Finding: The Project would not disturb any human remains, including those interred outside of formal cemeteries (Draft Supplemental EIR at p. 5.2-15). Facts in Support of Findings: The Project site has been extensively disturbed and has not been previously used as a cemetery. Thus, impacts related to human remains are less than significant. In the unanticipated event that human remains are found during project construction activities compliance with California Health and Safety Code Section 7050.5 would ensure that human remains are treated with dignity and as specified by law. Compliance with the existing California Health and Safety Code regulations would ensure impacts related to potential disturbance of human remains are less than significant. Therefore, impacts related to Project buildout of the site would be consistent with the impact conclusions set forth in the GPU FEIR, which determined that impacts to human remains would be less than significant (Draft Supplemental EIR at pp. 5.2-15 through 5.2-16). C. Energy Impact Finding: The Project would not result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation (Draft Supplemental EIR at p. 5.3-8). Facts in Support of Findings: Construction During construction of the proposed Project, energy would be consumed in three general forms, petroleum -based fuels, electricity, and energy used in the production of construction materials. Construction activities related to each phase of the proposed mixed -use Project would not be expected to result in demand for fuel greater on a per -unit -of -development basis than other development projects in Southern California. As identified in Table 5.3-3 of the Draft Supplemental EIR, the overall diesel fuel consumption during construction of the proposed Project would be 529,054 gallons for Phase 1, 287,909 gallons for Phase 2, and 637,296 gallons for Phase 3. Gasoline consumption would be 384,969 gallons for Phase 1, 99,845 gallons for Phase 2, and 416,625 gallons for Phase 3. Construction contractors are required to demonstrate compliance with applicable California Air Resources Board (CARE) regulations and compliance with existing CARB idling restrictions and the use of newer engines and equipment would reduce fuel combustion and energy consumption on the Project site. Overall, construction activities would require limited energy consumption and would comply with all existing regulations. Thus, impacts related to construction energy usage would be less than significant, which is consistent with the findings of the GPU FEIR (Draft Supplemental EIR at pp. 5.3-8 through 5.3-10). Operation Once operational, the mixed -use Project would generate demand for electricity, natural gas, as well as gasoline for motor vehicle trips. Operational use of energy includes the heating, cooling, and lighting of buildings, water heating, operation of electrical systems and plug-in appliances within buildings, parking lot and outdoor lighting, and the transport of electricity, natural gas, and water to the areas where they would be consumed. As identified in Table 5.3-3 of the Draft Supplemental EIR, Project operations for Phase 1 are estimated to consume approximately 431,837 gallons of diesel fuel and 1,435,828 gallons of gasoline fuel per year. Project operations for Phase 2 are estimated to consume approximately 181,517 gallons of diesel fuel and 570,283 gallons of gasoline fuel per year. Project operations for Phase 3 are estimated to consume approximately 261,236 gallons of diesel fuel and 868,,590 gallons of gasoline fuel per year. Project operations at buildout are estimated to consume approximately 874,590 gallons of diesel fuel and 2,874,701 gallons of gasoline fuel per year. In addition, the Proposed Project in Phase I would require approximately 17,182,736 kWh of electricity per year and approximately 279,772 therms of natural gas per year. Operation of the proposed Project in Phase 2 would require approximately 6,100,357 kWh of electricity per year and approximately 88,107 therms of natural gas per year. Operation of the proposed Project in Phase 3 would require approximately 9,271,206 kWh of electricity per year and approximately 151,580 therms of natural gas per year. Operation of the entire proposed Project at buildout would require approximately 32,554,299 kWh of electricity per year and approximately 519,459 therms of natural gas per year. g The proposed mixed --use development would be required to meet the current Title 24 energy efficiency standards. The City's administration of the Title 24 requirements and the City's Climate Action Plan includes review of design components and energy conservation measures that occurs during the permitting process, which ensures that all requirements are met. The Project does not propose any operational characteristics or features that would result in excessive or wasteful use of energy. The Project would consist of an urban infill redevelopment in a Transit Priority Area (TPA) and High Quality Transit Area that would provide mixed residential, open space., and commercial (retail restaurant) uses. Since it would be undertaken on a currently developed and underutilized site, and would be located near existing offsite employment, commercial, residential, and retail destinations and in proximity to existing public bus stops and freeways, which would result in reduced vehicle trips and Vehicle Miles Traveled (VMTj in comparison to a Project of similar size and land without close access to employment, service and retail destinations, public transit, and freeways. In addition, the Project site is within an area where existing infrastructure would provide for efficient delivery of electricity and natural gas to the Project and the Project would not inhibit the development of other alternative energy sources. Furthermore, existing and future regulations are likely to result in more efficient use of all types of energy, and reduction in reliance on non- renewable sources of energy. These include the federal Energy Independence and Security Act, the state Long Term Energy Efficiency Strategic Plan, SB 350 and AB 1007, which are designed to reduce reliance on non-renewable energy resources and reduce demand by providing federal tax credits for purchasing fuel -efficient items and improving the renewable fuel, appliance, and lighting standards. Thus, operation of the proposed Project would not use large amounts of energy or fuel in a wasteful, inefficient, or unnecessary manner, and impacts would be less than significant. This is consistent with the findings of the GPU FEIR, which determined that implementation of existing regulatory requirements would ensure that energy demand associated with growth under the GPU would not be inefficient, wasteful, or unnecessary; and that energy impacts would be less than significant. Moreover, although the Project's impacts related to energy would be less than significant, mitigation measures included in the Draft Supplemental EIR for other resource areas would serve to further reduce the Project's energy use. For instance, Draft Supplemental EIR Section 5.1, Air Quality, includes Mitigation Measures AQ-3 and AQ-4. Also, as detailed in Draft Supplemental EIR Section 5.5, Greenhouse Gas Emissions, Mitigation Measure GHG-1 requires installation of solar panels or other source of renewable electricity generation onsite to the maximum roof area available. Mitigation Measure GHG-2 requires the proposed Project to meet 2022 CALG reen Tier 2 voluntary energy efficiency standards, which surpass the building code energy efficiency requirements, and Mitigation Measure GHG-5 requires the proposed Project to install Energy Star certified or of equivalent energy efficient appliances in all residential units (Draft Supplemental EIR at pp. 5.3-10 through 5.3-13). D. Geology and Soils Impact Finding: The Project would not expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking (Draft Supplemental EIR at p. 5.4-9). Facts in Support of Findings: The Project site is within a seismically active region, with numerous faults capable of producing significant ground motions. The closest known active faults are associated with the San Joaquin Hills Fault, located approximately 1.3 miles northeast from the site; the Newport -Inglewood Fault Zone, approximately 4.1 miles southwest of the site (included as Appendix G to the Draft Supplemental EIR). Therefore, Project implementation could subject people and structures to hazards from ground shaking. However, seismic shaking is a risk throughout southern California, and the Project site is not at greater risk of seismic activity or impacts as compared to other areas within the region. The CBC includes provisions to reduce impacts caused by major structural failures or loss of life resulting from earthquakes or other geologic hazards. For example, Chapter 16 of the CBC contains requirements for design and construction of structures to resist loads, including earthquake loads. The CBC provides procedures for earthquake resistant structural design that include considerations for onsite soil conditions, occupancy, and the configuration of the structure including the structural system and height. The City of Santa Ana has adopted the CBC as part of the Municipal Code Chapter 8, Article 2, Division 1, which regulates all building and construction projects within the City and implements a minimum standard for building design and construction that includes specific requirements for seismic safety, excavation, foundations, retaining walls and site demolition. Structures built in the City are required to be built in compliance with the CBC. The Project would be required to adhere to the provisions of the CBC as part of the building plan check and development review process. Compliance with the requirements of the CBC for structural safety would reduce hazards from strong seismic ground shaking. Because the proposed Project would be required to be constructed in compliance with the CBC and the City's Municipal Code, which would be verified through the City's plan check and permitting process and is included as PPP GEO-1, the proposed Project would result in a less than significant impact related to strong seismic ground shaking (Draft Supplemental EIR at pp. 5.4-9 through 5.4-10). Plans, Program and Policies. PPP GEC#-1: CBC Compliance. The proposed Project is required to comply with the California Building Standards Code (CBC) as included in the City's Municipal Code as Chapter 8, Article 2, Division I. to preclude significant adverse effects associated with seismic and soils hazards. As part of CBC compliance, CBC related and geologist and,/or civil engineer specifications for the proposed Project shall be incorporated into grading plans and building specifications as a condition of construction permit approval. Impact Finding: The Project would not expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving seismic -related ground failure, including liquefaction (Draft Supplemental EIR at p. 5.4-10). Facts in Support of Findings: The Geotechnical Report (included as Appendix G to the Draft Supplemental EIR) identified that onsite soils consist of clayey soils that exist to a depth of approximately 30 feet bgs. Underlying soils include dense to very dense silty sand, poorly -graded sands, and lean clays. The highest historic groundwater on the Project site was encountered at approximately 5 feet bgs. Groundwater was encountered within onsite borings at depths between 12 feet and 16 feet bgs. However, due to the nature of the soils in the upper 50 feet, the Geotechnical Report determined that the liquefaction potential is considered low. Structures built in the City are required to be built in compliance with the CBC, as included in the City's Municipal Code as Chapter 8, Article 2, Division 1 (and in the Draft Supplemental EIR as PPP GEQ-1 ), which regulates all building and construction projects within the City and implements a minimum standard for building design and construction that includes specific requirements for seismic safety, excavation, foundations, retaining walls and site demolition. The Geotechnical Report prepared for the Project site provides CBC seismic design criteria that are specific to the onsite soils and the potential liquefaction and settlement. Compliance with the CBC, as included as PPP GEO-1, would require proper construction of building footings and foundations so that it would withstand the effects of potential ground movement, including liquefaction and settlement. The CBC, as currently adopted in the City's Municipal Code Chapter 8, Article 2, Division I. includes provisions to reduce impacts caused by potential major structural failures or loss of life resulting from geologic hazards. The City requires the Project specific engineering design recommendations be incorporated into grading plans and building specifications as a condition of construction permit approval. Therefore, the development of the proposed Project would be required to conform to the seismic design parameters of the CBC, as included as PPP GEC-1, would reduce hazards from seismic -related ground failure, including liquefaction and settlement to a less than significant level (Draft Supplemental EIR at p. 5.4-10). Plans, Program and Policies: PPP GEo-1: CBC Compliance. As listed previously. Impact Finding: The Project would not result in substantial soil erosion or the loss of topsoil (Draft Supplemental EIR at p. 5.4-1 1). Facts in Support of Findings: The City's Municipal Code Chapter 18-156, Control of Urban Runoff implements the requirements of the Orange County Municipal NDPES Storm Water Permit (Order No. R8-201 6-0001 ). All projects in the City are required to conform to the permit requirements, which includes installation of Best Management Practices (BMPs) in compliance with the NPDES permit, which establishes minimum stormwater management requirements and controls that are required to be implemented for the proposed Project. To reduce the potential for soil erosion and the loss of topsoil, a Stormwater Pollution Prevention Plan (SWPPP) is required by the Regional Water Quality Control Board (RWQCB) regulations to be developed by a QSD (Qualified SWPPP Developer). The SWPPP is required to address site -specific conditions related to specific grading and construction activities. With compliance with the City's Municipal Code, RWQCB requirements, and the BMPs in the SWPPP that is required to be prepared to implement the proposed Project, construction impacts related to erosion and loss of topsoil would be less than significant. In addition, the proposed Project includes installation of landscaping, such that during operation of the Project substantial areas of loose topsoil that could erode would not exist. Also, the onsite drainage features that would be installed by the Project have been designed to slow, filter, and slowly discharge stormwater into the offsite drainage system, which would also reduce the potential for stormwater to erode topsoil during Project operations. Furthermore, implementation of the Project requires City approval of a site -specific Water Quality Management Plan (WQMP) (included as Appendix M to the Draft Supplemental EIR), which would ensure that the City's Municipal Code, RWQCB requirements, and appropriate operational BMPs would be implemented to minimize or eliminate the potential for soil erosion or loss of topsoil to occur. As a result, potential impacts related to substantial soil erosion or loss of topsoil would be less than significant. Therefore, impacts related to Project buildout of the site would be consistent with the impact conclusions set forth in the GPU FEIR, which determined that impacts related to erosion and the loss of topsoil would be less than significant (Draft Supplemental EIR at p. 5.4-1 1 ). E. Hazards and Hazardous Materials Impact Finding: The Project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances or waste within 0.25 mile of an existing or proposed school (Draft Supplemental EIR at p. 5.6-25). Facts in Support of Findings: The Project site is located 0.5 mile west from the closest school, which is Taft Elementary School, located at 500 Keller Avenue, Santa Ana. Thus, the proposed Project would not be within one -quarter mile of an existing school (Draft Supplemental EIR at p. 5.6-25). Construction Project construction would involve the use and disposal of various hazardous materials. However, all storage, handling, use, and disposal of these materials are regulated by federal and state regulations that are implemented by the City of Santa Ana during construction permitting, such as those included as PPP HAZ-1 and PPP HAZ-2. In addition, Mitigation Measure HAZ-1 would ensure that contaminated soils are not released into the environment. Also, the hazardous materials would travel to and from the site from the 1-405 freeway and South Bristol Street, which is not in the direction of the school facilities. The freeway is located to the south and the closest school is located to the east of the site. Thus, the hazardous materials handled during construction of the proposed Project would not travel past the school facilities and potential impacts to the schools related to transport of hazardous materials would not occur (Draft Supplemental EIR at pp. 5.6-25 through 5.6-16). Operation Operation of the proposed Project includes activities related to retail commercial, restaurant, and multi -family residential development, which generally uses common hazardous materials, including: solvents, cleaning agents, paints, pesticides, batteries, and aerosol cans. Normal routine use of these products pursuant to existing regulations would not result in a significant hazard to the environment or school facilities in the vicinity of the proposed Project. Therefore, operational impacts related to nearby schools would be less than significant (Draft Supplemental EIR at p. 5.6-26). Plans, Program and Policies: PPP HAZ-1: SCAQMD Rule 1403. Prior to issuance of demolition permits, the Project applicant shall submit verification to the City Building and Safety Division that an asbestos survey has been conducted at all existing buildings located on the Project site. If asbestos or asbestos containing material is found, the Project applicant shall follow all procedural requirements and regulations of the South Coast Air Quality Management District (SCAQMD) Rule 1403. Rule 1403 regulations require that the following actions be taken: notification of SCAQMD prior to construction activity, asbestos removal in accordance with prescribed procedures, placement of collected asbestos in leak -tight containers or wrapping, and proper disposal. PPP HAZ-2: Lead. Prior to issuance of demolition permits, the Project applicant shall submit verification to the City Building and Safety Division that a lead -based paint survey has been conducted at all existing buildings located on the Project site. If lead -based paint is found, the Project applicant shall follow all procedural requirements and regulations for proper removal and disposal of the lead -based paint. CalOSHA has established limits of exposure to lead contained in dusts and fumes. Specifically, CCR Title 8, Section 1532.1 provides for exposure limits, exposure monitoring, and respiratory protection, and mandates good working practices by workers exposed to lead. Impact Finding: The Project would not result in a safety hazard or excessive noise for people residing or working in the project area for a project located within an airport land use plan or, where such plan has not been adopted, be within 2 miles of a public airport use airport or public use airport (Draft Supplemental EIR at p. 5.6-27). Facts in Support of Findings: The John Wayne Airport (SNA) is located approximately 1.4 miles southeast of the Project site. The Project site is not located within SNA's Airport Safety Zone, (as shown in Draft Supplemental EIR Figures 5.6-2 and 5.6-3) and is located outside of the airport's 60 CNEL contours (as shown on Draft Supplemental EIR Figures 5.7-2 and 5.7-3). The Airport Environs Land Use Plan (AELUP) for John Wayne Airport shows that residential land uses outside of the 60 CNEL contour are "normally consistent". However, the Project site is located within the AELUP Notification area for SNA and FAR Part 77 Notification Imaginary Surface area (shown on Draft Supplemental EIR Figure 5.6-1). The tallest point on the buildings would be approximately 285 feet above the existing ground level, which is approximately 30 feet above sea level. Thus, the top of the tallest point on the buildings would be approximately 315 feet above sea level. Because the Project site is located 1.4 miles northwest of SNA and is not within the Airport's safety zone, the proposed Project would not result in a safety hazard. However, as shown on Figure 5.6-1, the Project site is located within the 200- foot-high imaginary surface area for SNA, and the proposed Project would extend to approximately 315 feet above sea level. Therefore, FAA notification for the proposed Project is required. In addition, the proposed Project would not result in hazards related to excessive glare, light, steam, smoke, dust, or electronic interference. Exterior lighting fixtures and security lighting would be installed in accordance with Municipal Code Division 3, Building Security Regulations, which includes specifications for shielding and intensity of security lighting. In addition, the proposed Project would not use highly reflective surfaces, and does not include large areas of glass on the buildings, as shown in the Project elevations, included in Draft Supplemental EIR Chapter 3.0, Project Description. Therefore, the proposed Project would not generate substantial sources of glare. As described in Draft Supplemental EIR Section 5.1, Air Quality, operation of the proposed residential and commercial uses would not generate substantial quantities of steam, smoke, or dust emissions. As described, dust emissions are regulated by AQMD requirements and construction related air quality emissions that could include steam, smoke, and dust emissions would be less than significant with implementation of the standard AQMD Rules listed in Draft Supplemental EIR Section 5.1, Air Quality. The proposed Project consists of residential and commercial uses that would include the use of typical electronics, such as computers, televisions, and other electronics with wireless capability. The new residential and commercial uses on the site would use similar technology to those currently used on the site which do not cause electronic interference that could affect aircraft. Thus, impacts related to electronic interference with operations of the SNA would not occur. Due to the nature of the required City approvals (Le., the proposed Specific Plan and zoning amendment), the City of Santa Ana, pursuant to Public Utilities Code Section 21676, sent the proposed Project to the ALUC for review for consistency with the AELUP. An ALUC hearing was held on July 20, 2023 and the Project was found to be inconsistent with the ALUC policies. However, in accordance with Public Utilities Code Section 21676(B), at the August 29, 2023 City Council Hearing, the City Council initiated the first step in the overrule process by providing notice to ALUC and the California Department of Transportation Division of Aeronautics of the City's intention to overrule the ALUC's determination by providing the agencies with a Notice of Intent at least 45 days in advance of the overruling action. The City of Santa Ana may override the ALUC determination by a two-thirds majority vote by the City Council at the City Council Hearing for the Project so long as the City Council make specific consistency findings in accordance with the Public Utilities Code Section 21670. The proposed Project would comply with this ALUC notification and all other applicable rules and regulations as they pertain to SNA and airport safety. Overall, because the proposed Project is not located within the SNA Airport Safety Zone or the SNA 60 CNEL noise contour; and it would not result in hazards related to excessive glare, light, steam, smoke, dust, or electronic interference, the proposed Project would not introduce a safety hazard associated with airport operations for people residing, working, and visiting the Project site. Thus, Project -related hazard and noise impacts associated with SNA operations would be less than significant (Draft Supplemental EIR at pp. 5.6-27 through 5.6-28). Impact Finding: The Project would not impair implementation of, or physically interfere with, an adopted emergency response plan or emergency evacuation plan (Draft Supplemental EIR at p. 5.6-28). Facts in Support of Findings: lr`nnc#ri irtinn The proposed construction activities, including equipment and supply staging and storage, would occur within and adjacent to the Project site and would not restrict access of emergency vehicles to the Project site or adjacent areas. The proposed Project includes construction of new driveways to the Project site, new sidewalks, and utility improvements and connections that would require the temporary closure of travel lanes, but full roadway closure and traffic detours are not expected to be necessary. Construction activities that may temporarily restrict vehicular traffic would be required to implement adequate measures to facilitate the safe passage of persons and vehicles through/around any required temporary road restrictions in accordance with Section 503 of the California Fire Code (Title 24, California Code of Regulations, Part 9), which requires that prior to any activity that would encroach into a right-of-way, the area of encroachment be safeguarded through the installation of safety devices that would be specified by the City's Building and Safety Division during the construction permitting process to ensure that construction activities would not physically interfere with emergency access or evacuation. Therefore, implementation of the Project through the City's permitting process would reduce potential construction related physical interference impacts to emergency access to a less than significant level (Draft Supplemental EIR at p. 5.6-28). Operation The Project would include vehicular access to the site from driveways along adjacent roadways. As described in Draft Supplemental EIR Section 5.13, Transportation, these driveways would provide adequate and safe circulation to, from, and through the Project site and would provide a variety of routes for emergency responders to access the Project site and surrounding areas. During operation of the Project, residents, employees, and commercial building tenants would be required to maintain adequate emergency access for emergency vehicles as required and verified by the City and the C)C.FA. Because the Project is required to comply with all applicable City codes, as verified by the City and C)CFA, potential impacts related to emergency evacuation or emergency response plans would be less than significant (Draft Supplemental EIR at p. 5.6-28). F. Hydrology and Water Quality Impact Finding: The Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality (Draft Supplemental EIR at p. 5.7-10). Facts in Support of Findings: Construction Pollutants of concern during construction activities generally include sediments, trash, petroleum products, concrete waste (dry and wet), sanitary waste, and chemicals. Each of these pollutants on its own or in combination with other pollutants can have a detrimental effect on water quality. In addition, chemicals, liquid products, petroleum products (such as paints, solvents, and fuels), and concrete -related waste may be spilled or leaked during construction, which would have the potential to be transported via storm runoff into nearby receiving waters and eventually may affect surface or groundwater quality. During construction activities, excavated soil would be exposed, thereby increasing the potential for soil erosion and sedimentation to occur compared to existing conditions. In addition, during construction, vehicles and equipment are prone to tracking soil and,/or spoil from work areas to paved roadways, which is another form of erosion that could affect water quality. However, the use of BMPs during construction implemented as part of a SWPPP as required by the NPDES General Construction Permit and included as PPP WQ-1 would serve to ensure that Project impacts related to construction activities resulting in a degradation of water quality would be less than significant. As detailed in the Preliminary Geotechnical Investigation Report (Included as Appendix G to the Draft Supplemental EIR), the historic highest groundwater at the site has been mapped at a depth of about 5 feet bgs and groundwater in 2022 was encountered between depths of 12 feet and 16 feet bgs. If contaminated, release of dewatered groundwater to surface waters can introduce total dissolved solids to surface waters. If groundwater or perched groundwater is encountered during construction and groundwater dewatering is necessary, it would be completed in compliance with the Groundwater Discharge Permit, as specified PPP WQ-2. Compliance with the requirements of the Groundwater Discharge Permit would ensure impacts related to waste discharge requirements and water quality standards would be less than significant during dewatering activities, and no mitigation would be required (Draft Supplemental EIR at pp. 5.7-10 through 5.7-1 1). Operation The proposed Project includes operation of retail and restaurant commercial and multi -family residential uses. Potential pollutants associated with the proposed uses include various chemicals from cleaners, pathogens from pet wastes, nutrients from fertilizer, pesticides and sediment from landscaping, trash and debris, and oil and grease from vehicles. If these pollutants discharge into surface waters, it could result in degradation of water quality. The Newport Back Bay, to which the Project site ultimately drains, is currently listed as impaired on the USEPA's 303(d) list for various pollutants. Therefore, additional pollutant discharge could create new or exacerbate existing impairments within these waterbodies, which could result in a significant impact related to water quality. However, operation of the proposed Project would be required to comply with the requirements of the Santa Ana Regional MS4 Permit and Orange County DAMP to develop of a project -specific WQMP (included as PPP WQ-3) that would describe implementation of LID infrastructure and non- structural, structural, and source control and treatment control BMPs to protect surface water quality. In addition, the proposed Project would install a vegetated biotreatment system for water quality treatment, which have been sized to treat runoff from the Design Capture Storm (85th percentile, 24-hour) from the proposed Project. As storm water passes down through the planting soil, pollutants are filtered, adsorbed, biodegraded and sequestered by the soil and plants, functioning similar to bioretention systems. The discharge chamber at the end of the unit collects treated flows and discharges it into the existing and upsized storm drains. The WQMP (included as Appendix M to the Draft Supplemental EIR) is required to be approved prior to the issuance of a building or grading permit. The Project's WQMP would be reviewed and approved by the City to ensure it complies with the Santa Ana RWQCB M54 Permit regulations. Overall, implementation of the WQMP pursuant to the existing regulations would ensure that operation of the proposed Project would not violate any water quality standards, waste discharge requirements, or otherwise degrade water quality; and impacts would be less than significant (Draft Supplemental EIR at pp. 5.7-1 1 through 5.7-12). Plans, Program and Policies: PPP WO-1: NPDES%SWPPP. Prior to issuance of any grading or demolition permits, the applicant shall provide the City Building and Safety Division evidence of compliance with the NPDES (National Pollutant Discharge Elimination System) requirement to obtain a construction permit from the State Water Resource Control Board (SWRCB). The permit requirement applies to grading and construction sites of one acre or larger. The Project applicant proponent shall comply by submitting a Notice of Intent (NOI) and by developing and implementing a Stormwater Pollution Prevention Plan (SWPPP) and a monitoring program and reporting plan for the construction site. PPP WQ-2: Groundwater Dewatering Permits. Prior to initiation of excavation activities, the Project applicant shall obtain coverage under the Santa Ana RWQCB General Waste Discharge Requirements for Discharges to Surface Waters Resulting from De Minimis Discharges or Groundwater Dewatering Operations, and/'or Groundwater Cleanup/Remediation Operations at Sites within the Newport Bay Watershed Permit (Order No. R8-2019-0061, NPDES No. CAG918002), or any other subsequent permit for dewatering activities, and provide evidence of coverage to the City of Santa Ana Building and Safety Division designee. This shall include submission of a Notice of Intent (NOI) for coverage under the permit to the Santa Ana Regional Water Quality Control Board (RWQCB) at least 60 days prior to the start of excavation activities and anticipated discharge of dewatered groundwater to surface waters. Groundwater dewatering activities shall comply with all applicable provisions in the permit, including water sampling, analysis, treatment (if required), and reporting of dewatering-related discharges. Upon completion of groundwater dewatering activities, a Notice of Termination shall be submitted to the Santa Ana RWQCB. PPP WO-3: WQMP. Prior to the approval of the Grading Plan and issuance of Grading Permits a completed Water Quality Management Plan (WQMP) shall be submitted to and approved by the City Public Works Agency. The WQMP shall identify all Post -Construction, Site Design, Source Control, and Treatment Control Best Management Practices (BMPs) that will be incorporated into the development project in order to minimize the adverse effects on receiving waters. Impact Finding: The Project would not substantially decrease groundwater supplies or interfere with groundwater recharge such that the Project may impede sustainable groundwater management of the basin (Draft Supplemental EIR at p. 5.7-12). Facts in Support of Findings: Construction Any groundwater dewatering would be temporary and limited to the excavation area. Because of the relative size of the Project site, as compared to the water basin, and the limited scope of excavation that would be deep enough to encroach into groundwater, the volume of groundwater removed would not be substantial and would not decrease groundwater supplies or impede groundwater management. The proposed Project would comply with the requirements of Groundwater Discharge Permit, including testing and treatment, if necessary, that would be implemented through the RWQCB and the City's development permitting process (and included as PPP WQ-2). Thus, any dewatering activities during construction would result in less than significant impacts to groundwater (Draft Supplemental EIR at pp. 5.7-1 2 through 5.7-13). Operation The Orange County Basin provides approximately 76 percent of the City's water supply. The remaining supply comes from the Metropolitan Water District (23 percent) and recycled water (1 percent) (UWMP 2020). As shown on Table 5.7-1 of the Draft Supplemental EIR, the City's UWMP shows that the anticipated production of groundwater would remain steady from 2025 through 2045 and that in 2045 approximately 84.4 percent of supply would be from the Orange County Basin and 14.9 percent from imported/purchased sources. As detailed in Section 5.15, Utilities and Service Systems of the Draft Supplemental EIR, the supply of water would be sufficient during both normal years and multiple dry year conditions between 2025 and 2045 to meet all of the City's estimated needs, including the proposed Project. Therefore, the proposed Project would not result in changes to the projected groundwater pumping that would decrease groundwater supplies. Thus, impacts related to groundwater supplies would be less than significant. In addition, the onsite soils have a low infiltration rate and do not currently provide onsite infiltration. As such, infiltration of water to the existing groundwater basin is neither currently occurring, nor would occur by the proposed Project. Therefore, impacts related to interference with groundwater recharge would be less than significant (Draft Supplemental EIR at p. 5.7-13). Plans, Program and Policies: PPP WQ-2: Groundwater Dewatering Permits. As listed previously. Impact Finding: The Project would not substantially alter the existing drainage pattern of the area, including through the alteration of the course of a stream or river, in a manner which would result in a substantial erosion or siltation on- or off -site (Draft Supplemental EIR at p. 5.7-13). Facts in Support of Findings: Construction The existing NPDES Construction General Permit and Orange County DAMP require preparation and implementation of a SWPPP by a Qualified SWPPP Developer for the proposed construction activities (included as PPP WQ-1). The SWPPP is required to address site -specific conditions related to potential sources of sedimentation and erosion and would list the required BMPs that are necessary to reduce or eliminate the potential of erosion or alteration of a drainage pattern during construction activities to a less than significant level. In addition, a Qualified SWPPP Practitioner (QSP) is required to ensure compliance with the SWPPP through regular monitoring and visual inspections during construction activities. The SWPPP would be amended and BMPs revised, as determined necessary through field inspections, in order to protect against substantial soil erosion, the loss of topsoil, or alteration of the drainage pattern. Compliance with the Construction General Permit and a SWPPP prepared by a Qualified SWPPP Developer (QSD) and implemented by a QSP (per PPP WQ-1) would prevent construction -related impacts related to potential alteration of a drainage pattern or erosion from development activities. Overall, with implementation