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Rio Santiago Project
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SCH NO. 2009051072
Final Environmental Impact Report
Response to Comments,
Errata to Draft EIR, and
Mitigation Monitoring and Reporting Program
City of Orange - December 2013
EXHIBIT C �'���
� FEIR NO 1818-09(RESPONSE TO COMMENTS., C O M M U N I T Y P l A N N E R S
ERRATA TO DEIR AND MITIGATION I 278 G lenne re Street,SUlte � �0
MONITORING&REPORTING PROGRAM) Y
RIO SANTIAGO Laguna Beach,CA 9265 I
MAY 13,2014 CC MTG.
FINAL ENVIRONMENTAL IMPACT REPORT
RESPONSE TO COMMENTS�ERRATA TO DRAFT EIR�
AND MITIGATION MONITORING AND REPORTING PROGRAM
RIO SANTIAGO PROJECT
CITY OF ORANGE, CALIFORNIA
STATE CLEARINGHOUSE NO. 2009051072
LEAD AGENCY:
CITY OF ORANGE
300 EAST CHAPMAN AVENUE
ORANGE,CALIFORNIA 92g6E-150g
PREPARED BY:
VISTA COMMUNITY PLANNERS(VISTA�
12�8 GLENNEYRE STREET, SUITE 110
LAGUNA BEACH,CALIFORNIA 92561
CONTACT:
FRED TALARICO,PRINCIPAL
JAKKI TONKOVICH,PROJECT MANAGER
(949)494-6562
DECEMBER 2013
TABLE OF CONTENTS
Section Page
Tableof Contents.................................................................................................................i
Listof Appendices..............................................................................................................iv
1.0 INTRODUCTION......................................................................................................... 1-1
1.1 Purpose............................................................................................................... 1-1
1.2 Recirculation Consideration............................................................................... 1-2
1.3 Process................................................................................................................ 1-3
1.4 Organization of the EIR..................................................................................... 1-4
2.0 MASTER RESPONSES................................................................................................2-1
2.1 Introduction.....................................................................................................2.1-1
2.2 Aesthetics........................................................................................................2.2-1
2.3 Hazards and Hazardous Materials...................................................................2.3-1
2.4 Hydrology and Flooding.................................................................................2.4-1
2.5 Land Use and Planning....................................................................................2.5-1
2.6 Open Space......................................................................................................2.6-1
2.7 Recreation........................................................................................................2.7-1
2.8 Transportation and Traffic...............................................................................2.8-1
2.9 Cumulative Impacts.........................................................................................2.9-1
2.10 Alternatives...................................................................................................2.10-1
2.11 Public Participation Process..........................................................................2.11-1
2.12 Biological Resources.....................................................................................2.12-1
3.0 COMMENTS AND RESPONSES...............................................................................3-1
3.1 Introduction........................................................................................................ 3-1
3.2 Correspondence Received.................................................................................. 3-1
3.3 Comments and Responses.................................................................................. 3-3
4.0 ERRATA TO THE DRAFT EIR.................................................................................4-1
4.1 Introduction........................................................................................................4-1
4.2 EIR: Universal Changes....................................................................................4-1
43 EIR: Page Specific Changes............................................................................4-18
5.0 MITIGATION MONITORING AND COMPLIANCE PROGRAM........................5-1
5.1 Introduction........................................................................................................ 5-1
APPENDICES
APPENDIX A PUBLIC PARTICIPATION PROCESS
APPENDIX B BIOLOGICAL SURVEYS
APPENDIX C SANTA ANA RIVER, SANTIAGO CREEK GREENBELT PLAN, 1971
APPENDIX D SANTA ANA RIVER/SANTIAGO CREEK GREENBELT
IMPLEMENTATION PLAN
City of Orange-Response to Comments/Final EIR—December 2013 Page i
Rio Santiago Project SCH No. 2009051072
�E�:TI� ��{�:��T� .,� T�� � _ - - - _
1.1 Purpose
The City of Orange Community Development Department, Planning Division (City), as the Lead Agency
under the California Environmental Quality Act (CEQA), has prepared a Final Environmental Impact
Report (Final EIR) for the proposed Rio Santiago Specific Plan (State Clearinghouse No. 2009051072)
within the City. The Final EIR contains all of the required contents as outlined in Section 15132 of the
State CEQA Guidelines,including the following:
• The Draft EIR or a revision of the Draft EIR.
