HomeMy WebLinkAbout2025-041 - Certifing Final Supplemental Enviromental Impact for The Village RESOLUTION NO. 2025-041
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
SANTA ANA: (1) CERTIFYING THE FINAL SUPPLEMENTAL
ENVIRONMENTAL IMPACT REPORT FOR THE VILLAGE
SANTA ANA 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. 202002908) 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 Village Santa Ana Specific Plan Project ("Project") site is located
within the GPU South Bristol Street Focus Area (SBSFA) and is consistent with the GPU
land use designation; and
WHEREAS, the Project includes 11 addresses (1561, 1611, 1621, 1631, 1641,
and 1661 West Sunflower Avenue; 3820, 3840, and 3951 South Plaza Drive; and 3811
and 3851 South Bear Street) and seven parcels (412-131-10, 412-131-20, 412-131-21,
412-451-01, 412-451-02, 412-451-03, and 412-451-04), collectively referred to as 1561
W. Sunflower Avenue ("Project Site"),
WHEREAS, the Project entails, among other things: (1) demolition of the existing
structures on the Project Site; (2) the establishment of a new The Village Santa Ana
Specific Plan (SP No. 6) and a change of zone for the Project Site from Specific
Development No. 48 (SD-48) to SP No. 6 designation; (3) redevelopment of the Project
Site into an urban village consisting of up to 1,583 residential units, 80,000 square feet of
retail space, and 300,000 square feet of office space, including 7.5 acres of publicly
accessible open space and onsite parking and landscaping; and (4) approval of Vesting
Tentative Tract Map (VTTM) No. 2025- 06; and
WHEREAS, the City, in accordance with the California Environmental Quality Act
(CEQA), determined that a Supplemental Environmental Impact Report (SEIR) to the
GPU FEIR is required to evaluate the potential of the Project to result in new or
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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
WHEREAS, pursuant to State CEQA Guidelines Section 15082, on November 3,
2023, the City sent to the Office of Land Use and Climate Innovation 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 a SEIR would be prepared; and
WHEREAS, nine 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
November 15, 2023, to solicit comments on the scope of the environmental review of the
proposed Project, and two (2) written comments were received; and
WHEREAS, a Draft Supplemental Environmental Impact Report (Draft SEIR)
(SCH No. 2020029087) was prepared for the Project addressing comments received in
response to the NOP and evaluating the proposed Project's potentially significant
environmental impacts; and
WHEREAS, the Draft SEIR 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, noise, and tribal cultural resources; and
WHEREAS, the Draft SEIR further concluded that despite the incorporation of all
feasible mitigation measures, the proposed Project would nonetheless result in significant
and unavoidable impacts relating to recreation; and
WHEREAS, in accordance with State CEQA Guidelines Section 15085, a Notice
of Completion (NOC) was prepared and filed with the Office of Land Use and Climate
Innovation on April 17, 2025; and
WHEREAS, as required by State CEQA Guidelines Section 15087(a), the City
provided Notice of Availability of the Draft SEIR to the public at the same time that the
City sent the NOC to the Office of Land Use and Climate Innovation on April 17, 2025;
and
WHEREAS, during the public comment period, copies of the Draft SEIR and
technical appendices were available for review and inspection at City Hall, on the City's
website, and at the City of Santa Ana Southwest Senior Center; and
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WHEREAS, consistent with State CEQA Guidelines Section 15087(e), the Draft
SEIR was circulated for a 52-day public review and comment period from April 17, 2025,
to June 9, 2025; and
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 eight (8) written comment letters on the Draft SEIR;
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 SEIR, on August 4, 2025; and
WHEREAS, on August 4, 2025, the City released the Final SEIR; and
WHEREAS, the Final SEIR consists of the Draft SEIR, all technical appendices
prepared in support thereof; all documents incorporated by reference, all written
comments letters received on the Draft SEIR, written responses to all written comments
letters and verbal comments received on the Draft SEIR, revisions to the Draft SEIR and
technical appendices, the Mitigation Monitoring and Reporting Program (MMRP), and
Statement of Overriding Considerations; and
WHEREAS, on August 11, 2025, the Planning Commission conducted the public
hearing to consider the Final SEIR 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 SEIR for the Project, adopt Environmental Findings of Fact and a Statement of
Overriding Considerations for the Project, adopt a MMRP for the Project, and approve the
Project; and
WHEREAS, on September 16, 2025, the City Council held a duly noticed public
hearing to consider the Final SEIR and the Project, at which hearing members of the public
were afforded an opportunity to comment and the Project was fully considered; and
WHEREAS, all potentially significant adverse environmental impacts were
sufficiently analyzed in the Final SEIR; 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
SEIR, which is sufficiently detailed so that all of the potentially significant environmental
effects of the Project have been adequately evaluated; and
i
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WHEREAS, the Final SEIR prepared in connection with the Project sufficiently
analyzes the Project's potentially significant environmental impacts, and the Final SEIR
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 SEIR, are described in Chapter 4 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 SEIR, are described in Chapter 4 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 SEIR, would be considered less than significant, are
described in Chapter 5 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 Chapter 6 of the
Findings of Fact, attached hereto as Exhibit A; and
WHEREAS, the cumulative impacts of the Project identified in the Final SEIR and
set forth herein, are described in Chapters 4, 5, and 6 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 Chapter 7 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 Chapter 8 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 Chapter 9 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
Chapter 10 of the Findings of Fact, attached hereto as Exhibit A; and
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WHEREAS, all the mitigation measures identified in the Final SEIR and necessary
to reduce the potentially significant impacts of the Project to a level of less than significant
are set forth in the MMRP, attached hereto as Exhibit B; and
WHEREAS, prior to acting on the Project, 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 SEIR and all oral and written evidence presented to
it during all meetings and hearings; and
WHEREAS, the Final SEIR 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 SEIR 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
occurred.
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 SEIR, which it has reviewed and considered, and further finds that the Final SEIR
is an accurate and objective statement that has been completed in full compliance with
CEQA and the State CEQA Guidelines, and that the Final SEIR 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 SEIR that
would require recirculation of the Final SEIR.
Section 4. The City Council hereby:
A. Certifies the Final SEIR 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 recreation impacts of the proposed Project
against the benefits of the proposed Project.
C. Adopts the MMRP attached hereto and incorporated herein as Exhibit B,
consistent with Public Resources Code Section 21081.6; makes
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implementation of the mitigation measures in the MMRP a condition of
approval of the Project; and finds 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 16th day of September, 2025.
Vale 'e A ezcua
May r
APPROVED AS TO FORM:
Sonia R. Carvalho
City Attorney
By:
Melissa M. Crosthwaite
Senior Assistant City Attorney
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AYES: Councilmembers Amezcua Bacerra Hernandez Lopez,
Penaloza, Phan, Vazquez (7)
NOES: Councilmembers None (0)
ABSTAIN: Councilmembers None (0)
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. 2025-041 to be the original resolution adopted by the City Council of the City of Santa
Ana on September 16, 2025.
a
Date:
n ifer
City Clerk
City of Santa
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PAGE INTENTIONALLY LEFT BLANK
Exhibit A
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CEQA Findings of Fact
and
Statement of Overriding Considerations
for
The Village Santa Ana Specific Plan Project
State Clearinghouse No. 2020029087
Lead Agency:
City of Santa Ana
20 Civic Center Plaza, M-20
Santa Ana,CA 92701
August 2025
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TABLE OF CONTENTS
SECTION PAGE NO.
CHAPTER 1 INTRODUCTION.....................................................................................................1-1
1.1 Statutory Requirements...............................................................................................1-1
1.2 Document Format........................................................................................................1-2
1.3 Location and Custodian of Record of Proceedings .....................................................1-3
CHAPTER 2 PROJECT SUMMARY............................................................................................2-1
2.1 Description of Project Proposed for Approval..............................................................2-1
2.2 Agreements, Permits, and Approvals..........................................................................2-2
2.3 Project Objectives........................................................................................................2-3
CHAPTER 3 ENVIRONMENTAL REVIEW AND PUBLIC PARTICIPATION...................................3-1
CHAPTER 4 NO ENVIRONMENTAL EFFECTS AND LESS THAN SIGNIFICANT ENVIRONMENTAL
EFFECTS WITHOUT MITIGATION MEASURES...........................................................................4-1
4.1 Aesthetics................................................................................ ..4-1
4.2 Agriculture and Forestry Resources............................................................................4-3
4.3 Air Quality....................................................................................................................4-4
4.4 Biological Resources...................................................................................................4-6
4.5 Cultural Resources......................................................................................................4-8
4.6 Energy................................................................................................. .4-10
4.7 Geology and Soils .....................................................................................................4-12
4.8 Greenhouse Gas Emissions......................................................................................4-13
4.9 Hazards and Hazardous Materials ............................................................................4-15
4.10 Hydrology and Water Quality.....................................................................................4-20
4.11 Land Use and Planning.............................................................................................4-25
4.12 Mineral Resources.....................................................................................................4-27
4.13 Noise .........................................................................................................................4-28
4.14 Population and Housing ............................................................................................4-29
4.15 Public Services..........................................................................................................4-30
4.16 Transportation ...........................................................................................................4-34
4.17 Utilities and Service Systems....................................................................................4-37
4.18 Wildfire.......................................................................................................................4-45
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CHAPTER 5 LESS-THAN-SIGNIFICANT ENVIRONMENTAL EFFECTS WITH MITIGATION
INCORPORATED...........................................................................................................I............5-1
5.1 Air Quality....................................................................................................................5-1
5.2 Cultural Resources......................................................................................................5-6
5.3 Geology and Soils .......................................................................................................5-8
5.4 Noise .........................................................................................................................5-13
5.5 Tribal Cultural Resources..........................................................................................5-16
CHAPTER 6 SIGNIFICANT AND UNAVOIDABLE ENVIRONMENTAL EFFECTS..........................6-1
6.1 Recreation ...................................................................................................................6-1
CHAPTER 7 FINDINGS REGARDING SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL
CHANGES...............................................................................................................................7-1
CHAPTER 8 FINDINGS REGARDING GROWTH-INDUCING IMPACTS........................................8-1
CHAPTER 9 FINDINGS REGARDING PROJECT ALTERNATIVES..............................................9-1
9.1 Discussion of Alternatives Considered but Rejected...................................................9-2
9.1.1 Buildout of the Zoning Designation Alternative ....................................................9-2
9.1.2 Off-Site Alternative...............................................................................................9-3
9.2 Alternatives Selected for Further Analysis...................................................................9-3
9.2.1 Alternative 1: No Project/No Build........................................................................9-4
9.2.2 Alternative 2: Reduced Project Alternative...........................................................9-5
9.2.3 Alternative 3: Reduced Project with No Subterranean Parking Alternative..........9-6
9.3 Environmentally Superior Alternative ..........................................................................9-7
CHAPTER 10 STATEMENT OF OVERRIDING CONSIDERATIONS............................................10-1
10.1 Introduction................................................................................................................10-1
10.2 Significant Unavoidable Impacts ...............................................................................10-2
10.3 Project Benefits .........................................................................................................10-2
10.4 Conclusion.................................................................................................................10-3
I
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CHAPTER 1
INTRODUCTION
These California Environmental Quality Act(CEQA) Findings of Fact and Statement of Overriding
Considerations are for The Village Santa Ana Specific Plan Project, herein referred to as the
"Project." The City of Santa Ana (lead agency) prepared a Supplemental Environmental Impact
Report (EIR) to the City's General Plan Update (GPU) Final Program EIR (GPU PEIR) (State
Clearinghouse No. 2020029087) for the Project. The GPU PEIR was certified by the City on April
19, 2022.
1.1 STATUTORY REQUIREMENTS
CEQA requires that a number of written findings be made by the lead agency in connection with
certification of an EIR prior to approval of a project pursuant to Sections 15091 and 15093 of the
State CEQA Guidelines and Section 21081 of the Public Resources Code (PRC). The State
CEQA Guidelines Section 15091 provides that:
(a) No public agency shall approve or carry out a project for which an EIR has been certified
which identifies one or more significant environmental effects of the project unless the
public agency makes one or more written findings for each of those significant effects,
accompanied by a brief explanation of the rationale for each finding. The possible findings
are:
(1) Changes or alterations have been required in, or incorporated into, the project which
avoid or substantially lessen the significant environmental effect as identified in the
EIR.
(2) Such changes or alterations are within the responsibility and jurisdiction of another
public agency and not the agency making the finding. Such changes have been
adopted by such other agency or can or should be adopted by such other agency.
(3) Specific 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.
In short, pursuant to State CEQA Guidelines sections 15091(a) and (b), CEQA requires that the
lead agency adopt mitigation measures or alternatives, where feasible, to avoid or mitigate
significant environmental impacts that would otherwise occur with implementation of a proposed
project. However, project mitigation or alternatives are not required, where they are infeasible or
where the responsibility for modifying a proposed project lies with another agency.
Pursuant to PRC Section 21081(b),when a lead agency approves a project with significant effects
that cannot be mitigated to a less-than-significant level, the public agency is required to find that
specific overriding economic, legal, social, technological, or other benefits of the proposed project
outweigh the significant effects on the environment. State CEQA Guidelines Section 15093(a)
states that:
If the specific economic, legal, social, technological, or other benefits... of a
proposed project outweigh the unavoidable adverse environmental effects, the
adverse environmental effects may be considered "acceptable."
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The Supplemental EIR for the Project is composed of the following elements:
• The Village Santa Ana Specific Plan Project Draft Supplemental EIR and Technical
Appendices (April 2025);
• The Village Santa Ana Specific Plan Project Final Supplemental EIR (August 2025); and
• Santa Ana General Plan Update Program Environmental Impact Report (GPU PEIR),
SCH No. 2020029087.
1.2 DOCUMENT FORMAT
The Findings of Fact is organized into the following sections:
Chapter 1: Introduction outlines the organization of this document and identifies the location
and custodian of the record of proceedings.
Chapter 2: Project Summary provides a summary of the Project, overview of the discretionary
actions required for approval of the Project, and a statement of the Project's objectives.
Chapter 3: Environmental Review and Public Participation Process provides a summary of
previous environmental reviews related to the Project area that took place prior to the
environmental review done specifically for the Project, and a summary of public participation in
the environmental review for the Project.
Chapter 4: No Environmental Effects and Less Than Significant Environmental Effects
without Mitigation Measure presents a summary of those environmental issue areas where no
impacts or less than significant impacts would occur and a corresponding finding adopting the
Initial Study and PEIR's conclusions of no impact or less than significant impacts.
Chapter 5: Less Than Significant Environmental Effects with Mitigation Incorporated
presents a summary of potentially significant environmental effects for which implementation of
identified feasible mitigation measures would avoid or substantially reduce the environmental
effects to less-than-significant levels and provides a corresponding finding for each effect. In order
to ensure compliance and implementation, all of these measures are included in the Mitigation
Monitoring and Reporting Program (MMRP)-for the Project and adopted as conditions of the
Project by the Lead Agency.
Chapter 6: Significant and Unavoidable Environmental Effects presents a summary of
significant and unavoidable effects for which there are no known feasible mitigation measures
that would avoid or substantially reduce the environmental effects to less-than-significant levels
and provides a corresponding finding for each effect.
Chapter 7: Findings Regarding Significant Irreversible Environmental Changes presents a
summary of the significant irreversible environmental changes that would occur should the Project
be implemented.
Chapter 8: Findings Regarding Growth-Inducing Impacts presents a summary of the growth-
inducing effects considered for the Project.
Chapter 9: Findings Regarding Project Alternatives presents a summary of the alternatives
considered for the proposed Project.
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Chapter 10: Statement of Overriding Considerations presents a summary of all of the
significant unavoidable adverse impacts associated with the implementation of the proposed
Project. In addition, this chapter identifies the proposed Project's substantial benefits that
outweigh and override the proposed Project's significant unavoidable impacts, such that the
impacts are considered acceptable.
1.3 LOCATION AND CUSTODIAN OF RECORD OF PROCEEDINGS
The documents and other materials that constitute the record of proceedings upon which the
City's Project approval is based are located at the City's Planning Division office at 20 Civic Center
Plaza, M-20, Santa Ana, CA 92701. The City's Planning Division is the custodian of the
administrative record for the project. Copies of these documents, which constitute the record of
proceedings, are and at all relevant times have been and will be available upon request at the
offices of the Planning Division Counter. The record of proceedings is provided in compliance with
PRC Section 21081.6(a)(2) and State CEQA Guidelines Section 15091(e).
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CHAPTER 2
PROJECT SUMMARY
2.1 DESCRIPTION OF PROJECT PROPOSED FOR APPROVAL
The Village Santa Ana Specific Plan Project would provide for redevelopment of the
approximately 17.2-acre site located on the northeast corner of West Sunflower Avenue and Bear
Street, transected by South Plaza Drive. The project site comprises seven parcels (Assessor's
Parcel Numbers 412-451-01 through -04 and 412-131-10, -20, -21 ((Project Site)). The Project
Site is currently occupied by the South Coast Plaza Village commercial center on both sides of
South Plaza Drive which consists of approximately 164,049 square feet of retail shops and
restaurants, offices, and the Regency Theatres cinema building. The City's GPU Land Use
Element designates the project site as District Center-High (DC-5) within the South Bristol Street
Focus Area (SBSFA). Development in the DC-5 designation is intended to provide urban retail,
residential, mixed-use, and employment centers. The Project Site is currently zoned as Specific
Development Plan No. 48 (SD-48)which was adopted in 1989 and was last amended in 1997.
The Project would redevelop the site with mixed-use commercial and residential, residential only,
and commercial only buildings. A central commercial area would include a variety of commercial
uses, such as restaurants, a market, and retail uses, with additional commercial uses extending
through the ground floor of adjacent residential buildings. Stand-alone residential and mixed-use
buildings would provide housing opportunities for residents in the City's SBSFA. In total, The
Project would include up to 1,583 residential units (encompassing approximately 1,850,000
square feet of building space), 80,000 square feet of retail space, 300,000 square feet of office
space, and approximately 7.5 acres of publicly accessible open space and common areas. The
Specific Plan includes a maximum height of 25 stories with a minimum of 1 story for
commercial/office only buildings and no minimum height for residential or mixed-use buildings.
Parking would be provided in tower and podium buildings and underground building levels with
up to four levels below grade.
At full buildout, the Project is anticipated to provide a combined 13.8 acres of public and private
outdoor and recreation space including approximately 7.5 acres of publicly accessible open space
and common areas and 6.3 acres of private outdoor and amenity spaces. Public open spaces at
the Project would consist of active spaces, outdoor seating, garden paseos, a fitness loop, and a
recreational lawn. Private open space amenities include outdoor balconies and patios, pools and
spas, outdoor kitchens, and communal gathering spaces. The proposed Project would also
include roadway and streetscape modifications and improvements along Sunflower Avenue, Bear
Street, and South Plaza Drive in addition to new access points throughout the project site and a
bicycle network which includes a new Class IV cycle track along Sunflower Avenue, and a new
Class I bike path along Bear Street.
Construction of the proposed Project is anticipated to begin January 2026 and could take up to
20 years to complete. Construction of the proposed Project would be implemented in a series of
five phases to reflect anticipated market conditions and to ensure that access, public facilities,
and infrastructure connections are appropriately installed to serve the Project. Demolition of the
entire Project Site would occur during the first phase of the construction period. Subsequently,
the construction period for each phase would generally include excavation, grading, trenching,
pile driving, installation of utilities, building construction, architectural coating, paving activities,
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and installation of landscaping and hardscape elements for the respective phase. The maximum
excavation would reach approximately 52 feet below grade where up to four levels of
subterranean parking are proposed. Approximately 420,000 cubic yards of total material would
be excavated and likely hauled away from the project site.
2.2 AGREEMENTS, PERMITS, AND APPROVALS
The following approvals and/or permits would be required to implement the proposed Project. The
environmental documentation for the proposed Project would be used to facilitate compliance with
federal, state, and local laws and ordinances, as well as granting permits by various federal, state,
and local agencies having jurisdiction over one or more aspects of the Project.
City of Santa Ana
• The Village Santa Ana Specific Plan adoption by ordinance by City Council
• Environmental Impact Report(E IR) certification in accordance with the California
Environmental Quality Act (CEQA) by resolution by City Council
• Development Agreement: A development agreement between the Applicant and the
City describing development rights and public benefits for the development pursuant
Government Code Section 65864 et seq. The Development Agreement will be
reviewed concurrently with the Village Santa Ana Specific Plan and requires adoption
by ordinance by City Council.
• Tentative Tract Map to create legal conveyable lots for project development, formalize
the parcel boundaries, and provide for public rights-of-way for project access. The
Tentative Tract Map will be reviewed concurrently with the Village Santa Ana Specific
Plan and requires adoption by resolution by City Council.
• Demolition, grading, and building permits
City of Costa Mesa
• Issuance of encroachment permits
Santa Ana Regional Water Quality Control Board
• National Pollutant Discharge Elimination System (NPDES) Construction General
Permit(Order No. 2022-0057-DWQ)
• Orange County MS4 Permit (Order R8-2009-0030, NPDES No. CAS618030, as
amended by Order No. R8-2010-0062)
• General Waste Discharge Requirements for Discharges to Surface Waters Resulting
from De Minimis Discharges or Groundwater Dewatering Operations, and/or
Groundwater Clean up/Remediation Operations at Sites within the Newport Bay
Watershed Permit(Order No. R8-2019-0061, NPDES No. CAG918002)
Federal Aviation Administration
• Form 7460-1, Notice of Actual Construction or Alteration
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Orange County Airport Land Use Commission
• Land use review
Orange County Transportation Authority(OCTA)
• Issuance of approvals associated with bus stop improvements and relocations
South Coast Air Quality Management District
• Issuance of any permits to construct or permits to operate
2.3 PROJECT OBJECTIVES
State CEQA Guidelines Section 15124(b) (Title 14, California Code of Regulations [CCR])
requires that the description of the project shall contain a statement of objectives sought by the
proposed project. The project objectives have been developed to incorporate the GPU objectives
and vision, including the GPU SBSFA objectives. The following are the proposed Project
objectives:
• Implements the vision and objectives established in the City of Santa Ana General Plan
for the South Bristol Street Focus Area as the City's southern gateway and part of the
South Coast Metro area by creating 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
following are based on the South Bristol Street Focus Area objectives:
o Capitalizes on the success of the South Coast Metro area;
o Introduces mixed-use urban villages and encourage experiential commercial uses
that are more walkable, bike friendly, and transit oriented; and,
o Provides for mixed-use opportunities while protecting adjacent, established low
density neighborhoods.
• Fosters a neighborly environment where residents can live, work, and recreate in a vibrant
village community.
• Anchors Santa Ana's South Bristol Street Focus Area as envisioned by the City, which is
to transform conventional auto-oriented shopping plazas into dynamic nodes of activity
that blend healthy living, working, shopping, and dining in a contemporary village
environment.
• Captures Orange County's indoor-outdoor lifestyle through attention to detail in the design
of buildings, selection of materials, infusion of nature in outdoor spaces, and the activities
offered in the Village.
• Builds on the foundation of this dynamic area through new experiences in food, fitness,
and artisan retail.
• Complements the successful South Coast Metro area with a diversity of new housing in a
jobs-rich environment.
• Attracts the innovative and start-up culture of Orange County and provides thoughtfully
designed spaces to create and showcase new offerings.
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• Complements and does not compete with the emerging business environment of
Downtown Santa Ana.
• Allows for the flexible redevelopment of the underutilized project site to provide a balanced
mix of residential, retail, recreation, and office 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 GPU.
• Develops high quality residential spaces that reflect modern lifestyles, while responding
to the vision of the GPU to help bring higher density housing into a jobs-rich area of the
City planned for growth, to facilitate balancing the City's jabs-housing ratio.
• Provides a positive contribution to the local economy through new capital investment, the
creation of new jobs, development of more commercial opportunities, attraction of
economic activity, and the expansion of the tax base.
+ Enhances alternative transportation activity by creating a walkable and bikeable mixed-
use development that links with existing facilities and transit services to encourage non-
automotive travel within the Specific Plan area and the local community.
• Improves existing infrastructure to support the Village Santa Ana Specific Plan consistent
with the General Plan conditions.
+ Provides a project that contributes to the creation of a vibrant urban core for the City by
providing vibrant and attractive community amenities, recreational and open space areas,
and gathering spaces that are directly accessible to residents and the community, and
takes advantage of the site's location within the South Coast Metro area.
• Provides on-site open space and community-serving recreational amenities recognizing
that this area of the City is currently identified as park-deficient by the GPU.
• Provides 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 Sunflower Avenue and Bear
Street.
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CHAPTER 3
ENVIRONMENTAL REVIEW AND PUBLIC
PARTICIPATION
In conformance with CEQA and the State CEQA Guidelines, the City of Santa Ana conducted an
extensive environmental review of the Project, which included a Draft Supplemental EIR and a
Final Supplemental EIR, including technical reports, along with a public review and comment.
period. The following is a summary of the City's environmental review of this 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
November 3, 2023 through December 4, 2023 pursuant to State CEQA Guidelines 15082.
The NOP was posted at the Orange County Clerk's Office on November 3, 2023. The
notice was published in the Orange County Register, available 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. 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 NOP public review period ran for 30 days. The City received response letters from
the State, regional and local public agencies, and interested parties. These comment
letters were included in Appendix A: Notice of Preparation and Scoping Comments of the
Draft Supplemental EIR.
• A duly-noticed scoping meeting for the Supplemental EIR was held on November 15,
2023, at 6:00 p.m. at the McFadden Institute of Technology located at 2701 South Raitt
Street in the City of Santa Ana to obtain information from the public as to issues that should
be addressed in the Supplemental EIR. The notice of a public scoping meeting was
included in the NOP distributed on November 3, 2023 and was published in the Orange
County Register and was sent to agencies, interested parties, and individuals who
requested to be notified of the Project.
• The Draft Supplemental EIR was distributed by the City of Santa Ana, which was made
available for a 52-day public review period (April 17, 2025 through June 9, 2025). 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 on April 17,
2025, at the Orange County Register, and posted at the Orange County Clerk's Office and
the State Clearinghouse (SCH) at the Governor's Office of Land Use and Climate
Innovation (LCI) on April 17, 2025. 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 Southwest Senior Center,
located at 2201 West McFadden Avenue, Santa Ana, CA 92704. The Draft Supplemental
EIR was also available for review and download via the following City website location and
CEQAnet web portal: hftps://www,santa-ana.org/the-village-santa-ana-specific-plan/ and
https://ceganet.opr.ca.gov/. Additionally, the NOA was published in the Orange County
Register.
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• The City received a total of eight comment letters on the Draft Supplemental EIR from
public agencies and organizations regarding the merits of the Project or questions
regarding the Project. The City prepared responses to all written comments. The
comments and responses are contained in Section 2, Responses to Comments, of the
Final Supplemental EIR. Additionally, the Final Supplemental EIR contains revisions to
the Draft Supplemental EIR and final Mitigation Monitoring and Reporting Program.
• In accordance with CEQA, the City provided written responses to the public agencies that
commented on the Draft Supplemental EIR at least 10 days prior to certification of the
Supplemental EIR.
• Pursuant to State CEQA Guidelines Section 15095, staff is directed as follows: a) copy of
the Final Supplemental EIR and CEQA Findings of Fact shall be retained in the Project
files; and b) copy of the Final Supplemental EIR and CEQA Findings of Fact shall be
provided to the Project applicant who is responsible for providing a copy of the same to all
CEQA "responsible" agencies.
• Hearings before the City Council were held following a recommendation from the Planning
Commission.
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CHAPTER 4
NO ENVIRONMENTAL EFFECTS AND LESS-THAN-
SIGNIFICANT ENVIRONMENTAL EFFECTS WITHOUT
MITIGATION MEASURES
Based on the Supplemental EIR,the Project would have no or less-than-significant environmental
effects for the specific areas associated with the topics identified below.
4.1 AESTHETICS
Threshold AE-1: The Project would not have a substantial adverse effect on a scenic vista.
Findings: The City finds that the Project would result in less than significant impacts to aesthetics
related to scenic vistas. (Draft Supplemental EIR, pp. 5-5 — 5-6.)
Explanation of the Rationale: The Project would include a mix of commercial and residential
development that would be at a greater intensity and density in both height and area, as compared
to existing conditions. However,the Project is not located within or near a scenic vista, as defined
by the City's GP Conservation Element. The Santa Ana River is located approximately 2.5 miles
to the west of the Project site; Santiago Creek is located approximately 4.6 miles north of the
Project site. The Project activities would be limited to the boundaries of the project site. Therefore,
the Project would not have a substantial adverse effect on a scenic vista. Impacts would be less
than significant. (Draft Supplemental EIR, pp. 5-5—5-6.)
Threshold AE-2: The Project would not substantially damage scenic resources, including,
but not limited to, trees, rock outcroppings, and historic buildings within a
state scenic highway.
Findings: The City finds that the Project would result in no impact to aesthetics related to scenic
resources within a state scenic highway. (Draft Supplemental EIR, p. 5-6.)