of the existing construction regulations that would be verified by the City during the permitting approval process, impacts related to alteration of an existing drainage pattern during construction that could result in substantial erosion, siltation, and increases in stormwater runoff would be less than significant (Draft Supplemental EIR at pp. 5.7-13 through 5.7- 14). Operation The Project -specific Preliminary WQMP describes that the Project site currently includes 37.02 acres of impermeable surfaces, which equates to 40 percent of the site. After completion of Project construction, the site would have a 4 percent reduction in impermeable surfaces (i.e., 35.37 acres or 86 percent of the site would have impermeable surfaces). The proposed Project would maintain the existing drainage pattern. The Project includes offsite storm drain improvements pursuant to the City's Storm Drain Master Plan that involve replacing 2,230 lineal feet of the 54,/60-inch storm drain with a 72-inch lateral in Sunflower Avenue and replacing a 42-inch lateral in Plaza drive with a 6041nch lateral. Treated runoff would be conveyed to the existing and upsized City of Santa Ana storm drains in the roadways adjacent to the site. From there, flows would travel to the Orange County Flood Control District Santa Ana — Gardens and then the Delhi Channel that drains to Newport Bay and the Pacific Ocean. The MS4 permit and DAMP require new development projects to prepare a WQMP (included as PPP WQ-3) that is required to include BMPs to reduce the potential of erosion and/'or sedimentation through site design and structural treatment control BMPs. Overall, the proposed drainage system and adherence to the existing regulations would ensure that Project impacts related to alteration of a drainage pattern and erosion,/siltation from operational activities would be less than significant (Draft Supplemental EIR at pp. 5.7-14 through 5.7-15). Plans, Program and Policies: PPP WO-1: NPDES/SWPPP. As listed previously. PPP WO-3: WOMP. As listed previously. Impact Finding: The Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite (Draft Supplemental EIR at p. 5.7- 15 ). Facts in Support of Findings: Construction Implementation of the Project requires a SWPPP (included as PPP WQ-1) that would address site specific drainage issues related to construction of the Project and include EMPs to eliminate the potential of flooding or alteration of a drainage pattern during construction activities. This includes regular monitoring and visual inspections during construction activities. Compliance with the Construction General Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP WQ-1) as verified by the City through the construction permitting process would prevent construction -related impacts related to potential alteration of a drainage pattern or flooding on or offsite from development activities. Therefore, impacts would be less than significant (Draft Supplemental EIR at p. 5.7-15). Operation As described previously and detailed in Table 5.7-2 of the Draft Supplemental EIR, the proposed Project would result in a decrease of the 2-year, 24-hour storm runoff flowrate by 6.3 percent and the proposed Project would manage runoff with vegetated biotreatment systems that have been designed to accommodate the proposed Project design pursuant to the MS4 Permit and DAMP requirements. The units would filter, treat, and discharge runoff into the existing and upsized offsite storm drains. As part of the permitting approval process, the proposed drainage design and engineering plans would be reviewed by the City's Engineering Division to ensure that the proposed drainage would accommodate the appropriate design flows. Additionally, the City permitting process would ensure that the drainage system specifications adhere to the existing MS4 Permit and DAMP regulations, which would ensure that pollutants are removed prior to discharge. Overall, with compliance to the existing regulations as verified by the City's permitting process,. Project impacts related to the capacity of the drainage system and polluted runoff would be less than significant (Draft Supplemental EIR at pp. 5.7-15 through 5.7-16). Plans, Program and Policies: PPP WQ-1: NPDES/SWPPP. As listed previously. PPP WQ-3: WQMP. As listed previously. Impact Finding: The Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff (Draft Supplemental EIR at p. 5.7-16). Facts in Support of Findings: Construction Implementation of the Project requires a SWPPP (included as PPP WQ-1) that would address site specific pollutant and drainage issues related to construction of the Project and include BMPs to eliminate the potential of polluted runoff and increased runoff during construction activities. This includes regular monitoring and visual inspections during construction activities. Compliance with the Construction General Permit and a SWPPP prepared by a QSD and implemented by a QSP (per PPP WQ-1) as verified by the City through the construction permitting process would prevent construction -related impacts related to increases in runoff and pollution from development activities. Therefore, impacts would be less than significant. As part of the permitting approval process, the proposed drainage design and engineering plans would be reviewed by the City's Engineering Division to ensure that the proposed drainage would accommodate the appropriate design flows. Additionally, the City permitting process would ensure that the drainage system specifications adhere to the existing MS4 Permit and DAMP regulations, which would ensure that pollutants are removed prior to discharge. Overall, with compliance to the existing regulations as verified by the City's permitting process, Project impacts related to the capacity of the drainage system and polluted runoff would be less than significant (Draft Supplemental EIR at p. 5.7-16). Operation The Project would manage increased stormwater flow with vegetated biotreatment systems that have been designed to accommodate the increased volume pursuant to the MS4 permit and DAMP requirements. The units would retain, filter, treat, and slowly discharge runoff into the existing offsite drain. Additionally, the City permitting process would ensure that the drainage system accommodates new flows and that specifications adhere to the existing MS4 permit and DAMP regulations, which would ensure that pollutants are removed prior to discharge. Overall, with compliance to the existing regulations as verified by the City's permitting process, Project impacts related to the capacity of the drainage system and polluted runoff would be less than significant (Draft Supplemental EIR at p. 5.7-17). Plans, Program and Policies: PPP WQ-1: NPDES/SWPPP. As listed previously. Impact Finding: The Project would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would impede or redirect flood flows (Draft Supplemental EIR at p. 5.7-17). Facts in Support of Findings: The Project site does not include, and is not adjacent to, a stream or river. Implementation of the Project would not alter the course of a stream or river. In addition, according to the FEMA FIRM for the Project area (O6059CO279J), the Project site is located within "Zone X," which is an area determined to be outside of the 0.2 percent annual chance flood. Therefore, there is a low potential for onsite flooding to occur. Implementation of the proposed Project would result in a decrease of impermeable surfaces from 90 percent of the site to 86 percent of the site. The Project would maintain the existing drainage pattern; and drainage would be accommodated by onsite by vegetative biotreatment systems that have been sized to accommodate the DAMP required design storm. Therefore, the Project would not result in impeding or redirecting flood flows by the addition of the impervious surfaces. As detailed previously, the City's permitting process would ensure that the drainage system specifications adhere to the existing MS4 permit and DAMP regulations, and compliance with existing regulations would ensure that impacts would be less than significant (Draft Supplemental EIR at p. 5.7-17). Impact Finding: The Project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan (Draft Supplemental EIR at p. 5.7-18). Facts in Support of Findings: Use of BMPs during construction implemented as part of a SWPPP as required by the NPDES Construction General Permit and PPP WQ-1) and a RWQCB Groundwater Discharge Permit (implemented through PPP WQ-2) would serve to ensure that Project impacts related to construction activities resulting in a degradation of water quality would be less than significant. Thus, construction of the proposed Project would not conflict or obstruct implementation of a water quality control plan. Also, development projects are required to implement a WQMP (per the Regional MS4 Permit and PPP WQ-3) that would comply with the Orange County DAMP. The WQMP and applicable BMPs are verified as part of the City's permitting approval process, and construction plans would be required to demonstrate compliance with these regulations. Therefore, operation of the proposed Project would not conflict of obstruct with a water quality control plan. In addition, the OCWD manages basin water supply through the Basin Production Percentage (BPP), such that, the anticipated production of groundwater would remain steady from 2025 through 2040 (as shown in Draft Supplemental EIR Table 5.8-1 ). As detailed in Draft Supplemental EIR Section 5.15, aUtilities and Service Systems, the City's supply of water listed in Draft Supplemental EIR Table 5.7-1 would be sufficient during both normal years and multiple dry year conditions between 2025 and 2045 to meet all of the City's estimated needs, including the proposed Project. Therefore, the Project would be consistent with the groundwater management plan and would not conflict with or obstruct its implementation. Thus, impacts related to water quality control plan or sustainable groundwater management plan would be less than significant (Draft Supplemental EIR at p. 5.7- 18). Plans, Program and Policies: PPP WO-1: NPDES/SWPPP. As listed previously. PPP WO-2: Groundwater Dewatering Permits, PPP WO-3: WQMP. As listed previously. G. Land Use and Planning Impact Finding: The Project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect (Draft Supplemental EIR at p. 5.8-20). Facts in Support of Findings: 2020 RTP%SCS The 2020 RTP/SCS Goals that are relevant to the proposed Project focus largely on maximizing mobility, encouraging development patterns and densities that reduce infrastructure costs, and providing for efficiency. The proposed Project would be consistent with the applicable SCAG's 2020 RTP/SCS goals, as detailed in Draft Supplemental EIR Table 5.8-1. Therefore, implementation of the proposed Project would not result in conflict with RTP/SCS goals, and impacts would not occur (Draft Supplemental EIR at pp. 5.8-20 through 5.8-23). JWA Airport Environs Land Use Plan SNA is located approximately 1.4 miles southeast of the Project site within the AELUP Notification area and FAR Part 77 Notification area for the airport, but outside of the airport's 60 CNEL Contour. Draft Supplemental EIR Table 5.8-2 provides an assessment of the proposed Project's consistency with the AELUP for SNA. As detailed, the AELUP identifies the proposed mix -use residential land uses as normally consistent. Thus, pursuant to the AELUP for JWA, impacts related to land use compatibility would not occur (Draft Supplemental EIR at pp. 5.8-23 through 5.8-25). General Plan Land Use Designation The Project site currently has a General Plan Land Use designation of District Center -High (DC-5), which has a maximum Floor Area Ratio (FAR) of 5.0, or 125 dwelling units per acre (du/ac) and a maximum height of 25 stories that allows up to 8,733,780 SF of mixed uses, inclusive of residential uses, within the Project site. The GPU Land Use Element also states that the DC-5 designation is for "Transit -oriented and high density urban villages consisting of visually striking and dynamic buildings and spaces with a wide range and mix of residential, live -work, commercial, hotel, and employment -generating uses". The proposed Project would implement the City's GPU and the DC-5 land use designation for the Project site by removing the existing low intensity vehicle -oriented commercial development on the site and provide a new mixed -use development with up to 3,750 multi -family residential units; up to 350,000 SF of commercial uses; a 250-room hotel; a senior living continuum of care use with up to 200 units; and approximately 13.1 acres of common open space that would provide pedestrian connectivity throughout the site. The proposed Project would result in a residential density of 91 du/ac and a non-residential FAR of 2.7, which is within the DC-5 allowable residential density of up to 125 du,/ac and non-residential FAR of up to 5.0. The proposed Project would provide a mix of uses, including residential, retail, and commercial services, recreation, and entertainment. In addition, the Project site is located within a Transit Priority Area (TPA) and High Quality Transit Area, and is adjacent to six bus routes that provide connections to regional transit services. Thus, the proposed Project would implement, and would not conflict with, the General Plan land use designation for the site (Draft Supplemental EIR at pp. 5.8-25 through 5.8-26). GPU Focus Area The Project site is located within the GPU South Bristol Street Focus Area. The GPU Land Use Element states that the intent of the South Bristol Street Focus Area is to create opportunities to transform auto -oriented shopping plazas to walkable, bike -friendly, and transit -friendly urban villages that incorporate a mix of high intensity office and residential living with experiential commercial uses. The proposed Project would implement the intent of the South Bristol Street Focus Area by removing the existing low intensity auto -oriented shopping center on the site and provide a new mixed -use urban village with up to 3,750 multi -family residential units; up to 350,000 SF of commercial uses; a 250-room hotel; a senior living,/continuum of care use with up to 200 units; and approximately 13.1 acres of common open space that would provide pedestrian connectivity throughout the site. The proposed Project would be transit -friendly because the site is within a TPA and a High Quality Transit Area, and adjacent to six QCTA bus routes that connect to regional transportation. Additionally, the proposed Project would install on and offsite pedestrian and bicycle facilities and would include onsite bicycle parking/'lockers, etc. and therefore, would be bike friendly. The proposed Project would implement the intent and GPU vision for the South Bristol Street Focus Area. Impacts related to conflict with the GPU South Bristol Street Focus Area would not occur from implementation of the proposed Project. (Draft Supplemental EIR at p. 5.8-26). Land Use Consistency The areas surrounding the Project site are developed with residential, service, office, and commercial uses. Development of the site for multi -family residential, commercial (retail/restaurant/'hotel), and open space uses would integrate into the adjacent areas. The proposed Project would provide housing proximate to local employment centers, commercial retail services and restaurants for onsite residents and employees working nearby. In addition, the proposed Project would provide onsite open space and recreation activities that would integrate into the existing communities around the site. The proposed Project would provide vehicular, bicycle, and pedestrian access and would provide circulation improvements to efficiently integrate into the land uses and circulation infrastructure of the area. Overall, the proposed Project would not result in a land use inconsistency. The proposed Project would implement a mix of uses, including multi -family residential, and would provide locational efficiency as it allows people to work, live, and obtain services within a small area, which has the potential to reduce VMT in comparison to residential development that is farther from employment and services. As described throughout this Supplemental EIR, with implementation of existing regulations, the proposed Project would not result in significant environmental impacts such as light, noise, or air quality to the adjacent existing and planned land uses. Therefore, impacts related to land use inconsistency would be less than significant (Draft Supplemental EIR at pp. 5.8-26 through 5.8-27). General Plan Goals. Policies. and Objectives A detailed analysis of the proposed Project's consistency with the applicable goals, policies, and objectives of the City's GPU that serve to avoid or mitigate environmental impacts is provided in Table 5.8-3 of the Draft Supplemental EIR. As described, the proposed Project would be consistent with the relevant goals, policies, and objectives of the City's GPU that avoid or mitigate environmental impacts, and impacts related to conflict with a GPU policy related to an environmental effect would be less than significant (Draft Supplemental EIR at pp. 5.8-27 through 5.8-A3). ZoningDesignation The existing zoning of the Project site is General Commercial (C-2) north of Callen's Common, and Commercial Residential (CR) and General Commercial (C-2) south of Callen's Common, as shown on Figure 3-5, Existing Zoning, in Chapter 3.0, Project Description of the Draft Supplemental EIR. As listed previously, the C-2 zone is designated for general commercial uses that include: wholesale, automotive garages, retail, etc. Structures in the C-2 zone are limited to 35 feet in height, and 15- foot-wide yards are required adjacent to arterial streets, such as Sunflower Avenue and Bristol Street. The C-R zone is designated to integrate commercial and residential land uses that include retail and services, professional offices, one -family and multi -family dwellings, etc. with landscaped setbacks. The proposed SP zoning of the site would implement the GPU objectives for the South Bristol Street Focus Area, pursuant to the DC-5 General Plan land use designation. The proposed Specific Plan includes design guidelines for the non -auto oriented urban scale development that address site layout, building scaling and massing, building entry design, vehicle and pedestrian circulation, parking and loading area requirements, landscaping design requirements, and more. Because the proposed SP zoning would implement the existing land use designation and GPU vision for the South Bristol Street Focus Area, impacts related to conflict with a land use plan, policy, or program would not occur from implementation of the proposed Project (Draft Supplemental EIR at p. 5.8- 43). Regulations Governing Scenic Quality The proposed Specific Plan includes design guidelines that would govern scenic quality on the Project site pursuant to the DC-5 land use designation and objectives for the South Bristol Street Focus Area. Visual corridors would be protected through compliance with the proposed Specific Plan guidelines which require building setbacks from public view corridors, including a 20-foot average setback from South Bristol Street; a 15-foot average setback from MacArthur Boulevard, Sunflower Avenue, and South Plaza Drive; and a 12-foot average setback from Callen's Common, which are measured from the front of curb. Setbacks would be landscaped. Varying building setbacks and materials, along with landscaping as required by the Specific Plan design guidelines, would implement the GPU policies governing scenic quality. Table 5.8-4 of the Draft Supplemental EIR describes the proposed Project Is consistency with the relevant GPU goals and policies regarding aesthetics. As detailed, the proposed Project would be consistent with and implement the GPU policies through the design guidelines that are included in the proposed Specific Plan (Draft Supplemental EIR at pp. 5.8-43 through 5.8-48). H. Noise Impact Finding: The Project would not generate excessive groundborne vibration or groundborne noise levels (Draft Supplemental EIR at p. 5.9-30). Facts in Support of Findings: Construction Demolition, excavation, and grading activities are required for the Project and can result in varying degrees of groundborne vibration, depending on the equipment and methods used, distance to the affected structures and soil type. As indicated in Table 5.9-18 of the Draft Supplemental EIR, based on FTA data, vibration velocities from typical heavy construction equipment operations that would be used during Project construction range from 0.003 to 0.089 in/'sec PPV at 25 feet from the source of activity; and would range from 0.001 1 to 0.0315 in/'sec PPV at 50 feet from the source of activity. All of the onsite and offsite receptors are farther than 25 feet from construction areas; and therefore, actual vibrations at sensitive receptors would be less. These vibration levels would not be sustained during the entire construction period but would occur only during the times that heavy construction equipment is operating in the vicinity of the sensitive receivers. This level of vibration would be below the Caltrans building damage threshold of 0.2 in/sec PPV and vibration standard of 0.04 in/sec PPV for human annoyance at all receiver locations. Therefore, vibration impacts would be less than significant (Draft Supplemental EIR at pp. 5.9-30 through 5.9-31). Operation Operation of the proposed commercial and multi -family uses would include heavy trucks for residents moving in and out of the rental units, product deliveries to retail and restaurant uses, and garbage trucks for solid waste disposal. Truck vibration levels are dependent on vehicle characteristics, load, speed, and pavement conditions. However, typical vibration levels for the heavy truck activity at normal traffic speeds would be approximately 0.006 in,/sec PPV, based on the FTA Transit Noise Impact and Vibration Assessment. Truck movements on site would be travelling at very low speed, so it is expected that truck vibration at nearby sensitive receivers would be less than the vibration threshold of 0.08 in/sec PPV for fragile historic buildings and 0.04 in,/sec PPV for human annoyance, and therefore, would be less than significant. The operational vibration impacts that would be generated by the proposed Project would be less than those identified by the GPU FEIR, which were determined to be significant and unavoidable. Therefore, operational vibration impacts related to the proposed Project would not exceed those previously identified (Draft Supplemental EIR at p. 5.9-31 ). Impact Finding: The Project would not expose people residing or working in the Project area to excessive airport noise related to a public airport (Draft Supplemental EIR at p. 5.9-31 ). Facts in Support of Findings: The exterior noise thresholds outlined in the AELUP, multi -family residential development is considered normally consistent with exterior noise levels of less than 60 dBA CNEL, conditionally consistent with exterior noise levels between 60 and 65 dBA CNEL and normally inconsistent with exterior noise level above 65 dBA CNEL. For commercial retail land use, exterior noise levels are considered normally consistent with exterior noise levels of less than 65 dBA CNEL and conditionally consistent with exterior noise level above 65 dBA CNEL. As shown on Draft Supplemental EIR Figures 5.6-2 and 5.6-3, the Project site is located outside the airport's planned and actual (2019) 60 dBA CNEL aircraft noise level contour boundaries of SNA. Therefore, according to the AELUP, the Project residential and commercial retail land use is considered normally consistent with JWA aircraft noise exposure exterior noise level compatibility thresholds. Also, the airport -related noise at the Project site does not exceed the City's municipal code permissible noise levels. Additionally, the County's General Aviation Noise Ordinance prohibits commercial aircraft departures between the hours of 10:00 p.m. and 7:00 a.m. and arrivals between the hours of 1 1:00 p.m. and 7:00 a.m. These restrictions substantially limit the aircraft noise during the noise sensitive nighttime hours for residential use. Overall, the Project site would not be exposed to excessive noise levels from airport operations, and therefore, impacts would be less than significant (Draft Supplemental EIR at pp. 5.9-31 through 5.9-32). 1. Population and Housing Impact Finding: The Project would not induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure) (Draft Supplemental EIR at p. 5.10-8). Facts in Support of Findings: Housing and Population Growth Draft Supplemental EIR Table 5.10-8 shows that at full occupancy the Project would house approximately 9,238 residents. As shown in Draft Supplemental EIR Table 5.10-6, the buildout population of the South Bristol Street Focus Area was identified as 19,176 persons. Therefore, the Project buildout of 9,238 residents would be 48 percent of the GPU FEIR buildout for the South Bristol Street Focus Area, and population growth from the proposed Project would not exceed the growth identified in the GPU Final EIR. Therefore, the proposed Project would not induce substantial unplanned direct growth in the area, and impacts related to housing and population growth would be less than significant (Draft Supplemental EIR at p. 5.10-8). Employment Growth The proposed site redevelopment would also include 350,000 SF of commercial space and 250 hotel rooms, which would not exceed the increase of 3,505,130 SF of non-residential space that was planned for the South Bristol Street Focus Area by the GPU. In addition, employees would be needed associated with the proposed mix of uses, including the senior,/continuum of care units.. The proposed Project would result in a total of 1,092 employees at buildout and full occupancy, as shown in Draft Supplemental EIR Table 5.10-9. These employees would consist of approximately 14 percent of the GPU projected increase in employment from buildout of the South Bristol Street Focus Area. Therefore, employment growth from buildout of the proposed Project would not exceed the growth identified in the GPU Final EIR, and impacts related to employment growth would be less than significant (Draft Supplemental EIR at p. 5.10-9). Job Housina Balance The City of Santa Ana is jobs rich, with an existing jobs -housing ratio of 2.0. The proposed Project would reduce (improve) the jobs -housing ratio slightly by adding 1,092 jobs and 3,750 residential units (a ratio of 0.29 jobs per non -senior residential unit). The proposed Project would provide a regional beneficial effect of providing multi -family housing on the Project site in a jobs -rich area, where employees can easily travel to nearby employment opportunities. In addition, because the area is jobs -rich, the addition of residential units in the area would not require additional jobs that could result in growth. Conversely, the new residents would fill the need for employees that are anticipated by SCAG projections. Thus, the additional residential units would not indirectly result in the need for additional employment opportunities, which could result in growth. Therefore, this indirect impact related to growth would be less than significant. The proposed Project is located in Transit Priority Area and is in close proximity to existing transportation infrastructure that provides mobility for residents to employment opportunities within the region. The Project site is 0.5 mile from 1-405, which is easily accessible via an interchange at Bristol Street. As detailed in Section 5.13, Transportation, the ©range County Transportation Agency operates seven bus routes with bus stops adjacent to the Project site. In addition, the Project site is bound by sidewalks on Bristol Street, MacArthur Boulevard, South Plaza Drive, and Sunflower Avenue; and the proposed Project would install new onsite and offsite pedestrian and bicycle facilities, which would connect to other existing pedestrian and bicycle facilities. The residents and employees of the proposed Project would have convenient access to sustainable multimodal transportation that would allow for walking, biking, and the use of existing transit, which could reduce vehicular trips and the related effects (such as traffic, air quality, greenhouse gas emissions, and noise impacts). Thus, the improved jobs -housing ratio would be an indirect physical benefit of the proposed Project (Draft Supplemental EIR at pp. 5.10-9 through 5.10-10). Infrastructure The Project site is adjacent to existing roadways that would not be extended or upsized to serve the proposed Project. Although the proposed Project includes roadway improvements, they are related to installing ingress/egress to the proposed uses on the Project site and providing a multi - modal circulation system by enhancing pedestrian and bicycle facilities. These roadway improvements would provide for efficient and multi -modal circulation to, from, and within the Project site and would not provide additional roadways or roadway capacity that could indirectly induce substantial unplanned growth in the area. As described in Section 5.15, Utilities and Service Systems of the Draft Supplemental EIR, the proposed Project would install a new onsite water infrastructure system that would connect to water pipelines adjacent to the site. The onsite improvements include construction of a new 12-inch water line in Bristol Paseo and replacement of the existing 12-inch water line in Callen's Common with a new 12-inch main and connection of the new onsite infrastructure to the replacement line. The proposed Project also includes offsite infrastructure improvements that would replace an approximately 600-foot section of the existing 12-inch water main located at the northerly portion of Plaza Drive (immediately south of MacArthur Boulevard). The proposed Project would install a new onsite sewer system that would connect to the existing 78-inch Orange County Sanitation District (OCSD) sewer main in Sunflower Avenue As detailed in Section 5.15, Utilities and Service Systems of the Draft Supplemental EIR, the proposed Project would install a storm drain system within the onsite roadways to convey the stormwater to proposed vegetated biotreatment systems on the site and then to the existing or upgraded City storm drain systems in MacArthur Boulevard, South Plaza Drive, Sunflower Avenue, and Bristol Street. The proposed Project would upgrade the existing 54-inch reinforced concrete pipe (RCP) in Sunflower Avenue to a 72-inch RCP for 21230 linear feet and the existing 42-inch RCP in South Plaza Drive to a 60-inch RCP for 320 linear feet; however, these upgrades would replace existing storm drain lines and are to accommodate existing stormwater volumes. As such, the proposed Project would connect to existing or upgraded storm drain infrastructure and would not result in the expansion of storm drainage facilities in a manner which could accommodate substantial unplanned growth in the area. The Project site is currently being served by the existing natural gas and electric infrastructure that is adjacent to the site. The proposed Project would install new gas and electric infrastructure onsite that would connect to the existing natural gas and electric facilities that are in the adjacent roadway easements and are provided by Southern California Gas and Southern California Electric, respectively. The gas and electric infrastructure do not require extensions or capacity enhancements that could indirectly induce substantial unplanned growth in the area. Furthermore, no infrastructure would be extended or expanded to serve areas beyond the Project site, and indirect impacts related to the extension of infrastructure would not occur from implementation of the proposed Project. Overall, the proposed Project would not result in an increase in inducement of population growth beyond that identified by the GPU FEIR that would have the potential to create a significant physical change to the environment. As a result, impacts from buildout of the proposed Project would be less than significant and less than those identified in the +GPU FEIR, which were determined to be significant and unavoidable (Draft Supplemental EIR at pp. 5.10-10 through 5.10-1 1 ). J. Public Services Impact Finding: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered fire service facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios and response times or other performance objectives for fire protection services (Draft Supplemental EIR at p. 5.1 1-5). Facts in Support of Findings: The proposed Project would remove the existing 16 commercial buildings and develop 3,750 multi -family residences, 200 senior/continuum of care units, 250 hotel rooms, and 350,000 SF of new commercial uses. The proposed Project would result in 9,238 residents and 1,092 employees at full occupancy. This residential and employee population is expected to create the typical range of service calls to OCFA that are largely related to medical emergencies. The Project site is within 4 miles of 6 existing fire stations and the Project site is within a developed area that is currently served by these stations. The two nearest serving stations (Station 76 and 77) are slightly under and slightly over the response time standard 901h percentile of 8:30 minutes. The calls for service from the additional population at the Project site could result in an increase in response times, and result in Station 76 exceeding the existing standards for service or result in Station 77 further exceeding the existing standards for service, if the calls coincide with other calls for service. However, fire protection equipment and staffing can be augmented by the City as needed (with assistance from revenue provided by the proposed Project and the fire facilities fee required per Chapter 8-46 of the Municipal Code) to expand fire protection and emergency medical staffing and equipment provided from existing stations and better accommodate simultaneous service calls. Chapter 8-46 of the Santa Ana Municipal Code requires a fire facilities fee be paid prior to the issuance of building permit for construction of buildings exceeding two stories in height, such as the buildings included in the proposed Project. The purpose of the fire facilities fee is to improve fire stations in the City and provide revenue for equipment needed to fight fires in buildings over two stories in height. The proposed Project would be required to pay a fire facilities fee to fund the improvement of existing fire facilities and provision of any needed equipment. Additionally, the proposed Project would remove the existing buildings, which were constructed pursuant to fire code standards of the early 1970s and 1980s and develop new building structures pursuant to the most recent California building and fire codes, which would improve the fire safety of the Project site compared to the existing buildings. California's building/fire codes are published in their entirety every three years and were most recently updated in 2022. As all projects within the City, the proposed Project would be required per City permitting to comply with existing regulations, including the Santa Ana Fire Code and the OCFA Fire Prevention Guideline B-09, Fire Master Plans for Commercial and Residential Development. Overall, with the six existing fire stations within approximately 4 miles of the Project site, and the first and second responding stations 0.5 mile and 2.2 miles from the proposed Project, the area has adequate nearby fire facilities to serve the proposed Project in addition to the existing service needs of the area; and construction of a new or expanded fire station would not be required as a result of the proposed Project. As provided by the OCFA 2022 Statistical Annual Report, OCFA fire stations responded to 30,604 incidents resulting in 40,244-unit responses. Of the calls for service, 75 percent (22,835) were for emergency medical calls, 2 percent (734) were for fire incidents, and 23 percent (7,035) were for other incidents, which includes: cancelled service calls, ruptures, hazardous conditions, false alarms, and miscellaneous calls. Thus, the proposed Project would not result in substantial adverse physical impacts associated with the provision of, or the need for, new or physically altered fire protection facilities. Also, existing fire protection facilities, equipment, and staffing could be augmented as needed, as disclosed within the GPU FEIR (with assistance from revenue provided by the proposed Project and the fire facilities fee required prior to the issuance of building permits per Chapter 8-46 of the Municipal Code) to expand fire protection and emergency medical staffing and equipment provided from existing stations as the stations have capacity for additional staffing. Therefore, impacts related to fire protection services would be less than significant and consistent with those identified in the GPU FEIR, which determined that impacts related to fire protection services would be less than significant (Draft Supplemental EIR at pp. 5.1 1-5 through 5.1 1-6). Impact Finding: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered police service facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios and response times or other performance objectives for police services (Draft Supplemental EIR at p. 5.1 1 -1 2). Facts in Support of Findings: The proposed Project includes development of an administrative Police Department substation (no transfers or bookings) to be located within the commercial use area. The proposed Police Department substation would provide space for the expansion of policing services in the southern portion of the City including the ability to quickly respond to emergency calls from within the Project site. The construction and operational activities related to the new police substation are included as part of the proposed Project and would not result in any physical environmental effects beyond those identified throughout this Draft Supplemental EIR. For example, an analysis of construction emissions from building the new substation is included in Sections 5.1, .Air Quality, and 