. Comments and recommendations received on the Draft EIR either verbatim or in summary.
• A list of persons, organizations, and public agencies commenting on the Draft EIR.
. The responses of the Lead Agency to significant environmental points raised in the review and
consultation process.
• Any other information added by the Lead Agency.
This volume of the Final EIR consists of the public and agency comments on the Draft EIR, City
responses, and a Mitigation Monitoring and Compliance Program. Pursuant to Section 15088 of the State
CEQA Guidelines, the City has reviewed all comments received on the Draft EIR. Responses to these
comments are presented in Chapter 2.0, Master Responses and Chapter 3.0, Comments and Responses, of
this volume of the Final EIR. Any revisions to the Draft EIR based on these comments are contained in
Chapter 4.0,Errata to the Draft EIR, of this volume of the Final EIR in revision mode text(i.e., deletions
are shown with *��'����and additions are shown with italics).
Public and agency comments on the Draft EIR and City responses to these comments are an important
part of the CEQA process because they allow:
. Agencies and the public the opportunity to review and comment on the methods and analyses
contained in the Draft EIR.
. The ability to detect any omissions that may have occurred during the preparation of the Draft
EIR.
. The ability to check for accuracy of the analysis of the Draft EIR and make any necessary
revisions.
. The ability to discover and respond to public concerns.
City of Orange-Response to Comments/Final EIR—Decem6er 2013 Page 1-1
Rio Santiago Project SCH No. 2009051072
1.0 Introduction
1.2 Recirculation Consideration
In responding to public and agency comments, information has been added to clarify and expand upon the
impact discussions contained in the Draft EIR In some cases mitigation measures have been added or
revised.
In light of the information provided in response to public review comments, the City considered the need
to recirculate the EIR pursuant to CEQA. CEQA Section 15088.5(e)requires that an EIR which has been
made available for public review, but not yet certified, be recirculated whenever significant new
information has been added to the EIR. The entire document need not be recirculated, if revisions are
limited to specific portions of the document. The recirculated portions or document must be sent to
responsible and trustee agencies for consultation and fresh public notice must be given in the manner
provided for a draft EIR. New information is not presumed to be significant simply because it is new.
Indeed,pursuant to State CEQA Guidelines Section l 5088.5:
New information added to an EIR is not "significant" unless the EIR is changed in a way that
deprives the public of a meaningful opportunity to comment upon a substantial adverse
environmental effect of the project or a feasible way to mitigate or avoid such an effect . . . that
the project's proponents have declined to implement.
State CEQA Guidelines, § 15088.5(a):
In arder to be "significant,"the new information must constitute one of the following:
(1) A new significant environmental impact would result from the proj ect or from a new
mitigation measure proposed to be implemented.
(2) A substantial increase in the severity of an environmental impact would result unless
mitigation measures are adopted that reduce the impact to a level of insignificance.
(3) A feasible project alternative or mitigation measure considerably different from other
previously analyzed would clearly lessen the environmental impacts of the project, but the
project's proponent decline to adopt it.
(4) The draft EIR was so fundamentally and basically inadequate and conclusory in nature that
meaningful public review and comment were precluded.
(State CEQA Guidelines, §15088.5(a)(1)-(4); Laurel Heights II, 6 Ca1.4th at 1120.)
Neither the additional analyses provided in the Section 2.0, Master Responses, and Section 3.0, Response
to Comment, nor any mitigation measures discussed or amplified in the responses to comments results in
new or substantially increased significant impacts, and therefore no recirculation is required. It is
common, and in most cases necessary, far responses to comments to amplify and elaborate on the analysis
of an EIR. Such amplification, however, does not constitute significant new "information" unless it
triggers one of the four categories described in State CEQA Guidelines Section 15088.5(a). State CEQA
Page 1-2 City of Orange-Response to Comments/Final E/R—December 2013
SCH No. 2009051072 Rio Santiago Project
1.0 Introduction
Guidelines Section 15088.5(b) provides that "recirculation is not required where the new information
added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR."
[emphasis added]. The responses to comments and associated analysis properly fall within State CEQA
Guidelines Section 15088.5(b) and do not implicate State CEQA Guidelines Section 15088.5(a).
Some commenters expressed the opinion that recirculation of the Draft EIR was required based on an
assumption that mitigation measures and additional information would be "added" to the Draft EIR.