Explanation of the Rationale: The GPU PEIR states that no state scenic highways, eligible or
officially designated, traverse the City nor are located near the City. Though buildout consistent
with the GPU would lead to infill development and intensify the urban landscape, it would not
damage scenic resources, including rock outcroppings, trees, and historic buildings within state
scenic highways. There are no eligible or state designated scenic highways in the vicinity of the
Project site. Therefore, the Project would not impact scenic resources within a state scenic
highway, and there would be no impact. (Draft Supplemental EIR, p. 5-6.)
Threshold AE-3: The Project would not conflict with applicable zoning and other regulations
governing scenic quality.
Findings: The City finds that the Project would result in less than significant impacts to aesthetics
and would not conflict with applicable zoning and other regulations governing scenic quality. (Draft
Supplemental EIR, pp. 5-6--5-7.)
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Explanation of the Rationale: The Project site has a General Plan land use designation of DC-
5, which is intended to provide urban retail, residential, mixed-use, and employment centers with
an intensity of up to 5.0 floor area ratio and/or 125 dwelling units per acre, and a maximum height
of 25 stories. The Project would be consistent with this land use designation and development
standards, as it would include mixed-use commercial and residential buildings ranging up to 25
stories with an intensity of up to 5.0 floor area ratio and 125 dwelling units per acre. The Project
site is currently zoned as SD-48; however, the project's specific plan would replace SD-48 as the
zoning for The Village and would contain the development standards, permitted uses, and
administrative processes for future development at the Project site.
As the Project would be designed with a cohesive style that is compatible with its surrounding
development, the Project would support the existing visual character of the Project area,
Therefore, the Project would not conflict with applicable zoning and other regulations governing
scenic quality, and impacts would be less than significant. (Draft Supplemental EIR,
pp. 5-6-- 5-7.)
Threshold AE-4: The Project would not create a new source of substantial light or glare
which would adversely affect day or nighttime views in the area.
Findings: The City finds that the Project would result in less than significant impacts to aesthetics
related to light and glare. (Draft Supplemental EIR, pp. 5-7—5-8.)
Explanation of the Rationale: The Project would intensify development at the Project site both
horizontally and vertically, with a mix of residential, commercial, office, parking, and open space
uses. Thus, the Project would result in additional sources of light, such as building lighting,
landscape lighting, lighting along pedestrian pathways, security lighting, and parking lot lighting.
In addition, the Project would result in additional sources of glare due to light reflecting off parked
or traveling cars and building windows. However, the Project would utilize lighting that is typical
of the existing and surrounding developments. In addition, similar to development under the GPU,
the Project would be required to comply with the Title 24 Standards as amended by the Santa
Ana Municipal Code Chapter 8, Article Il and the City's Lighting Standards (Section 5 of the City's
Engineering Standards and Plans). In addition, the specific plan specifies implementation of the
exterior and landscape lighting design requirements. Therefore, because the Project would
comply with applicable regulations and implement lighting design criteria, the Project would not
adversely affect day or nighttime views in the area and impacts would be less than significant.
(Draft Supplemental EIR, pp. 5-7—5-8.)
Cumulative Impacts: The Project would not result in cumulative impacts concerning aesthetics.
Findings: The City finds that the Project would result in less than significant cumulative impacts
to aesthetics. (Draft Supplemental EIR, pp. 5-5 —5-8.)
Explanation of the Rationale: The Project is a mixed-use project located on an infill site. The
Project would include development that would be at a greater intensity and density in both height
and area, as well as additional sources of light, as compared to existing conditions. However, the
Project is not located within or near a scenic vista, would not substantially damage scenic
resources, and would be consistent with land use designation and development standards.
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Therefore, cumulative impacts related to aesthetics would be less than significant. (Draft
Supplemental EIR, pp. 5-5 —5-8.)
4.2 AGRICULTURE AND FORESTRY RESOURCES
Threshold AF-1: The Project would not convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance to nonagricultural uses.
Findings: The City finds that the Project would result in no impact to agriculture and forestry
resources related to the conversion of Prime Farmland, Unique Farmland, or Farmland of
Statewide Importance. (Draft Supplemental EIR, p. 5-8.)
Explanation of the Rationale: According to the California Department of Conservation's
California Important Farmland Finder mapping tool, the Project site and surrounding uses are
designated as "Urban and Built-Up Land." Therefore, no farmland exists on the Project site and
the Project would not convert farmland to non-agricultural use. (Draft Supplemental EIR, p. 5-8.)
Threshold AF-2: The Project would not conflict with existing zoning for agricultural use, or a
Williamson Act contract.
Findings: The City finds that the Project would result in no impact to agriculture and forestry
resources related to conflict with existing zoning for agricultural use, or a Williamson Act contract.
(Draft Supplemental EIR, p. 5-8)
Explanation of the Rationale: The Project site is zoned for Specific Development(SD-48),which
does not allow for agricultural use. Additionally, according to the California Department of
Conservation's California Williamson Act Enrollment Finder mapping tool, Orange County does
not have any land subject to a Williamson Act Contract. Therefore, the Project would not conflict
with existing zoning for agricultural use or with a Williamson Act contract. (Draft Supplemental
E I R, p. 5-8.)
ThresholdAF-3: The Project would not conflict with existing zoning for, or cause rezoning
of, forestland, timberland, or timberland zoned Timberland Production.
Findings: The City finds that the Project would result in no impact to agriculture and forestry
resources related to conflict with existing zoning for, or rezoning of, forestland, timberland, or
timberland zoned Timberland Production. (Draft Supplemental EIR, p. 5-9.)
Explanation of the Rationale: The City does not have any land designated or zoned for
forestland, timberland, or timberland zoned Timberland Production. The Project site is zoned for
Specific Development(SD-48), which does not allow for forestland or timberland uses. Therefore,
the Project would not conflict with existing zoning for forestland or timberland uses. (Draft
Supplemental EIR, p. 5-9.)
Threshold AF-4: The Project would not result in the loss of forestland or conversion of forest
land to non-forest use.
i
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Findings: The City finds that the Project would result in no impact to agriculture and forestry
resources related to the loss of forestland or conversion of forest land to non-forest use. (Draft
Supplemental EIR, p. 5-9.)
Explanation of the Rationale: The GPU PEIR states that the City does not have any land
designated or zoned for forestland. The Project site is currently developed with existing
commercial retail and surface parking lot uses and does not contain any forest land. Therefore,
the Project would not result in the loss of forest land or convert forest land to non-forest use. (Draft
Supplemental EIR, p. 5-9.)
Threshold AF-5: The Project would not involve other changes in the existing environment,
which, due to their location or nature, could result in conversion of
Farmland to nonagricultural use or conversion of forestland to non-
forest use.
Findings: The City finds that the Project would result in no impact to agriculture and forestry
resources related to other changes in the existing environment which could result in conversion
of Farmland to nonagricultural use or conversion of forestland to non-forest use. (Draft
Supplemental EIR, p. 5-9.)
Explanation of the Rationale: The City does not have any significant agricultural resources or
land designated or zoned for forestland, timberland, or timberland zoned Timberland Production.
The Project site and vicinity are designated as "Urban and Built-Up Land," and no farmland exists
on the Project site or surrounding uses. Therefore, the Project would not convert farmland or
forest land to non-agricultural or non-forest use. (Draft Supplemental EIR, p. 5-9.)
Cumulative Impacts: The Project would not result in cumulative impacts concerning agriculture
and forestry resources.
Findings: The City finds that the Project would result in no cumulative impacts concerning
agriculture and forestry resources. (Draft Supplemental EIR, pp. 5-8—5-9.)
Explanation of the Rationale: The City does not have any significant agricultural resources or
land designated or zoned for forestland, timberland, or timberland zoned Timberland Production.
Additionally, Orange County does not have any land subject to the Williamson Act Contract. The
Project site and vicinity are designated as "Urban and Built-Up Land," and no agriculture or
forestry resources exists on the Project site or surrounding uses. (Draft Supplemental EIR, pp. 5-
8-5-9.)
4.3 AIR QUALITY
ThresholdAQ-4: The Project would not result in other emissions, such as those leading to
odors, adversely affecting a substantial number of people.
Findings: The City finds that the Project would result in less than significant impacts to air quality
related to other emissions, such as odors. (Draft Supplemental EIR, pp. 4.1-47--4.1-48.)
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Additionally, the City finds that the Project will implement the following regulatory requirements
(Draft Supplemental EIR, p. 4.1-9):
RR AQ-2: Construction activities will be conducted in compliance with California Code of
Regulations, Title 13, Section 2449,which requires that nonessential idling of construction
equipment is restricted to five minutes or less.
RR AQ-3: Construction activities will be conducted in compliance with any applicable
South Coast Air Quality Management District rules and regulations, including but not
limited to:
• Rule 403, Fugitive Dust, for controlling fugitive dust and avoiding nuisance.
• Rule 402, Nuisance, which states that a project shall not "discharge from any
source whatsoever such quantities of air contaminants or other material which
cause injury, detriment, nuisance, or annoyance to any considerable number of
persons or to the public, or which endanger the comfort, repose, health or safety
of any such persons or the public, or which cause, or have a natural tendency to
cause, injury or damage to business or property."
• Rule 1113, which limits the volatile organic compound content of architectural
coatings.
• Rule 1466, Soil Disturbance. Projects that involve earth-moving activities of more
than 50 cubic yards of soil with applicable toxic air contaminants are subject to
this rule.
Explanation of the Rationale: Construction activities associated with the Project may generate
detectable odors from heavy-duty equipment exhaust and architectural coatings. However,
construction-related odors would be short-term in nature and cease upon completion of
construction activities. According to the Odor Complaints, Health Impacts, and Monitoring
Methods prepared for the California Air Resources Board, odors typically come from industrial
facilities, including wastewater treatment plants, municipal solid waste landfills, trash transfer
stations, composting facilities, animal agriculture, chemical and petroleum industries, and roadkill
collection facilities. The Project would not include any of these uses or odor sources. Because
the Project would include restaurants, there is the potential for uses within the immediate area to
experience odors associated with restaurant operations. However, the Project comply with
SCAQMD Rule 402 (Nuisance), which prohibits emission of any material that causes nuisance to
a considerable number of persons or endangers the comfort, health, or safety of any person.
Compliance with SCAQMD Rule 402 would ensure potential restaurant-related odors during
Project operation would not create objectionable odors affecting a substantial number of people,
and impacts related to odors during Project operation would be less than significant. (Draft
Supplemental EIR, pp. 4.1-47—4.1-48.)
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4.4 BIOLOGICAL RESOURCES
Threshold B-1: The Project would not have a substantial adverse effect, either directly or
through habitat modifications, on any species identified as a candidate,
sensitive, or special status species in local or regional plans, policies, or
regulations, or by the California Department of Fish and Wildlife or U.S.
Fish and Wildlife Service.
Findings: The City finds that the Project would result in less than significant impacts to biological
resources related to species identified as a candidate, sensitive, or special status species in local
or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or
U.S. Fish and Wildlife Service. (Draft Supplemental EIR, pp. 5-9—5-10.)
Explanation of the Rationale: The Project site is fully developed with existing commercial uses
and surface parking, and the surrounding area is heavily urbanized with residential and
commercial uses. The Project would involve infill development within an already highly disturbed
urban environment. The Project site includes limited, ornamental landscaping, including grass
lawns and trees. Due to the urbanized nature of the project site and surrounding area, there are
no natural, vegetated areas that could support candidate, sensitive, or special status species, or
habitat for such species. However, the existing trees on-site may provide habitat to nesting birds,
which are protected pursuant to the federal Migratory Bird Treaty Act of 1918 (MBTA) and the
California Fish and Game Code, The Project would comply with all applicable federal, state, and
local regulations including the MBTA and the California Fish and Game Code Section 3503, which
protect nesting birds and their eggs/young, To maintain compliance with the MBTA and California
Fish and Game Code, clearance surveys would be conducted prior to any ground disturbance or
vegetation removal activities to avoid direct or indirect impacts to active bird nests and/or nesting
birds if construction occurs during the nesting bird season. Therefore, the Project would not result
in direct impacts to special-status species identified as a candidate, sensitive, or special-status
species and impacts would be less than significant. (Draft Supplemental EIR, pp. 5-9 --5-10.)
Threshold B-2: The Project would not have a substantial adverse effect on any riparian
habitat or other sensitive natural community identified in local or regional
plans, policies, regulations or by the California Department of Fish and
Wildlife or U.S. Fish and Wildlife Service.
Findings: The City finds that the Project would result in no impact to biological resources related
to a substantial adverse effect on any riparian habitat or other sensitive natural community. (Draft
Supplemental EIR, pp. 5-10 —5-11.)
Explanation of the Rationale: The Project site is fully developed with commercial retail uses and
contains limited, ornamental landscaping. The ground cover consists primarily of paved,
developed areas and limited areas of vegetation, including trees and grass. There is no riparian
habitat or other sensitive natural communities within the Project site. Therefore, implementation
of the Project would not impact any riparian habitat or other sensitive natural community. (Draft
Supplemental EIR, pp. 5-10—5-11.)
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Threshold B-3: The Project would not have a substantial adverse effect on state or
federally protected wetlands (including, but not limited to, marsh, vernal
pool, coastal, etc.) through direct removal, filling, hydrological interruption,
or other means.
Findings: The City finds that the Project would result in no impact to biological resources related
to state or federally protected wetlands. (Draft Supplemental EIR, p. 5-11.)
Explanation of the Rationale: Based on a review of the U.S. Fish and Wildlife Service National
Wetlands Inventory, there are no wetlands within the Project site. Furthermore, no potential
jurisdictional drainages or wetland features were observed within Project site. The National
Wetlands Inventory identifies several wetland features in the Project vicinity. However, these
wetland habitats are engineered and man-made, and the Project would not impact these nearby
wetland features. Therefore, the Project would not have a substantial adverse effect on state or
federally protected wetlands, and no impact would occur. (Draft Supplemental EIR, p. 5-11.)
Threshold B-4: The Project would not interfere substantially with the movement of any
native resident or migratory fish or wildlife species or with established
native resident or migratory wildlife corridors, or impede the use of native
wildlife nursery sites.
Findings: The City finds that the Project would result in less than significant impacts to biological
resources related to interfering with the movement of any native resident or migratory fish or
wildlife species or with established native resident or migratory wildlife corridors, or impeding the
use of native wildlife nursery sites. (Draft Supplemental EIR, pp. 5-11 —5.12.)
Explanation of the Rationale: The Project site is located approximately 2.4 miles east of the
Santa Ana River, and 5.2 miles south of Santiago Creek. As such, the Project would not result in
impacts to either of these corridors. In addition, the Project site is not located within any wildlife
corridors, as it is fully developed and surrounded by urban land uses that provide minimal to no
opportunities for movement of wildlife. The Project would remove ornamental trees at the Project
site, which may provide suitable nesting habitat for birds protected under the META. To maintain
compliance with the MBTA and California Fish and Game Code Section 3503, clearance surveys
would be conducted prior to any ground disturbance or vegetation removal activities to avoid
direct or indirect impacts to active bird nests and/or nesting birds if construction occurs during the
nesting bird season. With compliance to the requirements of the MBTA, any direct or indirect
impacts on nesting birds would be reduced to a less than significant level. (Draft Supplemental
EIR, pp. 5-11 —5.12.)
Threshold B-5: The Project would not conflict with any local policies or ordinances
protecting biological resources, such as a tree preservation policy or
ordinance.
Findings: The City finds that the Project would result in less than significant impacts to biological
resources related to local policies or ordinances protecting biologics! resources, such as a tree
preservation policy or ordinance. (Draft Supplemental EIR, p. 5-12.)
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Explanation of the Rationale: The Project would remove a number of existing trees within the
rights-of-way. The Project would adhere to the following sections of the Municipal Code, which
contains codes that pertain to trees within parkways and rights-of-way: Section 33-191 Damaging
City Trees, Section 33-185 Street Tree Species to be Planted, and Section 33-188 Site Plan
Approval, as well as Article VI I, Regulation for the Planting, Maintenance, and Removal of Trees.
Therefore, the Project would not conflict with applicable tree policies. (Draft Supplemental EIR,
p. 5-12.)
Threshold B-6: The Project would not conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation Plan, or other
approved local, regional, or state habitat conservation plan.
Findings: The City finds that the Project would result in no impact to biological resources related
to conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local, regional, or state habitat conservation plan. (Draft
Supplemental EIR, p. 5-12.)
Explanation of the Rationale:The City of Santa Ana is not located within a Habitat Conservation
Plan or Natural Community Conservation Plan area. Therefore, the Project would not conflict with
applicable Habitat Conservation Plans or Natural Community Conservation Plans, and no impact
would occur. (Draft Supplemental EIR, p. 5-12.)
Cumulative Impacts: The Project would not result in cumulative impacts concerning biological
resources.
Findings: The City finds that the Project would result in less than significant cumulative impacts
to biological resources. (Draft Supplemental EIR, pp. 5-9—5-12.)
Explanation of the Rationale: The Project site is fully developed with existing commercial uses
and surface parking, and the surrounding area is heavily urbanized with residential and
commercial uses. The Project would involve infill development within an already highly disturbed
urban environment. The Project would result in no impacts related to sensitive natural
communities; federally protected wetlands; and conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or
state habitat conservation plan; and less-than-significant impacts related to candidate, sensitive,
or special status species; migratory fish or wildlife species or wildlife corridors; and conflict with
local policies or ordinances protecting biological resources.Therefore, cumulative impacts related
to biological resources would be less than significant. (Draft Supplemental EIR, pp. 5-9—5-12.)
4.6 CULTURAL RESOURCES
Threshold C-1: The Project would not cause a substantial adverse change in the
significance of a historical resource pursuant to Section 15064.5.
Findings: The City finds that the Project would result in no impact related to a substantial adverse
change in the significance of a historical resource. (Draft Supplemental EIR, pp. 4.2-13—4.2-14.)
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Explanation of the Rationale: A records search conducted for the Project indicated a total of
three cultural resources are documented within the half-mile search radius of the Project site.
However, none of these resources are located within or adjacent to the Project area, and no built
environment resources within the project area were identified in the Built Environment Resource
Directory. Additionally, the existing South Coast Village was evaluated for listing on the California
Register of Historical Resources in accordance with Section 15064.5(a)(2)-(3) of the State CEQA
Guidelines, and is recommended ineligible for listing in the California Register. Therefore, the
Project would not cause a substantial adverse change in the significance of a historical resource
and no impact would occur. (Draft Supplemental EIR, pp. 4.2-13--4.2-14.)
Threshold C-3: The Project would not disturb any human remains, including those interred
outside of dedicated cemeteries.
Findings: The City finds that the Project would result in less than significant impacts to cultural
resources related to human remains. (Draft Supplemental EIR, pp. 4.2-16—4.2-17.)
Additionally, the City finds that the Project will implement the following regulatory requirement
(Draft Supplemental EIR, p. 4.2-5):
RR CUL-1: California Health and Safety Code Section 7050.5 requires that if human
remains are discovered within the proposed project site, disturbance of the site shall halt
and remain halted until the coroner has investigated the circumstances, manner, and
cause of any death, and the recommendations concerning the treatment and disposition
of the human remains have been made to the person responsible for the excavation, or to
his or her authorized representative. If the coroner determines that the remains are not
subject to his or her authority and if the coroner recognizes or has reason to believe the
human remains to be those of a Native American, he or she shall contact, by telephone
within 24 hours, the Native American Heritage Commission.
Explanation of the Rationale: Sensitivity for buried human remains would be low at the Project
site, as the Project site does not contain cemeteries or known burial grounds, and past
construction activities have disturbed the entire property. However, as the Project would require
excavations that are anticipated to disturb a large part of the Project site at varying depths up to
a maximum depth of 52 feet for the subsurface parking garage, there is potential to encounter
previously unknown human remains. In the event that human remains are discovered, the
remains would be treated in accordance with California Health and Safety Code Section 7050.5
(RR CUL-1), State CEQA Guidelines Section 15064.5, and Public Resources Code Section
5097.98. Compliance with these regulations would ensure that impacts to human remains would
be less than significant. (Draft Supplemental EIR, pp. 4.2-16—4.2-17.)
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4.6 ENERGY
Threshold E-9: The Project would not result in potentially significant environmental impacts
due to wasteful, inefficient, or unnecessary consumption of energy
resources, during project construction or operation.
Findings: The City finds that the Project would result in no impact to energy related to wasteful,
inefficient, or unnecessary consumption of energy resources, during project construction or
operation. (Draft Supplemental EIR, pp. 4.3-11 —4.2-18.)
Additionally, the City finds that the Project will implement the following regulatory requirements
(Draft Supplemental EIR, p. 4.3-4):
RR E-1: Construction activities will be conducted in compliance with California Code of
Regulations Section 2485, which requires that nonessential idling of construction
equipment be restricted to five minutes or less.
RR E-2: At least 65 percent of all nonhazardous construction and demolition waste from
nonresidential construction associated with future development in the plan area shall be
recycled and/or salvaged for reuse in line with the 2016 California Green Building
Standards Code Section 5.408 (California Code of Regulations, Title 24, Part 11).
RR E-3: New buildings implemented as part of the General Plan Update are required to
achieve the current California Building Energy and Efficiency Standards (California Code
of Regulations, Title 24, Part 6) and California Green Building Standards Code (California
Code of Regulations, Title 24, Part 11).
RR E-4: Any appliances associated with development in the Plan Area shall meet the
requirements of the 2012 Appliance Efficiency Regulations.
RR E-b: Development under the General Plan Update shall support the goals of the
renewables portfolio standard, SB 350, and SB 100 to achieve a tiered increase in the use
of renewable energy to 60 percent by 2030, and 100 percent by 2045.
RR E-7: Development under the General Plan Update shall be in compliance with state
and local solid waste regulations including AB 939, AB 341, AB 1327, AB 1826, and
Section 5.408 of 2016 California Green Building Standards Code (California Code of
Regulations, Title 24, Part 11).
Explanation of the Rationale: The Project's annual average fuel consumption from gasoline
construction vehicle use during Phase 4 (phase with most gasoline consumption)would account
for 0.299 percent of the City's forecasted consumption of gasoline fuel and 0.029 percent of the
County's annual gasoline consumption. Additionally, the Project's annual average fuel
consumption from diesel construction equipment use during Phase 1 (phase with most diesel
consumption)would account for 0.166 percent of the City's forecasted consumption of diesel fuel
and 0.225 percent of the County's annual diesel consumption. As such, construction would have
a nominal effect on the local and regional energy supplies. Additionally, the Project would comply
with regulatory requirements, such as the 2022 CalGreen Code, USEPA Construction Equipment
Fuel Efficiency Standard, and California Code of Regulations Title 13, Sections 2449 and 2485.
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Therefore, construction fuel consumption would not be any more inefficient, wasteful, or
unnecessary than other similar development projects.
The Project's operational automotive transportation at full buildout is estimated to result in a net
increase that would account for 0.493 percent of the City and 0.053 percent of the County's
forecasted annual consumption of fuel for the buildout year of 2045. As such, the Project would
account for a nominal percentage of the forecasted annual operational automotive fuel
consumption for both the City and County and,thus,would have a nominal effect on the local and
regional energy supplies. The Project's operational energy consumption at full buildout would
result in a net increase of approximately 0.602 percent in electricity consumption and
approximately 0.309 percent in natural gas consumption of the City's consumption in for the
buildout year of 2045. The Project would also be required to comply with the most current and
applicable version of the Title 24 Building Energy Efficiency Standards and CALGreen Code.
Overall, the Project would account for a nominal energy consumption percentage of the City and
County's annual energy consumption. Therefore, the Project would not result in a significant
increase in construction and operational energy consumption. As such, impacts resulting from the
Project would be less than significant. (Draft Supplemental EIR, pp. 4.3-11 —4.2-18.)
Threshold E-2: The Project would not conflict with or obstruct a state or local plan for
renewable energy or energy efficiency.
Findings: The City finds that the Project would result in less than significant impacts to energy
related to conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
(Draft Supplemental EIR, pp. 4.3-19—4.3-23.)
Explanation of the Rationale: The Project.would comply with the State and regional plans for
renewable energy and energy efficiency. State and regional plans for renewable energy and
energy efficiency include the California Energy Commission's Integrated Energy Policy Report
and Title 24 standards, including the CALGreen Code. The Project would meet the most current
and latest Title 24 standards for energy efficiency and incorporate all applicable energy efficiency
measures (solar panels, high efficiency lighting, energy efficient appliances, etc.). Compliance
with Title 24 standards, including the CALGreen Code, would ensure the Project's consistency
with the Integrated Energy Policy Report building energy efficiency recommendations, which
would, in turn, ensure project conformance with the State's energy reduction goals. The Project
would also comply with applicable energy goals and policies in the GPU. As such, impacts
resulting from the Project related to consistency with adopted energy conservation plans or
state/local energy standards for renewable energy or energy efficiency would be less than
significant. (Draft Supplemental EIR, pp. 4.3-19 --4.3-23.)
Cumulative Impacts: The Project would not result in cumulative impacts concerning energy.
Findings: The City finds that the Project would result in less than significant cumulative impacts
related to energy. (Draft Supplemental EIR, pp. 4.3-24 --4.3-26.)
Explanation of the Rationale: The Project's electricity demand would not significantly increase
Southern California Edison's total electricity demand for its service population, and the Project's
natural gas demand would be nominal compared to SoCalGas' total natural gas demand for its
service population. The Project transportation fuel usage would represent a small percentage of
total fuel consumption within Orange County. In addition, the Project would not cause any new or
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additional significant cumulative impacts related to consistency with adopted energy conservation
plans or state/local energy standards for renewable energy or energy efficiency. Therefore,
cumulative impacts related to energy were determined to be less than significant. (Draft
Supplemental EIR, pp. 4.3-24—4.3-26.)
4.7 GEOLOGY AND SOILS
Threshold G-I(r): The Project would not directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury, or death involving rupture
of a known earthquake fault.
Findings: The City finds that the Project would result in less than significant impacts to geology
and soils related to rupture of a known earthquake fault. (Draft Supplemental EIR, p. 4.4-9.)
Additionally, the City finds that the Project will implement the following regulatory requirements
(Draft Supplemental EIR, pp. 4.4-3—4.4-4):
RR G-1: Every public agency enforcing building regulations must adopt the provisions of
the California Building Code (CBC), which is Title 24, Part 2 of the California Code of
Regulations. The most recent version is the 2019 CBC (effective January 1, 2020).1 The
CBC is updated every three years and provides minimum standards to protect property
and public safety by regulating the design and construction of excavations, foundations,
building frames, retaining walls, and other building elements to mitigate the effects of
seismic shaking and adverse soil conditions. The CBC also contains provisions for
earthquake safety based on factors including occupancy type, the types of soil and rock
on-site, and the strength of ground shaking with specified probability of occurring at a site.
RR G-2: Santa Ana Municipal Code, Chapter 8, Buildings and Structures. These codes
address grading standards, excavation, and fills. This also includes compliance with
regulations for unreinforced masonry structures in accordance with "Unreinforced
Masonry Law," found in California Government Code §§ 8875 et seq. The City of Santa
Ana Building Official may place additional requirements upon the construction of
infrastructure, buildings, and other improvements based on the findings from plan check,
soils testing, and geotechnical investigations.
Explanation of the Rationale: There are no known active faults located within or adjacent to the
Project site. The Project site is also not located within an Alquist-Priolo Fault Rupture Hazard
Zone. Therefore, the potential for primary ground rupture of a known earthquake fault is
considered very low at the Project site. Moreover, earthquake fault zones are existing
environmental conditions and the Project would not exacerbate the risk of earthquake faults.
Impacts related to rupture of a known earthquake fault would be less than significant. (Draft
Supplemental EIR, p. 4.4-9.)
Threshold G-9(iv): The Project would not directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury, or death
involving landslides.
Findings: The City finds that the Project would result in less than significant impacts to geology
and soils related to landslides. (Draft Supplemental EIR, p. 4.4-13).
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Explanation of the Rationale:The project site is not located within a zone of earthquake induced
landslide.Additionally, similar to the overall City topography, the project site is relatively flat; thus,
there would be no hazards related to slope stability. (Draft Supplemental EIR, p. 4.4-13)
Threshold G-2: The Project would not result in substantial soil erosion or the loss of topsoil.
Findings: The City finds that the Project would result in less than significant impacts to geology
and soils related to substantial soil erosion or the loss of topsoil. (Draft Supplemental EIR,
pp. 4.4-13—4.4-14).
Explanation of the Rationale: Construction of the Project would result in ground surface
disturbance during excavation and grading that could create the potential for erosion of soils to
occur. During construction, transport of sediments by stormwater runoff and wind would be
prevented through BMPs, such as implementation of Rule 403 dust control measures required by
the South Coast Air Quality Management District and a Storm Water Pollution Prevention Plan
for construction activities. In addition, the proposed addition of open space and expanded
landscaping would result in less impervious area compared to existing conditions, reducing the
potential for runoff and soil erosion. Therefore, with implementation of a project-specific Storm
Water Pollution Prevention Plan, associated BMPs during construction, and installation of
landscaping and open space to stabilize soils throughout the Project site, the Project would not
result in substantial soil erosion or the loss of topsoil and impacts would be less than significant.