5.5, Greenhouse Gas Emissions of the Draft Supplemental EIR. The proposed Project would result in an incremental increase in demands on law enforcement services but would not be significant when compared to the current demand levels. As described previously, the residential population of the Project site at full occupancy would be approximately 9,238 residents. Based on the Police Department's 2022 staffing ratio of 0.98 officers per thousand population, at buildout, the proposed Project would require 9 additional officers. These new officers would be added to the Police Department staffing and would be accommodated by the proposed administrative Police Department substation because not all 9 would work at the same time, with staggered shifts in the field and on patrol. With the additional staffing and onsite proposed administrative Police Department substation, law enforcement personnel are anticipated to be able to respond in a timely manner to emergency calls within the Project site. Because the addition of 9 additional officers, based on Project buildout assumptions, could be accommodated by the proposed administrative Police Department substation and also other existing City policing facilities, the proposed Project would not result in the requirement to construct any other new facilities or expand any of the City's existing policing facilities. Therefore, because the proposed Project incorporates a new substation as part of the proposed Project, the construction of which is analyzed in conjunction with the proposed Project, the proposed Project would not result in the need for additional new or physically altered police protection facilities offsite. The proposed substation is analyzed as part of the proposed Project and would not result in any substantial impacts beyond those identified in the Draft Supplemental EIR associated with the construction and operation of the proposed Project. As such proposed Project impacts would be consistent with those identified as part of the GPU FEIR, which determined that impacts related to police protection services would be less than significant (Draft Supplemental EIR at pp. 5.1 1-12 through 5.1 1-13). Impact Finding: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities, the construction of which could cause significant environmental impacts (Draft Supplemental EIR at p. 5.1 1-16). Facts in Support of Findings: The proposed Project would develop 3,750 multi -family apartments, which would provide housing for families that have school children. As detailed in Draft Supplemental EIR Table 5.1 1-5, the proposed Project would result in 1,678 students at full occupancy. As shown in Draft Supplemental EIR Table 5.1 1-6, at buildout of the proposed Project, Jefferson Elementary School and Segerstrom High School may be over -capacity and additional or expanded facilities may be needed. However, the Santa Ana Unified School District Facilities Master Plan identifies that Jefferson Elementary School is planned for addition of a new two-story classroom building with 13,560 SF and 12 teaching stations; and Segerstrom High School is planned for a new 121035 SF career technical education classroom building. These planned school facilities would assist in meeting future student capacity needs. In addition, the need for additional school facilities is addressed through compliance with school impact fee assessment. The existing Santa Ana Unified School District development impact fee is $4.08 per square foot for all new residential development, and $0.66 per square foot for new commercial development. Pursuant to Government Code Section 65995 applicants shall pay developer fees to the appropriate school districts at the time building permits are issued; and payment of the adopted fees provides full and complete mitigation of school impacts. As a result, impacts related to school facilities would be less than significant, which is consistent with the findings of the CPU FEIR (Draft Supplemental EIR at pp. 5.1 1-16 through 5.1 1-17). Impact Finding: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered library facilities, the construction of which could cause significant environmental impacts (Draft Supplemental EIR at p. 5.1 1-20). Facts in Support of Findings: The proposed Project would develop 3,750 multi -family apartments, and a senior living/continuum of care use with up to 200 units, and a hotel with up to 250 rooms. Project buildout would result in approximately 9,238 additional residents, which would increase the demand for library services in the City. However, library use has declined due to the availability of online library materials and may continue to decline as the information available on the Internet increases exponentially over time (American Enterprise Institute [AEI], 2022). Property tax revenue generated by the proposed Project, as well as future and existing development, would contribute municipal funding that could be used by the City to construct future library facilities. However, the decision to construct any such facilities and the nature of any construction would be within the discretion of the City, as the entity responsible for such construction and operation of the library. As the proposed Project would be developed consistent with the buildout assumption for the site pursuant to the GPU, impacts to library services would be consistent with those identified within the CPU FEIR. Therefore, impacts to library services would be less than significant (Draft Supplemental EIR at p. 5.1 1-20). K. Transportation Impact Finding: The Project would not conflict with a program, plan or ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. (Draft Supplemental EIR p. 5.13-10). Facts in Support of Findings: As detailed in Table 5.13-3 of the Draft Supplemental EIR, Phase 1 of the proposed Project is forecast to generate 4,167 "net" daily trips, with 545 "net" trips in the AM peak hour and 359 "net" trips in the PM peak hour. Phase 2 of the proposed Project is forecast to generate 3,241 "net" daily trips, with 293 "net" trips in the AM peak hour and 271 "net" trips in the PM peak hour. Phase 3 of the proposed Project is forecast to generate 80 fewer "net" daily trips, with 381 "net" trips in the AM peak hour and 58 "net" trips in the PM peak hour. Operation of all three Phases at buildout of the proposed Project is anticipated to generate 7,328 net daily trips, including 1,219 AM peak hour and 688 PM peak hour trips (Draft Supplemental EIR pp. 5.13- 10 through 5.13-1 1). Roadway The proposed Project would continue to provide vehicular access to the site from the adjacent roadways, but would provide new driveways: five unsignalized right -turn only driveways and one signalized driveway along South Plaza Drive, two unsignalized right -turn only driveways along MacArthur Boulevard, three unsignalized right -turn only driveways along Bristol Street (one of which would be truck driveway), two signalized driveways on Bristol Street, and two unsignalized right - turn only driveways and one signalized driveway along Sunflower Avenue. In addition, the proposed Project would provide pedestrian and bicycle access to and through the site from installation of new and/or reconstructed landscaped sidewalks, the internal Greenlink pedestrian circulation, and Class IV bike lanes on Bristol Street, MacArthur Boulevard, and Sunflower Avenue along the Project site frontage. As shown on Figure 3-12 of the Draft Supplemental EIR, Proposed Circulation Plan, the Related Bristol Specific Plan identifies multiple circulation improvements to connect the proposed redevelopment of the site to the existing circulation system adjacent to the site in a manner that would implement efficient multi -modal circulation to, from, and within the Project site. Thus, a conflict with a program, plan, or policy related to roadway circulation would be less than significant (Draft Supplemental EIR pp. 5.13-1 1 through 5.13-13). Transit Facilities The Project site is located within a TPA and a high -quality transit corridor and is served by OCTA Routes 55, 57, 76, 86, 150, and 553. These existing transit services would continue to serve the ridership in the area and would serve residents, employees, and visitors of the Project site. The proposed Project would not alter or conflict with existing transit stops and schedules, and impacts related to transit services would not occur (Draft Supplemental EIR p. 5.13-1 3). Bicycle Facilities As detailed previously, Bristol Street has Class II bike lanes. The Related Bristol Specific Plan includes installation of a Class IV bike lane on Bristol Street, MacArthur Boulevard, and Sunflower Avenue with a median buffer. Therefore, the proposed Project would enhance existing bicycle facilities within the Project vicinity. Implementation of the proposed Project would not conflict with existing or planned bike lanes or bicycle transportation. Thus, impacts related to bicycle facilities would not occur (Draft Supplemental EIR p. 5.13-13). Pedestrian Facilities Implementation of the Specific Plan would include roadway improvements within the Project site that would provide for new sidewalks where none exist currently or provide for sidewalk improvements, thereby improving pedestrian facilities and the sidewalk network. The proposed Project would also provide sidewalks throughout the Project site that would connect the different onsite uses. Therefore, the proposed Specific Plan would not conflict with pedestrian facilities, but instead would expand and provide additional facilities. Overall., impacts related to transit, bicycle, and pedestrian facilities would be less than significant. The GPU FEIR determined that growth under the GPU and improvements to the circulation system with buildout of the GPU would result in no conflicts with related policies, plans, and programs. Therefore, proposed Project impacts would be consistent with those identified in the GPU FEIR, which were determined to be less than significant (Draft Supplemental EIR p. 5.1 3-13). Impact Finding: The Project would not conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b) (Draft Supplemental EIR p. 5.13-21). Facts in Support of Findings: As shown on Draft Supplemental EIR Figure 5.13-2, the City of Santa Ana Traffic Impact Study Guidelines Appendix A identifies that the Project site is located within a TPA. The Project area is served by six OCTA Routes, including Routes 55, 57, 76, 86, 150, and 553. Specifically, OCTA Route 57 serves as a high --quality bus stop with headways of 15 minutes or less during weekday peak commute hours. In addition, as shown on Draft Supplemental EIR Figure 5.13-3, SCAG identifies that the Project site is within a High -Quality Transit Area. Consistent with general guidance from OPR, and CEQA Guidelines Section 15064.3(b)(1), a project that is located within a TPA or a High Quality Transit Area is presumed to have a less than significant impact related to VMT. Additionally, the proposed Project is consistent with the land uses in the RTP/SCS, which assumed the site would be constructed as an urban, mixed -use development that would reduce area VMT, consistent with the TPA designation. The Project site is within an identified Priority Growth Area pursuant to the 2020-2045 RTP/SCS based on its location within a SCAG High Quality Transit Area. The Project proposes land uses consistent with those permitted by the GPU, which is consistent with the land uses assumed for the Project site as part of the RTP/SCS. In addition, as shown in Draft Supplemental EIR Table 5.8-1, the proposed Project would be consistent with the policies set forth in the RTP/SCS. Therefore, as the proposed Project is located within both a TPA and a High -Quality Transit Area and would be developed consistent with the SCAG RTP/SCS, the proposed Project would meet this screening threshold; and impacts would be less than significant. Overall, pursuant to the City's VMT screening criteria and guidance from OPR and CEQA Guidelines Section 15064.3(b)(1), based on the site's location within a High -+Quality Transit Area and a TPA with proximity to a high -quality bus stop on Route 57, as well as the site's urban, mixed -uses consistent with the RTP/SCS, the proposed Project would result in less than significant impacts related to VMT. Therefore, proposed Project impacts would be consistent with those identified in the GPU FEIR, which determined that the infill and redevelopment pursuant to the GPU land use plan would result in less than significant impacts related to VMT (Draft Supplemental EIR pp. 5.1 3-21 through 5.13-22). Impact Finding: The Project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment) (Draft Supplemental EIR at p. 5.13-22). Facts in Support of Findings: Construction During construction, construction barriers and fencing would separate the operational and construction areas of the site; and construction vehicles would have separate driveway entrances and circulation patterns that would be specified by the City's Building Safety Division in construction permitting pursuant to California fire, access, and safety code requirements to avoid incompatible uses. Also, construction worker vehicles, haul trucks, and vendor trucks, would be staged on the portion of the Project site under construction for the duration of the construction period. As part of the grading plan and building plan review processes, City permits would require appropriate permitting requirements to facilitate the passage of persons and vehicles through/around any required road closures and measures to properly route heavy-duty construction vehicles entering and leaving the site (as applicable). As a result, impacts related to vehicular circulation design features and incompatible uses during construction of the proposed Project would be less than significant. Therefore, proposed Project impacts would be consistent with those identified in the GPU FEIR, which were determined to be less than significant (Draft Supplemental EIR at p. 5.13-22). Operation The roadway improvements, restriping, and related street, and bikeway improvements of Bristol Street, MacArthur Boulevard, and Sunflower Avenue that are part of the Project would be conducted in conformance with City design standards. Compliance with existing regulations would be ensured through the City's traffic engineering review and construction permitting process. Further, the proposed Project's commercial and residential mixed uses with roadways, sidewalks, and bicycle routes would be similar to surrounding uses and would not result in incompatible vehicular uses that could increase hazards. A driveway is designated for truck deliveries, which would reduce the potential for incompatible vehicle uses between trucks and resident or visitor passenger vehicles onsite during operation. As a result, impacts related to hazardous vehicular circulation design features and incompatible uses during operation of the proposed Project would be less than significant. Therefore, Project impacts would be consistent with those identified in the GPU FEIR, which were determined to be less than significant (Draft Supplemental EIR at pp. 5.1 3-22 through 5.13-23). Impact Finding: The Project would not result in inadequate emergency access (Draft Supplemental EIR at p. 5.13-23). Facts in Support of Findings: Construction During construction activities, the proposed Project could result in incompatible uses in relation to conf lict between passenger vehicles from site operations and construction vehicles, such as haul trucks and vendor trucks. However, construction barriers and fencing would separate the operational and construction areas of the site; and construction vehicles would have separate driveway entrances and circulation patterns that would be specified by the City's Building Safety Division in construction permitting pursuant to California fire, access, and safety code requirements. The roadway improvements and installation of driveways that would be implemented during construction of the proposed Project could require the temporary closure of travel lanes, but full roadway closure and traffic detours are not expected to be necessary. Also the construction activities would be required to implement measures to facilitate the passage of persons and vehicles through/around any required temporary road restrictions and ensure the safety of passage in accordance with Section 503 of the California Fire Code (Title 24, California Code of Regulations, Part 9) and the City of Santa Ana Fire Code, included as Municipal Code Chapter 14, which would be ensured through the City's construction permitting process. Thus, implementation of the proposed Project through the City's permitting process would ensure existing regulations are adhered to and would reduce potential construction related emergency access impacts to a less than significant level. Therefore, Project impacts related to emergency access during construction would be consistent with those identified in the GPU FEIR, which were determined to be less than significant (Draft Supplemental EIR at pp. 5.13-23 through 5.13-24). Operation As described previously, the Project driveways would provide adequate and safe circulation to and from the Project site and would provide several routes for emergency responders to access different portions of the Project site and surrounding areas. The City's development and permitting review process would ensure that all access and circulation to and through the site would meet California Fire Code Requirements included as Municipal Code Chapter 14. Because the proposed Project is required to comply with all applicable City codes, as verified by the City and C)CFA, potential impacts related to inadequate emergency access would be less than significant. Therefore, Project impacts related to emergency access would be consistent with those identified in the GPU FEIR, which were determined to be less than significant pursuant to compliance with existing regulations (Draft Supplemental EIR at p. 5.13-24). L. Utilities and Service Sy stems Impact Finding: The Project would not require or result in the relocation or construction of new water facilities, or expansion of existing facilities, the construction of which could cause significant environmental effects (Draft Supplemental EIR at p. 5.15-10). Facts in Support of Findings: The proposed Project would install a new onsite water infrastructure system that would connect to water mains adjacent to the site. The proposed Project also includes offsite infrastructure improvements that would replace a portion of the 12-inch water main in South Plaza Drive from MacArthur Boulevard to Sunflower Ave with a 1 2-inch water main. The new onsite and new offsite water infrastructure would convey water supplies to the proposed residences, commercial uses, and landscaping through plumbing/'landscaping fixtures that would be compliant with the Title 24/CALG Teen Plumbing Code for efficient use of water, which would be ensured through the City's development permitting process. The proposed Project would continue to receive water supplies through the existing and improved water mains that are adjacent and near the site. This is consistent with the GPU FEIR findings that the City's water distribution system is hydraulically sound, but that due to the age and capacity of the existing water infrastructure, water main replacements would be required. Overall, the installation of new water infrastructure and improvements to offsite aged infrastructure is included as part of the proposed Project and would not result in any physical environmental effects beyond those identified throughout the Draft Supplemental EIR. For example, analysis of construction emissions for excavation and installation of the water infrastructure is included in Sections 5.1, Air Quality, and 5.5, Greenhouse Gas Emissions, and noise related to construction activities is included in Section 5.9, Noise of the Draft Supplemental EIR. Therefore, impacts related to water infrastructure would be less than significant. This is consistent with the GPU FEIR, which determined that through its planning and CIP mechanisms, the City would provide improvements to aged infrastructure to have adequate capacity for the proposed increases in water flows from buildout of the GPU, including those from buildout of the South Bristol Street Focus Area, and that impacts would be less than significant (Draft Supplemental EIR at pp. 5.15-10 through 5.15-1 1). Impact Finding: The City would have sufficient water supplies available to serve the project and reasonably foreseeable development during normal, dry, and multiple dry years (Draft Supplemental EIR at p. 5.15-1 1). Facts in Support of Findings: As shown in Draft Supplemental EIR Table 5.15-6, the proposed Project would result in a total demand of 929 AFY at full occupancy, which would be a 899 AFY increase in comparison to the water demand from the existing uses. This volume of water supply was accounted for in the City's 2015 UWMP (as determined by the GPU FEIR). Additionally, as detailed previously in Table 5.15-5, the City has an additional supply of 5,500 to 6,500 AFY beyond that anticipated to be needed by the 2020 UWMP projections. Therefore, the City would have sufficient water supplies available. Because the proposed Project would result in an increase in demand for water supplies that has been accounted for within previous City water supply planning, and separately verified through a Project specific WSA, the City would have adequate water supplies available to serve the proposed Project, and impacts would be less than significant. Therefore, impacts related to water supplies from the proposed Project are consistent with the findings of the GPU FEIR, which determined that water demand increases as a result of the GPU are within the planned supplies from the City, OCWD, and M'WD during normal -dry and multiple- dry year scenarios, and that impacts would be less than significant (Draft Supplemental EIR at p. 5.1 5-1 1 ). Impact Finding: The Project would not require or result in the relocation or construction of new wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects (Draft Supplemental EIR at p. 5.15-15). Facts in Support of Findings: The proposed Project would install a new onsite sewer system that would connect directly to the 78-inch OCSD sewer main in Sunflower Avenue. Based on results of the Sewer Analysis Report (included as Appendix Q to the Draft Supplemental EIR), the proposed Project would install a new onsite sewer system that would connect to the existing 78-inch OCSD sewer main within the Sunflower Avenue right-of-way. The Sewer Analysis Report determined that the Sunflower Avenue OCSD sewer main has a maximum capacity of 96.8 cfs and has adequate capacity to accommodate the additional wastewater flows from the proposed Project. The construction activities related to the new onsite sewer system and connection to the existing 78- inch OCSD sewer main is included as part of the proposed Project and would not result in any physical environmental effects beyond those identified throughout the Draft Supplemental EIR. As the proposed Project includes facilities to serve the Project, it would not result in the need for construction of other new wastewater facilities or expansions, the construction of which could cause significant environmental effects. Therefore, impacts would be less than significant. This determination is consistent with that of the GPU FEIR, which determined that increases in wastewater from buildout of the South Bristol Street Focus Area increases would be accommodated by the OCSD trunk sewer mains that are proximate to the area, and that impacts related to sewer infrastructure would be less than significant (Draft Supplemental EIR at p. 5.15-15). Impact Finding: The Project would not result in a determination by the wastewater treatment provider that would serve the Project that it has adequate capacity to serve the Project's projected demand in addition to the provider's existing commitments (Draft Supplemental EIR at p. 5.15-15). Facts in Support of Findings: The Orange County Sanitation District (OCSD) Reclamation Plant No. 1 has an additional capacity of 52 mgd, which would accommodate the increase in wastewater flow from full occupancy of the proposed Project that would generate 762,241 gpd (0.76 mgd). As a result, implementation of the proposed Project would not result in inadequate capacity of the wastewater treatment plant to serve the Project's demand in addition to existing service commitments, and impacts would be less than significant. This is consistent with the GPU FEIR, which determined that wastewater generated through development in accordance with the GPU would have a less -than -significant impact on the existing wastewater collection and treatment facilities and systems (Draft Supplemental EIR at pp. 5.15-15 through 5.15-1 b). Impact Finding: The Project would not require or result in the relocation or construction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects (Draft Supplemental EIR at p. 5.15-20). Facts in Support of Findings: The Preliminary Water Quality Management Plan (WQMP) (included as Appendix M to the Draft Supplemental EIR) for the proposed Project describes that the Project site currently includes 37.02 acres of impermeable surfaces, which equates to 90 percent of the site. After completion of Project construction, the site would have a 4 percent reduction in impermeable surfaces to 35.37 acres or 86 percent of the site. The runoff within the Project site would be collected by roof drains, surface flow designed pavement, curbs, and area drains and conveyed to vegetated biotreatment system for treatment. Although the proposed Project would result in a reduction of stormwater runoff, the Project includes offsite storm drain improvements pursuant to the City's Storm Drain Master Plan that involve replacing 2,230 lineal feet of the 54/60- inch storm drain with a 72-inch lateral in Sunflower Avenue and replacing a 42-inch lateral in Plaza drive with a 60-inch lateral. This is being done to implement City's needed drainage Master Plan improvements within the rights -of -way that would be reconstructed as part of the proposed Project. The effects of the improvements are part of construction of the Project as a whole and are included in the evaluation throughout the Draft Supplemental EIR. Therefore, impacts related to drainage facilities would be less than significant. This finding is consistent with the GPU FEIR discussion related to development projects increasing onsite permeability and providing onsite detention systems that would be evaluated in detailed hydrology studies to ensure that existing peak flows would not be exceeded, thereby eliminating any potential increase in runoff and that impacts to the storm drain system would be less than significant (Draft Supplemental EIR at p. 5.15-20). Impact Finding: The Project would not generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals (Draft Supplemental EIR at p. 5.15-23). Facts in Support of Findings: r^nc+ri ie-fir%n The Project is estimated to generate approximately 1,009 tons of waste during demolition and additional waste during construction, which would occur over a 10-year period. However, Section 5.408.1 of the 2016 California Green Building Standards Code requires demolition and construction activities to recycle or reuse a minimum of 65 percent of the nonhazardous construction and demolition waste. Thus, the demolition and construction solid waste that would be disposed of at the landfill would be approximately 35 percent of the waste generated. Therefore, demolition activities, which would generate the most solid waste would generate approximately 353 tons of solid waste. In March 2023, the maximum tonnage received was 8,909.41 tons. Thus, the facility has additional capacity of 8,556.41 tons per day (CalRecycle 2023) and would be able to accommodate the construction solid waste from the proposed Project. Therefore, impacts related to landfill facilities from construction activities would be less than significant (Draft Supplemental EIR at p. 5.15-23). Operation Operation of the Project at buildout would generate approximately 25,913 tons of solid waste per year, at least 75 percent of which is required by California law to be recycled, which would reduce the volume of landfilled solid waste to approximately 7,734.8 tons per year, or 148.34 tons per week, as shown on Draft Supplemental EIR Table 5.15-9. As the Frank Bowerman Sanitary Landfill is permitted to accept 11,500 tons per day of solid waste, and in March 2023, the maximum tonnage received was 8,909 tons, the facility had additional capacity of 2,591 tons (Calrecycle 2023). Therefore, the Frank Bowerman Sanitary Landfill would be able to accommodate the addition of 148.34 tons of waste per week. Thus, the proposed Project would be served by a landfill with sufficient permitted capacity to accommodate the Project's solid waste disposal needs and the Project would not impair the attainment of solid waste reduction goals. Impacts related to landfill capacity would be less than significant (Draft Supplemental EIR at pp. 5.15-23 through 5.15-24). This page was intentionally left blank. SECTION IV IMPACTS MITIGATED TO A LEVEL OF LESS THAN SIGNIFICANT The City hereby finds that mitigation measures have been identified in the Supplemental EIR that would avoid or substantially lessen the following potentially significant environmental impacts to a less than significant level. The potentially significant impacts and the mitigation measures that would reduce them to a less than significant level are detailed in the Supplemental EIR and summarized below. A. Air Quality Impact Finding: The Project would not expose sensitive receptors to substantial pollutant concentrations (Draft Supplemental EIR at p. 5.1-32). Changes or alterations have been required in, or incorporated into, the Project that avoid or substantially lessen the significant environmental effect identified in the Draft Supplemental EIR Facts in Support of Findings: The nearest offsite sensitive receptor to the Phase 1 construction area is a multi -family residential building located approximately 130 feet (40 meters) to the west. The nearest offsite sensitive receptor to the Phase 2 construction area is a multi -family residential building located 410 feet (125 meters) to the north. The nearest offsite sensitive receptor to the Phase 3 construction area is a multi -family residential building located 130 feet (40 meters) to the west. Construction Phase 1 Table 5.1-23 of the Draft Supplemental EIR identifies daily localized onsite emissions that are estimated to occur during construction of Phase 1 of the proposed Project. As shown, emissions during the peak site preparation and grading construction activity of Phase 1 would exceed the SCAQMD's localized significance thresholds for NOx and PM2.5. However, as described previously GPU FEIR Mitigation Measure AQ-1 for GARB Tier 4 Final off -road construction equipment standards would reduce NOx emissions and Project Mitigation Measure AQ-1, Construction Exhaust and Dust Control, would reduce PM2.5 emissions to below the SCAQMD thresholds for localized significance, as shown in Draft Supplemental EIR Table 5.1-24. Therefore, LST impacts from construction of Phase 1 would be less than significant with incorporation of mitigation (Draft Supplemental EIR at pp. 5.1-32 through 5.1-33). Construction Phase 2 Table 5.1-25 of the Draft Supplemental EIR identifies daily localized onsite emissions that are estimated to occur during construction of Phase 2 of the proposed Project. As shown, emissions during the peak site preparation and grading construction activity of Phase 2 would exceed the SCAQMD's localized significance thresholds for NOx and PM2.5. However, as described previously GPU FEIR Mitigation Measure AQ-1 for CARE Tier 4 Final off -road construction equipment standards would reduce NOx emissions and Project Mitigation Measure AQ-1, Construction Exhaust and Dust Control, would reduce PM2.5 emissions to below the SCAQMD thresholds for localized significance, as shown in Draft Supplemental EIR Table 5.1-26. Therefore, LST impacts from construction of Phase 2 would be less than significant with incorporation of mitigation (Draft Supplemental EIR at pp. 5.1-33 through 5.1-34). Construction Phase 3 Table 5.1-27 of the Draft Supplemental EIR identifies daily localized onsite emissions that are estimated to occur during construction of Phase 3 of the proposed Project. As shown, emissions during the peak construction activity of site preparation during Phase 3 would exceed the SCAQMD localized significance threshold for PM2.5. However, as described previously Project Mitigation Measure AQ-1, Construction Exhaust and Dust Control, would be implemented, and would reduce PM2.5 emissions to below the SCAQMD thresholds for localized significance, as shown in Draft Supplemental EIR Table 5.1-28. Therefore, LST impacts from construction of Phase 3 would be less than significant with incorporation of mitigation (Draft Supplemental EIR at pp. 5.1-34 through 5.1- 35). Operation at Project Buildout Applying a 5-acre LST threshold as done by the Draft Supplemental EIR is a very conservative approach. As shown in Table 5.1-32 of the Draft Supplemental EIR, unmitigated emissions generated on site by the proposed Project would exceed the LST threshold for PM2.5. Therefore, operational mitigation would be required. As shown on Table 5.1-33 of the Draft Supplemental EIR, with implementation of operational mitigation measures that prohibit fireplaces, require use of electrical landscape equipment, and use of low VOC paints, PM2.5 emissions would be reduced to a less than significant level. Therefore, LST impacts of Project buildout would be less than significant with incorporation of mitigation (Draft Supplemental EIR at p. 5.1-37). Diesel Health Risk Assessment. A Health Risk Assessment (HRA) (included as Appendix C to the Draft Supplemental EIR) was prepared to evaluate the health risk impacts as a result of exposure to Diesel Particulate Matter (DPM) during construction of the proposed Project. Onsite truck idling was estimated to occur as trucks enter and travel through the site. SCAQMD recommends using a 10 in one million as the cancer risk threshold. The receptor with the greatest potential exposure to construction DPM source emissions are the closest residences, which are as close as 130 feet from construction activities. Draft Supplemental EIR Table 5.1-34 shows that DPM levels would be reduced below SCAQMD thresholds for residential and worker receptors with implementation of GPU FEI R Mitigation Measure AQ-1 and Project Mitigation Measure AQ-1 for CARE Tier 4 Final off -road construction equipment standards. Thus, construction DPM carcinogenic risks would be reduced to a less than significant level with incorporation of mitigation. The significance thresholds for DPM exposure also require an evaluation of non -cancer risk known as hazard index. A chronic hazard index of 1.0 is considered individually significant. As shown on Draft Supplemental EIR Table 5.1-35, the maximum chronic hazard index at offsite receptors during construction would be 0.003 with implementation of GPU FEIR Mitigation Measure AQ-1 and Project Mitigation Measure AQ-1 for CARB Tier 4 Final off -road construction equipment standards, which is less than the 1.0 threshold. Therefore, impacts related to non -carcinogenic hazards would be less than significant with incorporation of mitigation (Draft Supplemental EIR at pp. 5.1-38 through 5.1- 39). Mitigation Measures: GPU FEIR MM AQ-1: Prior to discretionary approval by the City of Santa Ana for development projects subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects), project applicants shall prepare and submit a technical assessment evaluating potential project construction -related air quality impacts to the City of Santa Ana for review and approval. The evaluation shall be prepared in conformance with South Coast Air Quality Management District (South Coast AQMD) methodology for assessing air quality impacts. If construction -related criteria air pollutants are determined to have the potential to exceed the South Coast AQMD's adopted thresholds of significance, the City of Santa Ana shall require that applicants for new development projects incorporate mitigation measures to reduce air pollutant emissions during construction activities. These identified measures shall be incorporated into all appropriate construction documents (e.g., construction management plans) submitted to the City and shall be verified by the City. Mitigation measures to reduce construction -related emissions could include, but are not limited to: • Require fugitive -dust control measures that exceed South Coast AQMD's Rule 403, such as: o Use of nontoxic soil stabilizers to reduce wind erosion. a Apply water every four hours to active soil -disturbing activities. o Tarp and/or maintain a minimum of 24 inches of freeboard on trucks hauling dirt, sand, soil, or other loose materials. • Use construction equipment rated by the United States Environmental Protection Agency as having Tier 3 (model year 2006 or newer) or Tier 4 (model year 2008 or newer) emission limits, applicable for engines between 50 and 750 horsepower. • Ensure that construction equipment is properly serviced and maintained to the manufacturer's standards. • Limit nonessential idling of construction equipment to no more than five consecutive minutes. • Limit onsite vehicle travel speeds on unpaved roads to 15 miles per hour. • Install wheel washers for all exiting trucks or wash off all trucks and equipment leaving the project area. Use Super -Compliant VOC paints for coating of architectural surfaces whenever possible. A list of Super- Compliant architectural coating manufactures can be found on the South Coast AQMD's website. Project Specific MM AQ-1: Construction Exhaust and Dust Control. Prior to issuance of Phase 1, Phase 2, and Phase 3 grading permits, the Project Applicant shall prepare and submit documentation to the City of Santa Ana Building and Safety Division that demonstrates the following: 0 Require fugitive -dust control measures that exceed