However, the discussions in added to each section of this response to comments document merely serve
to clarify or slightly modify the mitigation that would be already explicitly or implicitly implemented in
the Draft EIR.
However, in order to clarify that these additional measures would be implemented, they would be
incorporated into the EIR." This type of clarification is exactly what State CEQA Guidelines Section
15088.5(b) contemplates when it states that no recirculation is required when the new information
"merely clarifies"the analysis of the EIR.
A concern was expressed that these new measures and PDF's could be construed as "significant new
information" requiring recirculation. However, simply adding mitigation measures and PDF's does not
trigger recirculation. Instead, the test is whether new information added to an EIR changes the document
in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse
environmental effect of the project. None of the mitigation measures, PDF's, or the analysis in the
responses to comments comes close to meeting that standard. Therefore,recirculation is not required.
1.3 Process
As the Lead Agency for the project, the City took several steps to ensure that all interested parties had an
opportunity to comment on the Draft EIR, in accordance with Article 7, EIR Process, of the State CEQA
Guidelines (Section 15087 et. seq.). The Draft EIR was submitted to the Governor's Office of Planning
and Research, State Clearinghouse, which established a 45-day public review period from May 16, 2013
to July 1, 2013. The Draft EIR and its Appendices were available for public review online at
http://www.citvoforan�e.org/depts/commdev and at the following locations during the public review
period:
City of Orange City of Orange
Community Development Department City Clerk
Planning Division 300 East Chapman Avenue
300 East Chapman Avenue Orange, California 92866
Orange, California 92866
Orange Public Library& History Center El Modena Branch Library
407 East Chapman Avenue 380 South Hewes Street
Orange, California 92866 Orange, California 92866
City of Orange-Response to Comments/Final EIR—December 2013 Page 1-3
Rio Santiago Project SCH No. 2009051072
1.0 Introduction
Charles P. Taft Branch Library
740 East Taft Avenue
Orange, California 92866
The Notice of Availability(NOA) of the Draft EIR was posted at the City of Orange Clerk's office during
the public review period. The site was also posted in six perimeter locations and posting also occurred at
Linda Vista Elementary School. The NOA was mailed to various agencies and organizations and to
individuals that had previously requested such a notice. Additionally, the NOA was published in the
following newspaper publication on the following dates:
Orange City News May 16, 2013
1.4 Organization of the EIR
The contents of this volume of the EIR include the information required to be in compliance with CEQA.
In addition to this Introduction section, the remainder of the document is organized into the following
main sections individually described below. This document contains the following chapters:
Chapter 2.0: Master Responses
This section contains master responses to comments received during the public/agency review period.
Chapter 3.0: Comments and Responses
This section contains comments and responses to comments received during the public/agency review
period.
Section 4.0: Errata to the Draft EIR
?'his section identifies changes to the Draft EIR as a result of comments or corrections.
Section 5.0: Mitigation Monitoring and Compliance Program
This section provides the mitigation program that may be ador� ;.ouncil as part of the Final
EIR,pursuant to Public Resources Code Section 21081.F
Page 1-4 City of Orange-Response to Comments/Final E/R—December 2013
SCH No. 2009051072 Rio Santiago Project
��C�'��N �.���;A��►�'E���PC�N�E� 
2.1 Introduction
2.1.1 Background
This section provides an overview of the issues from the comments received on the Draft Environmental
Impact Report(Draft EIR). These issues were identified by a number of commenters and are summarized.
Each issue area is described below by topic and in several instances by subtopic. Following each issue
summary is a response. The order of the Master Responses does not reflect the importance of any single
issue in relation to all of the others. The issues are presented in the order they appear in the Draft EIR.
The City wishes to express its appreciation to each agency, group, and individual who took the time to
review the Draft EIR and to provide comments. The Draft EIR has been modified as appropriate in
response to the comments received, and the proposed project has been appropriately modified as a result
of the comments received. Please note that changes to the Draft EIR are in revision mode text (i.e.,
deletions are shown with strikethrough and additions are shown with italics). These notations indicate
changes to the Draft EIR to provide clarification, corrections, or revisions as needed as a result of public
comments or due to additional information that was received during the public review period. For a
complete list of changes to the Draft EIR,please refer to Section 4,Errata to the Draft EIR.