(Draft Supplemental EIR, pp. 4.4-13—4.4-14.)
Threshold G-5: 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.
Findings: The City finds that the Project would result in no impact to geology and soils related to
the use of septic tanks or alternative wastewater disposal systems. (Draft Supplemental EIR,
p. 4.4-18.)
Additionally, the City finds that the Project will implement the following regulatory requirement
(Draft Supplemental EIR, p. 4.4-4):
RR G-3: Santa Ana Municipal Code Section 39-51 requires that all buildings or structures
within the city that require plumbing fixtures must be connected to a public sewer.
Explanation of the Rationale: The Project would not use septic tanks or alternative wastewater
disposal systems. Sanitary wastewater at the project site is handled through connections to the
existing sanitary sewer system. No impact would occur. (Draft Supplemental EIR, p. 4.4-18.)
4.8 GREENHOUSE GAS EMISSIONS
Threshold GHG-1: The Project would not generate greenhouse gas emissions, either directly
or indirectly, that may have a significant impact on the environment.
Findings: The City finds that the Project would result in less than significant impacts to
greenhouse gases emissions. (Draft Supplemental EIR, pp. 4.5-18—4.5-23.)
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Additionally, the City finds that the Project will implement the following regulatory requirement
(Draft Supplemental EIR, p. 4.5-7):
RR GHGA: New buildings are required to achieve the current California Building Energy
Efficiency Standards (Title 24, Part 6) and California Green Building Standards
(CALGreen) Code (Title 24, Part 11). The 2019 Building Energy Efficiency Standards
became effective January 1, 2020. The Building and Energy Efficiency Standards and
CALGreen are updated tri-annually.
RR GHG-2: Construction activities are required to adhere to California Code of
Regulations, Title 13, Section 2449, which restricts the nonessential idling of construction
equipment to five minutes or less.
RR GHG-3: New buildings are required to adhere to the California Green Building
Standards Code and Water Efficient Landscape Ordinance requirements to increase
water efficiency and reduce urban per capita water demand.
RR GHG-7: The California Green Building Standards Code (CALGreen) requires the
recycling and/or salvaging for reuse at minimum of 65 percent of the nonhazardous
construction and demolition waste generated during most "new construction" projects
(CALGreen Code §§ 4.408 and 5.408). Construction contractors are required to submit a
construction waste management plan that identifies the construction and demolition waste
materials to be diverted from disposal by recycling, reuse on the project, or salvaged for
future use or sale and the amount (by weight or volume).
Explanation of the Rationale: The net increase in emissions from the Project compared to
existing conditions is 1.40 MTCO2e per year. Compared to the GPU horizon year emissions per
service population of 3.5 MTCO2e per year, the Project would result in a less severe impact, The
Project would be consistent with the 2022 Scoping Plan, 2020-2045 RTPISCS, City of Santa Ana
General Plan, and the City's Climate Action Plan. As the Project is consistent with these GHG
reduction plans, the Project would also be consistent with the State's long-term goal to achieve
statewide carbon neutrality(zero-net emissions).Specifically,the Project would be consistent with
several GPU goals and policies that may reduce GHG emissions, including goals and policies
from the Conservation Element related to air quality and climate, energy resources, and water
resources, and those from the Mobility Element related to sustainable transportation design,
Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.5-18 —4.5-23.)
Threshold GHG-2: The Project would not conflict with an applicable plan, policy or regulation
adopted for the purpose of reducing the emissions of greenhouse gases.
Findings: The City finds that the Project would result in less than significant impacts to
greenhouse gases emissions related to conflict with an applicable plan, policy or regulation.
Additionally, the City finds that the Project will implement regulatory requirements RR GHG-1
through RR GHG-3 and RR GHG-7 (listed above). (Draft Supplemental EIR, pp. 4.5-23—4.5-34.)
Explanation of the Rationale: The Project's characteristics render it consistent with Statewide,
regional, and local climate change mandates, plans, policies, and recommendations. More
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specifically, the GHG plan consistency analysis provided above demonstrates that the Project
would comply with the regulations and GHG reduction goals, policies, actions, and strategies
outlined in the 2022 Scoping Plan, 2020-2045 RTP/SCS, and the City's GPU and Climate Action
Plan. Consistency with these plans would reduce the impact of the Project's incremental
contribution to GHG emissions. Accordingly, the Project would not conflict with any applicable
plan, policy, regulation, or recommendation adopted for the purpose of reducing GHG emissions.
Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.5-23—4.5-34.)
Cumulative Impacts: The Project would not result in cumulative impacts concerning greenhouse
gas emissions.
Findings: The City finds that the Project would result in less than significant cumulative impacts
concerning greenhouse gas emissions. Additionally, the City finds that the Project will implement
regulatory requirements RR GHG-1 through RR GHG-3 and RR GHG-7 (listed above). (Draft
Supplemental EIR, pp. 4.5-34—4.5-35.)
Explanation of the Rationale: 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. The Project would be consistent with the 2022 Scoping Plan,
the 2020-2045 RTPISCS,the City of Santa Ana General Plan, and the City's Climate Action Plan.
As the Project is consistent with these GHG reduction plans, the Project would also be consistent
with the State's long-term goal to achieve carbon neutrality (zero-net emissions). Impacts related
to the generation of GHGs and consistency with an applicable GHG plan would be less than
significant. Therefore, the Project's contribution to cumulative impacts related to GHGs would not
be cumulatively considerable. Impacts would be less than significant. (Draft Supplemental EIR,
pp. 4.5-34—4.5-35.)
4.9 HAZARDS AND HAZARDOUS MATERIALS
Threshold H 1: The Project would not create a significant hazard to the public or the
environment through the routine transport, use, or disposal of hazardous
materials.
Findings: The City finds that the Project would result in less than significant impacts to hazards
and hazardous materials related to routine transport, use, or disposal of hazardous materials.
(Draft Supplemental EIR, pp. 4.6-17—4.6-19.)
Additionally, the City finds that the Project will implement the following regulatory requirement
(Draft Supplemental EIR, p. 4.6-9):
RR HAZ-1: Hazardous materials and hazardous wastes will be transported to and/or from
projects developed under the General Plan Update in compliance with any applicable state
and federal requirements, including the U.S. Department of Transportation regulations
listed in the Code of Federal Regulations (Title 49, Hazardous Materials Transportation
Act); California Department of Transportation standards; and the California Occupational
Safety and Health Administration standards.
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RR HAZ-2: Hazardous waste generation, transportation, treatment, storage, and disposal
will be conducted in compliance with Subtitle C of the Resource Conservation and
Recovery Act(Code of Federal Regulations,Title 40, Part 263), including the management
of nonhazardous solid wastes and underground tanks storing petroleum and other
hazardous substances. The projects developed under the General Plan Update will be
designed and constructed in accordance with the regulations of the Orange County Health
Care Agency, Environmental Health Division, which serves as the designated Certified
Unified Program Agency.
RR HAZ-4: Demolition activities that have the potential to expose construction workers
and/or the public to asbestos-containing materials or lead-based paint will be conducted
in accordance with applicable regulations, including, but not limited to:
• South Coast Air Quality Management District's Rule 1403
• California Health and Safety Code (Section 39650 et seq.)
• California Code of Regulations (Title 8, Section 1529)
• California Occupational Safety and Health Administration regulations (California
Code of Regulations, Title 8, Section 1629 [Asbestos] and Section 1532.1 [Lead])
• Code of Federal Regulations (Title 40, Part 61 [asbestos], Title 40, Part 763
[asbestos], and Title 29, Part 1926 [asbestos and lead])
RR HAZ-5: The removal of hazardous materials, such as polychlorinated biphenyls
(PCBs), mercury-containing light ballast, and mold, will be completed in accordance with
applicable regulations pursuant to 40 CFR 761 (PCBs), 40 CFR 273 (mercury-containing
light ballast), and 29 CFR 1926 (molds) by workers with the hazardous waste operations
and emergency response (HAZWOPER) training, as outlined in 29 CFR 1910.120 and 8
CC 5192.
RR HAZ-6: New construction, excavations, and/or new utility lines within 10 feet or
crossing existing high-pressure pipelines, natural gas/petroleum pipelines, or electrical
lines greater than 60,000 volts will be designed and constructed in accordance with the
California Code of Regulations (Title 8, Section 1541).
Explanation of the Rationale: The existing buildings on the project site were constructed
between 1971 and 1973 and it is likely that the building materials contain asbestos-containing
materials (ACMs), lead-based paint, and polychlorinated biphenyls. Surveys, testing, and
abatement would be required prior to demolition of the existing buildings, in addition to proper
removal and disposal, and would be conducted in accordance with the existing SCAQMD Rule
1403, California Occupational Safety and Health Administration, and California Health and Safety
Code. With compliance with relevant regulations and requirements, project construction activities
would not expose people to a substantial risk resulting from the release of hazardous materials
into the environment. impacts would be less than significant.
During operation, the .Project would include use, storage, and disposal of hazardous materials
typically associated with residential and commercial uses, including restaurants and retail stores.
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However, as with Project construction, all hazardous materials used on the Project site during
operation would be used, stored, and disposed of in accordance with manufacturer's standards
and all applicable federal, state, and local requirements. Therefore, with compliance with
manufacturer's standards and all applicable local, state, and federal laws and regulations relating
to environmental protection and the management of hazardous materials, impacts associated
with the routine transport, use, or disposal of hazardous materials during operation of the Project
would be less than significant. (Draft Supplemental EIR, pp. 4.6-17—4.6-19.)
Threshold H-2: The Project would not create 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.
Findings: The City finds that the Project would result in less than significant impacts to hazards
and hazardous materials related to reasonably foreseeable upset and accident conditions
involving the release of hazardous materials into the environment. Additionally, the City finds that
the Project will implement regulatory requirements RR HAZ-1, RR HAZ-2; RR HAZ-4 through RR
HAZ-6 (listed above). (Draft Supplemental EIR, pp. 4.6-19—4.6-20.)
Explanation of the Rationale: The Phase I Environmental Site Assessment conducted for the
Project revealed no evidence of Recognized Environmental Conditions (RECs) and/or Controlled
Recognized Environmental Conditions (CRECs) in connection with the Project site. In the event
that hazardous materials are found on-site during construction activities, materials would be
removed in accordance with procedural requirements and regulations for the proper removal and
disposal. With compliance with relevant regulations and requirements, Project construction
activities would not expose people to a substantial risk resulting from the reasonably foreseeable
upset and accident conditions involving the release of hazardous materials into the environment.
Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.6-19—4.6-20.)
Threshold H-3: The Project would not emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste within one-quarter mile
of an existing or proposed school.
Findings: The City finds that the Project would result in no impacts related to hazards and
hazardous materials within one-quarter mile of an existing or proposed school. Additionally, the
City finds that the Project will implement regulatory requirements RR HAZ-1, RR HAZ-2; RR HAZ-
4 through RR HAZ-6 (listed above). (Draft Supplemental EIR, pp. 4.6-20—4.6-21.)
Explanation of the Rationale: There are no schools within one-quarter mile of the Project site.
The closest school to the Project site is California Pacific Charter Schools, located approximately
0.3 mile to the southwest. No impacts would occur. (Draft Supplemental EIR, pp.4.6-20—4.6.21.)
Threshold H-4: The Project would not be located on a site which 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.
Findings: The City finds that the Project would result in no impacts to hazards and hazardous
materials related to hazardous materials sites pursuant to Government Code Section 65962.5.
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Additionally, the City finds that the Project will implement regulatory requirements RR HAZ-1, RR
HAZ-2; RR HAZ-4 through RR HAZ-6 (listed above). (Draft Supplemental EIR,
pp. 4.6-21 —4.6-22.)
Explanation of the Rationale: The Project site is not included on any hazardous waste site lists
included in the Department of Toxic Substances Control's EnviroStor database, which includes
CORTESE sites and the Environmental Protection Agency's database of regulated facilities, or
other lists compiled pursuant to Section 65962.5 of the Government Code. No impacts would
occur. (Draft Supplemental EIR, pp. 4.6-21 —4.6-22.)
Threshold H 5: The Project would not result in a safety hazard or excessive noise for
people residing or working in the project area within two miles of a public
airport or public use airport.
Findings: The City finds that the Project would result in no impacts to hazards and hazardous
materials related to airports. (Draft Supplemental EIR, pp. 4.6-22—4.6-23.)
Additionally, the City finds that the Project will implement regulatory requirements RR HAZ-1, RR
HAZ-2; RR HAZ-4 through RR HAZ-7 (listed above) and the following regulatory requirement
(Draft Supplemental EIR, p. 4.6-9):
RR HAZ-7: Development will be designed and constructed in accordance with the airport
environs land use plan for John Wayne Airport. Building height restrictions, as specified in
the airport environs land use plan, would apply in the city.
Explanation of the Rationale; The Project site is located approximately 1.5 miles northwest of
Santa Ana Airport(SNA) and outside any SNA Safety Compatibility Zones(including the Runway
Protection Zones) and the 60 dbA CNEL noise contours. Therefore, the Project would not result
in a safety hazard or excessive noise for people residing or working in the Project area. Further,
the Project site is located within the Airport Environs Land Use Plan Notification Area for SNA,
which includes the Federal Aviation Regulations Part 77 Notification Area. The Project is required
to be submitted to the Federal Aviation Agency (FAA) and the Orange County Airport Land Use
Commission for aeronautical review. Upon completion of the review process, the project would
not result in a safety hazard or excessive noise for people residing or working in the Project area.
No impact would occur. (Draft Supplemental EIR, pp. 4.6-22 —4.6-23.)
Threshold H-6: The Project would not impair implementation of or physically interfere with
an adopted emergency response plan or emergency evacuation plan.
Findings: The City finds that the Project would result in less than significant impacts to hazards
and hazardous materials related to an adopted emergency response plan or emergency
evacuation plan. Additionally, the City finds that the Project will implement regulatory
requirements RR HAZ-1, RR HAZ-2; RR HAZ-4 through RR HAZ-7 (listed above). (Draft
Supplemental EIR, pp. 4.6-23—4.6-24.)
Explanation of the Rationale:The Project would introduce new residential units, retail, and office
uses to a site that currently only includes retail uses. During construction of the Project, while it is
expected that the majority of construction activities would be confined to the Project site, limited
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off site construction activities may occur in adjacent street rights-of-way intermittently,which could
potentially require partial, temporary lane closures. However, if temporary lane closures are
necessary, the remaining travel lanes would remain open in accordance with standard traffic
control plans that would be submitted to and reviewed by the City's Public Works Agency
Development Engineering staff,which would ensure adequate circulation and emergency access.
Upon completion of construction activities, all travel lanes would be restored to pre-
existing conditions.
Operation of the Project would generate traffic in the Project site vicinity and would result in some
modifications to the Project site's access. However, public and private roadways throughout the
Project site would be designed to accommodate emergency vehicles for fire, ambulance, and
police services. The roadways would not have restricted access such as gates that would prevent
emergency vehicles from reaching the intended destinations. Roadway improvements and new
roadway construction would be constructed in accordance with the Orange County Fire Authority
standards and code requirements. Therefore, the Project would not physically interfere with or
impair the implementation of the City's emergency response plan. Impacts would be less than
significant. (Draft Supplemental EIR, pp. 4.6-23 —4.6-24.)
Threshold H-7: The Project would not expose people or structures, either directly or
indirectly,to a significant risk of loss, injury or death involving wildland fires.
Findings: The City finds that the Project would result in no impacts to hazards and hazardous
materials related to wildland fires. Additionally, the City finds that the Project will implement
regulatory requirements RR HAZ-1, RR HAZ-2; RR HAZ-4 through RR HAZ-7 (listed above).
(Draft Supplemental EIR, pp. 4.6-24.)
Explanation of the Rationale: The Project site is located in an urban, developed area within the
City and is surrounded by commercial and multi-family residential uses. No wildlands occur within
or near the Project site. No impacts related to risk of wildland fires would occur. (Draft
Supplemental EIR, p. 4. 6-24.)
Cumulative Impacts: The Project would not result in cumulative impacts concerning hazards and
hazardous materials.
Findings: The City finds that the Project would result in less than significant cumulative impacts
concerning hazards and hazardous materials. Additionally, the City finds that the Project will
implement regulatory requirements RR HAZA, RR HAZ-2; RR HAZ-4 through RR HAZ-7 (listed
above). (Draft Supplemental EIR, pp. 4.6-25—4.6-26.)
Explanation of the Rationale: As with the Project, related projects would require evaluation for
potential threats to public safety, including those associated with the use,storage, and/or disposal
of hazardous materials and would be required to comply with all applicable local,state,and federal
laws, rules and regulations. Because environmental safety issues are largely site-specific, this
evaluation would occur on a case-by-case for each individual project affected, in conjunction with
development proposals on these properties. The Project would result in less than significant
impacts related to hazards and hazardous materials. Therefore, the Project's impacts related to
hazards and hazardous materials would not be cumulatively considerable, and cumulative
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impacts to hazards and hazardous materials would be less than significant. (Draft Supplemental
EIR, pp. 4.6-25—4.6-26.)
4.10 HYDROLOGY AND WATER QUALITY
Threshold HYD-1: The Project would not violate any water quality standards or waste
discharge requirements or otherwise substantially degrade surface or
ground water quality.
Findings: The City finds that the Project would result in less than significant impacts to hydrology
and water quality related to water quality standards or waste discharge requirements violations.
(Draft Supplemental EIR, pp. 4.7-11 —4.7-14.)
Additionally, the City finds that the Project will implement the following regulatory requirement
(Draft Supplemental EIR, pp. 4.7-5—4.7-6):
RR HYD-1: All development pursuant to the General Plan Update shall comply with the
requirements of the Construction General Permit (Order No. 2022-0057-DWQ) for
stormwater discharges associated with construction activity. Compliance requires filing a
Notice of Intent, a Risk Assessment, a Site Map, a Storm Water Pollution Prevention Plan
and associated best management practices, an annual fee, and a signed certification
statement.
RR HYD-4: All development pursuant to the General Plan Update shall comply with the
requirements of the Orange County MS4 Permit (Order R8-2009-0030, NPDES No.
CAS618030, as amended by Order No. R8-2010-0062). The MS4 Permit requires new
development and redevelopment projects to:
• Control contaminants into storm drain systems
• Educate the public about stormwater impacts
• Detect and eliminate illicit discharges
• Control runoff from construction sites
• Implement best management practices and site-specific runoff controls and
treatments for new development and redevelopment
RR HYD-5: All development pursuant to the General Plan Update shall comply with the
requirements detailed in Chapter 18 Article IV of the Santa Ana Municipal Code.
Explanation of the Rationale: Construction activities associated with the Project have the
potential to result in the conveyance of soils and other pollutants due to soil erosion during grading
and soil stockpiling and subsequent siltation into municipal storm drains. However, construction
activities would comply with requirements of the Construction General Permit(as required by RR
HYD-1), including a project specific SWPPP and associated best management practices (BMPs).
Construction dewatering discharges would comply with the requirements of the Santa Ana
RWQCB's Groundwater Discharge Permit, which requires sampling and treatment measures as
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necessary to ensure groundwater discharges would not contain high levels of pollutants.
Therefore, with compliance to the Construction General Permit and Groundwater Discharge
Permit, the Project would not violate water quality standards or waste discharge requirements or
otherwise substantially degrade surface or groundwater during construction, and construction-
related impacts would be less than significant.
The Project's storm drain network would be designed to match existing drainage and flow patterns
to best utilize the capacities available in the existing public storm drain system. The Project would
follow the requirements of the local MS4 Permit, as required by RR HYD-4, and the Orange
County Technical Guidance Document and incorporate post-construction BMPs and low impact
development(LID) measures in its project-specific water quality management plan (WQMP). The
Project's WQMP must be reviewed and approved by the City to ensure it complies with the local
MS4 Permit and Orange County DAMP regulations. Therefore, with incorporation of typical post-
construction BMPs and LID measures and adherence to applicable permits, the Project would not
violate water quality standards or waste discharge requirements or otherwise substantially
degrade surface or groundwater during operation, and operational impacts would be less than
significant. (Draft Supplemental EIR, pp. 4.7-11 —4.7-14.)
Threshold HYD-2: The Project would not substantially decrease groundwater supplies or
interfere substantially with groundwater recharge such that the project may
impede sustainable groundwater management of the basin.
Findings: The City finds that the Project would result in less than significant impacts to hydrology
and water quality related to groundwater.Additionally,the City finds that the Project will implement
regulatory requirements RR HYD-1; RR HYD-4; and RR HYD-5 (listed above). (Draft
Supplemental EIR, pp. 4.7-14--4.7-15.)
Explanation of the Rationale: Construction of the Project would require dewatering activities
due to the Projects excavation for the proposed subterranean parking. However, dewatering
activities would be temporary and would not substantially decrease groundwater supplies.
Additionally, the Project would add a projected 339 acre-feet per year(AFY) of water demand in
the current year, which is approximately 1 percent of overall City water demand. The City would
have sufficient supply to meet the current and projected demand of the Project during normal,
single-dry, and multiple-dry years. In single-dry and multiple-dry years, thus, the Project would
not substantially decrease groundwater supplies. Further, because the Project site is already
developed with paved surfaces, development of the Project would not interfere with groundwater
recharge. Therefore, the Project would not substantially decrease groundwater supplies or
interfere substantially with groundwater recharge. Impacts would be less than significant. (Draft
Supplemental EIR, pp. 4.7-14—4.7-15.)
Threshold HYD-3ffl: 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: result in substantial erosion or siltation on- or off-site.
Findings: The City finds that the Project would result in less than significant impacts to hydrology
and water quality related to substantial erosion or siltation. Additionally, the City finds that the
Project will implement regulatory requirements RR HYD-1; RR HYD-4; and RR HYD-5 (listed
above). (Draft Supplemental EIR, pp. 4.7-16—4.7-17.)
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Explanation of the Rationale: Construction of the Project would require demolition of the existing
building structures, including foundations, floor slabs, and utilities systems and excavation for
subterranean parking structures which could temporarily alter the existing drainage pattern of the
site and could result in flooding on- or offsite. However, drainage would be controlled because
the Project would comply with the Construction General Permit and Groundwater Discharge
Permit.With adherence to the applicable permits and implementation of a project-specific SWPPP
and associated BMPs, construction of the project would not substantially alter the existing
drainage pattern of the site or area in a manner which would result in substantial erosion or
siltation on- or off-site.
The Project's grading and storm drain network would be designed to match existing drainage and
flow patterns and would integrate bio-filtration methods, pervious surfaces, and selective plant
materials to encourage on-site water retention. The Project would incorporate BMPs and LID
measures following the local MS4 Permit requirements (RR HYD-4) and Orange County
Technical Guidance Document; comply with the Santa Ana Municipal Code (RR HYD-5) and the
Construction General Permit (RR HYD-1); and prepare a WQMP to reduce impacts related to
erosion or siltation. Therefore, the Project would not substantially alter the existing drainage
pattern of the site or area in a manner which would result in substantial erosion or siltation on- or
off-site. Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.7-16--4.7-17.)
Threshold HYD-3(ii): 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 off-site.
Findings: The City finds that the Project would result in less than significant impacts to hydrology
and water quality related to flooding from surface runoff.Additionally,the City finds that the Project
will implement regulatory requirements RR HYD-1; RR HYD-4; and RR HYD-5 (listed above).
(Draft Supplemental EIR, pp. 4.7-17—4.7-18.)
Explanation of the Rationale: As previously discussed, the Project would adhere to the
applicable permits and implementation of a project-specific SWPPP and associated BMPs.
Therefore, construction of the Project would not substantially alter the existing drainage pattern
of the site or area in a manner which would result in substantial erosion or siltation on- or off-site.
Due to the high podium building drainage demand and the presence of multiple subterranean
garage entrances, on-site drainage systems would be sized to contain the 100-year storm
hydraulic grade line below the proposed finished surface to address the existing ponding issues.
The Project's grading and storm drain network design would ensure surface runoff, including
ponding water at the public driveways, would not result in flooding on-and off-site. Impacts would
be less than significant. (Draft Supplemental EIR, pp. 4.7-17—4.7-18.)
Threshold HYD-3(N): 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.
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Findings: The City finds that the Project would result in less than significant impacts to hydrology
and water quality related to stormwater drainage. Additionally, the City finds that the Project will
implement regulatory requirements RR HYD-1; RR HYD-4; and RR HYD-5 (listed above). (Draft
Supplemental EIR, pp. 4.7-19—4.7-20.)
Explanation of the Rationale: As previously discussed, the Project would adhere to applicable
permits (e.g., Construction General Permit and Santa Ana RWQCB's Groundwater Discharge
Permit, if necessary) and implement a project-specific SWPPP and associated BMPs; therefore,
construction of the Project would not substantially alter the existing drainage pattern of the site or
area in a manner which would result in substantial runoff water or polluted runoff.
The Project grading and storm drain network would be designed to match the existing drainage
and flow patterns to best utilize the capacities available in the existing public storm drain system
and may use underground detention systems and/or on-site drainage systems to contain excess
flows. The Project site would be required to implement bio-filtration as the primary water quality
treatment method. During each phase of Project development, the associated localized drainage
and water quality systems dedicated to each building site would be confirmed during the design
permitting phase with the City and constructed with each building before connecting to the on-site
backbone storm drain system. Therefore, the Project would not create or contribute runoff water,
including ponding water, which would exceed the capacity of existing or planned stormwater
drainage systems or provide substantial additional sources of polluted runoff. Impacts would be
less than significant. (Draft Supplemental EIR, pp. 4.7-19—4.7-20.)
Threshold HYD-3(iv): 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.
Findings: The City finds that the Project would result in less than significant impacts to hydrology
and water quality related to flood flows. Additionally, the City finds that the Project will implement
regulatory requirements RR HYD-1; RR HYD-4; and RR HYD-5 (listed above). (Draft
Supplemental EiR, pp. 4.7-20—4.7-21.)
Explanation of the Rationale:As discussed previously,with adherence to the applicable permits
(e.g., Construction General Permit and Santa Ana RWQCB's Groundwater Discharge Permit, if
necessary), implementation of a project-specific SWPPP and associated BMPs, construction of
the Project would not substantially alter the existing drainage pattern of the site or area in a
manner which would impede or redirect flood flows. Additionally, the Project site is not located
within a Special Flood Hazard Area, defined as the area that will be inundated by the base flood
or 100-year flood. Therefore, the potential for Project facilities to impede or redirect flood flows is
considered low. Impacts would be less than significant. (Draft Supplemental
EIR, pp. 4.7-20—4.7-21.)
Threshold HYD-4: The Project would not, in flood hazard, tsunami, or seiche zones, risk
release of pollutants due to project inundation.
Findings:The City finds that the Project would result in less than significant impacts to hydrology
and water quality related to flood hazard, tsunami, or seiche zones. Additionally, the City finds
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that the Project will implement regulatory requirements RR HYD-1; RR HYD-4; and RR HYD-5
(listed above). (Draft Supplemental EIR, pp. 4.7-21 —4.7-22.)
Explanation of the Rationale: The Project site is not located within a Special Flood Hazard Area
and the risk of flood hazard is low. Tsunamis affect low-lying areas along the coastline. As the
Project site is located approximately 6 miles from the coastline, the risk of tsunami hazard is low.
The Project site is within the inundation area of the Santiago Creek and the Prado Dam. However,
as stated in the GPU PEIR, the USACE and DSOD have ongoing assessments and measures to
certify dam efficiencies, and Santiago Creek and Prado Dam are required to maintain EAPs,
which would help minimize property damage and loss of life in emergency conditions. Therefore,
the risk of project inundation is low. Impacts would be less than significant. (Draft Supplemental
EIR, pp. 4.7-21 —4.7-22.)
Threshold HYD-5: The Project would not conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater management plan.
Findings: The City finds that the Project would result in less than significant impacts to hydrology
and water quality related to conflict with a water quality control plan or sustainable groundwater
management plan. Additionally, the City finds that the Project will implement regulatory
requirements RR HYD-1; RR HYD-4; and RR HYD-5 (listed above). (Draft Supplemental EIR,
pp. 4.7-22—4.7-23.)
Explanation of the Rationale: The Project would adhere to the requirements of the Construction
General Permit, Orange County MS4 Permit, and the City's Municipal Code as required by RR
HYD-1, HYD-4, and HYD-5, to reduce impacts to surface and groundwater quality. Water supply
for the Project would be provided by connections to the existing City utility infrastructure and not
by groundwater wells.The project's projected water demand would be sufficiently accommodated
by the City's water supply.Therefore,the Project would not obstruct or conflict with a water quality
control plan or sustainable groundwater management plan. Impacts would be less than
significant. (Draft Supplemental EIR, pp. 4.7-22—4.7-23.)