SCAQMD Rule 403 requirements: a Apply water at least three times daily to active soil -disturbing activities. o Tarp and/or maintain a minimum of 24 inches of freeboard on trucks hauling dirt, sand, soil, or other loose materials. o Limit onsite vehicle travel speeds on unpaved roads to 15 miles per hour. o Install wheel washers for all exiting trucks or wash off all trucks and equipment leaving the project area. • All off -road diesel -powered construction equipment greater than 50 horsepower meets California Air Resources Board Tier 4 Final off -road emissions standards. Requirements for Tier 4 Final equipment shall be included in applicable bid documents and successful contractor(s) must demonstrate the ability to supply such equipment. A copy of each equipment's Best Available Control Technology (BACT) documentation (certified tier specification or model year specification), and GARB or SCAQMD operating permit (if applicable) shall be provided to the City at the time of mobilization of each applicable unit of equipment. • Construction equipment shall be properly maintained according to manufacturer specifications. All equipment maintenance records and data sheets, including design specifications and emission control tier classifications shall be kept onsite and furnished to the lead agency or other regulators upon request. • All construction equipment and delivery vehicles shall be turned off when not in use, or limit onsite idling for no more than 5 minutes in any 1 hour. • Onsite electrical hook ups to a power grid shall be provided for electric construction tools including saws, drills, and compressors, where feasible, to reduce the need for diesel powered electric generators. Construction contracts shall require all off -road equipment with a power rating below 19 kilowatts (25 horsepower) (e.g., plate compactors, pressure washers, etc.) used during project construction be battery powered. • Prepare a construction traffic control plan detailing the locations of equipment staging areas, material stockpiles, proposed road closures, and hours of construction operations, and designing the plan to minimize impacts to roads frequented by passenger cars, pedestrians, bicyclists, and other non -truck traffic. • Provide information on transit and ridesharing programs and services to construction employees. B. Cultural Resources Impact Finding: The Project would not cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5 (Draft Supplemental EIR at p. 5.2-15 ). Changes or alterations have been required in, or incorporated into, the Project that avoid or substantially lessen the significant environmental effect identified in the Draft Supplemental EIR, Facts in Support of Findings: The site has been previously disturbed from both agricultural uses and development, including ground disturbance to depths for installation of the existing utility infrastructure that serves the site. As required by GPU FEIR Mitigation Measure CUL-4, an Archaeological Resources Assessment Report was prepared for the proposed Project to analyze the potential archaeological sensitivity of the Project site and the potential for Project ground disturbance to result in impacts to archaeological resources. As the Project site is sensitive for previously unknown archaeological resources, the Archaeological Resources Assessment Report (Appendix E to the Draft Supplemental EIR) determined that GPU FEIR Mitigation Measure CUL-6 would be required to be implemented to require an archaeologist to be retained for monitoring throughout proposed Project ground disturbing activities. In addition, the proposed Project would be required to implement Project -specific Mitigation Measure CR-1, which sets forth requirements should archaeological resources be uncovered during proposed Project activities, and Project -specific Mitigation Measure CR-2, which preparation of a monitoring report after the completion of monitoring activities. With implementation of GPU FEIR Mitigation Measure CUL-b and Project -specific Mitigation Measures CR-1 and CR-2, impacts would be less than significant. Therefore, impacts related to Project buildout of the site would be consistent with the impact conclusions set forth in the GPU FEIR, which determined that impacts to archaeological resources would be less than significant after implementation of mitigation (Draft Supplemental EIR at p. 5.2-15). Mitigation Measures: GPU FEIR MM CUL-4: For projects with ground disturbance e.g., grading, excavation, trenching, boring, or demolition that extend below the current grade prior to issuance of any permits required to conduct ground -disturbing activities, the City shall require an Archaeological Resources Assessment be conducted under the supervision of an archaeologist that meets the Secretary of the Interior's Professionally Qualified Standards in either prehistoric or historic archaeology. Assessments shall include a California Historical Resources Information System records search at the South Central Coastal Information Center and of the Sacred Land Files maintained by the Native American Heritage Commission. The records searches will determine if the proposed project area has been previously surveyed for archaeological resources, identify and characterize the results of previous cultural resource surveys, and disclose any cultural resources that have been recorded and/or evaluated. If unpaved surfaces are present within the project area, and the entire project area has not been previously surveyed within the past 10 years, a Phase I pedestrian survey shall be undertaken in proposed project areas to locate any surface cultural materials that may be present. GPU FEIR MM CUL-b: If the archaeological assessment did not identify archaeological resources but found the area to be highly sensitive for archaeological resources, a qualified archaeologist and a Native American monitor approved by a California Native American Tribe identified by the Native American Heritage Commission as culturally affiliated with the project area shall monitor all ground -disturbing construction and pre -construction activities in areas with previously undisturbed soil of high sensitivity. The archaeologist shall inform all construction personnel prior to construction activities of the proper procedures in the event of an archaeological discovery. The training shall be held in conjunction with the project's initial onsite safety meeting and shall explain the importance and legal basis for the protection of significant archaeological resources. The Native American monitor shall be invited to participate in this training. In the event that archaeological resources (artifacts or features) are exposed during ground- disturbing activities, construction activities in the immediate vicinity of the discovery shall be halted while the resources are evaluated for significance by an archaeologist who meets the Secretary's Standards. This will include tribal consultation and coordination with the Native American monitor in the case of a prehistoric archaeological resource or tribal resource. If the discovery proves to be significant, the long-term disposition of any collected materials should be determined in consultation with the affiliated tribes), where relevant; this could include curation with a recognized scientific or educational repository, transfer to the tribe, or respectful reinternment in an area designated by the tribe. Project Specific MM CR-1: If a resource is determined significant, the Project Applicant, qualified archaeologist, and tribal monitors (as included in MM TCR-1 ) Native American tribal representative shall meet and confer regarding the treatment measures and mitigation for such resources. Pursuant to PRC Section 21053.2(b), avoidance is the preferred method of preservation for archaeological resources and may include deeding archaeological resources into permanent conservation easements or planning parks, greenspace, or other open space to incorporate archaeological resources. If preservation in place or avoidance is not feasible, treatment may include implementation of archaeological data recovery excavations to remove the resource along with subsequent laboratory processing and analysis of the artifacts that are recovered. The methods and results of the data recovery excavations shall be included in the monitoring report that is described in MM CR-2. The report shall include a description of resources recovered, treatment of the resources, results of the artifact processing, analysis, and research, and evaluation of the resources with respect to the California Register of Historical Resources and CEQA. Construction activities in the immediate vicinity of the discovery can resume once the fieldwork component of the treatment measures has been implemented. These treatment measures and mitigation shall reduce any significant impacts by ensuring that either the resource is preserved in place or is removed prior to its destruction by construction activities. Project Specific MM CR-2: After monitoring has been completed, the qualified archaeologist shall prepare a monitoring report that details the results of monitoring activities, which shall be submitted to the City and to the SCCIC at the University California, Fullerton. C. Geology and Soils Impact Finding: The Project would not be located on a geologic unit or soils that is unstable, or that would become unstable as a result of the project, and potentially result in on- or offsite landslide, lateral spreading, subsidence, liquefaction or collapse (Draft Supplemental EIR at p. 5.4-1 1 ). Changes or alterations have been required in, or incorporated into, the Project that avoid or substantially lessen the significant environmental effect identified in the Draft Supplemental EIR. Facts in Support of Findings: The elevation of the site is approximately 34 feet above msl and the site is not located on or adjacent to a hillside or slope. Based on the relatively flat topography of the site, lack of a free face nearby and low liquefaction potential, the G eotechnical Report determined that the potential for lateral spreading on the site is low (Included as Appendix G to the Draft Supplemental EIR). Thus, impacts related to lateral spreading would be less than significant. Also, impacts related to landslides would not occur. However, as detailed in the Geotechnical Report (Included as Appendix G to the Draft Supplemental EIR), groundwater has been encountered at the site at between 5 and 16 feet bgs and excavations during Project construction are likely to encounter groundwater. The Geotechnical Report identified that excavations within potentially collapsible wet soils may need to be stabilized; and stabilization may consist of placement of a granular working mat consisting of geogrid and coarse gravel or sub -excavation and replacement with dried soil. Mitigation Measure GEO-1 has been included to require that the proposed Project comply with a final design -level geotechnical report that must be completed in compliance with the current CBC requirements and prepared to the satisfaction of the City's Building and Safety Division. Also, Mitigation Measure GEO-2 is included to ensure that geotechnical recommendations regarding groundwater induced unstable soils are implemented pursuant to existing CBC construction measures. Also, the CBC, as currently adopted in the City's Municipal Code Chapter 8, Article 2, Division 1, requires that a California Certified Engineering Geologist or California -licensed civil engineer provide site -specific engineering data for the proposed structures, which are reviewed by the City for appropriate inclusion as part of the building plan check and development review process. Compliance with the requirements of the CBC and City's Municipal Code for structural safety is included as PPP GEO-1 and would reduce potential impacts to a less than significant level. Therefore, due to the need for mitigation to ensure implementation of existing CBC measures, impacts related to Project buildout of the site would be slightly greater than the impact conclusions set forth in the GPU FEIR, which determined that impacts related to unstable soils would be less than significant with implementation of existing regulations (Draft Supplemental EIR at pp. 5.4-11 through 5.4-12). Plans, Program and Policies: PPP GEO-1: CBC Compliance. The proposed Protect is required to comply with the California Building Standards Code (CBC) as included in the City's Municipal Code as Chapter 8, Article 2, Division 11 to preclude significant adverse effects associated with seismic and soils hazards. As part of CBC compliance, CBC related and geologist and/or civil engineer specifications for the proposed Project shall be incorporated into grading plans and building specifications as a condition of construction permit approval. Mitigation Measures: MM GEO.1 Incorporation of and Compliance with a Design Level Geotechnical Report. A final design level geotechnical report that complies with all applicable state and local code requirements shall be prepared for each Project structure by a California licensed qualified geotechnical engineer consistent with the California Building Code and City of Santa Ana requirements applicable at the time of grading construction and shall include recommendations related to site grading and earthwork, fill materials, compaction, foundations, and other structural elements. The report recommendations shall be included in construction specifications and permits; and confirmed through onsite inspections. MM GEC)-2 Implementation of Geotechnical Recommendations for Groundwater and Expansive Soils. Project plans, grading specifications, and construction permitting shall incorporate site specific earthwork and ground improvement requirements related to groundwater saturated soils and expansive soils consistent with the California Building Code and City of Santa Ana requirements applicable at the time of grading/construction as stated in a design level geotechnical report and approved by the City's Building and Safety Division. This shall include recommendations related to discovery of groundwater, wet soils, or unstable soils during grading, stabilization, dewatering, fill materials, and foundations. Impact Finding: The Project would be located on expansive soils, as defined in table 1 B-1 B of the Uniform Building Code (1994) but would not create substantial risks to life or property (Draft Supplemental EIR at p. 5-4-12). Changes or alterations have been required in, or incorporated into, the Project that avoid or substantially lessen the significant environmental effect identified in the Draft Supplemental EIR. Facts in Support of Findings: The Project site contains lean and fat clays, and silty sand and poorly - graded sands with interbeds of clays, which have been tested and determined to have a medium to high potential for expansion due to the clay content (included as Appendix G to the Draft Supplemental EIR). The clayey soils are present onsite from the ground surface to approximately 25 to 30 feet bgs. Prior to approval of construction, an engineering level design geotechnical report is required to be prepared and submitted to the City that details the project designs that have been included to address potential geotechnical and soil conditions pursuant to the CBC requirements that are included in the City's Municipal Code Chapter 8, Article 2, Division 1, and implemented by Mitigation Measures GEO-1 and GEO-2. Therefore, due to the need for mitigation to ensure implementation of existing CBC measures, impacts related to Project buildout of the site would be slightly greater than the impact conclusions set forth in the GPU FEIR, which determined that impacts related to expansive soil would be less than significant with implementation of existing regulations (Draft Supplemental EIR at p. 5-4-1 2). Mitigation Measures: MM GEC)-1 Incorporation of and Compliance with a Design Level Geotechnical Report. As listed previously. MM GEC?-2 Implementation of Geotechnical Recommendations for Groundwater and Expansive Soils. As listed previously. Impact Finding: The Project would not directly or indirectly destroy a unique paleontological resource or site or unique geologic feature (Draft Supplemental EIR at p. 5.4-1 3). Changes or alterations have been required in, or incorporated into, the Project that avoid or substantially lessen the significant environmental effect identified in the Draft Supplemental EIR. Facts in Support of Findings: As described in Appendix H to the Draft Supplemental EIR, the Project site is underlain by Holocene -aged axial channel deposits, and due to the young age of the onsite soils, it is unlikely that excavation at the surface would impact fossil resources. However, Pleistocene age alluvium may exist below the younger axial channel deposits which could yield fossils. Thus, excavation and grading during construction of the proposed Project has the potential to impact paleontological resources. As such, impacts to paleontological resources within the Project site are potentially significant. Therefore, GPU FEIR Mitigation Measures GEC-2 and GEQ-3 would be required to confirm onsite sediments and provide measures in the case that a fossil is discovered onsite. In addition, Mitigation Measures PALEQ-1 through PALED-3 have been included to retain a qualified paleontologist prior to the start of excavation, provide paleontological resources sensitivity training, and monitor the site for excavations below 20 feet bgs. Mitigation Measure PALE?-4 has been included to identify and catalog any significant fossils and Mitigation Measure PALE4-5 has been included to prepare a Paleontological Resources Monitoring Report that summarizes the findings. Thus, with implementation of GPU FEIR and Project -specific mitigation measures, impacts related to paleontological resources would be less than significant. Therefore, impacts related to Project buildout of the site would be consistent with the impact conclusions set forth in the GPU FEIR, which determined that impacts related to paleontological resources would be less than significant with the implementation of mitigation (Draft Supplemental EIR at p. 5.4-12). Mitigation Measures: GPU FIER MM GEo-2: Low -to -High Sensitivity. Prior to issuance of a grading permit for projects involving ground disturbance in previously undisturbed areas mapped with "low- to -high" paleontological sensitivity (see Figure 5.6-3), the project applicant shall consult with a geologist or paleontologist to confirm whether the grading would occur at depths that could encounter highly sensitive sediments for paleontological resources. If confirmed that underlying sediments may have high sensitivity, construction activity shall be monitored by a qualified paleontologist. The paleontologist shall have the authority to halt construction during construction activity as outlined in Mitigation Measure GEO-3. GPU FEIR MM GEo-3: All Projects. In the event of any fossil discovery, regardless of depth or geologic formation, construction work shall halt within a 50-foot radius of the find until its significance can be determined by a Qualified Paleontologist. Significant fossils shall be recovered, prepared to the point of curation, identified by qualified experts, listed in a database to facilitate analysis, and deposited in a designated paleontological curation facility in accordance with the standards of the Society of Vertebrate Paleontology (2010). The most likely repository is the Natural History Museum of Los Angeles County (NHMLA). The repository shall be identified, and a curatorial arrangement shall be signed, prior to collection of the fossils. MM PALEo-1: Retention of a Oualified Paleontologist. Protect plans, grading specifications, and construction permitting shall ensure that prior to the start of excavation, the client shall retain a Qualified Paleontologist who meets the professional criteria established by the Society of Vertebrate Paleontology (SVP 2010) to oversee the implementation of all paleontological resources mitigation requirements for the proposed Project. MM PALEo-2: Paleontological Resources Sensitivity Training. Project plans, grading specifications, and construction permitting shall ensure that prior to the start of excavations, the Qualified Paleontologist, or their designee, shall conduct paleontological resources awareness training for onsite personnel. The training session shall focus on how to identify paleontological resources that may be encountered during excavations and the procedures to be followed in the event of their discovery. The City shall ensure onsite personnel are made available for and attend the training and retain documentation demonstrating attendance. MM PALEO-3: Paleontological Monitoring. Project plans, grading specifications, and construction permitting shall detail that paleontological resources monitoring shall be required for excavations below 20 feet below ground surface (bgs). Paleontological monitoring shall be conducted by a monitor who meets the professional criteria established by the Society of Vertebrate Paleontology working under the direct supervision of the Qualified Paleontologist. Monitoring can be reduced, or ceased entirely, if determined adequate by the Qualified Paleontologist. Recommendations for reduction or cessation of monitoring will be based on a more accurate understanding of the lithologic character and age of the sediments exposed during excavation. If deeper excavations continue to encounter younger, Holocene alluvium, monitoring shall be reduced from full-time to part-time monitoring or weekly inspections. If the Qualified Paleontologist determines, based on the lithologic character of the sediments, that there is very little likelihood of impacting Pleistocene marine sediments, paleontological monitoring shall cease entirely. The paleontological monitor shall collect any identifiable fossils encountered during the excavations. If onsite personnel discover potential fossils during excavations when a paleontological monitor is not present, they shall cease excavation within 50 feet of the discovery and contact the Qualified Paleontologist. Construction activities may resume after the discovery is assessed by the Qualified Paleontologist and appropriate treatment measures have been implemented. MM PALEO-4: Paleontological Resources Treatment and Disposition. Project plans, grading specifications, and construction permitting shall require that significant fossils be prepared to the point of identification and cataloged. Significant fossils shall be curated at a public, non-profit institution with a research interest in the material and with retrievable storage, such as the Natural History Museum of Los Angeles County, if such an institution agrees to accept the fossils. If no institution accepts the fossil collection, then the fossils may be donated to a local museum, historical society, school, or other institution for educational purposes. Accompanying notes, reports, maps, and photographs shall also be filed with the final repository. MM PALEO-5: Paleontological Resources Monitoring Report. Project plans, grading specifications, and construction permitting shall ensure that upon completion of the excavation phase of the Project, the Qualified Paleontologist shall prepare a report summarizing the results of the monitoring efforts. The report shall be submitted to the City to signify the satisfactory completion of required paleontological mitigation measures. If significant fossils are discovered, the report shall also be submitted to the appropriate repositories. D. Greenhouse Gas Emissions Impact Finding: The Project would not generate GHQ emission, either directly or indirectly, that may have a significant impact on the environment (Draft Supplemental EIR at p. 5.5-13). Changes or alterations have been required in, or incorporated into, the Project that avoid or substantially lessen the significant environmental effect identified in the Draft Supplemental EIR. Facts in Support of Findings: Construction The construction -related activities involve the following: demolition, site preparation, excavation, grading, paving, construction of structures and infrastructure, and architectural coatings. These construction activities would result in the emission of GHGs from equipment exhaust, construction - related vehicular activity and construction worker automobile trips. As shown on Draft Supplemental EIR Table 5.5-3, construction of Phase 1 of the proposed Project would result in the generation of approximately 36,506 MTCO2e. Construction of Phase 2 would generate approximately 10,091 MTCO2e, and construction of Phase 3 would generate approximately 34,142 MTCO2e. The amortized Project Phase 1 construction emissions would be 11217 MTCO2e per year while the amortized Project Phase 2 and Phase 3 construction emissions would be 336 MTCO2e and 1,138 MTCO2e per year, respectively. Total construction emissions and total amortized emissions for Project Buildout would be 80,740 MTCO2e and 2,691 MTCO2e per year, respectively. However, as detailed in Section 5.1, Air Quality, and listed below, the proposed Project would implement GPU FEIR Mitigation Measure AQ-1, which requires the use of advanced engine tiers (i.e., equipment engines meeting CARE Tier 4 Final emissions standards), which would reduce total construction emissions to 67,425 MTCO2e (2,248 MTCO2e per year) (Draft Supplemental EIR at pp. 5.5-13 through 5.5-14). Operation As shown in Draft Supplemental EIR Table 5.5-4, the proposed Project's total unmitigated increase in GHG emissions for Phase 1 would be approximately 20,597 MTCO2e, for Phase 2 would be 7,325 MTCO2e, for Phase 3 would be 14,147 MTCO2e, and 42,069 MTCO2e for Project buildout. The Greenhouse Gas Emissions Assessment (included as Appendix I to the Draft Supplemental EIR) describes that a majority of the GHG emissions (56 percent unmitigated and 52 percent mitigated) generated from the proposed Project at buildout are associated with non -construction related mobile sources. As detailed in Section 5.1, Air Quality, and listed below, proposed Project Mitigation Measure AQ-3: Vehicle Trip Reduction, Mitigation Measure AQ-4: Prohibition of Fireplaces, Mitigation Measure AQ-5: Electric Landscape Equipment, Mitigation Measure AQ-6: Low VOC Paint (Operations), Mitigation Measure ACC-7: Loading Dock Connections would reduce operational air quality emissions and would also reduce GHG emissions. Additionally, Project Mitigation Measure GHG-1, through Mitigation Measure GHG-5 is included to reduce GHG emissions from non -mobile sources such as the use of the energy efficient appliances, recycling solid waste, and photovoltaic solar panels, and the TDM program required by Mitigation Measure AQ-3 would reduce GHG emissions from commuting. No Greenhouse Gas emissions reductions were taken for the implementation of Project MM GHG-1. The GPU FEIR determined that implementation of the GPU and its policies would result in a net decrease in emissions of approximately 255,878 MTCO2e over existing conditions within the City. The proposed Project would implement the mitigation identified above to reduce GHG emissions; and the Project proposes a specific plan that would be consistent with the buildout assumptions and applicable development standards of the GPU. Impacts related to generation of GHG emissions would be less than significant with mitigation incorporated. As such, Project impacts would be consistent with the impact conclusions set forth in the GPU FEIR, which determined that impacts related to GHG emissions would be less than significant with mitigation incorporated (Draft Supplemental EIR at pp. 5.5-15 to 5.5-17). Mitigation Measures: Mitigation Measure GHG-1: Solar Panels. The Project shall be required to install solar photovoltaic (PV) panels or other source of renewable electricity generation on -site, based on the maximum roof area available for solar (i.e., solar -ready zone). The solar -ready zone shall comply with Section 1 10.10 of the 2022 California Energy Code and shall comply with access, pathway, ventilation, and spacing requirements, and exclude skylight area. The final PV generation facility size requires approval by Southern California Edison (SCE). SCE's Rule 21 governs operating and metering requirements for any facility connected to SCE's distribution system. Should SCE limit the offsite export, the proposed Project may utilize a battery energy storage system (BESS) to lower offsite export while maintaining onsite renewable generation to off -set consumption. The electrical system and infrastructure must be clearly labeled with noticeable and permanent signage. The schedule of photovoltaic system locations may be updated as needed. Mitigation Measure GHG-2: LEED, Charging Stations, and Bus Stops. Prior to the issuance of a Phase 1, Phase 21 or Phase 3 building permits, the Project Applicant or successor in interest shall provide documentation to the City of Santa Ana demonstrating the following: • The Project shall be designed to achieve Leadership in Energy and Environmental Design (LEED) certification. It shall also be designed consistent with CALGreen Tier 2 or will otherwise achieve a 20% reduction below 2022 Title 24 energy efficiency standards. The 2022 version of Title 24 (effective January 1, 2023, prior to the 2024 Supplement) is the baseline for improvement. • The Project shall provide facilities to support electric charging stations per the Tier 2 standards in Section A5.106.5.3 (Nonresidential Voluntary Measures) and Section A5.106.8.2 (Residential Voluntary Measures) of the 2022 CALGreen Code. The 2022 version of Title 24 (effective January 1, 2023, prior to the 2024 Supplement) is the baseline for improvement. • The Applicant shall coordinate with the City of Santa Ana and Orange County Transit Authority to ensure that bus pad and shelter improvements are incorporated, as appropriate. Mitigation Measure GHG-3: Landfill Waste. The development (Phase 1, Phase 2, and Phase 3) shall divert a minimum of 75 percent of landfill waste. Prior to issuance of certificate of occupancy, a recyclables collection and load area shall be constructed in compliance with the City standards for Recyclable Collection and Loading Areas. Mitigation Measure GHG-4: Electrical Landscape Equipment. Prior to the issuance of Phase 1, Phase 21, or Phase 3 occupancy permits, the City Planning and Building and Safety Divisions shall confirm that tenant lease agreements include contractual language that all landscaping equipment used on site shall be 100 percent electrically powered. This requirement shall be included in the third -party vendor agreements for landscape services for the building owner and tenants, as applicable. Mitigation Measure GHG-5: Energy Efficient Appliances. All major applicant provided in -unit residential appliances (e.g., dishwashers, refrigerators, clothes washers and dryers, water heaters, and for space heating) provided,/installed shall be electric (i.e., appliances that do not use natural gas, propane, or other fossil fuels) and Energy Star certified or of equivalent energy efficiency where applicable. Prior to the issuance of the certificate of occupancy, the City of Santa Ana shall verify implementation of this requirement. Installation of electric Energy Star —certified or equivalent appliances shall be verified by the Planning and Building Department during plan check. GPU FEIR Mitigation Measure AQ-1: As listed previously. Mitigation Measure AQ-3: Vehicle Trip Reduction. Develop a qualifying Commute Trip Reduction (CTR)/ Transportation Demand Management (TDM) plan to reduce mobile GHG emissions for all uses. The TDM plan shall be approved by the City of Santa Ana prior to the issuance of building permits. The TDM plan shall discourage single -occupancy vehicle trips and encourage alternative modes of transportation such as carpooling, taking transit, walking, and biking. The following measures shall be incorporated into the TDM plan. TDM Requirements for Non -Residential Uses: • The Project Applicant shall consult with the local transit service provider to maintain and identify opportunities to maximize transit. Evidence of compliance with this requirement may include correspondence from the local transit provider(s) regarding the potential need for installing bus shelters or bus stops at the site. • The portion of the TDM plan for non-residential uses shall include, but not be limited to the following potential measures: ride -matching assistance, preferential carpool parking, flexible work schedules for carpools, half-time transportation coordinators, providing a web site or message board for coordinating rides, designating adequate passenger loading and unloading and waiting areas for ride -sharing vehicles, and including bicycle end of trip facilities (such as bicycle parking and changing/shower facilities). This list may be updated as new methods become available. Verification of this measure shall occur prior to building permit issuance for the commercial uses. TDM Requirements for Residential Units: Rental Units. Upon a residential dwelling being rented or offered for rent, the Project Applicant shall notify and offer to the tenant or prospective tenant, materials describing public transit, ridesharing, and nonmotorized commuting opportunities in the vicinity of the development. The materials shall be approved by the City of Santa Ana. The materials shall be provided no later than the time the rental agreement is executed. This information shall be submitted to the City of Santa Ana Planning Division for review and approval, prior to the issuance of the first certificate of occupancy. Mitigation Measure AQ-4: Prohibition of Fireplaces. Project plans, specifications, and permitting shall state that wood -burning and natural gas devices are prohibited inside residential dwelling units. The purpose of this measure is to limit emissions of ROG, NOX, and particulate matter emissions from wood -burning and natural gas devices used for primary heat, supplemental heat, or ambiance. This prohibition shall be noted on the tenant deed and/or lease agreements to ensure that installation of wood -burning and natural gas devices do not occur during occupation of residences. Mitigation Measure AQ-5: Electric Landscape Equipment. Prior to the issuance of occupancy permits, the Planning Division shall confirm that the proposed Project's Codes Covenants and Restrictions (CC&Rs) and/or tenant lease agreements include contractual language that all landscaping equipment used on site shall be 100 percent electrically powered. All residential and non-residential properties shall be equipped with exterior electrical outlets to accommodate this requirement. This requirement shall be included in the third -party vendor agreements for landscape services for the building owner and tenants, as applicable. Mitigation Measure AQ-6: Low VOC Paint (Operations). The Project Applicant shall require by contract specifications for commercial development to use interior and exterior architectural coatings (paint and primer including parking lot paint) products that have a volatile organic compound rating of 10 grams per liter or less. Contract specifications shall be reviewed and approved by the City of Santa Ana prior to the issuance of occupancy permits. This measure shall be made a condition of approval for continued upkeep of the property. MM AQ-7: Loading Dock Connections. Prior to the approval of building permits, the City of Santa Ana shall confirm the construction documents demonstrate an adequate number of electrical service connections at loading docks for plug-in of the anticipated number of refrigerated trailers to reduce idling time and emissions. Impact Finding: The Project would not conflict with an applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of GHGs (Draft Supplemental EIR at p. 5.5-17). Changes or alterations have been required in, or incorporated into, the Project that avoid or substantially lessen the significant environmental effect identified in the Draft Supplemental EIR. Facts in Support of Findings: The proposed Project would provide a mixed -use community within a TPA and High -Quality Transit Area which has the potential to reduce GHG emissions from the reduction of VMT. The proposed Project provides for an onsite mix of uses that would limit the need to travel offsite for many amenities and retail/service needs. Providing a mixed -use development in such a location is consistent with the intent of the AB 32 Scoping Plan and SB 375, which is focused on changing land use patterns and improving transportation alternatives. The proposed Project would be implemented pursuant to the CALGreen Building/Title 24 requirements and would provide new land uses in a sustainable manner. The City's administration of the Title 24 requirements includes review of proposed energy conservation measures during the permitting process, which ensures that all requirements are met. In complying with the Title 24 standards, the proposed Project would be implementing regulations that reduce GHG emissions (Draft Supplemental EIR at p. 5.5-17). CARE Scoping Plan The proposed Project would not interfere with the state's implementation of AB 1 279's target of 85 percent below 1990 levels and carbon neutrality by 2045 because it does not interfere with implementation of the GHG reduction measures listed in CARB's Updated Scoping Plan (2022), as demonstrated in Draft Supplemental EIR Table 5.5-5. CARB's 2022 Scoping Plan reflects the 2045 target of an 85 percent reduction below 1990 levels, set by Executive Order B-55-18, and codified by AB 1279. The proposed Project would include a number of project design features and mitigation measures from the 2022 CARS Scoping Plan for construction and operation. The proposed Project would meet the three priority areas included in Appendix D to the CARB Scoping Plan; Transportation Electrification, VMT Reduction, and Building Decarbonization. As the proposed Project would implement key residential and mixed -use project attributes included in Appendix D as mitigation measures (Mitigation Measures GHG-1 through GHG-5 and AQ-4), the proposed Project would be consistent with the 2022 CARB Scoping Plan and the