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.1-1
Rio Santiago Project SCH No. 2009051072
2.2 Aesthetics
Several commenters expressed concerns related to aesthetic issues. The majority of these concerns
related to the following items:
1. A concern with potential impacts on scenic views and vistas.
2. A concern with the proposed project's potential incompatibility with the rural
environment/community character in the area.
3. A concern with potential light and glare impacts created by Planning Area B recreational uses.
4. A concern with structure heights was expressed. This concern included two-story structures in
Planning Area D and three-story structures in Planning Area C.
Section 5.1, Aesthetics describes potential impacts to visual resources on the project site, which may
result from the construction and operation of the proposed project. This section of the Draft EIR also
identifies mitigation measures to reduce any potentially significant land use and planning impacts and
describes the residual impact, if any, after imposition of the mitigation. The analysis used the following
thresholds of significance consistent with Appendix G of the State CEQA Guidelines:
Threshold AES-A Would the proposed project have a substantial adverse effect on a scenic vista?
Threshold AES-B Would the proposed project substantially damage scenic resources, including,
but not limited to, trees, rock outcroppings, and historic buildings within a state
scenic highway?
Threshold AES-C Would the proposed project substantially degrade the existing visual character
or quality of the site and its surroundings?
Threshold AES-D Would the proposed project create a new source of substantial light or glare
which would adversely affect day or nighttime views in the area?
2.2.1 Scenic Vistas &Views
Commenters requested infortnation related to the criteria for establishing "o�cially designated scenic
vistas". They expressed concern that the Draft EIR failed to adequately analyze the impacts of the
proposed project on aesthetics. They noted that the substantial raising of the project site by an estimated
10 feet for building pads with subsequent development above would eliminate scenic vistas from
Santiago Canyon Road and nearby viewpoints. They noted that in their opinion the Draft EIR should have
included clear exhibits showing pre and post-project visual conditions. Finally, commenters had the
opinion that the proposed project would ruin their view and decrease the value of their property and the
area as a whole.
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.2-1
Rio Santiago Project SCH No. 2009051072
2.2 Aesthetics
Vista and View Analysis
Evaluation of the project impacts related to scenic vistas is located in Draft EIR Section 5.1, Aesthetics
Threshold AES-A (Scenic Vistas). Additionally, evaluation related to the consistency of the proposed
project related to views of ridgelines is located in Draft EIR Section 5.10, Land Use and Planning Table
5.10-2, Project Consistency with the City of Orange General Plan. Please refer to Master Response
Section 2.5,Land Use and Planning related to the City's General Plan.
The Draft EIR notes that the City General Plan describes a viewshed as the space that is readily visible
from the public areas of the City. It is desirable that the views provided be inviting, meaningful, or even
scenic. Further, the Draft EIR notes that the City has not established specific criteria to evaluate impacts
to a scenic view in the community. Therefore, for the purposes of the Draft EIR, impacts to a scenic view
will be evaluated based on the following: "... sensitive public views that would be most affected by the
subject action (e.g., the greatest intensity of impact due to viewer proximity to the project and project
visibility, duration of the affected view, etc.)." The Draft EIR states that, "There are no adopted scenic
vistas identified in the City's or any Agency's general plan, specific plan, or zoning ordinance on or
=--�mediately adjacent to the project site. As noted above, Santiago Creek is not designated as a scenic
��an adopted plan."(Page 5.1-19 of the Draft EIR) The following discusses the findings of the EIR
related to vista and view impacts of the proposed project. Refer to Section 2.5,Land Use and Planning
for detailed information related to the consistency of the proposed project with adopted public policies
related to vistas and views.
Short-Te�m Const�uction
Related to Planning Area A, the Draft EIR found that the short-term construction impacts of the proposed
project would be anticipated to be consistent with the permitted, on-going backfilling operation.
However, grading and construction of infrastructure improvements for drainage and flood control are
project specific actions. PDF AES-14 and Mitigation Measure AES-1 would reduce construction impacts
(Impact AES-1); however, these would not eliminate this potential perceived short-term visual impact.