Cumulative Impacts: The Project would not result in cumulative impacts concerning hydrology
and water quality.
Findings: The City finds that the Project would result in less than significant cumulative impacts
concerning hydrology and water quality. Additionally, the City finds that the Project will implement
regulatory requirements RR HYD-1; RR HYD-4; and RR HYD-5 (listed above). (Draft
Supplemental EIR, pp. 4.7-23 --4.7-25.)
Explanation of the Rationale:
Similar to the Project, construction activities associated with GPU buildout and the related projects
have the potential to convey soils and other pollutants into municipal storm drains. During
operation of these projects, stormwater runoff from project sites could introduce or increase
pollutants that could runoff into municipal storm drains. However, as with the Project, projects
developed pursuant to the GPU and the related projects within the watersheds would be required
to implement water quality control measures pursuant to the NPDES General Construction
Permit, such as implementation of a SWPPP (for projects disturbing greater than one acre), a
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WQMP (for development and redevelopment projects), and BMPs to eliminate or reduce the
discharge of pollutants in stormwater discharges, reduce runoff, reduce erosion and
sedimentation, and increase filtration and infiltration.The NPDES permit requirements have been
set by the SWRCB and implemented by the RWQCB and the Orange County DAMP to reduce
incremental effects of individual projects so that they would not result in significant
cumulative impacts.
Additionally, the projected water demand from the GPU at buildout, which includes the Project, is
well within the projected total water demand for 2040 in the 2015 Urban Water Management Plan
for normal, dry year, and multiple dry year scenarios. Additionally, as the other related projects in
the cities of Irvine and Costa Mesa are within the OC Basin, it is assumed that the projected total
water demand for 2040 in the 2015 Urban Water Management Plan for normal, dry year, and
multiple dry year scenarios would be sufficient for the related projects. Further, mandatory
compliance with each city's Municipal Code would ensure that buildout of the GPU, the related
projects, and the Project would result in less than significant cumulative impacts related to
flood hazards.
Therefore, the Project's contribution to cumulative impacts related to hydrology and water quality
would not be cumulatively considerable. Impacts would be less than significant. (Draft
Supplemental EIR, pp. 4.7-23—4.7-25.)
4.11 LAND USE AND PLANNING
Threshold LU-1: The Project would not physically divide an established community.
Findings: The City finds that the Project would result in less than significant impacts to land use
and planning related to physically dividing an established community. (Draft Supplemental EIR,
pp. 4.8-20 —4.8-21.)
Additionally, the City finds that the Project will implement the following regulatory requirement
(Draft Supplemental EIR, pp. 4.8-8—4.8-9):
RR LU-1: Development associated with the General Plan Update would be designed and
constructed in accordance with the applicable provisions of Chapter 41 (Zoning) of the
City of Santa Ana Municipal Code. Development within specific plan areas, overlay areas,
and specific development districts would implement zoning and development standards
that are applicable within these subareas in addition to those in the underlying zoning
district.
RR HAZ-7: Development will be designed and constructed in accordance with the airport
environs land use plan (AELUP) for John Wayne Airport. Building height restrictions, as
specified in the AELUP, would apply in the city
Explanation of the Rationale: The Project implements land uses and activities that were
envisioned and analyzed in the GPU PEIR. The Project site is currently developed with 164,049
square feet of commercial uses, which comprises approximately 22 percent of the 17.2-acre site.
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The remaining project site is comprised of surface parking. The Project site currently does not
have any residential uses and no existing established community exists within the Project site.
The Project site is surrounded by commercial and multi-family residential uses, and the Project,
which proposes a mixed-use community that would include mixed-use commercial and
residential, residential only, and commercial only buildings, would connect the surrounding
properties through the proposed pedestrian, bicycle, and vehicular network. Additionally, the
Project would not introduce any new roadways that would bisect existing communities or
neighborhoods. Therefore, the Project would not physically divide an established community,.
Impacts would be less than significant. (Draft Supplemental EIR, pp. 4.8-20—4.8-21.)
Threshold LU 2: 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.
Findings: The City finds that the Project would result in less than significant impacts to land use
and planning related to conflict with a land use plan, policy, or regulation. Additionally, the City
finds that the Project will implement regulatory requirements RR LU-1 and RR HAZ-7 (listed
above). (Draft Supplemental EIR, pp. 4.8-21 —4.8-52.)
Explanation of the Rationale: The Project is consistent with applicable regional and local plans
and programs that have been adopted for the purpose of avoiding or mitigating an environmental
effect including SCAG's 2020-2045 RTPISCS, the Airport Environs Land Use Plan for John
Wayne Airport(SNA), the City's General Plan, and applicable zoning. Impacts would be less than
significant. (Draft Supplemental EIR, pp. 4.8-21 —4.8-52.)
Cumulative Impacts: The Project would not result in cumulative impacts concerning land use
and planning.
Findings: The City finds that the Project would result in less than significant cumulative impacts
concerning land use and planning. Additionally, the City finds that the Project will implement
regulatory requirements RR LU-1 and RR HAZ-7 (listed above). (Draft Supplemental EIR,
pp. 4.8-52 —4.8-53.)
Explanation of the Rationale: As with the Project, the GPU buildout and each related project
would be required to comply with their applicable land use plan and be subject to review by City
regulatory agencies and CEQA review. The Project would not physically divide an established
community or conflict with applicable land use plans and zoning standards. Therefore, the
Project's contribution to cumulative impacts to land use and planning would not be cumulatively
considerable. Impacts would be less than significant. (Draft Supplemental EIR,
pp. 4.8-52 —4.8-53.)
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4.12 MINERAL RESOURCES
Threshold M-1: The Project would not result in the loss of availability of a known mineral
resource that would be of value to the region and the residents of the state.
Findings: The City finds that the Project would result in no impacts to mineral resources related
to the loss of availability of a known mineral resource that would be of value to the region and the
residents of the state. (Draft Supplemental EIR, pp. 5-12—5-13.)
Explanation of the Rationale. The Project site is entirely located in an area designated as MRZ-
3, indicating that the significance of mineral deposits cannot be determined from the available
data. The Project site is currently developed with existing commercial retail and surface parking
lot uses. No mineral extraction occurs within or near the Project site, and no mineral extraction
would occur with implementation of the Project. Thus, the Project would not result in the loss of
availability of a known mineral resource that would be of value to the region and the residents of
the state. No impact would occur. (Draft Supplemental EIR, pp. pp. 5-12—5-13.)
Threshold M 2: The Project would not result in the loss of availability of a locally-important
mineral resource recovery site delineated on a local general plan, specific
plan or other land use plan.
Findings: The City finds that the Project would result in no impacts to mineral resources related
to the loss of availability of a locally-important mineral resource recovery site. (Draft Supplemental
EIR, p. 5-13.)
Explanation of the Rationale: The Project is not delineated as a locally important mineral
resource recovery site in the GPU or other land use plan. The Project would be located within a
fully developed urban site with no mineral resource sectors or active or inactive mines. Therefore,
implementation of the Project would not result in the loss of availability of a locally-important
mineral resource recovery site. No impact would occur. (Draft Supplemental EIR, p. 5-13.)
Cumulative Impacts: The Project would not result in cumulative impacts concerning mineral
resources.
Findings: The City finds that the Project would result in less than significant cumulative impacts
concerning mineral resources. (Draft Supplemental EIR, pp. 5-12—5-13.)
Explanation of the Rationale: The Project site is entirely located in an area designated as MRZ-
3 and is not delineated as a locally important mineral resource recovery site in the GPU or other
land use plan. The Project site is currently developed with existing commercial retail and surface
parking lot uses. No mineral extraction occurs within or near the Project site, and no mineral
extraction would occur with implementation of the Project. Thus, the Project would not result in
the loss of availability of a known mineral resource that would be of value to the region and the
residents of the state or of a locally-important mineral resource recovery site. No impact would
occur. Therefore, the Project's contribution to cumulative impacts related to mineral resources
would not be cumulatively considerable. No impacts would occur. (Draft Supplemental EIR,
pp. 5-12 —5-13.)
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4.13 NOISE
Threshold N 2: The Project would not result in generation of excessive groundborne
vibration or groundborne noise levels.
Findings: The City finds that the Project would result in less-than-significant impacts to noise
related to generation of excessive groundborne vibration. (Draft Supplemental EIR,
pp. 4.9-32 —4.9-35.)
Explanation of the Rationale: Project construction can generate varying degrees of
groundborne vibration, depending on the construction procedure and the construction equipment
used. The ground-borne vibration generated during construction activities would primarily impact
existing sensitive uses that are located adjacent to or within the immediate vicinity of individual
projects. The Project may potentially use pile drivers during construction and the nearest
residences are multi-family residences approximately 75 feet from the Project site, resulting in
vibration levels ranging from approximately 0.0006 inch/second PPV to approximately 0.1239
inch/second PPV at 75 feet. As a result, construction groundborne vibration would not be capable
of exceeding the 0.2 inch-per-second PPV significance threshold for human annoyance or
building damage at the nearest sensitive receptor. Therefore, vibration impacts would be less
than significant impact during construction.
Implementation of the Project would not involve land uses that include or require equipment,
facilities, or activities that would result in perceptible groundborne vibration. Heavy duty trucks
would occasionally travel through the surrounding roadways; however, it is unusual for vibration
from sources, such as buses and trucks, to be perceptible, even in locations close to major roads.
As such, it can be reasonably inferred that operation of the Project would not create perceptible
vibration impacts to the nearest sensitive receptors. Therefore, vibration impacts related to human
annoyance and building damage during operation would be less than significant. (Draft
Supplemental EIR, pp. 4.9-32—4.9-35)
Threshold N-3: The Project would not expose people residing orworking in the project area
located within two miles of a public airport or public use airport to excessive
noise levels.
Findings: The City finds that the Project would result in less--than-significant impacts to noise
related to exposing people residing or working in the project area located within two miles of a
public airport or public use airport to excessive noise levels. (Draft Supplemental EIR,
pp. 4.9-35—4.9-36.)
Explanation of the Rationale: The nearest airport is John Wayne Airport (SNA) located
approximately 1.5 miles southeast of the Project site. The Project site is located within the Airport
Environs Land Use Plan for John Wayne Airport(SNA) and the Federal Aviation Regulations Part
77 Notification Area, but outside of the General Aviation Runway Safety Zones. Future sensitive
uses proposed under the Project would be located outside of the 60 dBA CNEL noise contour of
SNA. Additionally, the project site is not located within the vicinity of a private airstrip or related
facilities. (Draft Supplemental EIR, p. 4.9-36.)
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4.14 POPULATION AND HOUSING
Threshold P-1: 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).
Findings: The City finds that the Project would result in less-than-significant impacts to population
and housing related to substantial unplanned population growth. (Draft Supplemental EIR,
pp. 4.10-10—4.10-12.)
Explanation of the Rationale:The Project would draw from the large regional workforce to build
out the phases during construction. As the nature of typical construction efforts in urbanized,
developed areas such as the Project is temporary and involves commuting to construction sites,
the construction workers are not expected to relocate to the Project site area and result in
substantial unplanned population growth in the area. Construction impacts would be less
than significant.
The Project would introduce housing and a residential population to a site where none currently
exist and would provide housing for approximately 3,659 individuals, at a 95.9 percent occupancy
rate. With respect to the Orange County Council of Governments projections, the Project would
be approximately 1.02 percent of the population and approximately 1.9 percent of the housing in
Santa Ana and would not exceed the growth identified in the GPU PEIR.The Project would benefit
the City by introducing multi-family housing in a jobs-rich area in which employees would be able
to easily commute to nearby employment opportunities. In addition, as the area is jobs-rich and
as the Project would slightly reduce(improve)the jobs to housing ratio, the addition of residential
units in the area would not require additional direct or indirect job growth. Furthermore, jobs
associated with the Project's retail and office uses would be filled to some extent by employees
already residing in the vicinity of the Project. Thus, the employment growth from the Project would
not exceed the growth identified in the GPU PEIR.
The Project would be consistent with the land use designations proposed in the GPU PEIR,which
allow for urban retail, residential, mixed-use, and employment centers with an intensity of up to
5.0 floor area ratio (FAR) and/or 125 dwelling units per acre; thus, no new substantial unplanned
population growth would occur that was not previously analyzed in the GPU PEIR. Therefore,
impacts related to unplanned population growth as a result of the Project would be less than
significant. (Draft Supplemental EIR, pp. 4.10-10—4.10-12.)
Threshold P-2: The Project would not displace substantial numbers of existing people or
housing, necessitating the construction of replacement housing elsewhere.
Findings: The City finds that the Project would result in no impacts to population and housing
related to displacement of existing people or housing. (Draft Supplemental EIR,
pp. 4.10-12—4.10-13.)
Explanation of the Rationale: The Project site is currently developed with existing commercial
retail uses and surface parking lot uses. No housing or residents are currently located within the
Project site. The Projectwould redevelop the approximately 17.2-acre site within the South Bristol
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Street Focus Area with a mix of residential and commercial uses that would provide approximately
1,583 residential units. Consistent with the GPU, implementation of the Project would provide
additional housing opportunities. Therefore, no people or housing would be displaced, and no
impacts would occur. (Draft Supplemental EIR, pp. 4.10-12--4.10-13.)
Cumulative Impacts: The Project would not result in cumulative impacts concerning population
and housing.
Findings: The City finds that the Project would result in less than significant cumulative impacts
concerning population and housing. (Draft Supplemental EIR, pp. 4.10-13—4.10-17.)
Explanation of the Rationale: Cumulative development located in the City of Santa Ana propose
various uses, including, but not limited to, apartments, single-family residences, offices,
commerciallretail uses, restaurants, hotels, warehouses, industrial uses, and gas station and car
wash uses. The Project with the related projects would account for 16.7 percent of the projected
housing growth (5.2 percent of the GPU buildout), 14.6 percent of the projected population growth
(3.3 percent of the GPU buildout), and 12.9 percent of the projected employment growth (0.9
percent of the GPU buildout)for the City.With respect to the OCCOG 2045 projections,the project
in combination with related projects would contribute to approximately 7.2 percent of the housing
and 3.9 percent of the population in Santa Ana.As previously described, the addition of housing
within the Project area would help to balance the jobs-housing ratio within the City, providing a
more equal distribution of employment and housing for the City and thereby reducing commute
trips and improving air quality. On a citywide scale, the GPU buildout and related projects within
the City of Santa Ana are within the CPU's vision and forecasted development buildout of
accommodating growth in a responsible manner by providing a balance of jobs and housing.
Therefore, the Project's contribution to cumulative impacts associated with population and
housing would not be cumulatively considerable. Impacts would be less than significant. (Draft
Supplemental EIR, pp. 4.10-12 —4.10-17.)
4.15 PUBLIC SERVICES
Threshold FP-1 The Project would not result in unplanned population growth or substantial
adverse physical impacts associated with the provision of new or physically
altered fire protection 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.
Findings: The City finds that the Project would result in less-than-significant impacts to public
services related to fire protection services. (Draft Supplemental EIR, pp. 4.11-14—4.11-15.)
Additionally, the City finds that the Project will implement the following regulatory requirement
(Draft Supplemental EIR, p. 4.11-3):
RR FP-1: New buildings are required to meet the fire regulations outlined in the California
Health and Safety Code (Sections 13000 et seq.).
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Explanation of the Rationale: Construction and operation of the Project would increase demand
for fire protection and emergency medical services over existing conditions. However, the Project
would be consistent with the land use designations proposed in the GPU PEIR; thus, no new
substantial unplanned growth would occur that was not previously analyzed in the GPU PEIR.
Additionally, while the calls for service from the additional population and employment at the
Project site could result in an increase in response times from nearby fire stations, Orange County
Fire Authority (OCFA) fire protection equipment and staffing may be augmented by the City, as
needed, and the Project would include payment of applicable fees to the City's general fund
towards fire protection facilities. Additionally, the Project would comply with OCFA's Fire
Prevention Guideline B-09 related to access driveways, access walkways to and around
buildings, water supply, and siting of hydrants consistent with the California Fire Code and
California Building Standards Code. Therefore, the Project's impacts on fire protection services
would be less than significant. (Draft Supplemental EIR, pp. 4.11-14 —4.11-15.)
Threshold PP-1: The Project would not result in substantial adverse physical impacts
associated with the provision of new or physically altered police protection
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 protection services.
Findings: The City finds that the Project would result in less-than-significant impacts to public
services related to police protection services. (Draft Supplemental EIR, pp.4.11-15—4.11-17.)
Explanation of the Rationale: The Project would be consistent with the land use designations
proposed in the GPU PEIR; thus, no new substantial unplanned growth would occur that was not
previously analyzed in the GPU PEIR. Nonetheless, this anticipated growth generated by the
Project would increase service calls but is expected to create the typical range of police service
calls,which may relate to crime and safety issues during project construction(e.g.,theft of building
materials and construction equipment and vandalism) and during project operation (e.g., vehicle
burglaries, thefts, commercial shoplifting, and disturbances). The Santa Ana Police Department
would review and approve the final site plans to ensure that Crime Prevention through
Environmental Design measures are incorporated into the Project's design. Additionally, the
Project would generate revenues for the City's general fund (in the form of property taxes, sales
tax, etc.) that could be used for the provision of new police facilities in the City. Therefore, the
Project's impacts on police protection services would be less than significant. (Draft Supplemental
EIR, pp. 4.11-15—4.11-17.)
Threshold SS-1: 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, in
order to maintain acceptable service ratios and response times or other
performance objectives for school services.
Findings: The City finds that the Project would result in less-than-significant impacts to public
services related to school services, (Draft Supplemental EIR, pp. 4.11-17 —4.11-18.)
Additionally, the City finds that the Project will implement the following regulatory requirement
(Draft Supplemental EIR, p. 4.11-6):
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RR SS-1: New residential and commercial development shall pay development fee
authorized by Section 65996 of the California Government Code to be "full and complete
school facilities mitigation."
Explanation of the Rationale: The Project would have the potential to generate approximately
307 new elementary school students, 176 new intermediate school students, and 226 new high
school students, for a total of 709 new students. All three Santa Ana Unified School District
schools serving the project site have enrollment capacity to serve the Project at buildout. In
addition, the Project would be required to pay developerlimpact fees pursuant to Senate Bill 50,
which would further reduce potential impacts to school services. Pursuant to California
Government Code Section 65995, payment of development fees would provide full and complete
mitigation of school impacts. (Draft Supplemental EIR, pp. 4.11-17—4.11-18.)
Threshold LS-1: 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, in
order to maintain acceptable service ratios and response times or other
performance objectives for library services.
Findings: The City finds that the Project would result in less-than-significant impacts to public
services related to library services. (Draft Supplemental EIR, pp. 4.11-18--4.11-20.)
Additionally, the City finds that the Project will implement the following regulatory requirement
(Draft Supplemental EIR, p. 4.11-6):
RR LS-1: New residential development shall pay a property excise tax per the City
Municipal Code Section 35-114, Residential Development Tax.
Explanation of the Rationale: The Project would be consistent with the land use designations
proposed in the GPU PEIR; thus, no new substantial unplanned growth would occur that was not
previously analyzed in the GPU PEIR. Nonetheless, the anticipated growth generated by the
Project would increase the demand for library services in the City. However, through compliance
with the policies regarding the payment of residential development tax and property taxes, which
would contribute to the City's general fund that could potentially be used for the expansion of the
existing libraries or construction of new library facilities, the Project's impacts on library services
would be less than significant. (Draft Supplemental EIR, pp. 4.11-18--4.11-20)
Cumulative Impacts: The Project would not result in cumulative impacts concerning
public services.
Findings: The City finds that the Project would result in less than significant cumulative impacts
concerning public services. (Draft Supplemental EIR, pp. 4.11-20—4.11-23.)
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Explanation of the Rationale:
Fire Protection
Buildout of the GPU and the related projects would be reviewed by the City and/or OCFA prior to
permit approval to ensure that all new development implement fire protection design features
pursuant to the CFC and CBSC to reduce potential fire hazards. In addition, each related project
proposing buildings over two stories in height would be required to pay a fire facilities fee. The
Project would be consistent with the land use designations evaluated in the GPU PEIR; thus, no
new substantial unplanned growth would occur that was not previously analyzed in the GPU
PEIR. Further, Project implementation would improve the fire safety of the project site compared
to existing conditions and adhere to OCFA's Fire Prevention Guideline B-09. The Project would
also contribute the appropriate payment of the fire facilities fee, residential development tax, and
property taxes, which would contribute to the City's general fund that could potentially be used for
the expansion of existing fire stations or construction new fire protection facilities. Therefore, the
Project's contribution to cumulative impacts associated with fire protection and emergency
services would not be cumulatively considerable,and therefore,cumulative impacts would be less
than significant. (Draft Supplemental EIR, pp. 4.11-20—4.11-21.)
Police Protection
Buildout of the GPU and related projects within the City of Santa Ana would have the potential to
generate additional demand for police protection services by the Santa Ana Police Department.
However, as part of the development project review process, the Santa Ana Police Department
would review and approve the final site plans for GPU buildout and each related project within the
City. In addition, GPU buildout and each related project within the City would generate revenues
to the City's general fund (in the form of property taxes, sales tax, etc.) that could be applied
toward the provision of new police facilities and related staffing in the City. The Project would not
result in substantial unplanned population growth that was not previously analyzed in the GPU
PEIR. Design of the Project would be reviewed and approved by the Santa Ana Police
Department, and the Project would generate revenues for the City's general fund that could be
used for the provision of new police facilities in the City. Therefore, the Project's contribution to
cumulative impacts associated with police protection services would not be cumulatively
considerable, and therefore, cumulative impacts to police protection services would be less than
significant. (Draft Supplemental EIR, p. 4.11-21.)
School Services
Buildout of the GPU and related projects within the boundaries of Santa Ana Unified School
District and Orange Unified School District have the potential to result in the need for additional
school resources. However, cumulative development would be subject to all applicable laws,
ordinances, and regulations in place for school services, such as payment to fund new schools
from the fee program pursuant to Senate Bill 50. Additionally,the Project would be consistent with
the land use designations proposed in the GPU PEIR;thus, no new substantial unplanned growth
would occur that was not previously analyzed in the GPU PEIR. Additionally, the Project would
be required to pay developer/impact fees pursuant to Senate Bill 50. As such, the Project's
contribution to cumulative impacts associated with school services would not be cumulatively
considerable, and therefore, cumulative impacts to school services would be less than significant.
(Draft Supplemental EIR, pp. 4.11-21 —4.11-22.)
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Library Services
Buildout of the GPU and the related projects within the City would potentially increase the need
for library services. However, only the projects that involve the development of residential uses
would generate additional demand for library services. Cumulative development within the City
with a residential component would be required to comply with RR L.S-1 for the payment of the
residential development tax and property taxes,which would contribute to the City's general fund
that could potentially be used for the expansion of the existing libraries or construction new library
facilities. Additionally, the Project would not result in new substantial unplanned growth that was
not previously analyzed in the GPU PEIR. Project implementation would also result in the
payment of the residential development tax and property taxes, which could potentially be used
for the expansion of the existing libraries or construction new library facilities. Therefore, the
Project's contribution to cumulative impacts associated with library services would not be
cumulatively considerable, and therefore, cumulative impacts to library services would be less
than significant. (Draft Supplemental EIR, pp. 4.11-22—4.11-23.)
4.16 TRANSPORTATION
Threshold T-1: The Project would not conflict with a program, plan, ordinance or policy
addressing the circulation system, including transit, roadway, bicycle and
pedestrian facilities.
Findings: The City finds that the Project would result in less-than-significant impacts to
transportation related to conflict with a program, plan, ordinance or policy addressing the
circulation system, including transit, roadway, bicycle and pedestrian facilities. (Draft
Supplemental EIR, p. 4.13-11)
Additionally, the City finds that the Project will implement the following regulatory requirements
(Draft Supplemental EIR, p. 4.13-4):
RR T-1: The City will design and operate a balanced, multimodal circulation system
network with all users in mind—including bicyclists, public transportation vehicles and
riders, and pedestrians of all ages and abilities in line with the California Complete Streets
Act (Assembly Bill 1358).
RR T-2: Projects pursuant to the General Plan Update will implement fire protection
requirements as detailed in the Orange County Fire Authority's Fire Prevention Guidelines
and in the California Fire Code.
Explanation of the Rationale: The Project would enhance the existing circulation network by
including improvements to existing roadways, providing a new internal network of private
roadways and loading zones to encourage the safe movement of people and goods, and providing
adequate parking for residents and visitors to the Project site. Additionally, the Project would
maintain the existing public transit stops located within, directly adjacent to, or in the vicinity of
the Project site and would continue to serve the ridership in the area which would include the
residents, employees, and visitors of the Project. The Project would also enhance the existing
bicycle and pedestrian facilities within the Project vicinity to allow residents, visitors, and other
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users to travel throughout The Village. Therefore, the Project would not conflict with a program,
plan, ordinance, or policy addressing the circulation system for roadways, transit, bicycle or
pedestrian facilities. Impacts would be less than significant. (Draft Supplemental EIR,
pp. 4.13-11 --4.13-14.)
Threshold T-2: The Project would not conflict or be inconsistent with State CEQA
Guidelines Section 15064.3(b).
Findings: The City finds that the Project would result in less4han-significant impacts to
transportation related to conflict or inconsistency with State CEQA Guidelines Section 15064.3(b).
Additionally,the City finds that the Project will implement regulatory requirements RR T-1 through
RR T-2 (listed above). (Draft Supplemental EIR, pp. 4.13-14—4.13-18.)
Explanation of the Rationale: The Project is located in a Transit Priority Area (TPA), and the
proposed land uses are consistent with the RTPISCS. Additionally, the Project would not result in
an increase in the VMT per service population (VMT/SP) from what was analyzed in the GPU
PEIR. The Traffic Impact Study Guidelines identifies areas in the City that cannot be screened
out because they are not located in a TPA and would,therefore, require a VMT analysis; however,
the Project is not located within such an area and is therefore screened out of VMT analysis.
Therefore, the Project would not conflict or be inconsistent with State CEQA Guidelines Section
15064.3(b). Impacts related to VMT as a result of the Project would be less than significant. (Draft
Supplemental EIR, pp. 4.13-14—4.13-18.)
Threshold T-3: 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).
Findings: The City finds that the Project would result in less-than-significant impacts to
transportation related to substantially increasing hazards due to a geometric design feature or
incompatible uses. Additionally, the City finds that the Project will implement regulatory
requirements RR T-1 through RR T-2 (listed above). (Draft Supplemental EIR,
pp. 4.13-18--4.13-19.)
Explanation of the Rationale: The Project would change circulation and mobility throughout the
Project site by providing sidewalks, pedestrian paths, and a bicycle network. Additionally, the
Project would include improvements to existing roadways, including Sunflower Avenue, Plaza
Drive, and Bear Street. All roadway improvements and new roadway construction would be
constructed in accordance with the Orange County Fire Authority standards and requirements,
the Santa Ana Citywide Design Guidelines, and design guidelines of the California Manual of
Uniform Traffic Control Devices. Additionally, during construction, a traffic control plan would be
implemented to ensure that appropriate construction traffic control measures are utilized for
adequate and safe access and circulation within and near the Project site for all modes of
transportation, including emergency vehicles. Consistent with the GPU PEIR, circulation network
improvements are subject to review by the City's Public Works engineering staff, which would
ensure that roadway and circulation network improvements meet geometric design standards
and, thus,would not substantially increase hazards. Lastly,the Project is consistent with the land
use designation of the site and,thus,would not introduce any incompatible uses that would result
in transportation hazards. Therefore, impacts related to substantially increased hazards due to a
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geometric design feature or incompatible uses would be less than significant. (Draft Supplemental
EIR, pp. 4.13-18—4.13-19.)
Threshold T-4: The Project would not result in inadequate emergency access.
Findings: The City finds that the Project would result in less-than-significant impacts to
transportation related to inadequate emergency access. Additionally, the City finds that the
Project will implement regulatory requirements RR T-1 through RR T-2 (listed above). (Draft
Supplemental EIR, p. 4.13-20.)
Explanation of the Rationale: The proposed public and private roadways throughout the Project
site would be designed to accommodate emergency vehicles for fire, ambulance, and police
services. The roadways would not have restricted access such as gates that would prevent
emergency vehicles from reaching the intended destinations. Roadway improvements and new
roadway construction would be constructed in accordance with the Orange County Fire Authority
standards and requirements. During construction, a traffic control plan would be implemented to
ensure that adequate and safe access is available within and near the Project site. Appropriate
construction traffic control measures would be utilized to ensure that emergency access to the
Project site and the safe circulation of all modes of transportation is maintained on adjacent rights-
of-way. Therefore, impacts related to inadequate emergency access would be less than
significant. (Draft Supplemental EIR, p. 4.13-20.)
Cumulative Impacts: The Project would not result in cumulative impacts
concerning transportation.