State's GHG reduction goals (Draft Supplemental EIR at pp. 5.5-18 through 5.5-22). City of Santa Ana Climate Action Plan The City of Santa Ana's Climate Action Plan (CAP) includes reduction measures that would help the City achieve its emissions reduction goal, which is consistent with the statewide goals identified. The proposed Project is consistent with City's CAP strategy of locating new mixed -use development within employment corridors to create a more optimal mix of land uses and reduce vehicle miles traveled. The proposed Project is an urban mixed -use infill project that would include local retail, housing, office, and hotel uses near transit routes, major freeways, and roadways. The proposed Project 4. includes pedestrian circulation and bicycle circulation infrastructure and facilities. The infill location, mix of uses, and proximity to transit would reduce dependency on cars, reduce time spent in traffic, closely links residents to jobs and services, and reduce VMT. As mobile sources are a significant component of GHG emissions, reducing VMTs is integral to achievement of state GHG reduction goals. As described in Draft Supplemental EIR Table 5.5-6, the proposed Project would be consistent with the relevant measures of the City's CAP. The proposed Project would not result in a conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of GHGs. The proposed Project would be implemented in compliance with state energy standards provided in Title 24, as well as future state regulations adopted to facilitate reductions in statewide GHG emissions. The proposed Project would not interfere with the state's implementation of AB 1279's target of 85 percent below 1990 levels and carbon neutrality by 2045 because it would be consistent with the CARB 2022 Scoping Plan, which is intended to achieve the reduction targets required by the state. In addition, the proposed Project would be consistent with the relevant City GPU goal and policies and the City's Climate Action Plan. Thus, the proposed Project would not result in a conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of GHGs, and impacts would be less than significant (Draft Supplemental EIR at pp. 5.5- 17 23 through 5.5-26). Mitigation Measures: Mitigation Measure GHG-1: Solar Panels. As listed previously. Mitigation Measure GHG-2: LEED, Charging Stations, and Bus Stops. As listed previously. Mitigation Measure GHG-3: Landfill Waste. As listed previously. Mitigation Measure GHG-4: Electrical Landscape Equipment. As listed previously. Mitigation Measure GHG-5: Energy Efficient Appliances. As listed previously. Mitigation Measure AQ-4: Prohibition of Fireplaces. As listed previously. E. Hazards and Hazardous Materials Impact Finding: The Project would not create a significant hazard to the public or the environment through the routine transport, use or disposal of hazardous materials (Draft Supplemental EIR at p. 5.6-22). Changes or alterations have been required in, or incorporated into, the Project that avoid or substantially lessen the significant environmental effect identified in the Draft Supplemental EIR. Facts in Support of Findings: rnncffri ir-finn The Phase I Environmental Site Assessment (included as Appendix J to the Draft Supplemental EIR) determined that asbestos -containing materials (ACMs) and lead -based paint may exist due to the date of construction of the existing buildings. Therefore, asbestos surveys and abatement would be required prior to demolition or renovation of the existing building pursuant to the existing South Coast Air Quality Management District (SCAQMD), Cal/OSHA, and the sections of the California Health and Safety Code. These requirements were developed to protect human health and the environment from the hazards associated with exposure to lead based materials and airborne asbestos fibers. Compliance with these existing regulations, as ensured through the permitting process and included as PPP HAZ-1 and PPP HAZ-2, would reduce impacts related to routine transport and disposal of asbestos -containing materials and lead -based paint during construction activities to a less than significant level. As described in the Phase II Environmental Site Assessments (Draft Supplemental EIR Appendix K1 and Appendix K2), soil within portions of the Project site exhibits concentrations of TPH-d, TPH-mo, and select SVOCs that exceed residential screening levels. The Phase II Environmental Site Assessments describe that soils with concentrations above residential screening levels and below commercial screening levels could be reused onsite as backfill material for non-residential and non - sensitive areas. However, soils that exceed both residential and commercial screening levels would need to be excavated and removed during Project excavation and grading activities as required by regulation and, as applicable, DTSC, California Integrated Waste Management Board, and/or the RWQCB. As a result, Mitigation Measure HAZ-1 would be implemented to reduce the potential risks related to accidental release and exposure of people and the environment to the contaminated soils. Mitigation Measure HAZ-1 requires that a qualified consultant prepare a Soil Management Plan (SMP) to be used during earthwork and grading to identify soils that cannot be reused onsite and offsite disposal. Mitigation Measure HAZ-1 requires excavation of contaminated soils be completed pursuant to existing DTSC and RWQCB requirements, soils sampling to ensure all contaminated soils are removed, and that a certified hazardous waste hauler remove and transport all TPH impacted soil and other potentially hazardous materials per California Hazardous Waste Regulations to a landfill permitted by the state to accept hazardous materials. Excavated soil containing hazardous substances would be classified as a hazardous waste if they exhibit the characteristics of ignitability, corrosivity, reactivity, or toxicity (CCR, Title 22, Division 4.5, Chapter 11, Article 3). The SMP would detail hazardous materials excavation and disposal methods and requirements pursuant to the regulation of Title 8 of the California Code of Regulations (CaIOSHAj and Department of Toxic Substances Control (DTSC} that regulates the removal, transportation, and disposal of hazardous waste to protect human health and the environment. With implementation of Mitigation Measure HAZ-1 "Impacts related to hazards from contaminated soils would be less than significant (Draft Supplemental EIR at p. 5.6-22). Plans, Program and Policies: PPP HAZ-1: SCAOMD Rule 1403. Prior to issuance of demolition permits,, the Project applicant shall submit verification to the City Building and Safety Division that an asbestos survey has been conducted at all existing buildings located on the Project site. If asbestos is found, the Project applicant shall follow all procedural requirements and regulations of South Coast Air Quality Management District Rule 1403. Rule 1403 regulations require that the following actions be taken: notification of SCAQMD prior to construction activity, asbestos removal in accordance with prescribed procedures, placement of collected asbestos in leak -tight containers or wrapping, and proper disposal. PPP HAZ-2: Lead. Prior to issuance of demolition permits, the Project applicant shall submit verification to the City Building and Safety Division that a lead -based paint survey has been eri I I I I conducted at all existing buildings located on the Project site. If lead -based paint is found, the Project applicant shall follow all procedural requirements and regulations for proper removal and disposal of the lead -based paint. Cal -OSHA has established limits of exposure to lead contained in dusts and fumes. Specifically, CCR Title 8, Section 1532.1 provides for exposure limits, exposure monitoring, and respiratory protection, and mandates good working practices by workers exposed to lead. Mitigation Measures: Mitigation Measure HAZ-1: Prior to issuance of a grading permit, a Soil Management Plan (SMP) shall be prepared by a qualified hazardous materials consultant and shall detail procedures and protocols for excavation and disposal of onsilte hazardous materials, including: • Any subsurface materials exposed during construction activities that appear potentially contaminated, based on either visual observation or suspect odors, shall be segregated, stockpiled, and tested for potential contamination. If contamination is found to be present per the California Department of Toxic Substances Control (DTSC} Environmental Screening Levels (ESLs) for the applicable use, and cannot be reused on the Project site, it shall be transported by a certified hazardous waste hauler to a landfill permitted by the state to accept hazardous materials and disposed of per California Hazardous Waste Regulations. • A Health and Safety Plan (HASP) shall be prepared for each contractor that addresses potential safety and health hazards and includes the requirements and procedures for employee protection. The HASP shall also outline proper soil handling procedures and health and safety requirements to minimize worker and public exposure to hazardous materials during construction. • All SMP measures shall be printed on the construction documents, contracts, and project plans prior to issuance of grading permits. Impact Finding: The Project would not create a significant hazard to the public or the environment through reasonably foreseeable upset or accident conditions involving the release of hazardous materials into the environment (Draft Supplemental EIR at p. 5.6-23). Changes or alterations have been required in, or incorporated into, the Project that avoid or substantially lessen the significant environmental effect identified in the Draft Supplemental EIR. Facts in Support of Findings: Construction Accidental Release. While the routine use, storage, transport, and disposal of hazardous materials in accordance with applicable regulations during demolition, excavation, grading, and construction activities would not pose health risks or result in significant impacts; improper use, storage, transportation and disposal of hazardous materials and wastes could result in accidental spills or releases, posing health risks to workers, the public, and the environment. Thus, implementation of the proposed Project could potentially result in the accidental release of hazardous materials. The use of best management practices (BMPs) during construction implemented as part of a Stormwater Pollution Prevention Plan (SWPPP) as required by the National Pollution Discharge Elimination System General Construction Permit (and included as PPP WQ-1) would minimize potential adverse effects to workers, the public, and the environment (Draft Supplemental EIR at p. 5.6-23). Contaminated Soils. As described previously, portions of the site contain soil that could be reused onsite as backfill material for non-residential and non -sensitive use areas. Soils that exceed applicable USEPA and/or DTSC Screening levels would require excavation and disposal pursuant to the requirements of the DTSC, California Integrated Waste Management Board, RWQCB, OCFA, and the OCHCA. As a result, Mitigation Measure HAZ-1 is included to require a Soil Management Plan (SMP) be implemented during earthwork and grading to remove and dispose of impacted soils. Mitigation Measure HAZ-1 requires handling of contaminated soils be completed pursuant to existing DTSC and RWQCB standards, soils sampling to ensure contaminated soils are removed, and that a certified hazardous waste hauler remove and transport hazardous materials per California Hazardous Waste Regulations to a Landfill permitted by the state to accept hazardous materials. With implementation of Mitigation Measure HAZ-1 impacts related to hazards from contaminated soils would be less than significant (Draft Supplemental EIR at pp. 5.6-23 through 5.6-24). Asbestos Containing Materials. Buildings on the Project site were constructed in the 1970s when many structures were constructed with what are now recognized as hazardous building materials, such as lead and asbestos. Demolition of these structures could result in the release of hazardous materials. However, asbestos abatement contractors must follow state regulations contained in California Code of Regulations Sections 1529, and 341.6 through 341.14 as implemented by SCAQMD Rule 1403 to ensure that asbestos removed during demolition or redevelopment of the existing buildings is transported and disposed of at an appropriate facility. Section 19827.5 of the California Health and Safety Code requires that local agencies not issue demolition permit until an applicant has demonstrated compliance with notification requirements under applicable federal regulations regarding hazardous air pollutants, including asbestos. These requirements are included as PPP HAZ-1 to ensure that the Project applicant submits verification to the City that the appropriate activities related to asbestos have occurred, which would reduce the potential of impacts related to asbestos to a less than significant level (Draft Supplemental EIR at p. 5.6-24). Undocumented Hazardous Materials, The Project site has a long history of various uses that includes use and storage of hazardous materials. As a result, there is the potential for undocumented hazardous material to exist onsite. Excavated soil containing hazardous substances and hazardous building materials would be classified as a hazardous waste if they exhibit the characteristics of ignitability, corrosivity, reactivity, or toxicity (CCR, Title 22, Division 4.5, Chapter 11, Article 3). State and federal laws require detailed planning to ensure that hazardous materials are properly handled, used, stored, and disposed of, and in the event that such materials are accidentally released, to prevent or to mitigate injury to health or the environment. These regulations are detailed previously and include, but are not limited to, the federal Resource Conservation and Recovery Act, the Occupational Safety and Health Act that is implemented by OSHA, and the Hazardous Materials Transportation Act. Additionally, the California Integrated Waste Management Board and the RWQCB specifically address management of hazardous materials and waste handling in their adopted regulations (CCR, Title 14 and CCR, Title 27). Also, Mitigation Measure HAZ-1 would reduce impacts related to other soil contamination, not identified previously. Thus, with implementation of existing regulations and Mitigation Measure HAZ-1, impacts related to upset or accident conditions involving the release of hazardous materials into the environment would be less than significant (Draft Supplemental EIR at pp. 5.6-24 through 5.6-25). Operation Development under the proposed Project would involve multi -family, restaurant, and retail commercial uses that would use and store common hazardous materials such as paints, solvents, and cleaning products. Also, building mechanical systems and grounds and landscape maintenance could also use a variety of products formulated with hazardous materials, including fuels, cleaners, lubricants, adhesives, sealers, and pesticides,/herbicides. A Water Quality Management Plan (WQMP) is required to be implemented for the proposed Project (as further discussed in Section 5.7, Hydrology and Water Quality and included as PPP WQ-2). The BMPs that would be implemented as part of the WQMP would protect human health and the environment should any accidental spills or releases of hazardous materials occur during operation of the proposed Project. Mitigation Measure HAZ-1 requires implementation of a Soil Management Plan to ensure appropriate removal and handling of potentially hazardous materials that could be encountered during site excavation and grading. As a result, operation of the proposed Project would not result in a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment, and impacts would be less than significant. Moreover, although impacts of the environment on a project do not require analysis or mitigation under CEQA and the proposed Project would not result in impacts on future users and residents, Mitigation Measure HAZ-2 is included and requires the Project applicant to conduct testing or design buildings to ensure that future users and residents of the proposed Project are not exposed to elevated levels of vapors (Draft Supplemental EIR at p. 5.6-25). Plans, Program and Policies (PPPs): PPP HAZ-1: SCAQMD Rule 1403. As listed previously. PPP HAZ-2: Lead. As listed previously. PPP WO-1: NPDES%SWPPP. Prior to issuance of any grading or demolition permits, the applicant shall provide the City Building and Safety Division evidence of compliance with the National Pollutant Discharge Elimination System (NPDES) requirement to obtain a construction permit from the State Water Resource Control Board (SWRCB). The permit requirement applies to grading and construction sites of one acre or larger. The Project applicant,/proponent shall comply by submitting a Notice of Intent (NOI) and by developing and implementing a Stormwater Pollution Prevention Plan (SWPPP) and a monitoring program and reporting plan for the construction site. PPP WQ-3: WQMP. Prior to the approval of the Grading Plan and issuance of Grading Permits a completed Water Quality Management Plan (WQMP) shall be submitted to and approved by the City Building and Safety Division. The WQMP shall identify all Post -Construction, Site Design, Source Control, and Treatment Control Best Management Practices (BMPs) that will be incorporated into the development project in order to minimize the adverse effects on receiving waters. Mitigation Measures: Mitigation Measure HAZ-1: Soil Management Plan (SMP). As listed previously. Mitigation Measure HAZ-2: Prior to issuance of a building permit for a future building within the Specific Plan area, the Project applicant shall, at its election, undertake one of the following three activities: (1) perform a subsurface soil vapor assessment demonstrating that vapor concentrations are within established limits for vapor intrusion into future buildings; (2) prepare a human health risk assessment (HHRA) demonstrating that documented levels of soil vapor do not represent a significant health risk to occupants of the future buildings; or (3) submit plans for a vapor intrusion mitigation system (VIMS) to be installed beneath the foundation of the future buildings. The Project applicant may rely on different measures of the foregoing options in different parts of the Specific Plan area. F. Noise Impact Finding: The Project would not result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies (Draft Supplemental EIR at p. 5.9-13). Facts in Support of Findings: Construction Per Section 18-314 (Special Provisions) of the City's Municipal Code noise sources associated with construction activities are exempt from the City's established noise standards as long as the activities do not take place between the hours of 8:00 p.m. and 7:00 a.m. on weekdays, including Saturday, or any time on Sunday or a federal holiday. The proposed Project's construction activities would occur pursuant to these regulations. Thus, the proposed Project would be in compliance with the City's construction related noise standards. Construction noise would be temporary in nature as the operation of each piece of construction equipment would not be constant throughout the construction day, and equipment would be turned off when not in use. Construction activities would occur throughout the Project site and would not be concentrated at a single point near sensitive receptors. Further, it is unlikely that multiple pieces of equipment would operate within the same area closest to sensitive receptors during Project construction. Because the analysis assumes that the noisiest equipment would operate concurrently at the construction boundary closest to the nearest sensitive receptor, it provides represents a conservative analysis of potential impacts. Construction noise levels drop off at a rate of about 6 dBA per doubling of distance between the noise source and receptor (Draft Supplemental EIR at pp. 5.9-13 through 5.9-15). Phase 1. As shown on Draft Supplemental EIR Table 5.9-8, construction noise for Phase 1 would be as close as 130 feet from the closest offsite residences, at the nearby receiver locations would range from 65.4 to 75.7 dBA Leq, which would not exceed the 80 d ba Leq daytime construction noise level threshold. Therefore, construction impacts related to Phase 1 would be less than significant (Draft Supplemental EIR at p. 5.9-15). Phase 2. Construction activity for Phase 2 would be as close as 410 feet from the closest offsite residences. As shown on Table 5.9-9 of the Draft Supplemental EIR, noise from Phase 2 construction at the closest nearby receiver locations would range from 55.4 to 68.0 dBA Leq. This would not exceed the 80 dba Leq daytime construction noise level threshold. In addition, Phase 2 construction would occur after Phase 1 is occupied. The onsite receptors in Phase 1 would be located as close as 130 feet away from the Phase 2 construction activity area where heavy equipment would be located. The loudest Phase 2 noise level would occur during grading and would be 75.6 dBA at the Phase 1 residences located 130 feet away, which would not exceed the 80 dBA Leq daytime construction noise level threshold at residential receiver locations. Therefore, construction noise impacts to offsite sensitive receptors related to Phase 2 would be less than significant (Draft Supplemental EIR at p. 5.9-15). Phase 3. As shown on Table 5.9-10 of the Draft Supplemental EIR, construction activity for Phase 3 would be as close as 130 feet from the closest offsite residences, and noise from Phase 3 construction at the nearby receiver locations would range from 65.4 to 75.9 dBA Leq. This would not exceed the 80 dBA Leq daytime construction noise level threshold. Therefore, construction noise impacts to offsite sensitive receptors related to Phase 3 would be less than significant. In addition, Phase 3 construction would occur after Phase 1 and Phase 2 are occupied. The onsite receptors in Phases 1 and 2 would be located as close as 130 feet away from the Phase 3 construction activity. The loudest Phase 3 noise level would occur during demolition and grading and would be 76.5 dBA at the closest Phase 1 and Phase 2 residences located 130 feet away. Therefore, Phase 3 construction would not exceed the 80 dBA Leq daytime construction noise level threshold at residential receiver locations. Therefore, construction noise impacts related to Phase 3 would be less than significant. Although noise generated from construction of Phases 1, 2, and 3 would be less than significant, the proposed Project would still be required to implement GPU FEIR Mitigation Measure N-1, which includes construction requirements to limit noise. The proposed Project would result in less impacts than the construction noise impacts that were identified in the GPU FEIR, which were identified as significant. Therefore, construction noise impacts related to the proposed Project would not exceed those previously identified (Draft Supplemental EIR at pp. 5.9-15 through 5.9-16). offsite Construction Noise. The offsite improvements include the installation and upgrade of water, stormwater, and sewer utilities, as well as roadway improvements that include sidewalks, bicycle facilities, landscaping, intersection improvements, median reconstruction, etc. The offsite improvements would include excavators, loaders, and trucks during pavement demolition and trenching activities and pavers, rollers, and loaders for paving activities. Draft Supplemental EIR Table 5.9-1 1 shows that the proposed Project's offsite construction noise would not exceed the FTA's standard. Additionally, when the worst -case offsite noise level (77.4 dBA during demolition) is combined with the worst -case onsite construction noise level (75.7 dBA during Phase 1 demolition), noise levels would be 79.6 dBA, which is below the FTA's 80 dBA standard. Therefore, construction noise impacts from offsite improvements would be less than significant. In addition, GPU FEIR Mitigation Measure N-1, which includes construction requirements to limit noise would be required to be implemented, which would reduce noise generated from proposed Project construction at sensitive receptor locations (Draft Supplemental EIR at pp. 5.9-16 through 5.9-17). Nighttime Concrete Pour Construction Noise. The proposed Project could include nighttime concrete pour activities. The nighttime concrete pours would use the following construction equipment: concrete mixer trucks, concrete pump truck, concrete vibrator, generator, trucks, and air compressors. Draft Supplemental EIR Table 5.9-12 shows that construction noise associated with nighttime concrete pours would be up to 71.0 dBA at the closest offsite sensitive receptors. Therefore, nighttime construction noise would exceed FTA's nighttime threshold of 70 dBA at offsite sensitive receptors and Project Mitigation Measure NOI-1 has been included to require enclosures for stationary (e.g., generators, air compressors, etc.) concrete pour equipment and buffer distances for mobile equipment (including concrete trucks) to minimize nighttime construction noise. Draft Supplemental EIR Table 5.9-12 shows that with implementation of GPU FEIR Mitigation Measure N- 1 and Project Mitigation Measure NOI-1, impacts related to nighttime concrete pour activities at offsite sensitive receptors would be less than significant (Draft Supplemental EIR at pp. 5.9-17 through 5.9-18). Construction Traffic Noise. Noise generated from construction traffic would increase short-term noise; however, these noise levels are temporary and would cease once construction is complete. The trucks associated with construction would occur during the allowable hours for construction specified in the Municipal Code (7:00 a.m. to 8:00 p.m. on weekdays and Saturdays). Trucks ("Including trucks hauling excavated material) would also occur during the allowable daytime hours only. Draft Supplemental EIR Table 5.9-13 shows that construction traffic noise levels would not exceed the 85 dBA construction thresholds for commercial uses (soil hauling would not occur along residential streets) and roadway noise levels would not increase ambient noise levels above the perceptible range (3.0 dBA) for any of the construction phases. Therefore, a less than significant impact would occur. Additionally, the GPU FEIR Mitigation Measure N-1 requires construction traffic use City approved haul routes to the extent feasible. Thus, ensuring that construction traffic would not use residential roadways (Draft Supplemental EIR at pp. 5.9-18 through 5.9-19). Operation Onsite operational Noise. Noise generated by the Project would occur from stationary equipment such as heating, ventilation, and air conditioning (HVAC) units that would be installed for the new development, use of parking facilities, trash removal activity, and activity at outdoor gathering areas. Based on these typical noise levels, operation of the Project would not result in an exceedance of the City's Municipal Code Section 18-313 noise standards. Also, the City's building and plan check permitting process includes verification that the location of operational noise sources would not result in an exceedance of the municipal code standards. At the closest sensitive receptor, approximately 130 feet away, mechanical equipment noise levels would attenuate to 43.7 dBA, which is below the City's ambient noise standards of 55 dBA for residential receptors and below the measured ambient levels ranging from 58.4 to 71.0 dBA (refer to Draft Supplemental EIR Table 5.9-4). Operation of mechanical equipment would not increase ambient noise levels beyond the acceptable compatible land use noise levels. Therefore, the proposed Project would result in a less than significant impact related to stationary noise levels. Thus, the City's standards development permitting process would ensure that the proposed Project would not generate on -site operational noise that would exceed noise standards. Therefore, impacts would be less than significant (Draft Supplemental EIR at pp. 5.9-19 through 5.9-21 ). Onsite Traffic operational Noise. Future residents at the Project site would be exposed to mobile traffic noise along Bristol Street, MacArthur Boulevard, Sunflower Avenue, and Plaza Drive. Table 5.9-17 shows that noise levels along these roadways would be up to 68.8 dBA (along Bristol Street from MacArthur Boulevard to Callen's Common) at 100 feet from the roadway centerline. At 70 feet, traffic noise would be approximately 71 dBA. However, this does not account for intervening structures and changes in altitude, as residences would be above commercial and retail uses. Therefore, the potential for the proposed Project to exceed the City's 65 dBA exterior and 45 dBA interior General Plan noise standards (based on an outdoor to indoor attenuation rate of 25 dB) cannot be excluded, and noise -reduction features, acoustical designs for the proposed residential buildings, and enforcement of the California Uniform Building Code would be required. However, Condition of Approval N0I-1 is included to require a detailed acoustical study demonstrating that all residential units would meet the City's General Plan 65 dBA exterior and 45 dBA interior noise standards by incorporating applicable noise reduction features. Compliance with Condition of Approval N0I-1 would ensure that the proposed Project meets the applicable City and state standards (Draft Supplemental EIR at pp. 5.9-13-29 through 5.9-30). Condition of Approval: COA N-1: On site Traffic Noise. Prior to issuance of building permits for Phase 1, Phase 2, and Phase 3, a detailed acoustical study based on architectural plans shall be prepared by a qualified acoustical consultant to demonstrate compliance with General Plan Noise Element Standards. The acoustical study shall be submitted to the City's Planning and Building Agency to demonstrate that all residential units would meet the City's 65 dBA exterior noise standard and 45 dBA interior noise standard to the satisfaction of the Planning and Building Agency Executive Director. This complies with the applicable sections of the California Building Code (Title 24 of the California Code of Regulations). The necessary noise reductions may be achieved by implementing noise control measures at the receiver locations. The required noise attenuation measures shall be incorporated into the applicable building plans and specifications. Mitigation Measures: GPU FEiR IViIIU''l ICI-1: Construction contractors shall implement the following measures for construction activities conducted in the City of Santa Ana. Construction plans submitted to the City shall identify these measures on demolition, grading, and construction plans submitted to the City: The City of Santa Ana Planning and Building Agency shall verify that grading, demolition, and/or construction plans submitted to the City include these notations prior to issuance of demolition, grading and/or building permits. • Construction activity is limited to the hours: Between 7:00 a.m. to 8:00 p.m. Monday through Saturday, as prescribed in Municipal Code Section 18-314(e). Construction is prohibited on Sundays. • During the entire active construction period, equipment and trucks used for project construction shall use the best -available noise control techniques (e.g., improved mufflers, equipment re -design, use of intake silencers, ducts, engine enclosures, and acoustically attenuating shields or shrouds), wherever feasible. • Impact tools (e.g., jack hammers and hoe rams) shall be hydraulically or electrically powered wherever possible. where the use of pneumatic tools is unavoidable, an exhaust muffler on the compressed air exhaust shall be used along with external noise jackets on the tools. • Stationary equipment such as generators and air compressors shall be located as far as feasible from nearby noise -sensitive uses. • Stockpiling shall be located as far as feasible from nearby noise -sensitive receptors. • Construction traffic shall be limited to approved haul routes established by the City Public Works Agency. Exceptions to approved routes must be granted by the Public Works Agency before any modification to approved haul routes. • At least 10 days prior to the start of construction activities, a sign shall be posted at the entrance(s) to the job site, clearly visible to the public, that includes permitted construction days and hours, as well as the telephone numbers of the City's and contractor's authorized representatives that are assigned to respond in the event of a noise or vibration complaint. If the authorized contractor's representative receives a complaint, he,/she shall investigate, take appropriate corrective action, and report the action to the City. • Signs shall be posted at the job site entrance(s), within the onsite construction zones, and along queueing lanes (if any) to reinforce the prohibition of unnecessary engine idling. All other equipment shall be turned off if not in use for more than 5 minutes. • During the entire active construction period and to the extent feasible, the use of noise - producing signals, including horns, whistles, alarms, and bells, shall be for safety warning purposes only. The construction manager shall use smart back-up alarms, which automatically adjust the alarm level based on the background noise level, or switch off back-up alarms and replace with human spotters in compliance with all safety requirements and laws. • Erect temporary noise barriers (at least as high as the exhaust of equipment and breaking line -of -sight between noise sources and sensitive receptors), as necessary and feasible, to maintain construction noise levels at or below the performance standard of 80 d BA Leq. Barriers shall be constructed with a solid material that has a density of at least 4 pounds per square foot with no gaps from the ground to the top of the barrier. Mitigation Measure N011-1: Prior to the issuance of construction/'grading permits, the Project Applicant shall obtain a permit from the City's Building and Safety Division to complete work outside the standard construction hours outlined in Santa Ana Municipal Code Section 1$-314(e). In addition, the Project Applicant and/'or contractor(s) shall develop a nighttime construction noise control plan that requires the following: Stationary equipment such as generators and air compressors shall adhere to the following: • Stationary equipment (e.g., generators, air compressors, etc.) shall be located 300 feet or more away from residences. • Stationary equipment shall be surrounded with noise barriers to achieve a minimum 10 dBA reduction. Alternatively, a temporary noise barrier may be used along the property line. Mobile equipment such as concrete mixer trucks, pump trucks shall adhere to the following: • The nighttime noise control plan shall prohibit mobile equipment and trucks from operating within the following distances to offsite sensitive receptors: ■ Phase 1: Trucks and equipment shall be 140 feet or more away from the Versailles residences along Plaza Drive. ■ Phase 2: No minimum distance required (Phase 2 is 410 feet from sensitive receptors and would not exceed thresholds). ■ Phase 3: Trucks and equipment shall be 150 feet or more away from the Versailles residences along Plaza Drive. • The nighttime noise control plan shall prohibit mobile equipment and trucks from operating within the following distances to onsite sensitive receptors: ■ Phase 1: No minimum distance is required because no onsite receptors would be constructed prior to Phase 1. ■ Phase 2: Trucks and equipment shall be 150 feet or more away from Phase 1 onsite residences. ■ Phase 3: Trucks and equipment shall be 170 feet or more away from Phase 1 and Phase 2 onsite residences. G. Tribal Cultural Resources Impact Finding: The Project would not cause a substantial adverse change in the significance of a tribal cultural resource that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historic resources as defined in Public Resources Code Section 5020.1(K) (Draft Supplemental EIR at p. 5.14-7). Changes or alterations have been required in, or incorporated into, the Project that avoid or substantially lessen the significant environmental effect identified in the Draft Supplemental EIR. Facts in Support of Findings: The City sent letters to 20 Native American representatives identified by NAHC, notifying them of the proposed Project in accordance with SB 18 and AB 52. The City consulted with each tribe that requested consultation. During the course of the tribal consultation process, no Native American tribe provided the City with substantial evidence indicating that tribal cultural resources, as defined in PRC Section 21074, are present on the Project site or have been found previously on the Project site. However, due to the Project site's location in an area where Native American tribes are known to have a cultural affiliation, there is the possibility that archaeological resources, including tribal cultural resources, could be encountered during ground disturbing construction activities. As such, Project -specific Mitigation Measures TCR-1 through TCR-3 would be implemented to require Native American monitoring during any ground disturbing activities on the Project site and to avoid potential impacts to tribal cultural resources that may be unearthed by Project construction activities. with implementation of GPU FEIR Mitigation Measures CUL-4 and CUL-6 and Project -specific Mitigation Measures TCR-1 through TCR-3, impacts to tribal cultural resources would be less than significant. Therefore, impacts related to Project buildout of the site would be consistent with the impact conclusions set forth in the GPU FEIR, which determined that impacts related to tribal cultural resources would be less than significant with the incorporation of mitigation (Draft Supplemental EIR at p. 5.14-7). Mitigation Measures: GPU FIER Mitigation Measure CUL-4: As listed previously. GPU FIER Mitigation Measure CUL-6: As listed previously. Mitigation Measure TCR-1: Retain a dative American Monitor Prior to Commencement of Ground -Disturbing Activities A. The Project Applicant shall retain a Native American monitor from or approved by the Gabrieleno Band of Mission Indians-Kizh Nation. The monitor shall be retained prior to the commencement of any "ground -disturbing activity" for the subject Project at any Project locations (i.e., both onsite and any offsite locations that are included in the Project description,/definition and,/or required in connection with the proposed Project, such as public improvement work). "Ground -disturbing activity" shall include, but is not limited to, demolition, pavement removal, potholing, auguring, grubbing, tree removal, boring, grading, excavation, drilling, and trenching. B. A copy of the executed monitoring agreement shall be submitted to the Lead Agency prior to the earlier of the commencement of any ground -disturbing activity, or the issuance of any permit necessary to commence a ground -disturbing activity. C. The monitor will complete daily monitoring logs that will provide descriptions of the relevant ground -disturbing activities, the type of construction activities performed, locations of ground - disturbing activities, soil types, cultural -related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs will identify and describe any discovered TCRs, including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., (collectively, tribal cultural resources, or "TCR"), as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs will be provided to the Project Applicant upon written request to the Tribe. D. Onsite tribal monitoring shall conclude upon the earlier of the following (1) written confirmation to the Kizh from a designated point of contact for the Project Applicant or lead agency that all ground -disturbing activities and phases that may involve ground -disturbing activities on the project site or in connection with the project are complete; or (2) a determination and written notification by the Kizh to the Project Applicant or Lead Agency that no future, planned construction activity and/'or development,/construction phase at the Project site possesses the potential to impact Kizh TCRs. Mitigation Measure TCR-2: Unanticipated Discovery of Tribal Cultural Resource objects (Non- Funerary/Non-Ceremonial) A. Upon discovery of any TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet) and shall not resume until the discovered TCR has been fully assessed by the Kizh monitor in consultation with a qualified archaeologist. The Kizh will recover and retain all discovered TCRs in the form and/'or manner the Tribe deems appropriate, in the Tribe's sole discretion, and for any purpose the Tribe deems appropriate, including for educational, cultural and,/or historic purposes. Mitigation Measure TCR-3: Unanticipated Discovery of Human Remains and Associated Funerary or Ceremonial objects A. Native American human remains are defined in PRC 5097.98 (d)(1) as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects, called associated grave goods in Public Resources Code Section 5097.98, are also to be treated according to this statute. 