Findings: The City finds that the Project would result in less-than-significant cumulative impacts
concerning transportation. Additionally, the City finds that the Project will implement regulatory
requirements RR T-1 through RR T-2 (listed above). (Draft Supplemental EIR,
pp. 4.13-21 —4.13-3.)
Explanation of the Rationale: Cumulative development under the GPU buildout and related
projects, including surrounding jurisdictions for the Cities of Costa Mesa and Irvine, would be
separately reviewed and approved by the respective jurisdiction to ensure their consistency with
applicable programs, plans, ordinances, and policies; VMT impacts; and compliance with existing
building and fire code standards associated with emergency access hazards. The Project would
connect to the existing circulation system while providing 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; would be consistent with SCAG's Connect SoCal RTPISCS and
provide for public transit options to future project users to further reduce VMT; and would be
designed in conformance with the City and Orange County Fire Authority's design standards to
ensure that no potentially hazardous design features or inadequate emergency access would be
introduced. Therefore, the Project's contribution to cumulative impacts associated with
transportation would not be cumulatively considerable. Impacts would be less than significant.
(Draft Supplemental EIR, pp. 4.13-21 —4.13-23.)
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4.17 UTILITIES AND SERVICE SYSTEMS
Threshold U 1: The Project would not require or result in the relocation or construction of
new or expanded water, wastewater treatment or storm water drainage,
electric power, natural gas, or telecommunications facilities, the
construction or relocation of which could cause significant environmental
effects.
Findings: The City finds that the Project would result in less-than-significant impacts to utilities
and service systems related to new or expanded water, wastewater treatment or storm water
drainage, electric power, natural gas, or telecommunications facilities. (Draft Supplemental EIR,
pp. 4.15-22—4.15-27.)
Additionally, the City finds that the Project will implement the following regulatory requirements
(Draft Supplemental EIR, pp. 4.15-8—4.15-14):
Water
RR U-5:Any development implemented under the General Plan Update shall abide by the
water conservation and efficiency requirements detailed in Chapter 8, Article XVI, Chapter
39, Article VI and Chapter 41, Article XVI of the Santa Ana Municipal Code.
RR U-6: Water connection fees shall be paid in accordance with Chapter 39, Article II of
the City's Municipal Code and plumbing shall be installed in compliance with Chapter 8,
Article III.
RR U-7 (Water): Water Supply Assessments and written verifications shall be prepared
for any development implemented under the General Plan Update that meets the criteria
of Senate Bill 610 or Senate Bill 221.
Wastewater
RR U-1: Any sewer utility infrastructure improvement associated with development under
the General Plan Update shall be designed, constructed, and operated in accordance with
Chapter 8, Article III, and Chapter 39, Article III, and of the Santa Ana Municipal Code.
RR U-2: Any new connections to the Orange County Sanitation District system or
expansion of a previous connection shall pay a capital facilities charge in accordance with
Ordinance No. OCSD-40.
RR U-3: Sewer utility infrastructure improvements associated with development under the
General Plan Update shall be designed,constructed, and operated in accordance with the
Orange County Sanitation District's Ordinance Nos. 25 and 48 and the wastewater
discharge requirements of the National Pollutant Discharge Elimination System permit
(Order No. R8-2012-0035).
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Stormwater
RR U-8(Stormwater): Storm drain shall be installed in compliance with Chapter 8, Article
III, of the Santa Ana Municipal Code.
RR HYDA: All development pursuant to the General Plan Update shall comply with the
requirements of the Construction General Permit (Order No. 2012-0006-DWQ) for
stormwater discharges associated with construction activity. Compliance requires filing a
Notice of Intent(NOI), a Risk Assessment, a Site Map, a Stormwater Pollution Prevention
Plan (SWPPP) and associated best management practices (BMPs), an annual fee, and a
signed certification statement.
RR HYD-4: All development pursuant to the General Plan Update shall comply with the
requirements of the Orange County MS4 Permit (Order R8-2009-0030, NPDES No.
CAS618030, as amended by Order No. 138-2010-0062). The MS4 Permit requires new
development and redevelopment projects to:
• Control contaminants into storm drain systems
• Educate the public about stormwater impacts
• Detect and eliminate illicit discharges
• Control runoff from construction sites
• Implement best management practices and site-specific runoff controls and
treatments for new development and redevelopment.
Dry Utilities
RR U-10: New buildings are required to achieve the current California Building Energy
and Efficiency Standards (Title 24, Part 6) and California Green Building Standards Code
(CALGreen) (Title 24, Part 11).
RR U-11: All new appliances would comply with the 2012 Appliance Efficiency
Regulations(Title 20, California Code of Regulations, Sections 1601 through 1608).
Explanation of the Rationale:
Water
The Project would involve the installation of water mains, hydrants, fire sprinklers, and proposed
recycled water and irrigation laterals and meters based on City and County input during the design
permitting phase.The water infrastructure improvements would comply with the City of Santa Ana
Design Guidelines for Water and Sewer Facilities and City of Santa Ana's Construction
Standards. Construction impacts associated with the installation of new water mains, fire
hydrants, and water connections would be temporary and would primarily involve trenching in
order to place the water lines below ground within previously disturbed roadways. Moreover,
water infrastructure improvement projects were considered in the GPU PEIR and supported by
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GPU policies. Therefore, the Project's impacts related to the relocation or construction of new or
expanded water facilities would be less than significant. As such, impacts resulting from the
Project would be less than significant. (Draft Supplemental EIR, p. 4.15-23.)
Wastewater
The Project would result in an increase in wastewater generation due to the Project site's change
in land use from commercial to mixed-use (i.e., residential uses and higher density would result
in greater wastewater generation. The Project's generated flow of 0.200 cubic feet per second
(cfs)would match the existing flow and no additional wastewater capacity would be required. As
part of Project development requirements, the Sewer Capacity Study, was submitted to the
Orange County Sanitation District (OC San) to verify capacity of the County sewer mains. OC
San review identified that there is existing capacity within the Sunflower trunk main; however, the
smaller Vitrified Clay Pipe (VCP) sewer mains in Bear Street and Plaza Drive have no additional
capacity beyond current discharges. Thus, the Project would include the construction of an on-
site private sewer network that would convey a majority of sewer flows generated west of Plaza
Drive within a private sewer network to connect to the City's VCP sewer main.All new connections
would be constructed per City and OC San standards. Final alignment, points of connections, and
limits of sewer removal and replacement would be developed during the design permitting phase.
All proposed wastewater infrastructure improvements and connections would comply with the City
of Santa Ana Design Guidelines for Water and Sewer Facilities, City of Santa Ana's Construction
Standards and City and OC San standards, which provide design criteria and construction
methods. Construction impacts associated with the installation of new sewer connections and
facilities would be temporary and would primarily involve trenching in order to place the lines
below ground. Further, the proposed wastewater infrastructure improvements would be located
in areas within the Project site and in previously disturbed roadways, and thus, the impacts from
installation and upgrades of the proposed on-site private sewer network are already accounted
for in the various resource sections of this Supplemental EIR. Therefore, with the Project's
impacts related to the relocation or construction of new or expanded wastewater facilities would
be less than significant.As such, impacts resulting from the Project would be less than significant.
(Draft Supplemental EIR, pp. 4.15-23—4.15-25.)
Stonnwater
The Project's grading and storm drain network would be designed to match the existing drainage
and flow patterns to best utilize the capacities available in the existing public storm drain system.
The Project would integrate bio-filtration methods, pervious surfaces, and selective plant materials
to encourage on-site water retention. Final routing of the storm drain system may require the
construction of underground detention systems to handle a minimum of the 10-year design storm,
per the latest version of the Orange County Local Drainage Manual and would be developed with
City and County input during the design permitting phase. The proposed drain improvements
would be constructed within previously disturbed roadways. Additionally, the impacts from
installation and upgrades to the storm drain system are already accounted for in the various
resource sections of this Supplemental EIR. Therefore, the Project's impacts related to the
relocation or construction of new or expanded stormwater facilities would be less than significant.
As such, impacts resulting from the Project would be less than significant. (Draft Supplemental
EIR, pp. 4.15-25-4.16-26.)
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Dry Utilities
The Project would result in service lines for new buildings to be extended or relocated from the
existing infrastructure. While the Project would increase energy demand at the site compared to
existing conditions, it would be required to comply with the latest applicable Building Energy
Efficiency Standards and CAL.Green requirements which provide efficiency standards related to
various building features, including appliances, water and space heating and cooling equipment,
building insulation and roofing, and lighting reducing energy usage. The Project would also install
solar panels on at least 30 percent of the roof area of buildings to generate electricity onsite,
offsetting demand from Southern California Edison's electrical distribution system. As such,
energy consumption for the project would be below California Energy Commission's forecasts,
the City's forecasted consumption for the proposed buildout of the General Plan in 2045, and the
current Countywide usage. Therefore, Project development would not require Southern California
Edison or Southern California Gas Company to obtain new or expanded electricity or natural gas
facilities, other than those proposed on-site. Thus, the Project's impacts related to the relocation
or construction of new or expanded electrical or natural gas facilities would be less
than significant.
Further,the existing communication services such as telephone, wi-fi, and cable television would
continue to be provided to the Project site by multiple providers. As various telecommunications
providers are available in the region, no significant expansion or construction of the
telecommunications network is anticipated. Therefore, the Project's impacts related to the
relocation or construction of new or expanded telecommunications facilities would be less than
significant. As such, impacts resulting from the Project would be less than significant. (Draft
Supplemental EIR, pp. 4.15-26—4.15-27.)
Threshold U-2: The Project would have sufficient water supplies available to serve the
project and reasonably foreseeable future development during normal, dry
and multiple dry years.
Findings: The City finds that the Project would result in less-than significant impacts to utilities
and service systems related to water supply. Additionally, the City finds that the Project will
implement regulatory requirements RR U-5 through RR U-7 (listed above). (Draft Supplemental
EIR, pp. 4.15-27—4.15-30.)
Explanation of the Rationale: Water demand for the Project during construction activities such
as soil compaction, dust control, and truck wheel washing, would be supplied by water trucks
and/or through connections to nearby water distribution lines. Construction activities would occur
intermittently throughout the construction period and would be temporary in nature; therefore,
construction impacts related to water supply would be less than significant.
For operations,the net water demand generated by the Project site at buildout would be 339 acre-
feet per year (AFY) which is approximately 1 percent of the overall City water demand. The
Project's future water demand from 2025 through 2045 would range from 300 AFY to 286 AFY.
In addition to the City's existing and planned future uses, the projected water demand for the
Project would be met by the City's water supply during normal, single-dry, and multiple-dry years.
Additionally, the Project would comply with water conservation and efficiency requirements
required by the Santa Ana Municipal Code, pay water connection fees, and implement GPU
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policies for water conservation, such as installing drought-tolerant plants, low-water turf surface,
bio-filtration planters, green roofs, drip irrigation, and localized capture and reuse. Therefore, the
Project would have sufficient water supplies available to serve the Project and reasonably
foreseeable future development during normal, dry and multiple dry years. Impacts would be less
than significant. (Draft Supplemental EIR, pp. 4.15-27—4.15-30.)
Threshold U-3: The Project would result in a determination by the wastewater treatment
provider which serves or may serve the project that it has adequate
capacity to serve the project's projected demand in addition to the
provider's existing commitments.
Findings: The City finds that the Project would result in less-than-significant impacts to utilities
and service systems related to wastewater treatment. Additionally, the City finds that the Project
will implement regulatory requirements RR U-1 through RR U-3 (listed above). (Draft
Supplemental EIR, pp. 4.15-30—4.15-31.)
Explanation of the Rationale: The Project would result in an increase in wastewater flows
generated from the Project site. The OC San's Treatment Plant No. 1 serves the General Plan
area and has a treatment capacity of 182 million gallons per day (mgd) and a minimum residual
treatment capacity of 52 mgd. The Project would result in a 0.27-mgd increase in wastewater
flows to Treatment Plant No. 1. Therefore, Treatment Plant No. 1 would have sufficient capacity
to treat the 0.27 mgd of wastewater flows generated by the Project in addition to existing
commitments. Impacts would be less than significant. (Draft Supplemental
EIR, pp. 4.15-30—4.15--1.)
Threshold U-4: 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,
Findings: The City finds that the Project would result in less-than-significant impacts to solid
waste related to generation in excess of state or local standards, capacity of the local
infrastructure or otherwise impair the attainment of solid waste reduction goals. (Draft
Supplemental EIR, pp. 4.15-31 —4.15-33.)
Additionally, the City finds that the Project will implement the following regulatory requirements
(Draft Supplemental EIR, p. 4.15-13):
RR U-7(Solid Waste):All development pursuant to the General Plan Update shall comply
with Section 4.408 of the 2019 California Green Building Code Standards, which requires
new development projects to submit and implement a construction waste management
plan in order to reduce the amount of construction waste transported to landfills.
RR U-8 (Solid Waste): All development pursuant to the General Plan Update shall store
and collect recyclable materials in compliance with Assembly Bill 341. Green waste will
be handled in accordance with Assembly Bill 1826.
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I
Explanation of the Rationale: Construction of the Project would generate a total of
approximately 17,846 tons over the course of a 20-year period, a large percentage of which would
occur during phase one, which includes demolition of the existing uses at the Project site. All
future construction activities would be required to demonstrate compliance with Assembly Bill
(AB) 939, which requires that at least 50 percent of waste produced is recycled, reduced, or
composted. In addition, the project would be constructed in accordance with CALGreen, which
requires recycling a minimum of 65 percent of the nonhazardous construction and demolition
debris, and submittal of a construction waste management plan. Compliance with these
regulations, as well as RR U-7 requiring implementation of a construction waste management
plan, would ensure the project's construction-related solid waste impacts would be less than
significant.
Operation of the Project would generate a total of approximately 35,700 pounds per day, or 17.85
tons per day (tpd). The maximum permitted capacity for the Frank Bowerman Sanitary Landfill
and the Olinda Alpha Landfill are 11,500 tpd and 8,000 tpd, respectively. Both landfills have an
average daily disposal rate of approximately 7,000 tpd, indicating that they would have sufficient
capacity to accommodate the Project's 17.85 tpd of solid waste (i.e., less than 1 percent of the
residual disposal capacity of the Frank Bowerman Sanitary Landfill). The Project would also be
required to comply with RR U-8, which states that all development pursuant to the GPU would be
required to store and collect recyclable materials and green waste in accordance with AB 341 and
AB 1826. Additionally, the Project would implement GPU policies to incorporate recycling and
organics collection activities to align with state waste reduction goals.Therefore,the Project would
not generate solid waste in excess of state or local standards, or in excess of the capacity of local
infrastructure. Impacts would be less than significant. (Draft Supplemental EIR,
pp. 4.15-31 —4.15-33.)
Threshold U-5: The Project would comply with federal, state, and local management and
reduction statutes and regulations related to solid waste.
Findings: The City finds that the Project would result in less-than-significant impacts to utilities
and service systems related to compliance with solid waste federal, state, and local management
and reduction statutes and regulations. Additionally, the City finds that the Project will implement
regulatory requirements RR U-7 through RR U-8 (listed above). (Draft Supplemental EIR,
p. 4.15-34.)
Explanation of the Rationale: Construction of the Project would be required to comply with the
requirements of AB 939, which requires that at least 50 percent of waste produced is recycled,
reduced, or composted, and CALGreen, which requires recycling a minimum of 65 percent of the
nonhazardous construction and demolition debris and submittal of a construction waste
management plan. Operation of the Project would also be required to comply with AB 939; AB
341,which requires diversion of a minimum of 75 percent of operational solid waste; and Chapter
16 Article II of the City's Municipal Code, which incorporates the waste requirements of SB 1383
for single-family, multi-family, and commercial uses. Additionally, the Project would implement
waste disposal services to allow for trash, recycling, and food waste for all residential and
commercial uses. Therefore, the Project would comply with applicable state and local regulations
related to solid waste. Impacts would be less than significant. (Draft Supplemental EIR,
pp. 4.15-31 —4.15-33.)
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Cumulative Impacts: The Project would not result in cumulative impacts concerning utilities and
service systems.
Findings: The City finds that the Projectwould result in no cumulative impacts concerning utilities
and service systems. Additionally, the City finds that the Project will implement regulatory
requirements RR U-1 through RR U-3; RR U-5 through RR U-8; RR U-10 through RR U-11; RR
HYD-1; and RR HYD-4 (listed above). (Draft Supplemental EIR, pp. 4.15-35 --4.15-38.)
Explanation of the Rationale:
Water
The geographic context for the analysis of cumulative impacts to water supply and infrastructure
is the City's water service area, which covers 27.5 square miles and includes the City of Santa
Ana and a small neighborhood in the City of Orange, near Tustin Avenue and Fairhaven by the
northeast corner of Santa Ana. The City's 2020 UWMP forecasts the water supply and demand
for its water service through 2045 which considers the GPU buildout assumptions and accounted
for the water demand generated by the types of land uses proposed by the related projects within
the City's water service area. As such, the City would have adequate water supplies to meet the
water demand during normal, single dry, and multiple dry years through 2045. In addition,the City
is able to purchase more water from MWD if necessary. Further, projects resulting from GPU
buildout and the related projects would be required to comply with regulatory requirements and
GPU policies that promote water conservation, prepare a Water Supply Assessment, and require
City review of each water service connection and infrastructure improvement.
The Project would have a less than significant impact on the City's water infrastructure and the
City would have sufficient water supplies to serve the Project during normal, single-dry, and
multiple-dry years. Therefore, the Project's contribution to cumulative impacts to water supply or
infrastructure would not be cumulatively considerable, and as such, cumulative impacts to water
supply or infrastructure would be less than significant. (Draft Supplemental EIR,
pp.4.15-35--4.15-38.)
Wastewater
The geographic context for the analysis of cumulative impacts to wastewater conveyance and
treatment would be the sewer service area of the City, which encompasses 27.2 square miles,
and OC San's service area,which covers a 479-square-mile area of central and northwest Orange
County and includes the cities of Santa Ana, Costa Mesa, and Irvine. Buildout of the GPU and
related projects would increase wastewater generation, thus cumulatively increasing wastewater
generation and infrastructure capacity, potentially requiring the relocation or construction of new
or expanded wastewater facilities. However, they would be required to perform a sewer
monitoring study to determine the adequacy of the sewer system, to pay the OC San Capital
Facilities Charge for new connections to the OC San System, and adhere to local standards.
Additionally, wastewater flows would be conveyed to OC San's Treatment Plant No. 1 or
Treatment Plant No.2 fortreatment which has a combined total capacity of 632 mgd.The project's
connections and upgrades to the sewer lines would result in less-than-significant impacts. In
addition, wastewater generated by the Project would be adequately served by OC San's
Treatment Plant No. 1. Therefore, the Project's contribution to cumulative impacts to wastewater
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conveyance and treatment infrastructure would not be cumulatively considerable, and cumulative
impacts related to wastewater treatment would be less than significant. (Draft Supplemental EIR,
p. 4.15-36.)
Stormwater
The extent of analysis of cumulative impacts for storm drainage systems is contiguous with the
City and Orange County Flood Control District (OCFCD) service areas. Depending on the project
type and design (e.g., new construction or significant reconstruction), buildout of the GPU and all
related projects could cumulatively increase stormwater flows, potentially requiring the relocation
or construction of new or expanded stormwater facilities; however, they would adhere to the
requirements of the NPDES and applicable permits (e.g., MS4, Industrial General Permit, and
Construction General Permit), which prevent post-development stormwater flows from exceeding
pre-development flows. Further, GPU buildout and the related projects would undergo the
development and review process and require hydrology studies as needed to assess stormwater
runoff and drainage. As such, GPU buildout and the related projects would result in less than
significant cumulative impacts related to stormwater.
The Project's grading and storm drain network would be designed to match the existing drainage
and flow patterns to best utilize the capacities available in the existing public storm drain system.
The Project would integrate bio-filtration methods, pervious surfaces, and selective plant materials
to encourage on-site water retention to ensure less than significant impacts related to stormwater
drainage. Therefore, the Project's contribution to cumulative impacts related to stormwater or
—infrastwctu-re-would-not-be-cumulativvely-considerable,and t_hug--umulati-ve-impac-ts-to-stcrmwater —or infrastructure would be less than significant. (Draft Supplemental EIR, pp. 4.15-36—4.15-37.)
Solid Waste
The extent of analysis of cumulative impacts for solid waste collection and disposal services is
contiguous with the Waste Management of Orange County service area Solid waste generated
by GPU buildout and the related projects within the City of Santa Ana would be primarily disposed
of at the Frank R. Bowerman Sanitary Landfill in Irvine and the Olinda Alpha Landfill in Brea. The
Orange County solid waste landfill system would continue maintain the 15-year countywide solid
waste landfill capacity as required by AB 939. Both landfills have sufficient capacity to
accommodate solid waste generated by the related projects and the Project. Moreover, the
Project and related projects would comply with all regulatory requirements to reduce solid waste
generation, including the requirements of AB 939, CALGreen, AB 341, and AB 1826, which would
reduce the amount of solid waste generated. Therefore, the Project's contribution to cumulative
impacts related to solid waste would not be cumulatively considerable, and as such, cumulative
impacts to solid waste would be less than significant. (Draft Supplemental EIR,
pp. 4.15-37—4.15-38.)
Dry Utilities
The extent of analysis of cumulative impacts for dry utilities (i.e., natural gas and electricity
services) is contiguous with the Southern California Gas Company and Southern California
Edison service areas. Although future developments would result in the use of renewable and
nonrenewable electricity and natural gas resources during construction and operation, which
could limit future availability, the sizes and types of uses proposed by the GPU buildout and
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related projects would use such resources on a relatively small scale. Additionally, future
development projects, including the Project, would be expected to incorporate energy
conservation features in compliance with applicable regulations, such as the Title 24 standards,
which include the CALGreen Code.The Project would not result in the need for expanded facilities
from SoCalGas, SCE, or telecommunications providers, as the existing capacities for dry utilities
would be sufficient to meet the Project's needs. Thus, the Project's contribution to cumulative
impacts to dry utility services would not be cumulatively considerable, and as such, cumulative
impacts to dry utility services would be less than significant. (Draft Supplemental EIR, p. 4.15-38.)
4.18 WILDFIRE
Threshold W-9: The Project would not substantially impair an adopted emergency response
plan or emergency evacuation plan.
Findings: The City finds that the Project would result in no impact to wildfire related to impairing
an adopted emergency response plan or emergency evacuation plan. (Draft Supplemental EIR,
p. 5-13.)
Explanation of the Rationale: The Project site is located within the City, which is not located in
or near a state responsibility area or lands classified as a very high fire hazard severity zone
(VHFHSZ). The nearest state responsibility area classified as VHFHSZ to the City is about four
miles east along the western edge of Loma Ridge, and the nearest VHFHSZ in a local
responsibility area is about 3.8 miles east at the southern tip of the Peters Canyon Regional Park.
Therefore, the Project would not substantially impair an adopted emergency response plan or
emergency evacuation plan, and no impact to wildfire would occur. (Draft Supplemental EIR,
p. 5-13.)
Threshold W-2: The Project would not, due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose project occupants to pollutant
concentrations from a wildfire or the uncontrolled spread of a wildfire.
Findings: The City finds that the Project would result in no impact to wildfire related to
exacerbating wildfire risks and exposing project occupants to pollutant concentrations from a
wildfire or the uncontrolled spread of a wildfire. (Draft Supplemental EIR, p. 5-13.)
Explanation of the Rationale:As previously discussed,the Project site is located within the City,
which is not located in or near a state responsibility area or lands classified as a VHFHSZ.
Therefore, the Project would not, due to slope, prevailing winds, and other factors, exacerbate
wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or
the uncontrolled spread of a wildfire. No impact to wildfire would occur. (Draft Supplemental EIR,
p. 5-13.)
Threshold W-3: The Project would not require the installation or maintenance of associated
infrastructure (such as roads, fuel breaks, emergency water sources,
power lines or other utilities)that may exacerbate fire risk or that may result
in temporary or ongoing impacts to the environment.
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Findings: The City finds that the Project would result in no impact to wildfire related to requiring
the installation or maintenance of associated infrastructure that may exacerbate fire risk or that
may result in temporary or ongoing impacts to the environment. (Draft Supplemental EIR, p. 5-14.)
Explanation of the Rationale:As previously discussed,the Project site is located within the City,
which is not located in or near a state responsibility area or lands classified as a VHFHSZ.
Therefore, the Project would not require the installation or maintenance of associated
infrastructure that may exacerbate fire risk or that may result in temporary or ongoing impacts to
the environment, and no impact to wildfire would occur. (Draft Supplemental EIR, p. 5-14.)
Threshold W-4: The Project would not expose people or structures to significant risks,
including downslope or downstream flooding or landslides, as a result of
runoff, post-fire slope instability, or drainage changes.
Findings: The City finds that the Project would result in no impact to wildfire related to exposing
people or structures to significant risks due to runoff, post fire slope instability or drainage
changes. (Draft Supplemental EIR, p. 5-14.)
Explanation of the Rationale:As previously discussed,the Project site is located within the City,
which is not located in or near a state responsibility area or lands classified as a VHFHSZ.
Therefore, the Project would not expose people or structures to significant risks, including
downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability,
or drainage changes. No impact to wildfire would occur. (Draft Supplemental EIR, p. 5-14.)
Cumulative Impacts: The Project would not result in cumulative impacts concerning wildfire.
Findings: The City finds that the Project would result in no cumulative impacts concerning
wildfire. (Draft Supplemental EIR, pp. 5-13—5-14.)
Explanation of the Rationale: The Project site is located within the City, which is not located in
or near a state responsibility area or lands classified as a VHFHSZ. Therefore, no cumulative
impacts to wildfire would occur. (Draft Supplemental EIR, pp. 5-13--5-14.)
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CHAPTER 5
LESS-THAN-SIGNIFICANT ENVIRONMENTAL
EFFECTS WITH MITIGATION INCORPORATED
Based on the Supplemental EIR, the Project would have less-than-significant environmental
effects with mitigation incorporated for the specific areas associated with the topics identified
below.
5.1 AIR QUALITY
Threshold AQ-9: The Project would not conflict with or obstruct implementation of the
applicable air quality plan with the implementation of mitigation.
Findings: The City finds that changes 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 Supplemental EIR. Specifically, the City finds that the following mitigation measure
shall be implemented to reduce potentially significant air quality impacts resulting from the Project
(Draft Supplemental EIR, p. 4.1-40):
Project-Specific MM AQ-1: Prior to the issuance of occupancy permits, the Planning
Division shall confirm that the proposed project's Covenants, Conditions, and Restrictions
(CC&Rs) and/or tenant lease agreements include contractual language that all
landscaping equipment used on-site shall utilize at least 50 percent electric landscaping
equipment (e.g., lawnmowers, leaf blowers, hedge trimmers). 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.
Additionally, the City finds that the Project will implement the following regulatory requirements
RR AQ-1 through RR AQ-3 (Draft Supplemental EIR, pp. 4.1-8—4.1-9):
RR AQ-1: New buildings are required to achieve the current California Building Energy
Efficiency Standards (Title 24, Part 6) and California Green Building Standards Code
(CALGreen) (Title 24, Part 11). The 2019 Building Energy Efficiency Standards became
effective January 1, 2020. The Building and Energy Efficiency Standards and CALGreen
are updated tri-annually with a goal to achieve net zero buildings energy for 2030.
RR AQ-2: Construction activities will be conducted in compliance with California Code of
Regulations,Title 13, Section 2449,which requires that nonessential idling of construction
equipment is restricted to five minutes or less.
RR AQ-3: Construction activities will be conducted in compliance with any applicable
South Coast Air Quality Management District rules and regulations, including but not
limited to:
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• Rule 403, Fugitive Dust, for controlling fugitive dust and avoiding nuisance.
• Rule 402, Nuisance, which states that a project shall not "discharge from any
source whatsoever such quantities of air contaminants or other material which
cause injury, detriment, nuisance, or annoyance to any considerable number of
persons or to the public, or which endanger the comfort, repose, health or safety
of any such persons or the public, or which cause, or have a natural tendency to
cause, injury or damage to business or property."
• Rule 1113, which limits the volatile organic compound content of architectural
coatings.
• Rule 1466, Soil Disturbance. Projects that involve earth-moving activities of more
than 50 cubic yards of soil with applicable toxic air contaminants are subject to this
rule.
Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.1,Air Quality, pages 4.1-27 through 4.1-30 of the Draft Supplemental EIR.
The following presents a summary of that rationale:
The determination of 2022 Air Quality Management Plan (AQMP) consistency focuses on the
long-term influence of a project on air quality in the South Coast Air Basin (SCAB). The Project
would not result in a long-term impact on the region's ability to meet State and Federal air quality
standards. Further, the Project's long-term influence on air quality in the SCAB would also be
consistent with the South Coast Air Quality Management District (SCAQMD) and Southern
California Association of Government's (SCAG's)goals and policies and is considered consistent
with the 2022 AQMP. As such, impacts resulting from the Project would be less than significant
for volatile organic compounds (VOCs) with implementation of Project-Specific MM AQ-1 and
regulatory requirements RR AQ-1 through RR AQ-3.