41 B. If Native American human remains and/or grave goods are discovered or recognized on the project site, then Public Resource Code 5097.9 as well as Health and Safety Code Section 7050.5 shall be followed. C. Human remains and grave/burial goods shall be treated alike per California Public Resources Code section 5097.98(d)(1) and (2). D. Preservation in place (i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods. E. Any discovery of human remains/burial goods shall be Kept confidential to prevent further disturbance. Impact Finding: The Project would not cause a substantial adverse change in the significance of a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.11 that considers the significance of the resource to a California Native American tribe (Draft Supplemental EIR at p. 5.14-7). Changes or alterations have been required in, or incorporated into, the Project that avoid or substantially lessen the significant environmental effect identified in the Draft Supplemental EIR. Facts in Support of Findings: The Project site has been heavily disturbed to substantial depths. The proposed Project involves excavation; however, no substantial evidence exists that TCRs are present in the Project site. Although, no TCRs have been identified, during the SB 18/AB 52 consultation, the Gabrieleno Band of Mission Indians — Kizh Nation stated that the Project lies within its ancestral tribal territory within a potentially sensitive area. Therefore, to avoid potential adverse effects to tribal cultural resources, Mitigation Measure TCR-1 has been included to provide for Native American resource sensitivity training, monitoring, and to prescribe activities should any inadvertent discoveries of tribal cultural resources be unearthed by Project construction activities. Additionally, California Health and Safety Code, Section 7050.5 requires that if human remains are discovered in the Project site, disturbance of the site shall halt and remain halted until the coroner has conducted an investigation. If the coroner determines that the remains are those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission. Therefore, with implementation of Mitigation Measure TCR-1 and the existing regulations, impacts to TCRs would be less than significant (Draft Supplemental EIR at pp. 5.14-7 through 5.14-$). Mitigation Measures. GPU FIER Mitigation Measure CUL-4: As listed previously. GPU FIER Mitigation Measure CUL-6: As listed previously. Mitigation Measure TCR-1: Retain a Native American Monitor Prior to Commencement of Ground -Disturbing Activities. As listed previously. Mitigation Measure TCR-2: Unanticipated Discovery of Tribal Cultural Resource Objects (Non- Funerary/Non-Ceremonial). As listed previously. Mitigation Measure TCR-3: Unanticipated Discovery of Human Remains and Associated Funerary or Ceremonial Objects. As listed previously. This page was intentionally left blank. SECTION V RESOLUTION REGARDING SIGNIFICANT AND UNAVOIDABLE ENVIRONMENTAL IMPACTS Public Resources Code section 21002 states that "it is the policy of the state that public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects. The Legislature further finds and declares that in the event specific economic, social, or other conditions make infeasible such project alternatives or such mitigation measures, individual projects may be approved in spite of one or more significant effects thereof." Section 15364 of the State CEQA Guidelines defines "feasible" as "capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors." The City Council hereby finds that, despite the incorporation of feasible measures outlined in the Final Supplemental EIR, the following impacts cannot be fully mitigated to a less than significant level. Despite these significant and unavoidable impacts, the City nevertheless approves the Project because of the benefits described in the Statement of Overriding Considerations included herein. M. Air Qua% Impact Finding: The Project would result in a conflict with or obstruct implementation of the applicable air quality plan (Draft Supplemental EIR at p. 5.1-23). Facts in Support of Findings: The SCAQMD's 2022 AQMP is the applicable air quality plan for the proposed Project. Pursuant to Consistency Criterion No. 1, projects that are consistent with the regional population, housing, and employment forecasts identified by SCAG are considered to be consistent with the AQMP growth projections, since the forecast assumptions by SLAG forms the basis of the land use and transportation control portions of the AQMP that result in air quality emissions. As shown on Table 5.10-8 (Section 5.10, Population and Housing, of the Draft Supplemental EIR), the Project buildout of 9,238 residents would be 48 percent of the GPU FEIR buildout for the South Bristol Street Focus Area, and population growth from the proposed Project would not exceed the growth identified in the GPU FEIR. Also, as shown on Draft Supplemental EIR Table 5.10-9, the proposed Project would result in a total of 1,092 employees at buildout and full occupancy. These employees would consist of approximately 14 percent of the GPU projected increase in employment from buildout of the South Bristol Street Focus Area. Therefore, employment growth from buildout of the proposed Project would not exceed the growth identified in the GPU FEIR. Therefore, the proposed Project would be within and consistent with SCAG's growth projections, and within the growth assumptions of the AQMP. Thus, the proposed Project would comply with AQMD AQMP Consistency Criterion No. 1. Regarding Consistency Criterion No. 2, which evaluates the potential of the proposed Project to increase the frequency or severity of existing air quality violations; an impact would occur if the long-term emissions associated with the proposed Project would exceed SCAQMD's regional significance thresholds for emissions of NOx and ROG. Although GPU FEIR Mitigation Measure AQ- 1 1 and Project Mitigation Measure AQ-1 requires the off -road construction equipment greater than 50 horsepower to meet CARE Tier 4 Final emission standards, and Project specific Mitigation Measure AQ-1 provides for construction exhaust and dust controls, construction emissions associated with NOx would remain above the SCAQMDs threshold. Also, Mitigation Measure AQ-3 requires a Transportation Demand Management (TDM) program, Mitigation Measure AQ-4 prohibits fireplaces, and Mitigation Measure AQ-6 requires the Project to use "Super -Compliant" low VOC paints to reduce operational ROG emissions. However, ROG emissions during operation of the Project at buildout would remain above the SCAQMD's threshold. There are no feasible mitigation measures that would reduce NOx and ROG emissions to below the SCAQMD thresholds. Therefore, the proposed Project would result in an impact related to Consistency Criterion No. 2. As a result, impacts related to consistency with the AQMP would be significant and unavoidable. This is consistent with the impacts identified in the GPU FEIR. Overall, despite the proposed Prolect's consistency with SCAG's regional growth forecasts and the GPU buildout of the South Bristol Street Focus Area per the DC-5 designation, the proposed Project would lead to increased regional air quality operational emissions that would exceed thresholds. Therefore, the proposed Project would result in a conflict with, or obstruct, implementation of the AQMP and impacts would be significant and unavoidable after implementation of mitigation measures that are detailed below. This finding is consistent with the findings of the GPU FEIR related to criteria emissions. (Draft Supplemental EIR at pp. 5.1-23 through 5.1-24). Impact Finding: The Project would result in a cumulatively considerable net increase of a criteria pollutant for which the project region is non -attainment under an applicable federal or state ambient air quality standard (Draft Supplemental EIR at p. 5.1-24). Facts in Support of Findings: Construction Draft Supplemental EIR Table 5.1-8 provides the maximum daily unmitigated emissions of criteria air pollutants from construction of Phase 1 of the proposed Project and shows that SCAQMD thresholds would be exceeded for NOx and ROG (VOC). The GPU FEIR Mitigation Measure AQ- 1 1 and Project Mitigation Measure AQ-1 requires the off -road construction equipment greater than 50 horsepower to meet CARB Tier 4 Final emissions standards in order to reduce diesel exhaust construction emissions. Project specific Mitigation Measure AQ-2 requires the proposed Project to use "Super -Compliant" low VOC paints to reduce ROG emissions to less than significant levels. Draft Supplemental EIR Table 5.1-9 shows that despite the implementation of mitigation, construction emissions associated with NOx during Phase 1 of construction would remain above the SCAQMD's threshold. Therefore, criteria emissions impacts related to construction of Phase 1 would be significant and unavoidable (Draft Supplemental EIR at p. 5.1-24). Overlapping Construction and Operation Emissions. Phase 1 operations + Phase 2 Construction. Phase 1 has the potential to be operational during Phase 2 construction. Draft Supplemental EIR Table 5.1-18 shows the overlapping emissions would exceed SCAQMD threshold for ROG and NOx and that Mitigation Measures AQ-1 through AQ-6 would be required. Draft Supplemental EIR Table 5.1-19 shows that overlapping emissions would continue to exceed SCAQMD thresholds for ROG after implementation of Mitigation Measures AQ- 1 through AQ-7. The majority of the proposed Project's ROG emission exceedances are from consumer products that the City cannot control emissions of; and therefore, cannot feasibly be reduced below the SCAQMD thresholds. As a result, impacts from overlapping emissions of Phase 1 operations and Phase 2 construction would be significant and unavoidable (Draft Supplemental EIR at p. 5.1-29) Phase 1 Operations + Phase 2 Operation + Phase 3 Construction. Phase 1 and Phase 2 have the potential to be operational during Phase 3 construction. Draft Supplemental EIR Table 5.1-21 shows that overlapping emissions would continue to exceed SCAQMD thresholds for ROG and NOx after implementation of Mitigation Measures AQ-1 through AQ-7. As detailed previously, the majority of the proposed Project's emission exceedances are from consumer product and mobile sources and cannot feasibly be reduced below the SCAQMD thresholds. Emissions from motor vehicles are controlled by state and federal standards and the City and proposed Project have no control over these standards. Therefore, impacts from overlapping emissions of Phases 1 and 2 operations and Phase 3 construction would be significant and unavoidable (Draft Supplemental EIR at p. 5.1-30). Buildout Operational Emissions The mitigated operational emissions from Phase 1, Phase 2, Phase 3 combined are provided in Draft Supplemental EIR Table 5.1-22, which shows that after implementation of Mitigation Measures AQ-1 through AQ-7 the net increase in operational emissions from the proposed Project at buildout would exceed thresholds for ROG. ROG emissions are generated from consumer products, the emissions of which are not controlled by either the City or the applicant. Therefore, operational air quality impacts would remain significant and unavoidable after implementation of mitigation. (Draft Supplemental EIR at pp. 5.1-30 through 5.1-31). N. Parks and Recreation Impact Finding: The Project would result in substantial adverse physical impacts associated with the provisions of new or altered park facilities, the construction of which could cause significant environmental impacts (Draft Supplemental EIR at p. 5.12-5). Facts in Support of Findings: As described in Draft Supplemental EIR Section 5.10, Population and Housing, the proposed Project is to result in 9,238 residents at full occupancy. This would increase demand for park and recreational facilities. Based on the GPU policy to attain 3 acres of parkland per every 1,000 residents, the proposed Project would result in a demand for approximately 27.7 acres of parkland, to support these additional populaces. The proposed Project would meet a portion of this increased need through provision of approximately 1 3.1 acres of public open space. In addition, each of the buildings with residential units would include private recreation facilities for residents. Future developments pursuant to the Specific Plan would provide public and private open space amenities at a ratio of 200 SF per unit, such as open space rooftop areas, tot lots, pools and spas, courtyards, fitness areas, dog runs, etc. Private open space areas, such as balconies and patios, would be provided at a ratio of 50 SF per unit, which is included in the 200 SF per unit requirement. Based on the ratio of 200 SF of open space per dwelling unit, buildout of the Specific Plan would include approximately 17.21 acres of public and private open space. Of that, approximately 187,500 SF (4-3 acres) of private open space would be provided based on the ratio of 50 SF per unit. Therefore, approximately 41.8 percent of the 41.13-acre Project site would be dedicated to public and private opens space amenities to meet the proposed Project's demands. Thus, onsite private and public amenities are anticipated to meet most of the park and recreation needs of Project residents. The proposed Project would require 14.6 acres of public parkland beyond the 13.1 acres proposed by the Project and 10.49 acres of combined public and private recreational amenities beyond that which is required by the Related Bristol Specific Plan development standards. The City currently has approximately 1.2 acres of public park and/or recreational space per every 1,000 residents; and therefore, does not have existing sufficient land or Citywide parks and recreation facilities to support in meeting the City's standard GPU policy as set forth in the findings of the GPU FEIR. Municipal Code Sections 35-108, 35-1 10, and 35-1 1 1 require that residential development fees be paid for the acquisition, construction, and renovation of park and recreation facilities prior to the issuance of a building permit for any construction which adds net residential units. Thus, the proposed Project would be required to comply with applicable Municipal Code requirements of 2 acres per 1,000 residents, which is less than the GPU policy of 3 acres per 1,000 residents, and/or pay development fees which would be used in part to acquire properties to build new park sites. In order to comply with the GPU policy, the proposed Project would require 27.7 acres of parkland or the dedication of approximately 67.3 percent of the Project site. While the proposed Project would provide approximately 17.21 acres of public and private open space onsite, inclusive of 13.1 acres of publicly accessible open space and facilities, and would comply with applicable Municipal Code requirements, the proposed Project would not provide 27.7 acres of parkland and recreation facilities onsite and would not meet the City of Santa Ana's performance standard for parkland, either on the site or cumulatively through the availability of parks and recreation facilities citywide. As discussed in the GPU FEIR, the City of Santa Ana is essentially fully built out and there is a lack of available vacant land to develop substantial new parks or expand existing facilities. Therefore, there would be no feasible mitigation measures that would be able to reduce the proposed Project's contribution to significant impacts related to the City's unsatisfactory level of resident to parkland ratio. As such, impacts would be significant and unavoidable, which is consistent with the findings of the GPU FEIR (Draft Supplemental EIR at pp. 5.12-5 through 5.1-6). Impact Finding: The Project would result in the increase of the use of existing neighborhood and regional parks or other recreational facilities such that a substantial physical deterioration of the facility would occur or be accelerated (Draft Supplemental EIR at p. 5.12-6). Facts in Support of Findings: As described in the previous finding, the proposed Project would provide 13.1 acres of onsite public parks as a part of the total 17.21 acres of open space and recreation facilities; and would be required to pay applicable fees pursuant to Municipal Code requirements, which would be used to maintain and improve other City parks and recreation facilities. However, as discussed within the GPU FEIR, the City of Santa Ana is currently parkland deficient and is not meeting the GPU policy of 3 acres per 1,000 residents. In addition, with buildout of the GPU, the existing parkland deficiency is expected to increase as additional residential units are constructed with limited parkland increases. Based on the California State Parks information for the Southern California region, the anticipated number of Project residents at full occupancy (9,238 residents), the distance and type of recreational facilities near the Project site, it is anticipated that the proposed Project would generate 1,543 additional park users two or more times per week, 1,275 additional park users about once per week, 1,903 additional park users once or twice per month, 2,254 additional park users several times a year, and 1,395 additional park users once or twice a year that would utilize the 69.8 acres of existing parks within 2 miles of the Project site and the 17.21 acres of parks and recreational facilities within the Project site. As the existing ratio of acreage of parks and recreational facilities to existing City population results in a parkland deficiency of approximately 154.44 acres, development of the proposed Project would continue to result in a deficiency in parkland throughout the City of Santa Ana. The Project proposes to provide approximately 1.4 acres of publicly accessible open space per 1,000 residents, which exceeds the approximately 1.2 acres per 1,000 residents currently existing within the City. Notwithstanding the Prolect's provision of public open space in proportion greater than existing currently in the City, it is reasonably foreseeable that the proposed Project would result in the increased use of existing parks and recreational facilities in a manner that results in accelerated substantial physical deterioration of the facility. As such, impacts would be significant and unavoidable, which is consistent with the findings of the GPU FEIR (Draft Supplemental EIR at pp. 5.12-6 through 5.12-8). Impact Finding: The Project would include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment (Draft Supplemental EIR at p. 5.12-8). Facts in Support of Findings: As described above, the proposed Project proposes 17.21 acres of common and private open space and recreation facilities, including 13.1 acres of public open space. The project -level impacts of development of these recreational amenities are considered part of the impacts of the proposed Project as a whole and are analyzed throughout the various sections of this Supplemental EIR. For example, activities such as grading and construction, as required for the park and recreational components of this proposed Project, are analyzed in the Air Quality, Greenhouse Gas Emissions, Noise, and Transportation sections. In addition, the proposed Project would contribute park development fees pursuant to Municipal Code Sections 35-108, 35-1 10, and 35-1 1 1 to be used towards the future expansion or maintenance parks and recreational facilities. However, the proposed Project's provision of parkland would not meet the 27.7 acres of parkland based on the GPU policy of 3 acres of parkland for every 1,000 residents, either on the site or cumulatively through the availability of parks and recreation facilities citywide. As such, the proposed Project could require the construction or expansion of recreational facilities, the construction of which could result in significant impacts. As such, impacts would be significant and unavoidable, which is consistent with the findings of the GPU FEIR (Draft Supplemental EIR at p. 5.12-8). This page was intentionally left blank. c:r,TinN V11 RESOLUTION REGARDING CUMULATIVE IMPACTS The City hereby finds that cumulative impacts have been identified in the Supplemental EIR, and are summarized below. A. Aesthetics The Project proposes a mixed -use infill development located in a TPA on an urban and developed site in the City of Santa Ana, as defined under Public Resources Code section 21099. Thus, the proposed Project's aesthetic impacts are not considered significant on the environment pursuant to Public Resources Code section 21099. (Draft Supplemental EIR at p. 5.16-7.) As a result, the proposed Project has a less than significant cumulative impact on the visual character and scenic resources within the City. B. Agriculture and Forestry Resources The Project site is developed for urban uses and located in an area that is completely developed for urban uses. The California Department of Conservation Important Farmland mapping identifies the Project site as Urban and Built -Up land (CDC 2023). No areas of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance would be affected by the proposed Project or converted to a non-agricultural use. The Project site is zoned General Commercial (C-2) north of Callen's Common and Commercial Residential (CR) and General Commercial (C-2) south of Callen's Common, is not in a Williamson Act contract, and the vicinity is void of agricultural use, forest land, or timberland. (Draft Supplemental EIR at p. 5.16-8.) The Project would have no impact on agriculture and forestry resources. As a result, no cumulative impact would occur. C. Air Quality Per SCAQMD's methodology, if an individual project would result in air emissions of criteria pollutants that exceeds the SCAQMD's thresholds for project -specific impacts, then it would also result in a cumulatively considerable net increase of these criteria pollutants. Mitigated emissions from construction would exceed regional thresholds for NOx, and mitigated overlapping construction and operational activities would result in exceedance of regional thresholds for ROG and NOx. Also, mitigated regional operational emissions of ROG would exceed thresholds at buildout of the proposed Project. The large majority of operational -source NOx emissions (by weight) would be generated by vehicle emissions that neither Project applicants nor the City have the ability to reduce. The majority of the proposed Project's ROG emission exceedances are from use of consumer products that the City cannot control emissions of; and therefore, cannot feasibly be reduced below the SCAQMD thresholds. As a result, NOx and ROG emissions from implementation of the proposed Project would be cumulatively considerable, and cumulative air quality impacts would be significant and unavoidable. (Draft Supplemental EIR at p. 5.1-43.) D. Biological Resources Development of cumulative projects could result in direct take of special -status species, construction and post -construction disturbances, special -status habitat conversion, and/or disruption of wildlife corridors. The Project site is heavily disturbed, graded, and is developed with 16 commercial buildings that are surrounded by paved surfaces, and is located within an urbanized area. No endangered, rare, threatened, or special status plant species (or associated habitats) or wildlife species designated by the U.S. Fish and Wildlife Service (USFWS), California Department of Fish and Wildlife (CDFW), or California Native Plant Society are known to occur on or adjacent to the site. In addition, there are no riparian habitat or other sensitive natural communities as identified in local or regional plans, policies, or regulations, or by the CDFW or USFWS. The Project site does not contain federally protected wetlands or jurisdictional areas that would be subject to Section 404 of the Clean Water Act, nor does it contain or is adjacent to any wildlife corridors. The proposed Project would therefore have less than significant impacts to biological resources. (Draft Supplemental EIR at pp. 5.16-8 through 5.16-10.) However, as with the proposed Project, all future cumulative development would undergo environmental review on a project -by -project basis, to evaluate potential impacts to biological resources and ensure compliance with the established regulatory framework. As such, cumulative Project impacts on biological resources would be less than significant. E. Cultural Resources Historic Resources: The proposed Project's contribution to cumulative impacts to historical resources was analyzed in context with past and reasonably foreseeable future projects in the City of Santa Ana and adjacent areas in Costa Mesa that were similarly influenced by the historical agricultural and then commercial and residential uses in the region. The cumulative impacts are evaluated in light of development projections in the City's GPU and GPU FEIR that evaluates conditions contributing to the cumulative effect and describes that the South Bristol Street Focus Area has a low potential to contain built environment historical resources. The record searches and field surveys indicate that there are no structures on the Project site or adjacent properties that would qualify as historic resources, and no impacts related to historic resources would occur. Therefore, implementation of the proposed Project would have no potential to contribute towards a significant cumulative impact to historical sites and/or resources. Thus, cumulative impacts from the proposed Project would be less than significant. Archaeological Resources: The cumulative study area for archaeological resources includes the Southern California region, which contains the same general prehistoric uses and migration trends as the Project area. The cumulative impacts are evaluated in light of development projections in the City's GPU and GPU FEIR that evaluate conditions contributing to the cumulative effects to archaeological resources. There is a possibility that ground -disturbing activities during Project construction may uncover or disturb unknown archaeological resources. However, the proposed Project would implement GPU FEIR Mitigation Measures CUL-6 and Project -specific Mitigation Measures CR-1 and CR-2 that would reduce the potential impact to unknown resources to a less than significant level. The likelihood of uncovering multiple currently unknown resources within the Project site that is sufficient to create a significant cumulative impact is low given the built nature of the Project site and City of Santa Ana and few archaeological resources that have been found in the vicinity to date. With compliance with Project -specific mitigation, cumulatively considerable impacts would be less than significant. Disturbance of Human Remains: Mandatory compliance with the provisions of California Health and Safety Code Section 7050.5, Public Resources Code Section 5097 et seq., and CEQA Guidelines Section 15064.5 would assure that the Project, in addition to all development projects, treat human remains that may be uncovered during development activities in accordance with prescribed, respectful, and appropriate practices, thereby avoiding significant cumulative impacts. (Draft Supplemental EIR at p. 5.2-16.) F. Energy The geographic context for analysis of cumulative impacts regarding energy includes past, present, and future development within Southern California because energy supplies (including electricity, natural gas, and petroleum) are generated and distributed throughout the Southern California region. All development projects throughout the region would be required to comply with the energy efficiency standards in the Title 24 requirements. Additionally, some of the developments could provide for additional reductions in energy consumption by use of solar panels, sky lights, or other LEED type energy efficiency infrastructure. With implementation of the existing energy conservation regulations, cumulative electricity and natural gas consumption would not be cumulatively wasteful, inefficient, or unnecessary. Petroleum consumption associated with the proposed mixed uses would be primarily attributable to transportation, especially vehicular use. However, state fuel efficiency standards and alternative fuels policies (per AB 1007 Pavely) would contribute to a reduction in fuel use, and the Federal Energy Independence and Security Act and the State Long Term Energy Efficiency Strategic Plan would reduce reliance on non-renewable energy resources. For these reasons, the consumption of petroleum would not occur in a wasteful, inefficient, or unnecessary manner and would be less than cumulatively considerable. (Draft Supplemental EIR at pp. 5.3-15 through 5.3-16.) G. Geology and Soils For geology and soils, the cumulative study area consists of the area that could be affected by proposed Project activities and the areas affected by other projects whose activities could directly or indirectly affect the geology and soils of the project site. The cumulative impacts are evaluated in light of development projections in the recent City General Plan update and GPU FEIR. Site -specific development projects within Santa Ana and adjacent areas within the City of Costa Mesa are subject to uniform site -development policies and construction standards imposed by the Cities that are based on the state requirements in the CBC and site -specific geotechnical studies prepared to define site -specific conditions that might pose a risk to safety, such as those described previously for the proposed Project. 'While increases in the number of people and structures subject to unstable geologic units and soils would increase in the proposed Project and with cumulative development, given the application of CBC requirements by the City through the construction permitting process, the cumulative effects would be less than significant. Paleontological Resources: The geographic area of potential cumulative impacts related to paleontological resources includes areas that are underlain by similar geologic units from the same time period, which includes the Grange County region. A cumulative impact could occur if development projects incrementally result in the loss of the same types of unique paleontological resources. As detailed in the City's GPU FEIR, the City, including the Project site, vary in paleontological sensitivity from low to high sensitivity increasing with depth. However, with incorporation of the GPU FEIR Mitigation Measures GEG-1 through GEG-3 and Project specific Mitigation Measures PALEG-1 through PALED-5, which require paleontological monitoring and provides procedures far fossil recovery which would preserve the quality and integrity of these resources, avoid them when possible, and salvage and preserve them if avoidance is not possible. These measures would reduce the potential for the proposed Project to result in cumulatively considerable impacts to a less than significant level. Therefore, impacts would be less than cumulatively significant. (Draft Supplemental EIR at pp. 5.4-13 through 5.4-14.) H. Greenhouse Gas Emissions The analysis of GHG emission impacts under CEQA contained in the Supplemental EIR effectively constitutes an analysis of a project's contribution to the significant cumulative impact of GHG emissions. State CEQA Guidelines Section 15183.5(b) states that compliance with GHG related plans can support a determination that a project's cumulative effect is not cumulatively considerable. As the proposed Project would be implemented in compliance with applicable plans for the reduction of GHG emissions, detailed previously, the contribution of the proposed Project to significant cumulative GHG impacts would be less than cumulatively considerable. The majority of the proposed Project's GHG emissions are generated by mobile emissions. The TDM program required by Mitigation Measure AQ-3 would reduce GHG emissions from commuting. Also, because the Project site is located within a TPA and a High Quality Transit Area with direct access to transit, bicycle, and pedestrian facilities, it would reduce VMT and the related GHG emissions. Further, the Project proposes a specific plan that would be consistent with the buildout assumptions and applicable development standards of the GPU. Therefore, impacts related to generation of GHG emissions from the proposed Project would be less than cumulatively significant with mitigation incorporated. In addition, because the proposed Project would not result in a conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of GHGs, it would not have the potential to cumulatively combine. Therefore, cumulative impacts related to a conflict with a policy for the purpose of reducing GHG emissions would not occur. (Draft Supplemental EIR at pp. 5.5-26 through 5.5-27.) 1. Hazardous and Hazardous Materials The proposed Project's contribution to cumulative impacts to hazards and hazardous was analyzed in context with past and foreseeably future projects in the City of Santa Ana and adjacent areas in Costa Mesa that are similarly affected by hazardous soil conditions, LUST conditions, asphalt contamination, and asbestos and lead containing building materials. Cumulative redevelopment and land use changes within the City would have the potential to expose future area residents, employees, and visitors to chemical hazards through redevelopment of sites and structures that may be contaminated from either historic or ongoing uses. The severity of potential hazards for individual projects would depend upon the location, type, and size of development and the specific hazards associated with individual sites. The closest cumulative development project is located across Bristol Street at the southeast corner of Bristol Street and MacArthur Boulevard, approximately 129 feet from the Project site. The cumulative project across Bristol Street is a renovation of the existing Chick-Fil-A restaurant and would not include extensive redevelopment of the area. It is unlikely that similar construction activities involving hazardous materials would occur simultaneously that could have the potential to cumulatively contribute to an impact. All hazardous materials users and transporters, as well as hazardous waste generators and disposers are subject to regulations that require proper transport, handling, use, storage, and disposal of such materials to ensure public safety, which are verified by the City during the construction and development permitting process. Thus, if hazardous materials are found to be present on present or future project sites appropriate remediation activities would be required pursuant to standard federal, state, and regional regulations. Mitigation Measure FIAZ-1 would be implemented to ensure that hazardous soil from the site would be handled and disposed of pursuant to existing regulations, which would reduce the potential of the proposed Project to result in a hazard that could cumulatively combine. Further, compliance with the relevant federal, state, and local regulations during the construction and operation of related projects would ensure that cumulative impacts from hazardous materials and emergency response/evacuation would be less than significant. (Draft Supplemental EIR at p. 5.6- 29.) I Hydrology and Water Qualify Water Quality: The geographic scope for cumulative impacts related to hydrology and water quality includes the Santa Ana Watershed and the Newport Back Bay because cumulative projects and developments pursuant to the proposed Project could incrementally exacerbate the existing impaired conditions and could result in new pollutant related impairments. Related developments within the watershed would be required to implement water quality control measures pursuant to the same NPDES General Construction Permit that requires implementation of a SWPPP (for construction), a WQMP (for operation) and BMPs to eliminate or reduce the discharge of pollutants in stormwater discharges, reduce runoff, reduce erosion and sedimentation, and increase filtration and infiltration, in areas permitted. The NPDES permit requirements have been set by the State Water Board and implemented by the RWQCB and the ©range County DAMP to reduce incremental effects of individual projects so that they would not become cumulatively considerable. Therefore, overall potential impacts to water quality associated with present and future development in the watershed would not be cumulatively considerable with compliance with all applicable laws, permits, ordinances and plans. As detailed previously, the proposed Project would be implemented in compliance with all regulations, as would be verified during the permitting process. Therefore, cumulative impacts related to water quality would be less than significant. Drainage: The geographic scope for cumulative impacts related to stormwater drainage includes the geographic area served by the existing stormwater infrastructure for the Project area, from capture of runoff through final discharge points. The proposed Project would result in a reduction in storm water runoff and includes installation of vegetated biotreatment systems that would filter and discharge runoff through storm drain connections to the offsite drainage infrastructure. The vegetated biotreatment systems would retain runoff and control drainage, pursuant to the required design storm. As a result, the proposed Project would not generate runoff that could combine with additional runoff from cumulative projects that could cumulatively combine to impact drainage. Thus, cumulative impacts related to drainage would be less than significant. Groundwater Basin: The geographic scope for cumulative impacts related to the groundwater basin is the Orange County Basin. The cumulative impacts are evaluated in light of development projections in the recent City General Plan update and GPU FEIR that evaluates conditions contributing to the cumulative effects to the groundwater basin. The volume of water that would be needed by the proposed Project is within the anticipated groundwater pumping volumes. Therefore, the proposed Project would not result in changes to the projected groundwater pumping that would decrease groundwater supplies. As a result, the proposed Project would not generate impacts related to the groundwater basin that have the potential to combine with effects from other projects to become cumulatively considerable. Therefore, cumulative impacts related to the groundwater basin would be less than significant. (Draft Supplemental EIR at pp. 5.7-1 8 through 5.7-19.) K. Land Use and Planning The cumulative study area for land use and planning includes the City of Santa Ana and nearby areas in the City of Costa Mesa. The vicinity of the Project site includes numerous projects within the City of Santa Ana and City of Costa Mesa. A large portion of these projects consist of multi -family residential, commercial, and office developments; which are similar, consistent, and complementary to the proposed Specific Plan mixed -use development. The proposed Project would not physically divide an established community. Therefore, the proposed Project would not have the potential to have a cumulatively considerable impact related to physically dividing communities. Also, the proposed Project would implement the GPU land use designation of the Project site and South Bristol Street Focus Area objectives. The site is located within a TPA and a High -Quality Transit Corridor, and the proposed Project is consistent with the SCAG's 2020 Connect RTP%SCS. The proposed Project is consistent with the SNA AELUP policies. Also, the proposed Project is consistent with all of the relevant GPU goals and policies. Furthermore, the proposed zone change would provide consistency with the existing GPU land use designation and focus area development objectives. Because the proposed Project would implement the GPU and would not result in conflicts with an applicable land use plan, policy, or regulation of an agency with jurisdiction over the proposed Project, which has the purpose of avoiding or mitigating an environmental effect, the proposed Project would not cumulatively contribute to such an impact that could occur from related projects. As a result, cumulative impacts related to land use and planning from the proposed Project would not be cumulatively considerable. (Draft Supplemental EIR at p. 5.8-48.) L. Mineral Resources The Project would have an impact on mineral resources because there are no known mineral resources present on the Project site nor is the Project site located within an area known to contain locally important mineral resources. (Draft Supplemental EIR at p. 5.6-10.) No cumulative impacts would occur. M. Noise Cumulative noise assessment considers development of the proposed Project in combination with ambient growth and other development projects within the vicinity of the proposed Project. As noise is a localized phenomenon, and drastically reduces in magnitude as distance from the source increases, only projects and ambient growth in the nearby area could combine with the proposed Project to result in cumulative noise impacts. Development of the proposed Project in combination with the related projects would result in an increase in construction -related and traffic -related noise. However, each of the related projects would be subject to the operational noise standards established in Section 18-31 3 of the City's Municipal Code, which establishes the allowable exterior noise standards for various types of land uses in the City. In addition, Section 1 8-314 of the City's Municipal Code allows for construction activities to be exempt from the noise standards set forth in Sections 18-312 and 18-31 3 of the City's Municipal Code as long as these activities do not take place between the hours of 8:00 p.m. and 7:00 a.m. on weekdays, including Saturday, or anytime on Sunday or a federal holiday. In addition, the City of Tustin has a similar municipal code requirement related to construction noise. Construction noise is localized in nature and decreases substantially with distance. Consequently, in order to achieve a substantial cumulative increase in construction noise levels, more than one source emitting high levels of construction noise would need to be in close proximity to the proposed Project. The nearest development projects to the Project site include the South Coast Village Mixed -Use project that is adjacent to the southwest of the Project site and the Chick-Fil-A expansion project that is across Bristol Street to the northeast of the Project site. The Chick-Fil-A expansion project is currently in plan check and completion of construction of that project would likely be completed by the time construction of Phase 1 of the proposed Project commences. The South Coast Village Mixed - Use project is still in the early stages of entitlement. Therefore, there is potential that construction of the South Coast Village Mixed -Use project overlaps with construction of Phase 1 of the proposed Project. However, due to the size of the Project site, varying locations onsite where construction would occur, and the limited offsite construction noise levels that would be generated from the proposed Project, it would not combine to become cumulatively considerable, and cumulative noise impacts associated with construction activities would be less than significant. Cumulative construction could also result in the exposure of people to or the generation of excessive groundborne vibration. The proposed Project would result in limited vibration at 25 and 50 feet from construction activities. Due the rapid attenuation of groundborne vibration, the size of the Project site, and the location of the nearest project and limited potential for overlapping construction, the proposed Project would not result in vibration that could combine with other development projects. Thus, the proposed Project would not contribute to cumulative vibration impacts and impacts would be less than significant. Stationary noise sources that would be generated by the proposed Project would result in noise levels that would be below the existing City noise standards. Because the Project site is surrounded by roadways and proposed buildings and parking structures are setback from roadways, noise from the site would attenuate to diminish, and would not combine with other stationary sources of adjacent uses. Thus, stationary noise sources from the proposed Project would result in impacts that are less than cumulatively significant. Cumulative mobile source noise impacts would occur primarily as a result of increased traffic on local roadways due to the proposed Project and related projects within the study area. Therefore, cumulative traffic -generated noise impacts have been assessed based on the contribution of the proposed Project in the Project buildout condition. Cumulative increases in traffic noise levels were estimated by comparing the existing and Project buildout without and with Project scenarios. The volume of traffic generated by the proposed Project on MacArthur Boulevard, between SR-55 SB Ramps and SR-55 NB Ramps, would exceed 1.5 dBA for an ambient noise environment of 65 dBA and higher when comparing Year 2045 With proposed Project conditions to existing conditions. However, the proposed Project's incremental contribution would be 0.1 dBA (i.e., far below a 3.0 barely perceptible increase and below the City's 1.5 dBA increase). Therefore, although related cumulative projects and growth would increase traffic noise levels along this segment, the proposed Project's incremental effects would be less than cumulatively significant. The GPU FEIR identified significant and unavoidable impacts for traffic noise; but did not analyze this segment of MacArthur Boulevard. However, GPU FEIR Figure 5.12-5 and Figure 5.12-10 show that this segment of MacArthur Boulevard (between SR-55 SB Ramps and SR-55 NB Ramps) is also within the 70+ dBA contour of SR-55). Therefore, the year 2045 noise level of 69.3 dBA would be lower than the SR-55 traffic noise in this area. Overall, cumulative operational noise impacts from related projects, in conjunction with noise from the proposed Project would not be cumulatively considerable and cumulative traffic noise impacts would be less than significant. (Draft Supplemental EIR at pp. 5.9-32 through 5.9-36.) N. Population and Housing The geographic area in which cumulative impacts to population and housing would occur is the City of Santa Ana, and summary of projections utilized in this analysis of cumulative population and housing impacts is from the summary of the GPU Land Use Element and GPU Final EIR, which evaluates conditions contributing to the cumulative population and housing growth effects. Implementation of the proposed Project would result in 3,750 additional multi -family residential units and 200 senior living/'continuum of care units, as well as 350,000 SF of retail uses and a 250- room hotel. The proposed residential units are within the GPU planned increase in residential units within the South Bristol Street Focus Area. The estimated 9,238 residents at buildout and complete occupancy (a conservative estimate as vacancy in the City is 3.5 percent) would be 48 percent of the GPU FEIR estimated buildout for the South Bristol Street Focus Area, and the 1,092 jobs would consist of 148 percent of the anticipated growth in jobs within the South Bristol Street Focus Area. Hence, the increase in population and housing that would occur from the proposed Project would not exceed those anticipated from buildout of the GPU, as identified in with the GPU Final EIR. Development of the proposed Project in combination with other development projects in the vicinity would result in a cumulative increase in population. However, the proposed Project's portion of the cumulative increase is within those anticipated by the GPU Final EIR. Thus, the proposed Project would not generate any new or increased cumulative impacts related to population and housing. The addition of housing within the Project area would have a favorable effect on the jobs -housing balance, which could reduce environmental effects of long commute trips, such as air quality and greenhouse gas emissions. Also, infrastructure improvements to accommodate the proposed development on the Project site are based on the GPU development assumptions for the site. As a result, no extension of infrastructure would occur that could induce cumulative growth beyond that assumed with buildout of the GPU. Furthermore, infrastructure upgrades and extensions that may be included in related projects would not affect or be related to the proposed Project. Therefore, proposed Project impacts are less than cumulatively considerable, and therefore, less than significant. (Draft Supplemental EIR at pp. 5.10-1 1 through 5.10-12.) O. Public Services Fire Protection Service: The geographic context for cumulative fire protection and emergency services is the C)CFA service area within the City of Santa Ana because the City owns and maintains the 10 existing f ire stations within the City. Staffing of the fire stations is done through contracting with GCFA. Thus, augmenting the existing fire station facilities, equipment, and staffing is under the jurisdiction of the City. Like the proposed Project, buildout of the City pursuant to the GPU would involve redevelopment of existing lands for more intensive uses; and the projects would be reviewed by City and C)CFA staff prior to permit approval to ensure that the projects implement fire protection design features per California building and fire code regulations that would reduce potential fire hazards. Cumulative increased demands for services would also be offset by the City of Santa Ana fire facilities fee that is required for each city development project. There are ten cumulative projects within Santa Ana in the Project vicinity that would combine to generate additional demands for C)CFA services from the six City -owned fire stations located within approximately 4 miles of the Project site, including Stations 76 and 77 that are firstand second responding stations to the Project site. Four of the ten other projects include multi -family housing. The four other residential projects are anticipated to provide a total of 2,088 new residential units. Because six of the City's ten existing fire stations are located approximately 4 miles of the Project site, and related projects would be subject to the same impact fees that provide funding for additional equipment and staffing, and fire safe construction requirements, impacts related to fire services from the proposed Project would not combine with other related projects to result in a cumulative impact related to the need for new or physically altered fire service facilities. Further, as disclosed in the GPU FEIR, fire vehicles, staff, equipment, and expansion of existing facilities would be funded by the 10-year cash contract with C)CFA that is valid until 2030 and buildout pursuant to the GPU would result in less than significant impacts to fire protection services. Therefore, cumulative impacts associated with fire services would be less than cumulatively considerable. (Draft Supplemental EIR at pp. 5.1 1-6 through 5.1 1-7.) Police Services:_The geographic context for cumulative police services is the area served by the City of Santa Ana Police Department. The proposed Project would result in an incremental increase in demands on law enforcement services and based on the Police Department's 2022 staffing of 0.98 officers per thousand population, the proposed Project would require approximately 9 additional officers based on buildout of the proposed Project. These additional officers would be accommodated by the proposed administrative Police Department substation on the site. Table 5-1 of the Draft Supplemental EIR lists projects within the Police Department's Southcoast District that would be served by the same Police Department patrol staffing. Because the proposed Project includes an administrative Police Department substation facility and payment of development impact fees, as required for all development projects, it would provide facilities to accommodate police protection demands from Project residents and residents in the vicinity of the proposed Project, including residents of other cumulative projects. The expansion of police services is funded by business taxes, property taxes, sales taxes, and utility users' taxes that are generated by each development within the City. Additional Police Department personnel and associated equipment are provided through City's the annual budget review process. Because the proposed Project would provide an administrative Police Department substation on the site and generate fees for future needed Police Department personnel and equipment, the law enforcement service -related impacts from the proposed Project would not combine with other related projects to result in a cumulatively considerable impact. The proposed Project would not combine with other development projects to require expansion or construction of new police facilities, which could result in a significant environmental effect. Therefore, cumulative impacts associated with police services would be less than significant, which would be consistent with the findings of the GPU FEIR. (Draft Supplemental EIR at p. 5.1 1-13.) School Services: The geographic context for cumulative impacts to schools is the Santa Ana Unified School District boundaries. The proposed Project and other development within the Santa Ana Unified School District could generate additional students resulting in the need to expand or construct new schools. At buildout, the proposed Project could generate approximately 1,678 additional students that would be accommodated by the existing schools with additional capacity available for cumulative projects. The attendance boundaries of Jefferson Elementary, McFadden Intermediate, Segerstrom High School include areas anticipating several multi -family residential development projects that are anticipated to generate additional students within the attendance boundaries of these schools. Thus, the proposed Project in combination with related projects would result in the exceedance of capacity at a minimum of two school facilities. Expansion of existing facilities are planned at both schools, and some of the existing and,/or future students could transfer to other schools within the school district that have some capacity; however, one or more school facilities within the Santa Ana Unified School District may be over capacity with implementation of the proposed Project in combination with related projects. However, the state provided authority for school districts to assess impact fees for both residential and non-residential development projects. Fees collected in accordance with Government Code Section 65995(b) allow the Santa Ana Unified School District to plan and construct for future growth. Furthermore, the payment of those fees constitutes full mitigation for the impacts generated by new development, per Government Code Section 65995, which would reduce potential impacts related to the projects cumulative school service impacts to a less than significant level, which is consistent with the findings of the GPU FEIR. (Draft Supplemental EIR at p. 5.1 1-17.) Library Services: The geographic scope for cumulative library services is the City of Santa Ana, which is the area served by the existing City libraries. As described previously, library service needs have changed with resources being available online and the availability of high-speed internet services in residences, residential amenity areas, and commercial locations. Therefore, new development, such as the proposed Project, results in a limited need for library resources/services or square footage of library space. Although demand for library services may incrementally increase as cumulative development occurs through implementation of the GPU as discussed in the GPU FEIR, library use has declined due to the availability of online library materials and may continue to decline as the information available on the Internet increases exponentially over time (AEI, 2022). Thus, the combined effect of the proposed Prolect's impacts related to libraries would not result in the need for a new or expanded library, the construction of which could result in significant impacts. Therefore, impacts from cumulative impacts associated with library services would be less than significant. (Draft Supplemental EIR at pp. 5.1 1-20 through 5.1 1-21.) P. Recreation The cumulative area of recreation impacts for the proposed Project includes the City of Santa Ana. The City currently has approximately 1.2 acres of public park and/or recreational space per every 1,000 residents which is below the City's GPU policy parkland standard of 3 acres of parkland per 1,000 residents. Based on 3 acres of public park and/or recreational space per 1,000 residents, buildout of the proposed Project results in a need for approximately 27.7 acres of parkland to serve the 9,238 new residents of the Project site. The 1 3.1-acres of public parks provided onsite would be approximately 14.6 acres less than the 27.7 acres of public parkland required, and the overall provision of 17.21 acres of common or private open space would be 10.49 acres less than the City's parkland standard. Therefore, the proposed Project would exacerbate the existing citywide parkland deficiency. Although the proposed Project and cumulative projects would be required to provide park and recreational facilities and/'or pay in - lieu fees as required by the municipal code, there is a lack of available land to develop new parks or expand existing facilities and the proposed Project's impacts related to the amount of parkland within the City would be cumulatively considerable and cumulative impacts related to parks and recreational facilities would be significant. (Draft Supplemental EIR at pp. 5.1 2-8 through 5.1 2-9.) Q. Transportation The cumulative traffic study area for the proposed Project includes the City of Santa Ana and the information utilized in this cumulative analysis is based on the potential to combine with impacts from projects in the vicinity of the proposed Project, and projections contained within the Santa Ana GPU and Orange County Transportation Analysis Model (OCTAM). Circulation System The proposed Project would connect to the existing circulation system and implement the City's traffic engineering design standards. In addition, the proposed Project would provide new facilities to enhance the use of public transit, pedestrian, and bicycle mobility; and would not conflict with a plan, ordinance, or policy addressing circulation. Because the proposed Project would enhance facilities consistent with existing plans, it would not result in a cumulatively considerable impact. In addition, cumulative development in the City and surrounding jurisdictions would be subject to site - specific reviews, including reviews of sidewalk, bike lane, and bus stop designs that would not allow potential cumulatively considerable impacts related to alternative transportation. Therefore, the proposed Project would not cumulatively combine with other projects to result in impacts. Vehicle Miles Traveled The cumulative traffic study area for the proposed Project includes the City of Santa Ana. Pursuant to the City's Traffic Impact Study Guidelines, a cumulative impact could occur if the proposed Project has the potential to increase the average VMT per service population of the City and is based on the projections provided in the City's GPU and GPU FEIR. The Project site is located within a SCAG High Quality Transit Area and a Transit Priority Area, adjacent to seven OCTA bus stops, including a high quality bus stop for OCTA Route 57. Based on City, OPR, and CEQA Guidelines screening criteria, the proposed Project would not result in increasing the average VMT per service population of the City. Therefore, VMT impacts from the proposed Project would not be cumulatively considerable. In addition, as detailed previously, the proposed Project would implement a mix of complementary onsite uses that would reduce the need for traveling outside of the Project site and would implement a multi -modal circulation system of sidewalks, bicycle lanes, and transit that is intended to reduce VMT, which would also result in a less than cumulatively significant impact related to VMT. This finding is consistent with the GPU FEIR determination that VMT impacts would be less than significant from buildout of the GPU land use plan. Design and Emergency Access Hazards The proposed Project would not result in impacts related to incompatible uses, hazards due to roadway design, or emergency access. The proposed circulation layout would be required to be installed in conformance with City design standards that would be ensured through the City's development permitting process to provide that no potentially hazardous design features or inadequate emergency access would be introduced by the proposed Project that could combine with potential hazards from other nearby projects. As the Project's proposed improvements would be implemented in compliance with City traffic engineering standards and OCFA design standards, it would not result in an impact that could become cumulatively considerable. In addition, cumulative development in the City and surrounding jurisdictions would be subject to site -specific reviews, including reviews by building and fire protection authorities that would require compliance with existing building and fire code standards that limit the potential of other projects to result in cumulatively considerable design hazards. Therefore, potential impacts related to circulation design features and emergency access would not be cumulatively considerable. (Draft Supplemental EIR at pp. 5.13-24 through 5.13-25.) R. Tribal Cultural Resources The cumulative study area for tribal cultural resources includes the Southern California region, which contains the same general tribal historic setting of the Gabrieleno and Juaneno Tribes. Other projects in the vicinity of the proposed Project would involve ground disturbances that could reveal buried TCRs. Cumulative impacts to TCRs would be reduced by compliance with applicable regulations and consultations required by SB 18 and AB 52. The Project site and vicinity is not known to contain TCRs; however, Mitigation Measure TCR-1 would be implemented to ensure that impacts would not occur in the case of an inadvertent discovery of a potential TCR. This mitigation measure would ensure that the proposed Project would not contribute to a cumulative loss of TCRs. Therefore, cumulative impacts would be less than significant. (Draft Supplemental EIR at p. 5.14-8.) (Draft Supplemental EIR at P. 5.14-8.) S. Utilities and Service Systems Water: Cumulative water supply impacts are considered on a citywide basis and are associated with the capacity of the infrastructure system and the adequacy of the City's infrastructure and primary sources of water that include groundwater pumped through City wells, deliveries of imported water from MWD, and recycled water from OCwD. Potential impacts related to water supply and infrastructure are based on the projections contained within the City's GPU, GPU FEIR, 2015 UwMP, and 2020 UVWMP. During construction of the proposed Project new water mains would be installed to serve the proposed buildings and landscaping, which would connect to improved offsite water mains that are adjacent to the Project site. The onsite water system has been designed for the proposed Project and would be served by existing and improved offsite infrastructure. The City requires that all water system improvements be confirmed through hydraulic studies to confirm compliance with engineering standards, and ensure that cumulative impacts do not occur. The WSA that was prepared for the proposed Project describes that the 2020 MWD UWMP details the ability to meet the demands of its member agencies, including the City of Santa Ana, through 2045. In addition, the City of Santa Ana 2015 UWMP, GPU FEIR, and 2020 UWMP confirmed the ability of the City to meet water needs in multiple dry year scenarios with buildout of the South Bristol Street Focus Area. Thus, the City would have water supplies available to serve the proposed Project and reasonably foreseeable development in normal, dry, or multiple dry years. Impacts related to a cumulatively considerable increase in water supply demands would be less than significant. (Draft Supplemental EIR at p. 5.15-12.) Wastewater: -Cumulative wastewater infrastructure impacts are considered on a systemwide basis and are associated with the overall capacity of existing and planned infrastructure. The cumulative system evaluated includes the sewer system that serves the Project site and conveys wastewater to the OCSD wastewater treatment and disposal system. With the proposed Project, the sewer system would have sufficient capacity to handle the increased flows resulting from implementation of the proposed Project. The continued regular assessment, maintenance, and upgrades of the sewer system by the City and OCSD would reduce the potential of cumulative development projects to result in a cumulatively substantial increase in wastewater such that new or expanded facilities would be required. Thus, increases in wastewater in the sewer system would result in a less than significant cumulative impact. (Draft Supplemental EIR at p. 5.15- 1 b.) Drainage: -The geographic scope for cumulative impacts related to stormwater drainage includes the geographic area served by the existing stormwater infrastructure for the Project area, from capture of runoff through final discharge points. The proposed Project would result in a reduction in stormwater runoff from the Project site. As a result, the proposed Project would not generate additional runoff that could combine with runoff from cumulative projects that could cumulatively combine to impact drainage. Thus, cumulative impacts related to drainage would be less than significant. (Draft Supplemental EIR at p. 5.15-21.) Solid Waste: -The geographic scope of cumulative analysis for landfill capacity is the service area for the Frank Bowerman Sanitary Landfill, which serves the Project area. The projections of future landfill capacity based on the entire projected waste stream going to these landfills is used for cumulative impact analysis. As described previously, the Frank Bowerman Sanitary Landfill has a maximum permitted capacity of 1 1,500 tons per day and in March 2023 had a maximum disposal of 8,909 tons and a remaining capacity of 2,591 tons per day (CalRecycle 2023). The 124.24 tons of solid waste per week from operation of the proposed Project would be 4.8 percent of the remaining daily capacity of the landfill. Due to this small percentage, the increase in solid waste from the proposed Project would be less than cumulatively considerable and would be less than significant. (Draft Supplemental EIR at pp. 5.15-24 through 5.15.-25.) T. Wildfire According to the CAL FIRE Fire Hazard Severity Zone map, the Project site is not within an area identified as a Fire Hazard Area that may contain substantial fire risk or a Very High Fire Hazard Severity Zone (VHFHSZ) (Cal Fire 2023). The Project site and surrounding area are currently developed, and therefore lack the combustible materials and vegetation necessary for the uncontrollable spread of a wildfire. The proposed Project would not substantially impair an adopted emergency response plan or emergency evacuation plan, or exacerbate wildfire risks. The Project does not require the installation or maintenance of associated infrastructure that would exacerbate fire risk or that would result in impacts to the environment. (Draft Supplemental EIR at pp. 5.16-10 through 5.16-1 1.) Thus, the Project would have less than significant impacts on wildfire risks, and no cumulative impacts would occur. SECTION VII RESOLUTION REGARDING SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES Section 151 26.2(c) of the CEQA Guidelines requires that an EIR discuss "any significant irreversible environmental changes which would be involved in the proposed action should it be implemented." Generally, a project would result in significant irreversible environmental changes if one of the following scenarios is involved: • The project would involve a large commitment of nonrenewable resources. • Irreversible damage can result from environmental accidents associated with the project. • The proposed consumption of resources is not justified (e.g., the Project results in the wasteful use of energy). The Project would result in or contribute to the following irreversible environmental changes: • Lands in the Project area that are currently developed with commercial uses would be re- committed to multi -family residential and commercial retail uses once the proposed buildings are constructed. Secondary effects associated with this irreversible commitment of land resources include: o Increased vehicle miles traveled on area roadways (Draft Supplemental EIR Section 5.13. Transportation). o Emissions of air pollutants and greenhouse gas emissions associated with Project construction and operation (Draft Supplemental EIR Section 5.1, Air Quality). o Consumption of non-renewable energy associated with construction and operation of the proposed Project due to the use of automobiles, lighting, heating and cooling systems, appliances, and the like (Draft Supplemental EIR Section 5.3, Energy). o Increased ambient noise associated with an increase in activities and traffic from the Project (Draft Supplemental EIR Section 5.9, Noise). In regard to energy usage from the proposed Project, as demonstrated in the analyses contained in Draft Supplemental EIR Section 5.3, Energy, the proposed Project would not involve wasteful or unjustifiable use of non-renewable resources, and conservation efforts would be enforced during construction and Operation of proposed development. The proposed development would incorporate energy -generating and conserving project design features, including those required by the California Building Code, California Energy Code Title 24, which specify green building standards for new developments. (Draft Supplemental EIR, pp. 5.16-6 through 5.16-7.) This page was intentionally left blank. SECTION VIII RESOLUTION REGARDING GROWTH -INDUCING IMPACTS AND COMMITMENT OF RESOURCES Draft Supplemental EIR Section 5.16, Mandatory Findings of Significance, evaluates the potential for the proposed Project to affect economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. Employment Related Growth As detailed in Draft Supplemental EIR Section 5.10, Population and Housing, the Project is anticipated to generate approximately 1,092 employees at full occupancy, which would be approximately 14 percent of the GPU projected increase in employment from buildout of the South Bristol Street Focus Area. Therefore, employment growth from buildout of the proposed Project would not exceed the growth identified in the GPU Final EIR, and impacts related to employment growth would be less than significant (Draft Supplemental EIR, pp. 5.10-8 through 5.16-9) Infrastructure Obstacles to Growth The proposed Project would redevelop the existing onsite infrastructure systems and provide an offsite sewer line improvement that would connect to the existing offsite systems that currently serve the Project site. The new infrastructure would not provide additional capacity beyond what is needed to serve the proposed Project. In addition, because the Project is within a developed area that is receiving services from existing infrastructure and would connect to the existing infrastructure, development of the proposed Project would not result in an expansion of overall capacity, extension of infrastructure, or provision of services in areas or an unserved area. Therefore, infrastructure improvements would not result in significant growth inducing impacts (Draft Supplemental EIR, pp. 5.10-10 through 5.16-1 1) Land Development Regulation Obstacles to Growth The proposed Project includes amendments to the zoning code to allow for the redevelopment of the site to provide the proposed mixed -use development. The Project includes a proposed zoning change from Regional Commercial (C-2) and General Commercial (CR) to the Related Bristol Specific Plan District which would also provide specific development regulations for the mixed -use Project. The proposed Project is redevelopment of an already developed area that has been used for urban uses since 1972 and is surrounded by urban development or areas planned for urban development. The proposed Project would involve a change to development regulations and would result in onsite residents and additional onsite employees. However, the zoning change is parcel specific and would result in growth that is consistent with the General Plan. Thus, changes to the Project site's zoning designation would not result in removing an obstacle to growth within the Project vicinity. In addition, the Project's consistency with SCAG policies regarding regional growth -inducement are evaluated in Draft Supplemental EIR Section 5.8, Land Use and Planning, and Section 5.10, Population and Housing. As described in those sections, the growth anticipated by SCAG's projections