Threshold AQ-2: The Project would not result in a cumulatively considerable net increase of
any criteria pollutant for which the project region is non-attainment under
an applicable federal or State ambient air quality standard with the
implementation of mitigation.
Findings: The City finds that changes 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 Supplemental EIR. Specifically, the City finds that the following mitigation measures
shall be implemented to reduce potentially significant air quality impacts resulting from the Project
(Draft Supplemental EIR, pp. 4.1-39—4.1-40):
GPU PEIR 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 (SCAQMD) methodology for assessing air quality
impacts. If construction-related criteria air pollutants are determined to have the potential
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to exceed the SCAQMD'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 SCAQMD's Rule 403, such as:
o Use of nontoxic soil stabilizers to reduce wind erosion.
o 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 on-site 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 volatile organic compound paints for coating of architectural
surfaces whenever possible. A list of Super-Compliant architectural coating
manufactures can be found on the SCAQMD's website.
GPU PEIR MM AQ-2: 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 operation phase-related air quality impacts to the City of Santa
Ana for review and approval. The evaluation shall be prepared in conformance with
SCAQMD methodology in assessing air quality impacts. If operation-related air pollutants
are determined to have the potential to exceed the SCAQMD'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
operational activities. The identified measures shall be included as part of the conditions
of approval. Possible mitigation measures to reduce long-term emissions could include,
but are not limited to the following:
• For site-specific development that requires refrigerated vehicles, the construction
documents shall demonstrate an adequate number of electrical service
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connections at loading docks for plug-in of the anticipated number of refrigerated
trailers to reduce idling time and emissions.
• Applicants for manufacturing and light industrial uses shall consider energy
storage and combined heat and power in appropriate applications to optimize
renewable energy generation systems and avoid peak energy use.
• Site-specific developments with truck delivery and loading areas and truck parking
spaces shall include signage as a reminder to limit idling of vehicles while parked
for loading/unloading in accordance with California Air Resources Board Rule 2845
(13 CCR Chapter 10 Section 2485).
• Provide changing/shower facilities as specified in Section A5.106.4.3 of the
CALGreen Code (Nonresidential Voluntary Measures).
• Provide bicycle parking facilities per Section A4.106.9 (Residential Voluntary
Measures)of the CALGreen Code and Sec. 41-1307.1 of the Santa Ana Municipal
Code.
• Provide preferential parking spaces for low-emitting, fuel-efficient, and carpool/van
vehicles per Section A5.106.5.1 of the CALGreen Code (Nonresidential Voluntary
Measures),
• Provide facilities to support electric charging stations per Section A5.106.5.3
(Nonresidential Voluntary Measures) and Section A5.106.8.2 (Residential
Voluntary Measures) of the CALGreen Code.
• Applicant-provided appliances (e.g., dishwashers, refrigerators, clothes washers,
and dryers) shall be Energy Star—certified appliances or appliances of equivalent
energy efficiency. Installation of Energy Star— certified or equivalent appliances
shall be verified by Building & Safety during plan check.
• Applicants for future development projects along existing and planned transit
routes 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.
Refer to Project-Specific MM AQ-1, above.
Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.1,Air Quality, pages 4.1-31 through 4.1-41 of the Draft Supplemental EIR.
The following presents a summary of that rationale:
The evaluation provided in the Draft Supplemental EIR determined that the Project's construction-
related and operation phase-related air quality impacts would be less than significant, with the
exception of operational VOC emissions during the summer. Regarding the mitigation measures
in the GPU PEIR related to this threshold, the technical assessment and appendices prepared for
the Project satisfy GPU PEIR MM AQ-1 and MM AQ-2, which require preparation of a technical
assessment evaluating a potential project's construction-related and operation phase-related air
quality impacts. The possible mitigation measures to reduce short-term and long-term emissions
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listed under GPU PEIR MM AQ-1 and AQ-2 are either suggested for industrial uses or do not
directly reduce operational VOC emissions. Therefore, Project-Specific MM AQ-1 would be
implemented to reduce significant impacts related to VOCs during Project operations.
Threshold AQ-3: The Project would not expose sensitive receptors to substantial pollutant
concentrations with the implementation of mitigation.
Findings: The City finds that changes 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 Supplemental EIR. Specifically, the City finds that GPU PEIR MM AQ-1 (listed above)
shall be implemented to reduce potentially significant air quality impacts resulting from the Project.
(Draft Supplemental EIR, p. 4.1-39.)
Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.1,Air Quality, pages 4.1-42 through 4.1-47 of the Draft Supplemental EIR.
The following presents a summary of that rationale:
The Project would not expose sensitive receptors to substantial pollutant concentrations, including
to significant health risk impacts for residential sensitive receptors during project construction with
the implementation of GPU PEIR MM AQ-1. Pursuant to GPU PEIR MM AQ-1, the Project
requires use of construction equipment rated by the USEPA as having Tier 4 (model year 2008
or newer) emissions limits, applicable for engines between 50 and 750 horsepower. The total
highest calculated carcinogenic risk would be approximately 7.36 in one million and would not
exceed the SCAQMD threshold of 10 in one million with the implementation of GPU PEIR MM
AQ-1. Therefore, construction activities associated with the Project are not anticipated to result in
a significant cancer or other health risk to nearby sensitive receptors, and, as such, the health
impacts during construction of the Project would be less than significant with
mitigation incorporated.
Further, by complying with GPU PEIR MM AQ-1, the Project would reduce construction-related
DPM emissions and associated acute risk, and the highest maximum chronic and acute hazard
index associated with the mitigated emissions from Project construction at residential sensitive
receptors would be 0.136 and 0.918 and would not exceed the 1.0 chronic hazard index for
individual significance. Therefore, the Project's chronic and acute hazard index would be less
than significant with mitigation incorporated.
Cumulative Impacts: The Project would not result in cumulative impacts concerning air quality
with the implementation of mitigation.
Findings: The City finds that changes 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 Supplemental EIR. Specifically, the City finds that GPU PEIR MM AQ-1 and Project
Specific MM AQ-1 (listed previously) shall be implemented to reduce potentially significant air
quality impacts resulting from the Project. (Draft Supplemental EIR, pp. 4.1-39--4.1-41.)
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Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.1, Air Quality, pages 4.1-48 through 4.1-51 of the Draft Supplemental EIR.
The following presents a summary of that rationale:
The Project would not have a considerable contribution to cumulative impacts related to
consistency with applicable air quality plans or regional and localized emissions with the
implementation of Project-Specific MM AQ-1, to reduce the Project's operational emissions of
VOCs and its contribution of ozone precursors to the SCAB to below the SCAQMD's threshold of
significance. Additionally, GPU PEIR MM AQ-1 would require the use of construction equipment
rated by the USEPA as having Tier 4 emissions limits for engines between 50 and 750
horsepower to reduce the carcinogenic and acute hazard risks. Therefore, cumulative impacts
related to consistency with applicable air quality plans and regional and localized emissions were
determined to be less than significant after mitigation.
5.2 CULTURAL RESOURCES
Threshold C-2 The Project would not cause a substantial adverse change in the
significance of an archaeological resource pursuant to State CEQA
Guidelines Section 15064.5 with the implementation of mitigation.
Findings: The City finds that changes 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 Supplemental EIR. Specifically, the City finds that the following mitigation measure
shall be implemented to reduce potentially significant cultural resource impacts resulting from the
Project (Draft Supplemental EIR, pp. 4,2-15—4.2-16):
GPU PEIR MM CUL-6: 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 on-site 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. and 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 tribe(s), where
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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.
Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.2, Cultural Resources, pages 4.2-14 through 4.2-16 of the Draft
Supplemental EIR. The following presents a summary of that rationale:
Due to the Project site's past disturbances, which resulted in the disturbance of archaeological
sites buried at shallow depths, the sensitivity for cultural resources consisting of archaeological
sites is considered low at and near the surface of the Project site. However,this does not preclude
the possibility that subsurface archaeological deposits underlie the project site, especially in areas
where only minimal ground disturbance have occurred (i.e., the existing surface parking lots or
structures with shallow foundations). Additionally, the sensitivity for potential buried prehistoric
archaeological sites increases in the undisturbed soils at lower depths. The Project would require
a maximum depth of 52 feet for the proposed subsurface parking garage increasing the sensitivity
for potential buried prehistoric archaeological resources. Therefore,the Project would incorporate
GPU PEIR MM CUL-6, which would reduce impacts to potential archaeological resources. With
the implementation of the GPU PEIR MM CUL-6, impacts to archaeological resources would be
less than significant.
Cumulative Impacts: The Project would not result in cumulative impacts concerning cultural
resources with the implementation of mitigation.
Findings: The City finds that changes 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 Supplemental EIR. Specifically, the City finds that GPU PEIR MM CUL-6 (listed
previously) shall be implemented to reduce potentially significant cultural resource impacts
resulting from the Project. (Draft Supplemental EIR, pp. 4.2-15 —4.2-16.)
Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.2, Cultural Resources, pages 4.2-17 through 4.2-19 of the Draft
Supplemental EIR. The following presents a summary of that rationale:
The Project would not have a considerable contribution to cumulative impacts related to
archaeological resources with implementation of GPU PEIR MM CUL-6, which would reduce the
potential to impact undiscovered resources during ground-disturbing activities during Project
construction of the proposed subsurface parking garage. Incorporation of GPU PEIR MM CUL-6
would reduce the Project's potential impacts to archaeological resources to less than significant
levels. Therefore, the Project's impacts to archaeological resources would not be cumulatively
considerable.
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5.3 GEOLOGY AND SOILS
Threshold G-9(ii): The Project would not directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury, or death involving: strong seismic ground
shaking, with the implementation of mitigation.
Findings: The City finds that changes 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 Supplemental EIR. Specifically, the City finds that the following mitigation measures
shall be implemented to reduce potentially significant geological impacts resulting from the Project
(Draft Supplemental EIR, p. 4.4-11).
Project-Specific MM G-1: Incorporation of and Compliance with a Design-Level
Geotechnical Investigation. A final design-level geotechnical investigation that complies.
with all applicable state and local code requirements shall be prepared for each project
structure by a qualified, California-licensed geotechnical engineer consistent with the
California Building Code and City of Santa Ana requirements applicable at the time of
issuance of grading or construction permits. The final design-level geotechnical
investigation shall include recommendations related to site grading and earthwork, fill
materials, compaction, foundations, dewatering, and other structural elements. The report
recommendations shall be included in construction specifications and permits, approved
by the City's Building and Safety Division, and confirmed through on-site Inspections.
Project-Specific MM G-2: Implementation of Geotechnical Recommendations. Project
plans, grading specifications, and construction permitting shall incorporate site-specific
earthwork and ground improvement requirements related to seismic ground shaking,
liquefaction, settlement, collapse, subsidence, and expansive soils consistent with the
California Building Code and City of Santa Ana requirements applicable at the time of
issuance of grading or construction permits as stated in the final design level geotechnical
investigation and approved by the City's Building and Safety Division. This shall include
recommendations related to site grading and earthwork, fill materials, compaction,
foundations, dewatering, and other structural elements.
Additionally,the City finds that the Project will implement regulatory requirements RR G-1 through
RR G-3 (listed above). (Draft Supplemental EIR, pp. 4.4-3—4.4-4.)
Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.4, Geology and Soils, pages 4.4-10 through 4.4-12 of the Draft
Supplemental EIR. The following presents a summary of that rationale:
One of the primary seismic hazards at the Project site is ground shaking due the Project site's
proximity to the San Joaquin Hills Blind Thrust Fault and the Newport-Inglewood Fault. Consistent
with the GPU PEIR, the Project would be designed and constructed to meet or exceed current
design standards as found in the latest California Building Code(CBC)and other applicable local,
state, and federal codes to minimize impacts related to strong seismic ground shaking.
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Additionally, the City requires the Project-specific engineering design recommendations from a
design-level geotechnical investigation be incorporated into grading plans and building
specifications as a condition of construction permit approval: These recommendations have been
incorporated into Project-Specific MM G-1 and MM G-2. Therefore, impacts to seismic ground
shaking would be less than significant with mitigation incorporated.
Threshold G-9(X): The Project would not directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury, or death involving:
seismic-related ground failure, including liquefaction, with the
implementation of mitigation.
Findings: The City finds that changes 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 Supplemental EIR. Specifically, the City finds that Project-Specific MM G-1 and MM
G-2 (listed previously) shall be implemented to reduce potentially significant geological impacts
resulting from the Project. Additionally, the City finds that the Project will implement regulatory
requirements RR G-1 through RR G-3 (listed above). (Draft Supplemental EIR, p. 4.4-11.)
Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.4, Geology and Soils, pages 4.4-12 through 4.4-13 of the Draft
Supplemental EIR. The following presents a summary of that rationale:
Another primary seismic hazard at the Project site is potential ground deformation due to
liquefaction, based on California Regional Geologic Maps indicating the Project site as having
potentially liquefiable soil. Though the liquefaction analysis performed for the Project indicated
that the Project site has low to moderate liquefaction potential due to the clay layer that caps the
site and the depth to the liquefaction prone layers, Project-Specific MM G-1 and MM G-2 would
be implemented which requires review and approval of the final design-level geotechnical
investigation, including proper foundation design measures based on 2022 CBC standards, by
the City's Building and Safety Division as part of the construction permit approval process.
Therefore, impacts to seismic-related ground failure, including liquefaction would be less than
significant with mitigation incorporated.
Threshold G-3: The Project would not be located on a geologic unit or soil that is unstable,
or that would become unstable as a result of the Project, and potentially
result in on-or off-site landslide, lateral spreading, subsidence, liquefaction
or collapse, with the implementation of mitigation.
Findings: The City finds that changes 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 Supplemental EIR. Specifically, the City finds that Project-Specific MM G-1 and MM
G-2 (listed previously) shall be implemented to reduce potentially significant geological and soil
impacts resulting from the Project to less-than-significant. Additionally, the City finds that the
Project will implement regulatory requirements RR G-1 through RR G-3 (listed above). (Draft
Supplemental EIR, p. 4.4-11.)
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Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.4, Geology and Soils, pages 4.4-15 through 4.4-17 of the Draft
Supplemental EIR. The following presents a summary of that rationale:
The Project site is underlain by moderately compressible soils as well as soil with low to moderate
potential for seismically induced settlements. Model analysis resulted in 1 to 2 inches of total
settlement below a mat slab foundation. Implementation of Project-Specific MM G-1 and MM G-
2 to prepare a detailed geotechnical investigation in support of the final design plans and apply
the recommendations which include measures related to foundation specifications for heavier,
intermediate, and lighter structures, such as use of pile or pier foundations, mat/raft foundations,
stone columns, injection grouting, or deep soil mixing,to reduce impacts related to settlement and
collapse, would result in less than significant impacts related to settlement and collapse.
In addition, the Project site has relatively shallow groundwater conditions. Direct groundwater
extraction would not occur as part of the Project; however, excavations deeper than approximately
10 to 15 feet are likely to encounter groundwater seepage, and excavations deeper than 15 feet
may encounter artesian conditions. Project-Specific MM G-1 and MM G-2 to prepare a detailed
geotechnical investigation in support of the final design plans would include local dewatering and
inflow control for excavations deeper than approximately 15 to 20 feet for construction activities.
Therefore, impacts to subsidence would be less than significant with mitigation incorporated.
Further, slope failure and landslides are not a major hazard in Santa Ana because the entire city
is nearly flat. Lateral spreading is a type of liquefaction-induced ground failure on mildly sloping
ground. Impacts related to landslides or lateral spreading are less than significant. Refer to
Threshold G-1(iii)for the discussion on liquefaction.
Threshold G-4: The Project would not be located on expansive soil, as defined in Table 18-
1-B of the Uniform Building Code (1994), creating substantial direct or
indirect risks to life or property, with the implementation of mitigation.
Findings: The City finds that changes 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 Supplemental EIR. Specifically, the City finds that Project-Specific MM G-1 and MM
G-2 (listed previously)shall be implemented to reduce potentially significant soil impacts resulting
from the Project. Additionally, the City finds that the Project will implement regulatory
requirements RR G-1 through RR G-3 (listed above). (Draft Supplemental EIR, p. 4.4-11.)
Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.4, Geology and Soils, pages 4.4-17 through 4.4-18 of the Draft
Supplemental EIR. The following presents a summary of that rationale:
The Project site contains alluvium which consists primarily of clay and silt in the upper 15 to 20
feet, with local thin lenses of sandy alluvium. Below 20 feet, there is considerably more sand and
sandy silt layers, with local thin layers of clay. Clay-based soils are susceptible to expansion;
therefore, implementation of Project-Specific MM G-1 and MM G-2 would include
recommendations or measures for preventing expansive soils as part of the detailed geotechnical
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investigation in support of the final design plans. Therefore, impacts to expansive soils would be
less than significant with mitigation incorporated.
Threshold G-6: The Project would not directly or indirectly destroy a unique paleontological
resource or site or unique geologic feature, with the implementation of
mitigation.
Findings: The City finds that changes 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 Supplemental EIR. Specifically, the City finds that the following mitigation measures
shall be implemented to reduce potentially significant paleontological impacts resulting from the
Project(Draft Supplemental EIR, p. 4.4-20—4.4-21):
GPU PEIR MM GEO-2: Prior to issuance of a grading permit for projects involving ground
disturbance in previously undisturbed areas mapped with "low-to-high" paleontological
sensitivity, 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 PEIR MM GEO-3: 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. The
repository shall be identified and a curatorial arrangement shall be signed prior to
collection of the fossils.
Project-Specific MM G-3: The project applicant shall retain a qualified professional
paleontologist to monitor or supervise full-time monitoring should excavation occur into
native Pleistocene-age soil and bedrock greater than 4 feet in depth. Ground disturbance
refers to activities that would impact subsurface geologic deposits, such as grading,
excavation, boring, etc. Activities taking place in current topsoil or within previously
disturbed fill sediments, e.g., clearing, grubbing, pavement rehabilitation, do not require
paleontological monitoring. Bedrock can occur at varying depths depending on the portion
of the project area.
If no significant fossils have been recovered after 50 percent of excavation has been
completed, full-time monitoring may be modified to weekly spot-check monitoring at the
discretion of the qualified professional paleontologist. If the qualified professional
paleontologist determines during the course of excavations that project excavations are
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located within fill or disturbed soils, or that the sensitivity for significant paleontological
resources is otherwise low, then monitoring may be reduced or suspended at the qualified
professional paleontologist's discretion. The determination to reduce or discontinue
paleontological monitoring in the project area shall be based on the professional opinion
of the qualified professional paleontologist regarding the potential for fossils to be present
after a reasonable extent of the geology and stratigraphy has been evaluated.
Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.4, Geology and Soils, pages 4.4-19 through 4.4-21 of the Draft
Supplemental EIR. The following presents a summary of that rationale:
No significant fossils have been previously recovered from the project area, but several vertebrate
and invertebrate fossils have been recovered within one mile of the project area and exposures
of rock formations are anticipated to underlie the Project area. The geology of the Project area
may include Pleistocene-age deposits at unknown depths, suggesting that Project-related
ground-disturbing activities, such as for the proposed subsurface parking garage that would
require a maximum excavation depth of 52 feet, have the potential to destroy or otherwise
adversely impact significant paleontological resources below young Holocene-age soils at
unknown depths within the Project area. Therefore, the Project would implement GPU PEIR MMs
GEO-2 and GEO-3. GPU MM GEO-2 requires consultation with a geologist or paleontologist to
confirm whether the grading would occur at depths that could encounter highly sensitive
sediments for paleontological resources. In compliance with GPU PEIR MM GEO-2, construction
activity for the Project would be monitored by a qualified paleontologist. GPU MM GEO-3 would
require work be halted in the event of a fossil discovery. Additionally, Project-Specific MM G-3
provides procedures for paleontological monitoring. Therefore, impacts to paleontological
resources would be less than significant with mitigation incorporated.
Cumulative Impacts: The Project would not result in cumulative impacts concerning geology and
soils, with the implementation of mitigation.
Findings: The City finds that changes 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 Supplemental EIR. Specifically, the City finds that GPU PEIR MM GEO-2 and MM
GEO-3 and Project-Specific MM G-1 through G-3 (listed previously) shall be implemented to
reduce potentially significant geology and soils impacts resulting from the Project. Additionally,
the City finds that the Project will implement regulatory requirements RR G-1 through RR G-3
(listed above). (Draft Supplemental EIR, pp. 4.4-11 and 4.4-20—4.4-21.)
Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.4, Geology and Soils, pages 4.4-21 through 4.4-22 of the Draft
Supplemental EIR. The following presents a summary of that rationale:
Due to the site-specific nature of geological conditions(e.g., soils, geological features, subsurface
features, seismic features), geological impacts are typically limited to individual projects and their
project sites, and do not contribute to cumulative impacts. The GPU buildout and all projects on
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the related project lists would be subject to their own project-specific impact analysis and would
be required to incorporate feasible mitigation measures to reduce any potentially significant
impacts to a less than significant level. The Project would implement mitigation measures (i.e.,
Project-Specific MM G-1 and MM G-2) to reduce impacts to a less than significant level. As a
result, the Project's incremental effects would not cause the combined cumulative impacts to
become significant and thus, are not cumulatively considerable.
The GPU PEIR identified a significant but mitigable impact on previously unrecorded
paleontological resources, to which the related projects could incrementally contribute. Such
cumulative impacts from grading activities for projects within the City of Santa Ana would be
reduced with the implementation of GPU PEIR MM GEO-1 through MM GEO-3. Additionally, all
related projects (including those within Costa Mesa and Irvine) would adhere to their respective
General Plan policies and/or mitigation measures to protect paleontological resources. The
excavation required for the proposed subsurface parking garage could encounter sensitive
sediments for paleontological resources. However, the Project would implement GPU PEIR MMs
GEO-2 and GEO-3 and Project-Specific MM G-3, which would protect any discovered
paleontological resources. Therefore, the Project's contribution to cumulative impacts on
paleontological resources would not be cumulatively considerable, and therefore, would be less
than significant with mitigation incorporated.
5.4 NOISE
Threshold N-1: 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, with the
implementation of mitigation.
Findings: The City finds that changes 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 Supplemental EIR. Specifically, the City finds that the following mitigation measure
shall be implemented to reduce potentially significant noise impacts resulting from the Project
(Draft Supplemental EIR, p. 4.9-32):
Project-Specific MM NOI-1: Prior to the issuance of a permit to conduct nighttime
construction activities (e.g., overnight concrete pours), the Project Applicant shall obtain
a permit from the City to complete work outside the standard construction hours outlined
in Santa Ana Municipal Code Section 18-314(e). In addition, the Project Applicant and/or
contractor(s) shall develop a nighttime construction noise control plan that demonstrates
the construction techniques that will be implemented to ensure noise levels remain below
the Federal Transit Administration's (FTA's) nighttime construction noise criterion of 70
dBA Leq (A-weighted decibel equivalent sound level). Examples of such construction
techniques include but are not limited to the following:
• Locate stationary equipment (e.g., generators, air compressors, etc.) away from
off site residences/sensitive receptors.
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• Surround stationary equipment with noise barriers or utilize a temporary noise
barrier to block the line of sight from such equipment to nearby off-site
residences/sensitive receptors.
• Identify minimum separation distances between mobile equipment (e.g., concrete
mixer trucks, concrete pump trucks, etc.) and residences/sensitive receptors.
Additionally, the City finds that the Project will implement the following regulatory requirements
RR NOI-1 through RR NOI-3 (Draft Supplemental EIR, p. 4.9-4):
RR NOI-1: California Building Code: The California Building Code (CBC), Title 24, Part 2,
Volume 1, Chapter 12, Interior Environment, Section 1207.11.2, Allowable Interior Noise
Levels, requires that interior noise levels attributable to exterior sources shall not exceed
45 dB in any habitable room. The noise metric is evaluated as either the day-night average
sound level (Ldn) or the community noise equivalent level (CNEL), consistent with the
noise element of the local general plan.
The State of California's noise insulation standards for non-residential uses are codified
in the California Code of Regulations, Title 24, Building Standards Administrative Code,
Part 11, CALGreen. CALGreen noise standards are applied to new or renovation
construction projects in California to control interior noise levels resulting from exterior
noise sources. Proposed projects may use either the prescriptive method (Section
5.607.4.1) or the performance method (Section 5.507.4.2)to show compliance. Under the
prescriptive method, a project must demonstrate transmission loss ratings for the wall and
roof-ceiling assemblies and exterior windows when located within a noise environment of
65 dBA CNEL or higher. Under the performance method, a project must demonstrate that
interior noise levels do not exceed 50 dBA Leq(1hr).
RR NOI-2: Construction Noise Sources: Section 18-314(e) of the Santa Ana Municipal
Code prohibits construction activities to the hours of 7:00 AM to 8:00 PM Monday through
Saturday.
RR NOI-3: Stationary Noise Sources: Section 18.312 of the Santa Ana Municipal Code
establishes standards for stationary noise sources.
Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.9, Noise, pages 4.9-20 through 4.9-32 of the Draft Supplemental EIR. The
following presents a summary of that rationale:
The Project operational noise impacts would result in less than significant impacts. The Project's
construction noise would not have the potential to exceed the FTA's construction noise criterion
of 80 dBA Leq. Furthermore, Project construction activities would comply with the construction
hours specified in Section 18-314(e) of the Santa Ana Municipal Code, which restricts
construction activities to the daytime hours of 7:00 a.m. to 8:00 p.m., Monday through Saturday.
The only exception would be for nighttime concrete pours, which would occur a maximum of 2
nights per phase, should continuous pours be necessary for geotechnical considerations. Noise
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from nighttime construction activity could exceed the FTA's nighttime construction noise criterion
of 70 dBA Leq at off-site residential uses. As such, implementation of Project-Specific MM NOI-1
would reduce noise levels during nighttime concrete pours by at least 10 dBA. Project-Specific
MM NOI-1 requires a nighttime construction control plan and implementation of construction
techniques, including installation of temporary noise barriers or enclosures during Phases 2 and
3 to protect sensitive receptors to the north and west, use of mufflers on construction equipment,
and placement of construction equipment away from sensitive receptors. Therefore, impacts to
construction noise during nighttime concrete pours would be less than significant with mitigation
incorporated.
Cumulative Impacts: The Project would not result in cumulative impacts concerning noise, with
the implementation of mitigation.
Findings: The City finds that changes 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 Supplemental EIR. Specifically, the City finds that Project-Specific MM NOI-1 (listed
previously) shall be implemented to reduce potentially significant noise impacts resulting from the
Project. (Draft Supplemental EIR, p. 4.9-32.)
Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.9, Noise, pages 4.9-36 through 4.2-44 of the Draft Supplemental EIR. The
following presents a summary of that rationale:
Construction activities associated with the Project and cumulative growth may overlap, resulting
in increased construction noise in the Project vicinity. However, construction noise primarily
affects the areas immediately adjacent to a construction site. Due to the distance and intervening
structures, cumulative construction noise from related projects would not be perceptible. With
exception of the Related Bristol Specific Plan Project,the related projects are located at distances
well removed from the Project site. The Related Bristol Specific Plan Project is located directly to
the east of the Project site of which construction of the area closest to the Project would not
overlap (Related Bristol Specific Plan Phase 1 construction start 2026) with construction of the
Project in the area directly adjacent(Project Phase 4 construction start 2036).The Related Bristol
Specific Plan Project is anticipated to be completed in 2036. With the rapid attenuation of noise
with distance, construction noise from the Project and Related Bristol Specific Plan Project would
not combine to result in significant cumulative effects. The Project would implement Project-
Specific MM NOI-1 to reduce noise levels during nighttime concrete pours by at least 10 dBA by
requiring a nighttime construction control plan and implementation of construction techniques,
including installation of temporary noise barriers or enclosures during Phases 2 and 3 to protect
sensitive receptors to the north and west, use of mufflers on construction equipment, and
placement of construction equipment away from sensitive receptors. In the unlikely event that
nighttime concrete pours for both the Related Bristol Specific Plan Project and the Project occur
on the same nights in the vicinity of each other, both projects would be required to obtain a permit
from the City, including development of a nighttime construction noise control plan, as specified
in the respective project-specific noise mitigation measures, which would reduce noise levels
below the significance criteria. Cumulative impacts related to mobile, stationary, and vibration
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would be less than significant.Therefore,the Project's contribution to cumulative impacts on noise
would not be cumulatively considerable, and therefore, would be less than significant with
mitigation incorporated.
6.6 TRIBAL CULTURAL RESOURCES
Threshold TCR-1: The Project would not cause a substantial adverse change in the
significance of a tribal cultural resource, defined in Public Resources Code
Section 21074 as either a site, feature, place, cultural landscape that is
geographically defined in terms of the size and scope of the landscape,
sacred place, or object with cultural value to a California Native American
tribe, and that is listed or eligible for listing in the California Register of
Historical Resources, or in a local register of historical resources as defined
in Public Resources Code Section 5020.1(k), with the implementation of
mitigation.