are consistent with the increases in population (9,238 residents) and employees (1,092 employees) anticipated at full capacity of the Project. Therefore, impacts related to growth from changes in existing regulations pertaining to land development would be less than significant (Draft Supplemental EIR, pp. 5.8-20 through 5.8-43 and 5.10-10 through 5.10-1 1 ) Public Service Obstacles to Growth The proposed Project is expected to incrementally increase the demand for fire protection and emergency response, police protection, and school services. However, as described in Draft Supplemental EIR Section 5.1 1, Public ,services, the proposed Project would not require development of additional facilities or expansion of existing facilities to maintain existing levels of service. The Project would develop a police substation that would be able to accommodate the 9 additional officers required for the development. The proposed substation is analyzed as part of the proposed Project and would not result in any substantial impacts beyond those identified in the Draft Supplemental EIR associated with the construction and operation of the proposed Project. Therefore, an indirect growth inducing impact as a result of expanded or new public facilities that could support other development in addition to the proposed Project would not occur. The proposed Project would not have significant growth inducing consequences that would require the need to expand public services to maintain desired levels of service (Draft Supplemental EIR, pp. 5.1 1-5 through 5.1 1-20) Other Activities Related to Growth The proposed Project involves amendments to the City of Santa Ana Zoning Ordinance, but those amendments are specific to the allowable land uses on the Project site itself. The proposed Project does not propose changes to any of the City's building safety standards (i.e., building, grading, plumbing, mechanical, electrical, or fire codes). The Project would comply with all applicable City plans, policies, and ordinances. In addition, Project features and mitigation measures have been identified within the Draft Supplemental EIR to ensure that the Project minimizes environmental impacts. The Project would not involve any precedent -setting action that could encourage and facilitate other activities that significantly affect the environment. I m acts of Growth All physical environmental effects from construction of development of the proposed Project have been analyzed in the Draft Supplemental EIR. For example, activities such as excavation, grading, and construction as required for the proposed mixed uses were analyzed in the Draft Supplemental EIR Sections 5.1, Air Quality, 5.6, Hazards and Hazardous Materials, and 5.9, Noise. Therefore, construction of the proposed Project has been analyzed in the Draft Supplemental EIR and would be adequately mitigated either through implementation of existing regulations and/or mitigation measures. The surrounding area is already urbanized and there is not many opportunities for additional growth. Further, the proposed infrastructure is only sized to serve the Project site or consistent with the City's infrastructure plans and would not have capacity to serve additional development projects in the area. The Project would not individually or cumulatively encourage or facilitate substantial growth. Based on the foregoing analysis, the Project would not directly or indirectly result in substantial, adverse growth -inducing impacts. (Draft Supplemental EIR, pp. 5.16- 2 through 5.16-6.) This page was intentionally left blank. SECTION Ix RESOLUTION REGARDING ALTERNATIVES The City of Santa Ana hereby declares that it has considered and rejected as infeasible the alternatives identified in the Supplemental EIR and described below. Section 15126.6 of the State CEQA Guidelines requires an EIR to describe a range of reasonable alternatives to the Project, or to the location of the Project, which could feasibly achieve most of its basic objectives, but would avoid or substantially lessen any of the significant effects identified in the EIR analysis. An EIR is not required to consider every conceivable alternative to a proposed project. Rather, an EIR must consider a reasonable range of alternatives that are potentially feasible; an EIR is not required to consider alternatives that are infeasible. In addition, an EIR should evaluate the comparative merits of the alternatives. Therefore, this section sets forth the potential alternatives to the Project analyzed in the Supplemental EIR and evaluates them in light of the objectives of the Project, as required by CEQA. Objectives The following objectives have been identified in order to aid decision makers in their review of the proposed Project and its associated environmental impacts. • Implement the vision and objectives established in the City of Santa Ana General Plan for the South Bristol Street Focus Area to create a southern gateway to the City. The South Bristol Street Focus Area objectives: a Capitalize on the success of the South Coast Metro area; o Introduce mixed -use urban villages and encourage experiential commercial uses that are more walkable, bike friendly, and transit oriented; Q Realize an intense, multi -story presence along the Bristol Street corridor; and • Provide for mixed -use opportunities while protecting adjacent, established low density neighborhoods. • Allow for the flexible redevelopment of the underutilized Project site to provide a balanced mix of residential, retail, and hospitality uses in the South Bristol Street Focus Area that integrate into the existing urban systems and provide a safe and attractive environment for living and working, as encouraged by the G PU. • Transform an auto -oriented shopping plaza with large surface parking areas to a community which maximizes opportunities for onsite open space which can be accomplished through the provision of subsurface shared parking and intensity of land use permitted by the General Plan. • Develop high quality residential spaces that reflect modern lifestyles, while responding to the need for additional housing at a higher density in an area of the City planned for growth. • Develop a project with a mix of land uses that stimulate economic activity, commerce, and new housing opportunities in the South Bristol Street Focus Area. • Have a positive contribution to the local economy through new capital investment, the creation of new jobs, and the expansion of the tax base. • Create a walkable mixed -use development to encourage and enhance pedestrian activity within the Specific Plan area and the local community. • Enhance non -vehicular activity by providing onsite and offsite pedestrian and bicycle facilities that link with existing facilities and transit services. • Improve existing infrastructure to support the Related Bristol Specific Plan consistent with the General Plan conditions. • Provide a project that contributes to the creation of a vibrant urban core for the City and takes advantage of the site's location within the South Coast Metro area. Provide a project that contains vibrant and attractive community amenities, recreational and open space areas, and gathering spaces that are directly accessible to residents and the community. • Provide community benefits commensurate with the Specific Plan development proposal including public open space onsite and locations for public community events, as well as streetscape improvements along the Project site frontages of MacArthur Boulevard, Bristol Street, Sunflower Avenue and South Plaza Drive. Alternatives Ivey provisions of the State CEQA Guidelines relating to the alternatives analysis (Section 15126.6 et seq.) are summarized below: • The discussion of alternatives shall focus on alternatives to the Project or its location that are capable of avoiding or substantially lessening any significant effects of the Project, even if these alternatives would impede to some degree the attainment of the Project objectives or would be more -costly. • The "No Project" alternative shall be evaluated along with its impact. The "No Project" analysis shall discuss the existing conditions, as well as what would be reasonably expected to occur in the foreseeable future if the Project is not approved. • The range of alternatives required in an EIR is governed by a "rule of reason"; therefore, the EIR must evaluate only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the Project. • For alternative locations, only locations that would avoid or substantially lessen any of the significant effects of the Project need be considered for inclusion in the EIR. • An EIR need not consider an alternative whose effects cannot be reasonably ascertained and whose implementation is remote and speculative. Rationale for Selecting Potentially Feasible Alternatives The alternatives must include a no -project alternative and a range of reasonable alternatives to the Project if those reasonable alternatives would attain most of the Project objectives while substantially lessening the potentially significant project impacts. The range of alternatives discussed in an EIR is governed by a "rule of reason," which the State CEQA Guidelines Section 15126.6(f)(3) defines as: ... set[ting] forth only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the Project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the Project. The range of feasible alternatives shall be selected and discussed in a manner to foster meaningful public participation and informed decision -making. Among the factors that may be taken into account when addressing the feasibility of alternatives (as described in the State CEQA Guidelines Section 15126.6(f)([1 ]) are environmental impacts, site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the Project proponent could reasonably acquire, control, or otherwise have access to an alternative site. An EIR need not consider an alternative whose effects could not be reasonably identified, and whose implementation is remote or speculative. For purposes of this analysis, the Project alternatives are evaluated to determine the extent to which they attain the basic Project objectives, while significantly lessening any significant effects of the Project. Alternatives Analysis The goal for evaluating any alternatives is to identify ways to avoid or lessen the significant environmental effects resulting from implementation of the proposed Project, while attaining most of the Project objectives. The City of Santa Ana has included the following 3 alternatives for consideration: • No Project/No Build Alternative • Reduced Project Alternative • Build Out of the Existing Zoning Designations Alternative Alternatives Not Selected for Analysis Alternative Site: An alternate site for the proposed Project was eliminated from further consideration. The Project objectives are to redevelop the Project site consistent with the objectives of the City's GPU District Center -High (DC-5) land use designation and South Bristol Street Focus Area that includes new mixed -use development with housing in proximity to transit. In addition, due to the urban and built out nature of the City, development of 3,750 multi -family residential units, 350,000 SF of commercial uses, a 250 room hotel, and 200 senior living,/continuum of care units on another 41.13-acre underutilized site at a different location would likely require demolition of existing structures, require similar mitigation, and have similar impacts as the proposed Project. CEQA specifies that the key question regarding alternative site consideration is "whether any of the significant effects of the project would be avoided or substantially lessened by putting the project at another location." Given the size and nature of the proposed Project and the Project objectives, it would be infeasible to develop and operate the proposed Project on an alternative site with fewer environmental impacts, while also implementing the City's GPU. Therefore, the Alternative Site Alternative was rejected from further consideration on the following grounds, each of which individually provides sufficient justification for rejection of this alternative: (1) the alternative does not avoid any significant and unavoidable impact, (2) the alternative would likely not further reduce any of the proposed project's significant impacts; and (3) the alternative is technically, financially, and legally infeasible given the size and nature of the proposed project. This alternative is therefore eliminated from further consideration (Draft Supplemental EIR, pp. 6-4 through 6-5). No Project/Buildout of Existing General Plan Designation. Buildout of the Project site at the maximum allowable density pursuant to the City's General Plan DC-5 land use designation was eliminated from further consideration. The DC-5 land use designation allows for development of the Project site at a maximum 125 dwelling units per acre (du/ac) and a FAR of 5.0, which would allow for development of up to 8,733,780 SF of mixed uses, inclusive of residential uses. The proposed Project would result in approximately 91 du/ac and a FAR of 2.7. The No Project/Buildout of Existing General Plan Designation Alternative would result in an 85 percent intensification of uses onsite in comparison to the proposed Project. This alternative would require demolition of the same structures, require similar mitigation, and would increase air quality emissions and require more parkland in comparison to the proposed Project. Given the increased intensity of the No Project/Buildout of the Existing General Plan Designation Alternative, it would not result in fewer environmental impacts than the proposed Project. Therefore, the No Project/Buildout of Existing General Plan Designation Alternative was rejected from further consideration on the following grounds, each of which individually provides sufficient justification for rejection of this alternative: (1) the alternative does not avoid any significant and unavoidable impact, and (2) the alternative would likely not further reduce any of the proposed project's significant impacts (Draft Supplemental EIR, p. 6-5 ). Description of Alternatives Alternative 1 — No Project/No Build Alternative Pursuant to Section 15126.6(e)(2) of the CEQA Guidelines, the EIR is required to "discuss the existing conditions at the time the notice of preparation is published, or if no notice of preparation is published, at the time the environmental analysis is commenced, as well as what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services." Therefore, under this alternative, no development would occur on the Project site and it would remain in its existing condition with three existing buildings with 16 existing buildings totaling 465,063 SF functioning as a shopping center. in this alternative scenario, the 16 buildings are assumed to be fully operational as a shopping center with restaurants, a supermarket, banks, a dry cleaner, medical and dental offices, financial offices, and fitness uses. Hence, this alternative compares the impacts of the proposed Project with the existing buildings operating at full capacity for shopping center uses (Draft Supplemental EIR, pp. 6-6 through 6-13). Alternative 2 — Reduced Project Alternative Under this alternative, a reduction in the commercial square -footage that would be developed onsite. Pursuant to discussion with City planning staff, it was determined that a reasonable decrease in developed on the Project site is 100,000 SF of commercial retail and the elimination of the 250- room hotel. This alternative would develop and operate 3,750 multi -family residential units, a 200- room senior Iiving/'continuum of care facility, and 250,000 SF of retail and restaurant commercial uses. The reduction would result in the construction of 1,375 units, 200 senior living continuum of care units, and 150,000 SF of commercial uses in Phase 1; including an administrative Police Department substation to be located within the commercial use area. Approximately 856 units and 65,000 SF of commercial uses would be constructed in Phase 2; and 1,519 units and 35,000 SF of commercial uses would be constructed in Phase 3. To support the reduced Project under this alternative, the same ratio of parking spaces would be provided as proposed for the proposed Project. Under the Reduced Project Alternative, certain offsite improvements (including storm drain upgrades, restriping, and signal installation) are assumed, consistent with the proposed Project. In addition, the some amount of recreational facilities and common open space would be provided as the proposed Project. Like the proposed Project, this alternative would require a zoning map amendment to amend the existing zoning of General Commercial (C-2) and Commercial Residential (CR) to Related Bristol Specific Plan District (Draft Supplemental EIR, pp. 6-13 through 6-22). Alternative 3 — Build out of the Existing Land Use and Zoning Alternative Under this alternative, no zoning map amendment would occur, and the Project site would be built out according to the existing zoning designations. Therefore, this alternative would include development of the 23.96-acre area north of Callen's Common with only commercial uses pursuant to the C-2 zoning designation, which would result in approximately 782,774 SF at the maximum FAR of 0.75 with a building height of 35 feet. This alternative would provide surface parking and would not develop Bristol Central Park in the northern portion of the site. Also, the 17.17-acre area south of Callen's Common would be redeveloped with commercial uses and mixed -uses pursuant to the CR zoning designation, which would result in approximately 250,000 SF of ground -floor commercial uses and office space, approximately 250 hotel rooms, approximately 200 senior living continuum of care units, and 11375 multi -family units would be developed to a maximum FAR of 5.0. Buildings at the northwestern corner of the CR zoned area would be a maximum of 50 feet, buildings at 200 feet from adjacent residential uses would be a maximum height of 100 feet. The buildings toward the southeast corner of the site would be a maximum of 25 stories. Parking within areas south of Callen's Common would be underground and open space within this area would be consistent with the proposed Project. Overall, buildout of the Existing Zoning Alternative would develop the site with 682,774 SF more commercial space than proposed by the Project, totaling 1,032,774 SF of commercial uses (including an administrative Police Department substation), the same number of hotel rooms and senior living/continuum of care units as the proposed Project, and 2,375 fewer residential units for a total of 1,375 multi -family units(Draft Supplemental EIR, pp. 6-22 through 6-30). Evaluation of Alternatives Alternative I — No Pro ject/No Build Alternative The No Proiect/No Build Alternative would avoid the significant and unavoidable air quality, and parks and recreation impacts that would occur from the proposed Project. Additionally, operational impacts would be reduced and mitigation measures, which include measures related to air quality, cultural resources, geology and soils, greenhouse gas emissions, hazards and hazardous materials, noise, and tribal cultural resources, would not be required. However, the environmental benefits of the Project would also not be realized, such as implementation of the General Plan DC-5 land use and South Bristol Street Focus Area objectives, improvements to offsite bicycle lanes, sidewalks, and stormwater infrastructure, CALGreen,/DAMP/LI D infrastructure improvements to storm water quality, and a reduction of drainage runoff from the area, removal of potentially contaminated soils, provision of housing within TPAs and High Quality Transit Areas, improvements to the jobs/'housing balance, and the potential to reduce vehicle miles traveled. The No Project No Build Alternative would not meet any of the Project objectives. The site would not be redeveloped to provide housing to help meet the region's demand for housing, would not provide a development consistent with other regional redevelopment in the South Bristol Street Focus Area, would not develop housing to assist the City in meeting its jobs,/housing balance, would not provide onsite uses that reduce VMT, and would not implement SCAG RTP%SCS policies related to providing additional housing near employment centers. Overall, this alternative would not meet any of the objectives of the proposed Project (Draft Supplemental EIR, pp. 6-1 2 through 6-1 3). Finding: The City of Santa Ana finds that the No Project/'No Build Alternative would not redevelop the site to provide development consistent with other regional redevelopment in the South Bristol Street Focus Area, would not develop housing to assist the City in meeting its jobs/'housing balance, would not provide onsite uses that reduce VMT, and would not implement SCAG RTP/SCS policies related to providing additional housing near employment centers. Overall, the No Project,/No Build Alternative fails to meet any of the Project objectives (Draft Supplemental EIR at p. 6-12) and is rejected on that basis. Alternative 2 — Reduced Project Alternative The Reduced Project Alternative would result in 2,722 fewer daily vehicular trips than the proposed Project. The reduction in vehicular emissions and consumer products from this alternative would reduce operational air quality impacts to a less than significant level. However, significant and unavoidable impacts related to construction air quality emissions would continue to occur and cumulative parkland deficiencies from implementation of this alternative. Additionally, the mitigation required for implementation of the proposed Project would continue to be required for the Reduced Project Alternative to reduce impacts related to air quality, cultural resources, geology and soils, greenhouse gas emissions, hazards and hazardous materials, noise, and tribal cultural resources to a less than significant level. Overall, although the volume of impacts would be less by the Reduced Project Alternative in comparison to the proposed Project, the Reduced Project Alternative would not eliminate all of the significant and unavoidable impacts of the proposed Project or eliminate the need for mitigation. Furthermore, the Reduced Project Alternative would result in a reduced beneficial impact. Providing less commercial space and no hotel space on the Project site would result in fewer opportunities to improve the jobs -housing balance as residents would have the potential to travel to fewer local employment opportunities. The Reduced Project Alternative would meet the Project objectives, but not to the same extent as the proposed Project. The site would be redeveloped to provide housing to help meet the region's demand for housing, would provide a development consistent with other regional redevelopment in the South Bristol Street Focus Area. However, no hotel rooms and less commercial space would be provided and a reduced improvement to the jobs -housing balance and VMT would occur. Overall, this alternative would meet the objectives of the proposed Project, but not to the same extent as the proposed Project (Draft Supplemental EIR, pp. 6-20 through 6-21 ). Finding: The City of Santa Ana finds that the Reduced Project Alternative would result in less commercial space and a reduced improvement to the jobs -housing balance and VMT would occur. In addition, the Reduced Project Alternative would not eliminate all of the significant and unavoidable impacts of the proposed Project or eliminate the need for mitigation. Thus, the Reduced Project Alternative would not achieve the Project objectives to the same extent as the proposed Project, would continue to result in significant and unavoidable impacts, and would continue to require mitigation. The Reduced Project Alternative is rejected on that basis. Alternative 3 — Build out of the Existing Land Use and Zoning Alternative The Build Out of the Existing Zoning Alternative would result in 9,541 more daily vehicular trips than the proposed Project. The increase in vehicular trips from this alternative would increase the proposed Project's significant and unavoidable operational air quality impacts. and unavoidable impacts related to air quality and parks and recreation would continue to occur from implementation of this alternative. Further, this alternative would result in significant and unavoidable impacts related to operational traffic noise. Additionally, the mitigation required for air quality, cultural resources, geology and soils, greenhouse gas emissions, hazards and hazardous materials, noise, and tribal cultural resources would continue to be required for the Buildout of the Existing Zoning Alternative. Overall, although the volume of impacts would be greater from the Build Out of the Existing Zoning Alternative in comparison to the proposed Project, the Build Out of the Existing Zoning Alternative would not eliminate any of the significant and unavoidable impacts of the proposed Project or eliminate the need for mitigation. Furthermore, the Build Out of the Existing Land Use and Zoning Alternative would result in a reduced beneficial impact, as it would not provide as many multi- family units on the Project site; and therefore, would not improve the jobs -housing balance. The Build Out of Existing Zoning would meet the Project objectives, but not to the same extent as the proposed Project. The site would be redeveloped to provide housing to help meet the region's demand for housing, would provide a development consistent with other regional redevelopments in the South Bristol Street Focus Area. However, fewer residential multifamily units would be provided and a reduced improvement to the jobs -housing balance and VMT would occur. Additionally, the alternative would result in less implementation of SCAG RTP/SCS policies related to providing additional housing near employment centers. Overall, this alternative would meet the objectives of the proposed Project, but not to the same extent as the proposed Project (Draft Supplemental EIR, pp. 6-29 through 6-30). Finding: The City of Santa Ana finds that the Build Out of the Existing Zoning Alternative would not assist the City in meeting its jobs/housing balance. In addition, the Reduced Project Alternative would not eliminate all of the significant and unavoidable impacts of the proposed Project or eliminate the need for mitigation. In fact, it would create an additional significant unavoidable impact related to traffic noise. Thus, the Build Out of the Existing Land Use and Zoning Alternative would not achieve the Project objectives to the same extent as the proposed Project. The Build Out of the Existing Zoning Alternative is rejected on that basis. Environmentally Superior Alternative Section 15126.6(e)(2) of the CEQA Guidelines indicates that an analysis of alternatives to a proposed project shall identify an environmentally superior alternative among the alternatives evaluated in an EIR. The CEQA Guidelines also state that should it be determined that the No Project/No Build Alternative is the environmentally superior alternative, the EIR shall identify another environmentally superior alternative among the remaining alternatives. The Reduced Project Alternative would reduce the Project's significant and unavoidable operational air quality impacts to a less than significant level. However, significant and unavoidable impacts related to construction air quality emissions and parkland deficiencies would continue to occur from implementation of this alternative. In addition, the Reduced Project Alternative would result in a reduced beneficial impact. Eliminating the hotel and providing less commercial space on the Project site would result in fewer opportunities for the creation of new jobs. This alternative would continue to require mitigation related to air quality, cultural resources, geology and soils, greenhouse gas emissions, hazards and hazardous materials, noise, and tribal cultural resources to reduce impacts to a less than significant level. In addition, Reduced Project Alternative would meet the Project objectives but not to the same extent as the proposed Project. While the Reduced Project Alternative would result in additional employment, it would not result in the creation of new jobs to the same extent as the proposed Project. The Reduced Project Alternative would introduce mixed -uses to the Project site and would provide for new economic activity, but to a lesser extent as no hotel would be developed and less commercial square footage would be developed. Overall, this alternative would meet the objectives of the proposed Project, but not to the same extent as the proposed Project (Draft Supplemental EIR, pp. 6-30 through 6-34.) This page was intentionally left blank X. STATEMENT OF OVERRIDING CONSIDERATIONS Introduction The City of Santa Ana is the Lead Agency under CEQA for preparation, review and certification of the Supplemental EIR for Related Bristol Mixed -Use Project (Project). As the Lead Agency, the City is also responsible for determining the potential environmental impacts of the proposed action and which of those impacts are significant, and which can be mitigated through imposition of mitigation measures to avoid or minimize those impacts to a level of less than significant. CEQA then requires the Lead Agency to balance the benefits of a proposed action against its significant unavoidable adverse environmental impacts in determining whether or not to approve the proposed Project. In making this determination the City is guided by CEQA Guidelines Section 15093, Statement of Overriding Considerations, which states; (a) CEQA requires the decision -making agency to balance, as applicable, the economic, legal, social, technological, or other benefits of a proposed project against its unavoidable environmental risks when determining whether to approve the project. If the specific economic, legal, social, technological, or other benefits of a proposal (sic) project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered "acceptable." (b) When the lead agency approves a project which will result in the occurrence of significant effects which are identified in the Final Supplemental EIR but are not avoided or substantially lessened, the agency shall state in writing the specific reasons to support its action based on the Final Supplemental EIR and/or other information in the record. The statement of overriding considerations shall be supported by substantial evidence in the record. (c) If an agency makes a statement of overriding considerations, the statement should be included in the record of the project approval and should be mentioned in the notice of determination. This statement does not substitute for, and shall be in addition to, findings required pursuant to Section 15091. In addition, Public Resources Code Section 21081 (b) requires that where a public agency finds that specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or alternatives identified in an EIR and thereby leave significant unavoidable effects, the public agency must also find that overriding economic, legal, social, technological, or other benefits of the project outweigh the significant effects of the project. Pursuant to Public Resources Code Section 21081 (b) and the State CEQA Guidelines Section 15093, the City has balanced the benefits of the proposed Project against the unavoidable adverse impacts associated with the Project and has adopted all feasible mitigation measures with respect to these impacts. The City also has examined alternatives to the proposed Project, none of which both meet the Project objectives and is environmentally preferable to the proposed Project for the reasons discussed in the Findings and Facts in Support of Findings. The City of Santa Ana, as the Lead Agency for this Project, and having reviewed the Supplemental EIR for the Related Bristol Mixed -Use Project, and reviewed all written materials within the City's public record and heard all oral testimony presented at public hearings, adopts this Statement of Overriding Considerations, which has balanced the benefits of the Project against its significant unavoidable adverse environmental impacts in reaching its decision to approve the Project. Overriding Considerations The City, after balancing the specific economic, legal, social, technological, and other benefits of the Project, has determined that the unavoidable adverse environmental impacts identified above may be considered acceptable due to the following specific considerations which outweigh the unavoidable, adverse environmental impacts of the Project, each of which standing alone is sufficient to support approval of the Project, in accordance with CEQA Section 21081 (b) and CEQA Guideline Section 15093. The specific economic, legal, social, technological, or other benefits of the Project are as follows: • The project implements the vision of the General Plan for the South Bristol Street Focus Area by: © Capitalizing on the success of the South Coast Metro area o Introducing mixed -use urban villages and encourage experiential commercial uses that are more walkable, bike friendly, and transit -oriented a Realizing an intense, multistory presence along the corridor a Providing for mixed -use opportunities while protecting adjacent, established low density neighborhoods © Creating: ■ New development that establishes vibrant public outdoor space appropriately scaled to the size and type of project, including 13.1 acres of publicly -accessible onsite open space areas ■ Building design that is dynamic and strong, creating a distinct impression ■ Mixed -use spaces of similar scale to those south of Sunflower Avenue. • The Project implements capital investment through construction of new buildings and offsite infrastructure improvements to enhance the City's economic and fiscal viability pursuant to the City of Santa Ana General Plan. • The Project improves the jobs -housing balance in the City, beneficially providing multi -family housing in a jobs -rich area so that employees can easily travel to employment opportunities. • The Project reduces vehicle miles traveled and the related traffic congestion, air quality, and greenhouse gas emissions through the provision of a multi -modal, mixed -use development by bringing residents and visitors closer to their routine destinations like their workplace, gym, grocery store, park, bank, and restaurants. • Related Bristol will significantly enhance the pedestrian experience along the south Bristol corridor with new landscaping, pedestrian -oriented sidewalks and protected bike lanes. • The Project transforms an underutilized site currently dominated by an asphalt parking lot and partially vacant retail center into a walkable, pedestrian -friendly village with approximately 13.1 acres of actively programmed, publicly accessible open space. • The Project transforms an underutilized site to an economically viable development consistent with the General Plan objectives for the South Bristol Street Focus Area and combines residential uses with community -serving commercial uses near employment opportunities, freeway access, and transit. • The Project implements the SCAG Regional Transportation Plan,/Sustainable Communities Strategy (RTP/SCS) Land Use Policies related to population and housing by providing additional housing near employment centers. • Consistent with the General Plan, the Project facilitates the economic development of the City by creating an expanded employment base and new diverse employment opportunities. The Economic and Fiscal Analysis (2023) prepared for the Project determined that the Project will generate approximately 5,900 construction jobs and 1,600 permanent jobs. The Project's implementation will be a powerful catalyst for business growth and sustainability in south Santa Ana for generations to come. • The Economic and Fiscal Analysis (2023) prepared for the Project determined that due to greater construction costs and scale, the Project would generate close to $2.9 billion in total economic activity in Orange County. • The Economic and Fiscal Analysis determined that the Project could generate a net surplus of approximately $10.7 million per year to the City's General Fund. In comparison, the existing (partially vacant) commercial center on the site is estimated to generate a net fiscal benefit of about $2.8 million per year. • The Project creates a high quality, master planned mixed -use development that will attract an array of businesses and provide a variety of employment and housing opportunities and creates an annual net fiscal surplus. EXHIBIT B MITIGATION MONITORING AND REPORTING PROGRAM 55394.00062\424764 25 Lu oG a O W a ui � 0 z a 0. p � a �z LL. z V a� 00 z OC p z MEMM z OV Z a J 00 � N .. ca p LU W J Io- 'a LY Ix C slow 4i N rw CL wpm O Some p M C;) 0) 0) C �° C m ©Ll' m o o ,o m .Q - o a a C O O V L .� C C C a CG D VO? a V? to C3 to Vi C) to V) V) O O LJ.1 +- } 4- u u u u O U E c E C E v Q � O O _ �_ O O O v •- v a a . o E .0 o c a o E o tA tA O N O O- L .O 0 0 .� O O ,L V O O} •L V L CL a. 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N s ,� 0 Oi N 0 O N v 0 d } i s s i r7 > } Q N N o N = N •_ N 0 V -0 0 � Z3 O 0 3 } _ > O O = c O (� Z3 N V in -0 0L Q O 00 a) E V a — 0 s} `o 0 N .- — a c o o .Q a •— 'a 0 C �' 0 " 4- a 0 N E L 0 a b. CL -0 a) a) N 0 +- = p -C } V C 0 Q 0 _— +- L s_ p tU a) � > j ,O O V -0 _0 4- � N } } Q o �n } � N N � = N 0 = N a) .� L Q CL u O -0 V > w Lo N CT L 0 LAC 60 0 +- — c O E to N E_ tv Q_ a0 O s = a) o to � �u 4- •r3 Q .--_ _ . v' N a) a {) O LL_ V a) 0 a) Q 43 •_ r LL a V } L 0 a L ;� O © a) - 4- � 2 '� N = 0 CL O o 0 o 0 a) tea) o -0 VI V ta:�. ( j ,`0- ,off }�� V �J LL a Q V J V Q CL Q E CL CL 0 Q °' 0 E CV O CL 0 V) Q -0 00 W T Q U LE V) Me a s CL e� E Omom a) V � •j d c Z •a C m e0 Q} MEO �L" > .0 E a Q 6 to O u c ;,� a �. O .i tli _N Qa! } V) O W '� 7 4- to O sn � W u O N V E c L CL EN ._ O •� 4- 0 L- •'L O N O O N L CD O} +- u = O O-�� 3O en •�! —,_ Imo ,v v Q 0 �- Z3 Z3 •— L c —a) L ,v •Q O� to v Q e _ ti,J L} A W m O a— <OC, n }0 N( Q -0N Q %0 } a : O i tA •� L V :J vS.. O O. 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