Findings: The City finds that changes 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 Supplemental EIR. Specifically, the City finds that the following mitigation measures
shall be implemented to reduce potentially significant tribal cultural resource impacts resulting
from the Project(Final Supplemental EIR, p. 3-9—3-11):
GPU PEIR MM CUL-6, listed previously.
Project-Specific MM TCR-1: Native American Monitor - Gabrieleho Band of Mission
Indians-Kizh Nation:
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 tribal cultural resources,
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
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and burial goods. Copies of monitor logs will be provided to the project applicant
upon written request to the Tribe.
d. Onsite tribal monitoring by the Kizh Nation and/or their representatives 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 tribal cultural resources.
Project-Specific MM TCR-2: Unanticipated Discovery of Tribal Cultural Resource
Objects (Non-Funerary/Non-Ceremonial): Gabrieleno Band of Mission Indians-Kizh
Nation
a. Upon discovery of any tribal cultural resources, 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 tribal cultural resource has been
fully assessed by the Kizh monitor in consultation with a qualified archaeologist.
The Kizh will recover and retain all discovered tribal cultural resources 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.
Project-Specific MM TCR-3: Unanticipated Discovery of Human Remains and
Associated Funerary or Ceremonial Objects:
a. Native American human remains are defined in Public Resources Code Section
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.
b. If Native American human remains and/or grave goods are discovered or
recognized on the project site, then Public Resources Code Section 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 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.
Project-Specific MM TCR-4: Native American Monitor - Juaneno Band of Mission
Indians, Acjachemen Nation- Belardes:
a. The Project applicant shall retain a Native American Monitor from or approved by
the Juaneno Band of Mission Indians,Acjachemen Nation- Belardes. The monitor
i
i
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shall be retained prior to the commencement of any ground-disturbing activity for
the subject project at all project locations (i.e., both on-site and any off-site
locations that are included in the project description/ definition and/or required in
connection with the 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 (City) prior
to the commencement of any ground-disturbing activity, or the issuance of any
permit necessary to commence 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 tribal cultural resources
(TCRs), including but not limited to, Native American cultural and historical
artifacts, remains, places of significance, etc., 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. On-site tribal monitoring by the Juaneno Band of Mission Indians and/or their
representatives shall conclude upon the latter of the following (1) written
confirmation to the Tribe or Tribal monitoring agency from a designated point of
contact for the Project applicant that all ground-disturbing activities and phases
that may involve the Project are complete; or (2) a determination and written
notification by the Tribe or Tribal monitoring agency to the Executive Director of
the Planning and Building Agency, or designee that no future, planned construction
activity and/or development/construction phase at the Project site possesses the
potential to impact TCRs.
Project-Specific MM TCR-5: Unanticipated Discovery of Tribal Cultural Resource
Objects(Non-Funerary/Non-Ceremonial)-Juaneno Band of Mission Indians,Acjachemen
Nation- Belardes:
a. Upon discovery of any tribal cultural resources (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 Juaneno Band of Mission Indians monitor in consultation with a
qualified archaeologist. The Tribe or Tribal monitoring agency 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.
Project-Specific MM TCR-6: Tribal Cultural Resource Finds, Dispute Resolution, and
Final Disposition:
If a tribal cultural resource is identified, then avoidance is the preferred treatment. If
avoidance is not feasible and both Tribal monitoring entities claim cultural affiliation with
and/or ancestral ties to the discovered resources, then a Cultural Resources Monitoring
and Treatment Plan shall be created by the archaeologist, in coordination with the
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consulting tribes (Gabrieleno Band of Mission Indians-Kizh Nation and the Juaneno Band
of Mission Indians, Acjachemen Nation-Belardes) and all subsequent finds shall be
subject to this Plan. The consultation effort is intended to be a meaningful and timely
process of seeking, discussing, and considering carefully the views of others, in a manner
that is cognizant of all parties' cultural values and, where feasible, seeking agreement on
the appropriate treatment and disposition of TCRs discovered. Final disposition of any
excavated resources may include, but would not be limited to, reburying, relocating,
recording, and/or another culturally appropriate treatment such as transfer to one of the
consulting tribes for any purpose the Tribe deems appropriate, including for educational,
cultural and/or historic purposes. If it is determined that mutual agreement cannot be
reached within 30 days of the initial consultation meeting, the Plan shall be written such
that any excavated resources shall be reinterred on site in a location free from future
ground-disturbing construction activities after documentation is complete. Project
construction will not resume within the immediate vicinity of the discovery (i.e., not less
than the surrounding 50 feet) until the Cultural Resources Monitoring and Treatment Plan
is prepared and implemented to the satisfaction of the City.
Additionally, the City finds that the Project will implement the following regulatory requirements
(Draft Supplemental EIR, p. 4.14-4):
RR TCR-1: As per Assembly Bill 52, within 14 days of deciding to undertake a project or
determining that a project application is complete, the lead agency must provide formal
written notification to all tribes who have requested it.
RR CULA: California Health and Safety Code Section 7050.5 requires that if human
remains are discovered within the proposed project site, disturbance of the site shall halt
and remain halted until the coroner has investigated the circumstances, manner, and
cause of any death, and the recommendations concerning the treatment and disposition
of the human remains have been made to the person responsible for the excavation, or to
his or her authorized representative. If the coroner determines that the remains are not
subject to his or her authority and if the coroner recognizes or has reason to believe the
human remains to be those of a Native American, he or she shall contact, by telephone
within 24 hours, the Native American Heritage Commission.
Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.14, Tribal Cultural Resources, pages 4.14-9 through 4.14-12 of the Draft
Supplemental EIR and in Chapter 3, Revisions to the Draft Supplemental EIR, of the Final
Supplemental EIR. The following presents a summary of that rationale:
The Project's Sacred Lands File search yielded negative results and additional research identified
no historical or archaeological resources within the Project site and a 0.5-mile radius. The City
consulted with the Gabrieleno Band of Mission Indians-Kith Nation and the Juaneno Band of
Mission Indians, Acjachemen Nati on-Bela rdes. 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 previously discussed, excavations for the Project are
anticipated to disturb a large part of the Project site to a maximum depth of approximately 52 feet
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for the subsurface parking garage. The sensitivity for potential buried prehistoric archaeological
sites at the Project site is considered low at the surface and near surface due to past disturbances;
however, the sensitivity increases in these undisturbed soils. Therefore, implementation of GPU
PEIR MM CUL-6 would require monitoring during all ground-disturbing construction activity and
pre-construction activities within previously undisturbed soils by a qualified archaeologist and a
Native American monitor, worker training, and procedures in case of a find. In addition, Project-
Specific MM TCR- 1 through MM TCR-5 are proposed for implementation as requested by the
Gabrieleno Band of Mission Indians-Kith Nation and the Juaneno Band of Mission Indians,
Acjachemen Nation-Belardes, to require procedures for Native American monitoring and to avoid
potential impacts to tribal cultural resources that may be unearthed from project construction
activities. Project-Specific MM TCR-6 is proposed for resource identification, dispute resolution,
and final disposition in the event of an unanticipated discovery of a tribal cultural resource.
Therefore, Project impacts to tribal cultural resources would be less than significant with mitigation
incorporated.
Threshold TCR-2: The Project would not cause a substantial adverse change in the
significance of a tribal cultural resource, defined in Public Resources Code
Section 21074 as either a site, feature, place, cultural landscape that is
geographically defined in terms of the size and scope of the landscape,
sacred place, or object with cultural value to a California Native American
tribe, and that is 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 5024.1, In
applying the criteria set forth in subdivision (c) of Public Resource Code
Section 5024.1, the lead agency shall consider the significance of the
resource to a California Native American tribe, with the implementation
of mitigation.
Findings: The City finds that changes 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 Supplemental EIR. Specifically, the City finds that GPU PEIR MM CUL-6 and Project-
Specific MM TCR-1 through MM TCR-6 (listed previously) shall be implemented to reduce
potentially significant tribal cultural resource impacts resulting from the Project. (Final
Supplemental EIR, p. 3-9—3-11.)
Additionally, the City finds that the Project will implement regulatory requirements RR TCR-1
through RR CUL-1 (listed above). (Draft Supplemental EIR, p. 4.14-4.)
Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.14, Tribal Cultural Resources, pages 4.14-13 through 4.14-14 of the Draft
Supplemental EIR and in Chapter 3, Revisions to the Draft Supplemental EIR, of the Final
Supplemental EIR. The following presents a summary of that rationale:
As previously discussed, the Project's Sacred Lands File search yielded negative results and
additional research identified no historical or archaeological resources within the Project site and
a 0.5-mile radius.The City's consultation with the Gabrieleno Band of Mission Indians-Kizh Nation
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and the Juaneno Band of Mission Indians,Acjachemen Nation-Belardes determined tribal cultural
resources may potentially be encountered during ground disturbing construction activities. The
potential to encounter buried prehistoric archaeological sites exists for excavation in undisturbed
soils. Therefore, GPU PEIR MM CUL-6 and Project-Specific MM TCR-1 through MM TCR-6 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
from Project construction activities. Therefore, project impacts to tribal cultural resources would
be less than significant with mitigation incorporated.
Cumulative Impacts: The Project would not result in cumulative impacts concerning tribal cultural
resources, with the implementation of mitigation.
Findings: The City finds that changes 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 Supplemental EIR. Specifically,the City finds that GPU PEIR MM CUL-6 and Project-
Specific MM TCR-1 through MM TCR-6 (listed previously) shall be implemented to reduce
potentially significant tribal cultural resource impacts resulting from the Project. Additionally, the
City finds that the Project will implement regulatory requirements RR TCR-1 through RR CULA
(listed above). (Draft Supplemental EIR, p. 4.14-4.)
Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.14, Tribal Cultural Resources, pages 4.14-14 through 4.14-15 of the Draft
Supplemental EIR and in Chapter 3, Revisions to the Draft Supplemental EIR, of the Final
Supplemental EIR. The following presents a summary of that rationale:
As previously discussed, the Project site and vicinity are not known to contain tribal cultural
resources. However, the excavation required for the proposed subsurface parking garage could
encounter prehistoric archaeological sites containing tribal cultural resources. If tribal cultural
resources are encountered during construction, the Project has the potential to contribute to
cumulative impacts. However, the Project would implement GPU PEIR MM CUL-6 and Project-
Specific MM TCR-1 through MM TCR-6, which would protect any discovered tribal cultural
resources. Therefore, the Project's contribution to cumulative impacts on tribal cultural resources
would not be cumulatively considerable and would be less than significant with mitigation
incorporated.
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CHAPTER 6
SIGNIFICANT AND UNAVOIDABLE
ENVIRONMENTAL EFFECTS
The Final EIR determined that the Project has potentially significant environmental effects that
cannot be feasibly mitigated to less-than-significant levels, and such impacts would be significant
and unavoidable. These impacts and the corresponding findings are identified below.
6.1 RECREATION
Threshold R-9: The Project would increase the use of existing neighborhood and regional
parks or other recreational facilities such that substantial physical
deterioration of the facility would occur or be accelerated.
Findings: The City finds that specific economic, legal, social, technological, or other
considerations make infeasible the mitigation measures or project alternatives identified in the
Final Supplemental EIR. While changes or alterations have been required in, or incorporated into,
including regulatory requirement RR REC-1 below, the Project to address this significant effect
on the environment, no feasible mitigation measures exist to reduce impacts to a less-than-
significant level.
RR REC-1: Residential development associated with the General Plan Update will be
required to comply with the provisions of the Municipal Code Chapter 35, Article IV
(Residential Development Fee). Residential development is mandated to pay fees,
dedicate land in lieu thereof, or a combination of both for the purpose of preserving
recreational facilities in the City.
However, pursuant to PRC Section 21081(a)(3), as described in the Statement of Overriding
Considerations, the City has determined that this impact is acceptable based on specific
overriding considerations found in Chapter 8 below.
Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.12, Recreation, pages 4.12-10 through 4.12-13 of the Draft Supplemental
EIR. The following presents a summary of that rationale:
The Project would redevelop an approximately 17.2-acre site with a mix of residential and
commercial uses and is conservatively estimated to provide housing for 3,815 individuals. To
meet the GPU policy of providing 3 acres of public park or recreational space per 1,000 residents,
the Project would need to provide a total of 11.4 acres. The Project would meet a significant
portion of this increased need through provision of 7.5 acres of publicly accessible open space
and common areas, which equates to providing 2 acres of publicly accessible open space per
1,000 residents. These publicly accessible areas include active spaces, such as walkways and a
fitness loop, and passive open spaces, such as pocket parks and gathering areas for outdoor
programming. Additionally, the Project would provide 6.3 acres of private outdoor and amenity
spaces, including outdoor balconies and patios, pools and spas, communal gathering spaces,
etc., totaling a combined 13.8 acres, or approximately 80 percent of the 17.2-acre Project site, of
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public and private outdoor and recreational space to the residents. This total 13.8 acres is
anticipated to meet the potential park and recreation needs of the Project residents; however, the
Project residents may also use park and recreational facilities that are in the vicinity of the Project
site. Such additional park visits may result in physical deterioration of recreational facilities due to
the increased foot traffic and usage of park facilities. Such wear on facilities would be expected
to contribute to the need for maintenance activities including, but are not limited to: replacement
or fixing of picnic area tables and trash receptacles; painting and equipment maintenance of
basketball,tennis,swimming, and other sports facilities; upkeep on playfield,trail, and landscaped
areas; and maintenance of restroorn and parking areas.
Nonetheless, the Project would meet the City's 2022 Parks Master Plan short-range goal of
providing 1.5 acres of parkland per 1,000 residents and comply with applicable municipal code
requirements and Regulatory Requirement (RR) REC-1 requiring residential development fees
for the acquisition, construction, and renovation of park and recreation facilities pursuant to Santa
Ana Municipal Code Section 35-108 of Chapter 35, Article 4, and Sections 35-110 and 35-111 of
Chapter 35,Article 4. The Project would contribute additional public park and recreation space to
the City's available public parkland and recreational spaces at a ratio of 2 acres per 1,000
residents, which is higher than the 1.2 ratio assessed for the GPU buildout, in the GPU PEIR.
Moreover, the Project would provide tax revenues to the City, including contributions to the
applicable community facilities district, for park maintenance that would help offset the additional
deterioration occurring from the Project residents. Taken together, the Project's proposed 13.8
acres of outdoor and recreational space(comprised of 7.5 acres of publicly accessible open space
and 6.3 acres of private outdoor and amenity spaces), combined with the payment of applicable
fees and tax revenues serve to reduce potential impacts discussed in the GPU PEIR. Regardless,
since the Project would not fully meet the GPU policy of providing 3 acres of parkland and
recreation facilities per 1,000 residents, it is reasonably foreseeable that the 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 facilities.
Furthermore, 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, as identified
in the GPU PEIR, there would be no feasible mitigation measures that would be able to reduce
this significant impact, or the project's contribution thereto, to a less-than-significant level. As
such, impacts would be significant and unavoidable, which is consistent with the findings of the
GPU PEIR,
Threshold R-2: 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.
Findings: The City finds that specific economic, legal, social, technological, or other
considerations make infeasible the mitigation measures or project alternatives identified in the
Final Supplemental EIR. While changes or alterations have been required in, or incorporated into,
including regulatory requirement RR REC-1 (listed above), the Project to address this significant
effect on the environment, no feasible mitigation measures exist to reduce impacts to a less-than-
significant level. However, pursuant to PRC Section 21081(a)(3), as described in the Statement
of Overriding Considerations, the City has determined that this impact is acceptable based on
specific overriding considerations found in Chapter 8 below.
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Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.12, Recreation, pages 4.12-13 through 4.12-15 of the Draft Supplemental
EIR. The following presents a summary of that rationale:
The Project would provide 7.5 acres of public park/recreation and open space, which when
considering the Project's 3,816 residents at maximum buildout, results in a ratio of 2 acres per
1,000 residents, which is higher than the 1.2 ratio (based on 516.86 acres for 431,629 residents)
assessed in the GPU PEIR for the GPU buildout. Further, the Project would be developing this
park/recreation and open space in the South Bristol Street Focus Area, an area identified by the
GPU PEIR and the 2022 Parks Master Plan that is deficient in public parkland and recreational
resources.Additionally,the Project would be required to pay applicable fees pursuant to Municipal
Code Section 35-108 of Chapter 35, Article 4, and Sections 35-110 and 35-111 of Chapter 35,
Article 4, in accordance with RR REC-1, to be used towards the future expansion or renovation
of parks and recreational facilities in the City, as well as other applicable community facilities
district fees assessed to maintain park facilities.
However, as previously discussed, the Project's provision of parkland would not fully meet the
GPU policy to provide a ratio of 3 acres of parkland for every 1,000 residents. While development
of the Project would not result in significant unmitigable impacts to the environmental resources
such as air quality, cultural resources, geology and soils, greenhouse gas emissions, hazards
and hazardous materials, hydrology and water quality, noise, transportation, and tribal cultural
resources, development and operation of future new or expanded recreational facilities may have
an adverse physical effect on the environment, including impacts relating to air quality, biological
resources, lighting, noise, and traffic. Consequently, impacts from the Project would be potentially
significant.
As discussed in the GPU PEIR, the City of Santa Ana is essentially fully built out and there is
limited available land to develop new parks or expand existing facilities, and there would be no
feasible mitigation measures that would reduce significant impacts related to the City's parkland
to resident ratio to a less-than-significant level. The Project is consistent with the buildout
envisioned in the GPU for the Project area, which was analyzed in the GPU PEIR along with
buildout of the City and found to result in significant and unavoidable impacts related to related to
recreation, based on the possibility that future project-specific developments could result in
significant, adverse physical effects an the environment. The Project's provision of 7.5 acres of
public park and recreation facilities and applicable fees would lessen the impact identified in the
GPU PEIR. Therefore, while the Project would contribute to the significant and unavoidable
recreation impacts disclosed in the GPU PEIR, the Project would not result in a substantial
increase in the severity of the previously identified impacts and would not result in any new
significant impacts.
Cumulative Impacts: The Project would result in cumulative impacts concerning recreation.
Findings: The City finds that specific economic, legal, social, technological, or other
considerations make infeasible the mitigation measures or project alternatives identified in the
Final Supplemental EIR. While changes or alterations have been required in, or incorporated into,
including regulatory requirement RR REC-1 (listed above), the Project to address this significant
effect on the environment, no feasible mitigation measures exist to reduce impacts to a less-than-
significant level. However, pursuant to PRC Section 21081(a)(3), as described in the Statement
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of Overriding Considerations, the City has determined that this impact is acceptable based on
specific overriding considerations found in Chapter 8 below.
Explanation of the Rationale: The rationale and facts supporting the above finding are fully
developed in Section 4.12, Recreation, pages 4.12-15 through 4.12-18 of the Draft Supplemental
EIR. The following presents a summary of that rationale:
Together with the contribution from the Project's maximum buildout of 3,815 persons and 7.5
acres of publicly accessible parks/recreation facilities and open space,the Project plus the related
projects would result in a total of 14,273 persons and 21.4 acres of publicly accessible
park/recreation facilities and open space, for a ratio of 1.5 acres per 1,005 residents. While the
Project and the related projects would improve the GPU buildout's parkland-per-resident ratio and
would be required to provide park and recreational facilities and/or pay in-lieu fees as required by
the municipal code, due to the lack of available land to develop new parks or expand existing
facilities, the ratio would still remain below the CPU's parkland standard. For this reason, the
Project's incremental contribution relating to the deficiency of parkland within the City would be
cumulatively considerable. No feasible mitigation measures were identified in the GPU EIR to
reduce this impact to a less than significant level and there remain no feasible mitigation
measures.While the Project's incremental contribution to cumulative impacts related to recreation
would improve the existing cumulative scenario and the impacts identified in the GPU PEIR,
cumulative impacts to recreation resources would remain significant and unavoidable.
i
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CHAPTER 7
FINDINGS REGARDING
SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL
CHANGES
Sections 15126(c) and 15126.2(c) of the CEQA Guidelines, require that an EIR address any
significant irreversible environmental changes that would occur should the project be
implemented. Generally, a project would result in significant irreversible environmental changes
if any of the following would occur:
• The project would involve a large commitment of non-renewable resources;
• The primary and secondary impacts of the project would generally commit future
generations to similar uses;
• The project involves uses in which irreversible damage could result from any potential
environmental accidents; or
• The proposed consumption of resources is not justified.
Commitment of the Proposed Project's Site for Future Generations
The Project site is developed with existing commercial uses. Implementation of the Project would
continue the commercial uses and also provide residential uses. Secondary effects associated
with construction and operation of the Project include: emissions of air pollutants; consumption of
non-renewable energy; and increased ambient noise due to increased activities. However, the
Project implements land uses and activities that were envisioned and analyzed in the GPU PEIR,
and as analyzed in the aforementioned sections, the Project would not result in unmitigable
significant impacts beyond those identified in the GPU PEIR. As a result, the Project would not
result in a new commitment of the Project site for future generations. (Draft Supplemental EIR,
pp. 5-3--5-4.)
Large Commitment of Resources
Resources that would be consumed during Project construction include water, electricity, natural
gas, fossil fuels, and building materials, such as lumber, cement, steel, copper, other metals,
glass, aggregate, asphalt,and composite materials. However, the building materials would largely
be used during construction and would not be further consumed during operations. Additionally,
use of such resources would not be unusual compared with other construction projects and would
not substantially affect the availability of such resources.
During operations, the proposed commercial and residential uses would consume utility
resources, such as water, electricity, natural gas, and other petroleum-based fuels, as well as
paints, solvents, and cleaner for normal maintenance activities, similar to other residential and
commercial uses. The Project would not substantially affect the availability of such resources.
(Draft Supplemental EIR, p. 5-4.)
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Consumption of Resources
Construction and operation of the Project would require the use of both renewable and non-
renewable resources and construction materials. However, the Project would not involve the
wasteful or unjustifiable use of non-renewable resources during construction or long-term
operation. None of the building materials anticipated for the Project would be unique, rare, in short
supply, or require creation of new resource extraction sites or new manufacturing and delivery
channels. The Project would meet the most current and latest Title 24 standards for energy
efficiency and incorporate all applicable energy efficiency measures (solar panels, high efficiency
lighting, energy efficient appliances, etc.), which help to reduce energy consumption. The Project
site is also located in a designated Transit Opportunity Corridor and would develop the site with
residential, commercial, office, and recreation opportunities that would encourage use of public
transportation. Further, implementation of the Project would also satisfy the achievement of the
Project objectives, which includes objectives that are beneficial to the growth and prosperity of
the City. (Draft Supplemental EIR, p. 5-4.)
Irreversible Environmental Damage
Construction and long-term operation of the Project would involve the limited transport, storage,
use, and disposal of hazardous materials related to typical residential and commercial uses.
However, all hazardous materials used on the Project site would be used, stored, and disposed
of in accordance with manufacturer's standards and all applicable federal, state, and local
requirements such as those set forth by the California Occupational Safety and Health
Administration, California Emergency Management Agency, California Department of Toxic
Substances Control, and the Orange County Environmental Health Division of the Health Care
Agency. Further, the Phase I Environmental Site Assessment prepared for the Project did not
identify recognized environmental conditions at the site that would create significant hazards to
the public and environment. Therefore, the Project would not involve uses in which irreversible
damage could result from a potential environmental accident associated with the Project. (Draft
Supplemental EIR, pp. 5-4—5-5.)
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CHAPTER 8
FINDINGS REGARDING
GROWTH-INDUCING IMPACTS
Section 15126.2(e) of the State CEQA Guidelines requires a Draft EIR to discuss the ways the
Project could foster economic or population growth or the construction of additional housing,
directly or indirectly, in the surrounding environment. In accordance with State CEQA Guidelines
Section 15126.2(e), a Project would be considered to have a growth-inducing effect if it would:
• Directly or indirectly foster economic or population growth, or the construction of
additional housing in the surrounding environment;
• Remove obstacles to population growth (e.g., construction of an infrastructure
expansion to allow for more construction in service areas);
• Tax existing community service facilities, requiring the construction of new facilities
that could cause significant environmental effects; or
• Encourage and facilitate other activities that could significantly affect the environment,
either individually or cumulatively.
In addition, State CEQA Guidelines states that that growth inducement must not be assumed.
State CEQA Guidelines Section 15126.2(e) states that growth-inducing effects are not to be
construed as necessarily beneficial, detrimental or of little significance to the environment.
Therefore,the following analysis is provided as additional information on ways in which the Project
could contribute to significant changes in the environment beyond the direct consequences of
developing the land use concepts examined in the Draft Supplemental EIR.
Establish substantial new permanent employment opportunities or otherwise stimulate
economic activity such that it would result in the need for additional housing, businesses,
and services to support increased economic activities.
The Project would redevelop the site to provide up to 1,583 residential units (encompassing
approximately 1,850,000 square feet of building space), 80,000 square feet of retail space,
300,000 square feet of office space, and approximately 7.5 acres of publicly accessible open
space and common areas. Based on employment factors provided in the GPU PEIR, the
proposed retail and office space would generate approximately 985 jobs, resulting in a generated
net increase of 657 jobs compared to existing conditions. The generated net increase resulting
from the Project would not exceed the projected increase for nonresidential uses and employment
in the South Bristol Street Focus Area and therefore, would not result in unplanned
employment growth.
In addition, the Project would slightly reduce (improve) the City's jobs to housing ratio and would
benefit the City by introducing multi-family housing to the project site in a jobs-rich area in which
employees would be able to easily commute to nearby employment opportunities. Because the
area is jobs-rich, the addition of residential units in the area would not require additional job
growth. Therefore, the residential units would not indirectly result in the need for additional
employment opportunities, which could result in unplanned growth.
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Furthermore,jobs associated with the project's retail and office uses would be filled to some extent
by employees already residing in the vicinity of the Project. Residents and employees in the
Project vicinity 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
thus, reduce travel impacts related to traffic, air quality, and greenhouse gas emissions. In
addition, as the Project would provide housing, it would not result in the need for additional
housing. Implementation of the Project would stimulate economic activity as envisioned in the
GPU in a manner that balances the City's needs for housing, commerce, and recreation, without
inducing unplanned growth. (Draft Supplemental EIR, p. 5-15.)
Remove obstacles to growth, e.g., through the construction or extension of major
infrastructure facilities that do not presently exist in the project area or would add
substantial capacity that could accommodate additional unplanned growth.
The Project is an infill redevelopment of an existing commercial property in the SBSFA. Overall,
the Project would redevelop the existing on-site infrastructure systems for water, water quality,
wastewater, and stormwater utility improvements to meet project-related demand. The new
infrastructure would not provide additional capacity beyond what is needed to serve the Project.
In addition, because the Project is within a developed area that is receiving services from existing
utility infrastructure and would connect to the existing infrastructure, development of the Project
would not result in an expansion of overall capacity, extension of infrastructure, or provision of
services in areas or an unserved area. Therefore, implementation of the Project would not remove
obstacles to growth or add substantial capacity that could accommodate additional unplanned
growth. (Draft Supplemental EIR, pp. 5-15—5-16.)
Remove obstacles to growth through changes in existing regulations pertaining to land
development.
Adoption of the Village Santa Ana Specific Plan, which contains the proposed development
standards, permitted uses, and administrative processes for future development, pursues the
envisioned buildout of the property as part of the City's GPU Land Use Plan, The Project would
be consistent with the land use designations proposed in the GPU PEIR, which allow for urban
retail, residential, mixed-use, and employment centers with an intensity of up to 5.0 FAR and/or
125 dwelling units per acre.
Additionally, the Project's estimated 3,659 residents would be 3.8 percent of the GPU PEIR's
estimated 96,855 persons resulting from Citywide growth, and the proposed 1,583 housing units
would be 4.4 percent of the GPU PEIR's estimated 36,261 housing units planned to be added
Citywide. Therefore, the population and housing growth from the Project would not exceed the
growth identified in the GPU PEIR. The Project would generate a net increase of 657 jobs which
would not exceed the increase in 3,505,130 square feet of nonresidential space and 7,865 jobs
projected for the SBSFA. Further, the Project would have a 0.42 jobs to housing ratio (i.e., 657
jobs to 1,583 housing units). The City of Santa Ana is jobs-rich with an existing jobs-housing ratio
of 2.0. The Project would slightly reduce (improve) the jobs to housing ratio and would benefit the
City by introducing multi-family housing to the Project site in a jobs-rich area in which employees
would be able to easily commute to nearby employment opportunities. In addition, as the area is
jobs-rich, the addition of residential units in the area would not require additional job growth.Thus,
the resulting population, housing, and employment growth from the Project would not exceed the
growth identified in the GPU PEIR, and no new substantial unplanned population growth would
occur that was not previously analyzed in the GPU PEIR. Further, Therefore, the Project would
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not remove obstacles to growth through changes in existing regulations pertaining to land
development. (Draft Supplemental EIR, pp. 5-16--5-17.)
Result in the Need to Expand One or More Public Service Facilities to Maintain Desired
Levels of Service
Implementation of the Project would result in increased demand for fire protection, police
protection, school services, and recreational facilities. The provision of new or physically altered
government facilities is typically associated with unplanned population growth or new residential
development. Buildout of the Project would not increase demand beyond that assumed for
buildout of the South Bristol Street Focus Area in the GPU PEIR, and thus, would not be
considered unplanned population growth. Further, the Project would adhere to regulations and
requirements such as undergoing site plan review by the Orange County Fire Authority and Santa
Ana Police Department and payment of facility fees and developer/impact fees. Therefore, the
Project would not result in the need to expand one or more public service facilities to maintain
desired levels of service. (Draft Supplemental EIR, p. 5-17.)
Involve Some Other Action that Could Encourage and Facilitate Other Activitles that Could
Significantly Affect the Environment
The Project involves a zoning amendment to replace the existing SD-48 zoning of the Project site;
however, the proposed amendment is specific to the allowable land uses at the Project site. The
Project would 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 to reduce potential environmental impacts to the amount feasible.
Therefore, the Project would not involve some other action that could encourage and facilitate
other activities that significantly affect the environment. (Draft Supplemental EIR, p. 5-17—5-18.)
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CHAPTER 9
FINDINGS REGARDING
PROJECT ALTERNATIVES
The[haft Supplemental EIR analyzed three alternatives to the Project as proposed and evaluated
these alternatives for their ability to avoid or reduce the Project's significant environmental effects
while also meeting the majority of the Project's objectives. The City finds that it has considered
and rejected as infeasible the alternatives identified in the EIR and described below. This section
sets forth the potential alternatives to the Project analyzed in the EIR and evaluates them in light
of the Project objectives, as required by CEQA.
Where significant impacts are identified, section 15126.6 of the State CEQA Guidelines requires
EIRs to consider and discuss alternatives to the proposed actions. Subsection (a) states:
(a) An EIR shall describe a range of reasonable alternatives to the project, or to the
location of the project, which would feasibly attain most of the basic objectives of
the project but would avoid or substantially lessen any of the significant effects of
the project, and evaluate the comparative merits of the alternatives. An EIR need
not consider every conceivable alternative to a project. Rather it must consider a
reasonable range of potentially feasible alternatives that will foster informed
decision-making and public participation. An EIR is not required to consider
alternatives which are infeasible. The lead agency is responsible for selecting a
range of project alternatives for examination and must publicly disclose its
reasoning for selecting those alternatives. There is no ironclad rule governing the
nature or scope of the alternatives to be discussed other than the rule of reason.
Subsection 15126.6(b) states the purpose of the alternatives analysis:
(b) Because an EIR must identify ways to mitigate or avoid the significant effects that
a project may have on the environment(Public Resources Code Section 21002.1),
the discussion of alternatives shall focus on alternatives to the project or its location
which 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.
In subsection 15126.6(c), the State CEQA Guidelines describe the selection process for a
range of reasonable alternatives:
(c) The range of potential alternatives to the proposed project shall include those that
could feasibly accomplish most of the basic objectives of the Project and could
avoid or substantially lessen one or more of the significant effects. The EIR should
briefly describe the rationale for selecting the alternatives to be discussed. The EIR
should also identify any alternatives that were considered by the lead agency but
were rejected as infeasible during the scoping process and briefly explain the
reasons underlying the lead agency's determination. Additional information
explaining the choice of alternatives may be included in the administrative record.
Among the factors that may be used to eliminate alternatives from detailed
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consideration in an EIR are: (i) failure to meet most of the basic project objectives,
(ii) infeasibility, or(iii) inability to avoid significant environmental impacts.
The range of alternatives required is governed by a "rule of reason" that requires the EIR to set
forth only those alternatives necessary to permit a reasoned choice. The EIR shall include
sufficient information about each alternative to allow meaningful evaluation, analysis, and
comparison with the proposed Project. Alternatives are 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.
As set forth in these findings, the implementation of the Project would not in result in significant
impacts that are considered unavoidable, with the exception of impacts related to recreation. In
making the alternatives findings below, the City of Santa Ana certifies that it has independently
reviewed and considered the information on alternatives provided in the EIR, including the
information provided in the comments on the Draft Supplemental EIR and the responses thereto.
9.1 DISCUSSION OF ALTERNATIVES CONSIDERED BUT REJECTED
Section 15126.6(c) of the State CEQA Guidelines specifies that an EIR should (1) identify
alternatives that were considered by the lead agency but were eliminated from detailed
consideration because they were determined to be infeasible during the scoping process; and (2)
briefly explain the reasons underlying the lead agency's determination. Among the factors that
may be used to eliminate alternatives from detailed consideration in an EIR are: (i)failure to meet
most of the basic project objectives; (ii) infeasibility; and/or (iii) inability to avoid significant
environmental impacts.
Alternatives that were considered but rejected during the scoping process for detailed evaluation
in Section 6.5 Alternatives Considered but Rejected of the Draft Supplemental EIR are
discussed below:
9.1.1 Buildout of the Zoning Designation Alternative
The Buildout of the Zoning Designation Alternative would entail buildout of the project site
pursuant to the standards and regulations in the City's SD-48, amended in January 1989.' The
SD-48 permitted uses include, but are not limited to, retail specialty, office, restaurants, specialty
markets, beauty salons, banks, and theaters. Conditional uses permitted included live dance
entertainment and alcoholic beverage sales. The SD-48 also includes development standards for
parking for land use types, building setbacks (at a minimum of 15 feet), height (at a maximum of
35 feet), landscaping, signage, and building uses. The project site is currently occupied by the
South Coast Plaza Village commercial center on both sides of South Plaza Drive which consists
of approximately 164,049 square feet of retail shops and restaurants, offices, and the Regency
Theatres cinema building.The majority of the buildings are at the maximum height of 35 feet.The
property also provides surface parking, a variety of trees and a half-acre open space lawn area.
Therefore, the existing development at the project site is reflective of the standards established
under SD-48. It is not realistic that the site would be redeveloped with new or modified commercial
uses consistent with the existing SD-48 zoning. Additionally, the permitted uses under the SD-48
do not allow for residential, office, or open space uses.
1 City of Santa Ana, January 17, 1989, Specific Development No. 48,Amendment Application 1017 NS-1997.
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Finding: The City Council rejects the Buildout of the Zoning Designation Alternative, on the
following grounds, each of which individually provides sufficient justification for rejection of this
alternative: (1) this alternative would not achieve the basic project objectives of developing a
residential mixed-use residential project and would not implement the GPU's vision for the South
Bristol Street Focus Area; and (2) the alternative is technically, financially, and legally infeasible
given that the existing development at the Project site is reflective of the standards established
under SD-48 and it is not realistic the site would be redeveloped with new or modified commercial
uses consistent with the existing SD-48 zoning Thus, this alternative was eliminated from
further consideration
9.1.2 Off-Site Alternative
According to State CEQA Guidelines Section 15126.6[f][2][A], only locations that would avoid or
substantially lessen any of the significant effects of the project need be considered for inclusion
in the EIR. The Project would not cause any new significant impacts or substantial increase in
previously identified significant impacts from those identified in the GPU PEIR.
As discussed in the project objectives, a fundamental purpose of building out the Project at the
selected Project site is to implement the vision and objectives established in the City of Santa Ana
General Plan for the South Bristol Street Focus Area, primarily to transform auto-oriented
shopping plazas into walkable, bike-friendly, and transit-friendly urban villages. Thus, the Project
would redevelop an existing auto-oriented plaza that has already been disturbed by previous uses
and is served by existing services, avoiding the need for new construction at an undeveloped site.
Additionally, due to their age, the existing buildings at the South Coast Plaza Village have
outdated infrastructure, which results in operational inefficiencies and outdated seismic
code compliance.
The Project site is located in a fully developed urban area of the City of Santa Ana and acquiring
off-site property may not be financially reasonable or logistically feasible. Acquiring new property
outside of the existing project site would also not eliminate the need to transform the existing auto-
oriented shopping plazas in the South Bristol Street Focus Area into urban villages. Furthermore,
there are limited, if any available properties comparable to the Project site of sufficient size,
dimensions, and land use designation (District Center), and without existing residences that would
otherwise require displacement within the GPU-identified South Bristol Street Focus Area and
South Coast Metro Area that would allow for high-intensity mixed uses.
Finding: The City Council rejects the Off-Site Alternative, on the following grounds, each of which
individually provides sufficient justification for rejection of this alternative: (1)the alternative would
not meet project objectives; and (2) acquiring off-site property may not be financially reasonable
or logistically feasible. For these reasons, this alternative has been eliminated from
further consideration.
9.2 ALTERNATIVES SELECTED FOR FURTHER ANALYSIS
The following alternatives were selected for evaluation in Section 6.6 Alternatives Selected for
Further Analysis of the Draft Supplemental EIR:
• Alternative 1: No ProjecVNo Build Alternative
• Alternative 2: Reduced Project Alternative
• Alternative 3: Reduced Project with No Subterranean Parking Alternative
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Table 9-1: Summary Comparison of the Impacts of the Alternatives provides, in summary format,
a comparison between the level of impacts for each alternative and the Project. In addition, Table
9-2: Summary Comparison of the Alternatives' Ability to Meet Project Objectives provides a
comparison of the ability of each of the alternatives to meet the objectives of the Project.
9.2.1 Alternative 'I: No ProjectlNo Build
Pursuant to State CEQA Guidelines Section 15126.6(e), the EIR is required to evaluate and
analyze the impacts of a No Project Alternative. When the project is the revision of an existing
land use or regulatory plan, policy, or ongoing operation, the No Project Alternative includes 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.
Further, State CEQA Guidelines Section 15126.6(e)(3)(B) states, "In certain instances, the no
project alternative means `no build' wherein the existing environmental setting is maintained." In
addition,the No Project/No Build Alternative includes 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 new development would occur on the project site, and the
site would remain in its existing condition as the South Coast Plaza Village with seven existing
buildings, totaling approximately 164,049 square feet of existing commercial retail uses, with
surface parking and landscaping. In this alternative scenario, the seven buildings are assumed to
be fully operational as a shopping plaza with multiple retail uses, a restaurant, and a movie
theater. (Draft Supplemental EIR, p. 6-7.)
Environmental Effects: The No Project/No Build Alternative would result in the continued
operation of the existing South Coast Plaza Village, containing seven commercial buildings,
surface parking, and landscaping. Development and operation of the proposed mixed-use
development would not occur. As a result, the No Project/No Build Alternative would result in
reduced impacts related to construction and operation compared to the Project and would not
require the mitigation measures related to air quality, cultural resources,geology and soils, noise,
and tribal cultural resources. However, the benefits of the Project would also not occur, including
implementation of the GPU South Bristol Street Focus Area objectives; improvements to roadway,
pedestrian, bicycle infrastructure; low impact development (LID) -compliant infrastructure
improvements; provision of housing within a Transit Priority Area (TPA); and improvements to the
jobs/housing balance. Further, the No Project/No Build Alternative would not build out the GPU's
DC-5 designation as a major development activity area and anchor to the City's commercial
corridors and would not implement the GPU South Bristol Street Focus Area vision and objectives,
or the SCAG policies promoting high-density, infill development. This alternative also would not
assist in the improvement of the job/housing balance or reduction in vehicle miles traveled (VMT).
Therefore, this alternative would not be consistent with the GPU and would not implement the
City's land use plan to the same extent as the Project. Impacts under the No Project/No Build
Alternative related to land use would be greater than the less-than-significant impacts of the
Project. Generally, the impacts of the No Project/No Build Alternative would be less in severity
than those of the Project and would not require implementation of mitigation measures, with the
exception of land use and planning; however, this alternative would not implement the benefits
resulting from the Project. (Draft Supplemental EIR, pp. 6-8—6-13.)
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Attainment of Project Objectives: The No Project/No Build Alternative not meet any of the
project objectives listed in Section 2.3, Project Objectives. The No Project/No Build Alternative
would continue the operation of the existing South Coast Plaza Village and maintain the existing
seven commercial buildings and surface parking. The No Project/No Build Alternative would not
implement the mixed-use development, containing integrated residential and commercial uses,
which contributes to the creation of a vibrant urban core by enhancing community amenities,
recreational, and open space areas and providing alternative transportation and mobility options
in the GPU South Bristol Street Focus Area. The Project site would remain a conventional auto-
oriented shopping plaza with large surface parking areas. (Draft Supplemental EIR,
pp. 6-13—6-14.)
Findings: The City Council rejects Alternative 1: No ProjectlNo Build Alternative, on the following
grounds, each of which individually provides sufficient justification for rejection of this alternative:
(1)the alternative fails to meet any of the basic Project objectives; (2)the alternative would result
in increased impacts relating to land use and planning; and (3) the alternative is infeasible.
9.2.2 Alternative 2: Reduced Project Alternative
The Reduced Project Alternative would reduce the commercial square footage, change the
residential mix to reduce the number of residents, and remove the office uses from the mixed use
development to minimize operational impacts to volatile organic compounds associated with area
sources and construction-related impacts related to ground disturbance. Alternative 2 would
reduce the total commercial square footage to 50,000 square feet, provide 1,433 multi-family
residential units and 150 senior (age restricted) living units, and provide 7.5 acres of publicly
accessible parks/recreation facilities and open space. To support the Reduced Project
Alternative's mix of uses, the total number of parking stalls would be reduced to 2,296 stalls.
Further, the total amount of bicycle stalls would be reduced to 138 stalls. Maximum excavation
depths would reach 14 feet below ground surface (bgs) for one level of subterranean parking
under this alternative. (Draft Supplemental EIR, p. 6-14.)
Environmental Effects: The Reduced Project Alternative would result in a reduced magnitude
of construction-related impacts to air quality, GHG emissions, and noise. However, as with the
Project, impacts would still be less than significant or less than significant with mitigation, which
would be similar to those of the Project due to the similar types of construction activities.
During operation, the Reduced Project Alternative would be expected to result in reduced
emissions of criteria pollutants and GHGs, energy consumption, vehicle miles traveled, overall
population, and demand for public services, parks, and utility services. The overall reduction in
volume of these factors would occur primarily due to the reduced commercial square footage
elimination of office uses, and the replacement of some standard residential units with senior
living residences. The Reduced Project Alternative would provide 7.5 acres of publicly accessible
parks/recreation facilities and open space, resulting in a slightly higher recreation-to-resident ratio
of 2.1 acres per 1,000 residents than the Project. However, significant and unavoidable impacts
to recreation would remain. Although the volume of impacts would be reduced by the Reduced
Project Alternative in comparison to the Project, the Reduced Project Alternative would not
eliminate the significant and unavoidable recreation impacts or the less than significant impacts
of the Project. (Draft Supplemental EIR, pp. 6-14—6-20.)
Attainment of Project Objectives: The Reduced Project Alternative would meet the project
objectives, but not to the same extent as the Project. The Reduced Project Alternative would still
transform the conventional auto-oriented shopping plaza with large surface parking areas to a
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mixed-use development. However, this alternative would not maximize the opportunities to the
same extent as the Project as described in the Project objectives to incorporate a mix of high-
intensity office and residential living with experiential commercial uses as there would be fewer
retail services and no office uses. Although this alternative would still provide new retail services
and associated jobs, the fewer retail services would result in a net decrease of jobs from existing
conditions and would not complement the South Coast Metro area with a diversity of new housing
in a jobs-rich environment as strongly as the Project. (Draft Supplemental EIR, p. 6-21.)
Findings: The City Council rejects Alternative 2: Reduced Project Alternative, on the following
grounds, each of which individually provides sufficient justification for rejection of this alternative:
(1) the alternative fails to meet the basic Project objectives to the same extent as the proposed
Project; and (2) the alternative fails to avoid or reduce the Project's significant and unavoidable
impacts relating to recreation.
9.2.3 Alternative 3: Reduced Project with No Subterranean Parking Alternative
The Reduced Project with No Subterranean Parking Alternative would reduce residential and
commercial uses and remove office space to minimize operational impacts to volatile organic
compounds associated with area sources and avoid the construction-related impacts related to
ground disturbance required for subterranean parking(i.e., excavations below 14 bgs).Alternative
3 would reduce the number of residential units to 1,000 units, the total commercial area to 25,000
square feet, and the publicly accessible parks/recreation facilities and open space to 6.8 acres.
This alternative would not include the proposed subterranean parking level and associated
excavation activities and would reduce the overall length and magnitude of construction phasing.
Alternative 3 would construct two surface parking lots and a three-level parking garage in addition
to the podium parking levels within the residential buildings. To support Alternative 3, a parking
garage would be added to Block D(located in the northern central portion of the project site), and
surface parking would be added to Blocks F and H (located in the eastern central portion and the
center of the project site, respectively). The total amount of parking stalls would be reduced to
1,500 stalls, and the total amount of bicycle stalls would be reduced to 96 stalls. (Draft
Supplemental EIR, p. 6-21.)
Environmental Effects: The Reduced Project with No Subterranean Parking Alternative would
result in a reduced magnitude of impacts related to construction activities and resulting area and
depth of ground disturbance. As such, construction impacts related to air quality, cultural
resources, geology and soils, GHG emissions, noise, and tribal cultural resources would be
reduced. However, as with the Project, impacts would still be less than significant or less than
significant with mitigation, but residual impacts would be less when compared to those of
the Project.
During operation, the Reduced Project with No Subterranean Parking Alternative would be
expected to result in reduced emissions of criteria pollutants and GHGs, energy consumption,
vehicle miles traveled, overall population, and demand for public services and utility services.The
Reduced Project with No Subterranean Parking Alternative would provide 6.8 acres of publicly
accessible parks/recreation facilities and open space, resulting in a higher recreation-to-resident
ratio of 2.8 acres per 1,000 residents than the Project. However, significant and unavoidable
impacts to recreation would remain. Although the volume of impacts would be reduced by the
Reduced Project with No Subterranean Parking Alternative in comparison to the Project, the
Reduced Project with No Subterranean Parking Alternative would not eliminate the significant and
unavoidable recreation impacts or the less than significant impacts of the Project. (Draft
Supplemental EIR, pp. 6-27—6-28.)
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i
Attainment of Project Objectives: The Reduced Project with No Subterranean Parking
Alternative would not fully meet all of the project objectives. Though the Reduced Project with No
Subterranean Parking Alternative would transform the conventional auto-oriented shopping plaza
with large surface parking areas to a mixed-use development,this alternative would not maximize
the opportunities as described in the project objectives as there would be fewer retail services
and park space, no office uses, and no subsurface shared parking areas. The reduced
commercial and removal of office uses would result in a net decrease of jobs from existing
conditions that would not fully maximize the economic opportunities of the project site as
encouraged by the GPU or complement the South Coast Metro area with a diversity of new
housing in a jobs-rich environment. (Draft Supplemental EIR, p. 6-28.)
Findings: The City Council rejects Alternative 3: Reduced Project with No Subterranean
Parking Alternative, on the following grounds, each of which individually provides sufficient
justification for rejection of this alternative: (1) the alternative fails to meet the basic Project
objectives to the same extent as the proposed Project; and (2) the alternative fails to avoid or
reduce the Project's significant and unavoidable impacts relating to recreation.
9.3 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
CEQA requires a lead agency to identify the environmentally superior alternative when
significant environmental impacts result from a proposed project and, in cases where the "No
Project' Alternative is environmentally superior to the project, the environmentally superior
development alternative must be identified. The Environmentally Superior Alternative for the
proposed project would be the No ProjecttNo Build Alternative. When the No Project alternative
is identified as the environmentally superior alternative, the EIR shall also identify an
environmentally superior alternative among the other alternatives. (State CEQA Guidelines,
§15126.6(3)(1).) One alternative has been identified as "environmentally superior"to the Project:
the Reduced Project with No Subterranean Parking Alternative. The reduction or elimination of
project components under this alternative would result in reduced impacts to operational air
quality emissions, energy, GHG emissions, noise, population and housing, transportation, and
demand for public services and utility services. The Reduced Project with No Subterranean
Parking Alternative would still require mitigation measures during construction related to air
quality, cultural resources, geology and soils, noise, and tribal cultural resources, though the
residual impacts would be less than those of the Project.
Operation of the Reduced Project with No Subterranean Parking Alternative would still result in
less than significant impacts that are similar when compared to the Project for hazards and
hazardous materials, hydrology and water quality, and land use and planning. This alternative
would also result in reduced operational air quality emissions, eliminating the need for the Project-
Specific MM AQ-1.The Reduced Project with No Subterranean Parking Alternative would provide
6.8 acres of publicly accessible parks/recreation facilities and open space, resulting in a
recreation-to-resident ratio of 2.8 acres per 1,000 residents which is higher than the 1.2 ratio of
the GPU PEI R but lower than the CPU's parkland standard of 3 acres per 1,000 residents. Thus,
significant and unavoidable impacts to recreation would remain. Although the volume of impacts
would be reduced by the Reduced Project with No Subterranean Parking Alternative in
comparison to the Project, the Reduced Project with No Subterranean Parking Alternative would
not eliminate the significant and unavoidable recreation impacts or the less than significant
impacts of the Project. The Reduced Project with No Subterranean Parking Alternative would
provide fewer residential units, retail services, and no office uses, and thus would implement the
GPU South Bristol Street Focus Area objectives and many of the SCAG policies related to high-
Resolution No. 2025-041
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density, infill development, and improvement of the job/housing balance at a lesser extent than
the Project. However, impacts to land use and planning would be less than significant and similar
to those of the Project.
Overall, although the magnitude of impacts would be less under the Reduced Project with No
Subterranean Parking Alternative in comparison to the Project, the Reduced Project with No
Subterranean Parking Alternative would not eliminate the significant and unavoidable recreation
impacts, the less than significant impacts of the Project, or the need for mitigation.
In addition, the Reduced Project with No Subterranean Parking Alternative would not fully meet
all of the Project objectives. As previously discussed, though the Reduced Project with No
Subterranean Parking Alternative would transform the conventional auto-oriented shopping plaza
with large surface parking areas to a mixed-use development, this alternative would not maximize
the opportunities as described in the Project objectives as there would be fewer retail services
and park space, no office uses, and no subsurface shared parking areas. The reduced
commercial and removal of office uses would result in a net decrease of jobs from existing
conditions that would not fully maximize the economic opportunities of the Project site as
encouraged by the GPU. Overall, with the exception of a few Project objectives, this alternative
meets most of the Project objectives, but not to the same extent as the Project. (Draft
Supplemental EIR, p. 6-29.)
Resolution No. 2025-041
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CHAPTER 10
STATEMENT OF
OVERRIDING CONSIDERATIONS
10.1 INTRODUCTION
The City of Santa Ana is the Lead Agency under CEQA for preparation, review and certification
of the Supplemental EIR for proposed The Village Santa Ana Specific Plan Project (proposed
Project or The Village). 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 State 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, including region-wide or statewide
environmental 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, including region-wide or statewide environmental benefits,
of a proposed 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 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 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 Project, none of
which both meet the Project objectives and are environmentally preferable to the. Project for the
Resolution No. 2025-041
Page 110 of 140
reasons discussed in the Findings (as described in Chapter 7, Findings Regarding
Project Alternatives).
The City of Santa Ana, as the Lead Agency for this Project, and having reviewed the information
contained in The Village Santa Ana Specific Plan Draft Supplemental EIR and the Final
Supplemental EIR, including responses to comments, 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
the significant unavoidable adverse environmental impacts in reaching its decision to approve
the Project.
10.2 SIGNIFICANT UNAVOIDABLE IMPACTS
Although all potential project impacts have been substantially avoided or mitigated as described
in the preceding findings, there is no complete mitigation for the Project impacts related to
recreation. Details of the significant unavoidable adverse impacts related to recreation were
discussed in the Supplemental EIR and are summarized or were otherwise provided in the CEQA
Findings of Fact (as described above).
10.3 PROJECT BENEFITS
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
are considered acceptable due to the following specific considerations which outweigh the
unavoidable, adverse environmental impact of the Project, each of which standing alone is
sufficient to support approval of the Project, in accordance with Public Resources Code Section
21081(b) and State CEQA Guidelines 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:
o Capitalizing on the success of the South Coast Metro area;
o Introducing mixed-use urban villages and encouraging experiential,commercial
uses that are more walkable, bike friendly, and transit-oriented;
o Providing for mixed-use opportunities while protecting adjacent, established low
density neighborhoods.
• The Project fosters a neighborly environment where residents can live, work, and recreate
in a vibrant village community.
• The Project anchors Santa Ana's South Bristol Street Focus Area as envisioned by the
City to transform conventional auto-oriented shopping plazas into dynamic nodes of
activity that blend healthy living, working, shopping, and dining in a contemporary village
environment with 7.5 acres of publicly accessible open space and common areas which
captures Orange County's indoor-outdoor lifestyle.
• The Project allows for the flexible redevelopment of the underutilized project site to provide
a balanced mix of residential, retail, recreation, and office 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 and consistent with the GPU.
I
I
Resolution No. 2025-041
Page 111 of 140
• The Project will redevelop the underutilized and currently vehicle-centric site by
introducing a mixed-use development within a Pedestrian Opportunity Zone by developing
sidewalks, pedestrian pathways, and a fitness loop to encourage pedestrian mobility to
reduce overall VMT compared to the existing conditions.
• The Project provides a positive contribution to the local economy through new capital
investment, the creation of new jobs, development of more commercial opportunities,
attraction of economic activity, and the expansion of the tax base.
• The Project develops high quality residential spaces that reflect modern lifestyles, while
responding to the vision of the GPU to help bring higher density housing into a jobs-rich
area of the City planned for growth, to facilitate balancing the City's jobs-housing ratio.
• The Project includes new residential and mixed-use buildings that would provide housing
opportunities for residents in the City's South Bristol Street Focus Area which
complements the successful South Coast Metro area with a diversity of new housing in a
jobs-rich environment and implements the goals and policies of SCAG's Regional
Transportation Plan/Sustainable Communities Strategy.
• The Project enhances alternative transportation activity by creating a walkable and
bikeable mixed-use development that links with existing facilities and transit services to
encourage non-automotive travel within the Specific Plan area and the local community.
• The Project contributes to the creation of a vibrant urban core for the City by providing
vibrant and attractive community amenities, recreational and open space areas, and
gathering spaces that are directly accessible to residents and the community, and takes
advantage of the site's location within the South Coast Metro area.
• The Project provides 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 Sunflower Avenue and Bear Street.
10.4 CONCLUSION
The City Council finds that each of the specific economic, legal, social, technological,
environmental, and other considerations, and the benefits of the Project separately and
independently outweigh the remaining significant, adverse impacts related to recreation and is an
overriding consideration independently warranting approval of the Project. The remaining
significant adverse impacts identified in Chapter 6 above, are acceptable in light of each of these
overriding considerations, and the substantial evidence that supports the enumerated benefits of
the Project can be found in the Findings of Fact herein, the Final Supplemental EIR, the Project
itself, and the record of all proceedings in connection with the approval of the Project. In the event
that any court decision or regulatory action results in a determination that there are additional
remaining significant impacts resulting from the City's approval of the Project that cannot be
avoided even with the incorporation of all feasible mitigation measures into the Project, the CEQA
Findings of Fact and Statement of Overriding Considerations herein shall be deemed to apply to
such additional remaining significant impacts.
Resolution No. 2025-041
Page 112 of 140
Exhibit B
Resolution No. 2025-041
Page 113 of 140
CHAPTER 4
MITIGATION MONITORING AND REPORTING
PROGRAM
The California Environmental Quality Act(CEQA) requires a lead or public agency that approves
or carries out a project for which an Environmental Impact Report has been certified which
identifies one or more significant adverse environmental effects and where findings with respect
to changes or alterations in the project have been made, to adopt a "reporting or monitoring
program for the changes to the project which it has adopted or made a condition of project
approval in order to mitigate or avoid significant effects on the environment" (CEQA, Public
Resources Code Sections 21081, 21081.6). In compliance with these requirements, the City of
Santa Ana, lead agency, has prepared the Mitigation Monitoring and Reporting Program (MMRP)
to ensure that adopted mitigation measures are successfully implemented for the Village Santa
Ana Specific Plan Project (project). The MMRP for the project, presented as Table 4-1, lists the
mitigation measures by environmental topic and identifies the timing for each measure, the
responsible party, and the monitoring party. The City of Santa Ana is the lead agency for the
project and is responsible for implementation of the MMRP.
Any modifications to the terms and/or timing of the mitigation measures in this MMRP shall provide
a level of environmental protection equal to, or greater than the approved mitigation measure.
The City of Santa Ana, in conjunction with any appropriate agencies or City departments, shall
determine the adequacy of any proposed modifications and, if necessary, may refer said
determination to the Planning Commission and/or City Council. Any costs associated with
information required to make a determination of adequacy shall be borne by the Applicant. No
changes to the MMRP shall be permitted unless the MMRP continues to satisfy the requirements
of CEQA as determined by the City, the lead agency for the project.
Resolution No. 2025-041
Page 114 of 140
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