Therefore, the proposed project would have an unavoidable short-term significant impact on scenic views
di�ring construction activity. (Page 5.1-17 of the Draft EIR)
Related to Planning Areas B and C the Draft EIR found that the proposed project construction activities in
Planning Areas B and C would not be anticipated to significantly impact scenic vistas as views would
remain similar to the existing conditions at the time of the NOP (backfill operation). Therefore, a less
than significant impact would occur and no mitigation measures are proposed. (Page 5.1-17 of the Draft
EIR)
Related to Planning Area D, the Draft EIR found that the proposed project would have an unavoidable
short-term significant impact on scenic views during construction activity. This impact would be
temporary; however, it may be perceived as substantially degrading the visual character of the vacant
portion of Planning Area D. Therefore, the proposed project would have an unavoidable short-term
significant impact on scenic views during construction activity.
Page 2.2-2 City of Orange-Response to Comments/Final E/R—December 2013
SCH No. 2009051072 Rio Santiago Project
2.2 Aesthetics
Long-Term Operation
Related to Planning Area A, the Draft EIR found that the proposed project provides for the re-vegetation
of the areas subject to flood-control improvements. The multi-purpose trail is not anticipated to be
considered a substantial degradation of the visual character of the Planning Area. Therefore, a less than
significant impact would occur and no mitigation measures are proposed for this area. (Page 5.1-31 of the
Draft EIR) Related to Planning Areas B, C, and D, the Draft EIR found that the development in these
areas may be perceived as substantially degrading scenic views to and of the project site. Therefore, an
unavoidable long-term visual impact would occur. (Page 5.1-31 of the Draft EIR) This long-term
unavoidable visual impact includes views of distant ridgelines. Please refer to Draft EIR Section 5.1,
Aesthetics specifically Impacts AES-1,AES-2, and AES-3. The Draft EIR does indicate that the proposed
project may be perceived as:
Impact AES-1: Substantially degrading the short-term visual impact on a portion of Planning
Area A.
Impact AES-2: Substantially degrading the short-term visual impact on a portion of Planning
Area D.
Impact AES-3: Substantially degrading the long-term visual character of a portion of the project
site, including Planning Areas B, C, and D.
The Draft EIR states that adjacent properties and roadways have visual access to the project site. Figure
5.1-4, View Analysis through Figure 5.1-12, View Analysis of the Draft EIR provide existing and photo
simulations of the proposed project. Photo simulations are provided for the same views as existing
conditions as indicated on Figure 5.1-2, Photograph Location Map, and Figure 5.1-3, Project Site
Photographs of the Draft EIR.
The proposed project would alter existing views in the project vicinity as described in Table 5.1-2, Scenic
View Analysis. It is the opinion of the City that these figures show pre-and post-project visual conditions
on the project site. The height of the project's building in proximity to East Santiago Canyon Road, as
noted above, could block views of distant ridgelines. This long-term unavoidable visual impact includes
views of distant ridgelines. Commenters had the opinion that the proposed project would "ruin"
(emphasis added) their view and decrease the value of their properties and the area as a whole. The
consideration of a projects effect on adjacent property values is not a CEQA consideration and such
analysis would be speculative. CEQA requires only the analysis of effects that are reasonably foreseeable
and not changes that are speculative in nature. It is the opinion of the City that commenters' concerns are
speculative in nature. Therefore,no further analysis of these concerns is warranted.
The Draft EIR does indicate that the proposed project may be perceived as:
Impact AES-1: Substantially degrading the short-term visual impact on a portion of Planning
Area A.
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.2-3
Rio Santiago Project SCH No. 2009051072
2.2 Aesthetics
Impact AES-2: Substantially degrading the short-term visual impact on a portion of Planning
Area D.
Impact AES-3: Substantially degrading the long-term visual character of a portion of the project
site, including Planning Areas B, C, and D.
The Draft EIR indicates that with the inclusion of Mitigation Measures AES-1 through AES-3, the project
impacts would be reduced; however, a significant unavoidable impact related to scenic views in the short-
term Planning Area A (Impact AES-1) and Planning Area D (AES-2) and long-term to Planning Areas
B,C, and D (Impact AES-3) would occur. The opinions of commenters related to scenic views and vistas
do not change the analysis or conclusions of the Draft EIR because they does not raise any factually based
issues related to the adequacy of environmental analysis conducted in the Draft EIR. Therefore, no
further analysis of this concern is warranted.
2.2.2 Rural Character/Community Character
In opposition to the proposed project, several commenters expressed the opinion that the proposed project
is deeply flawed and not at all in keeping with the current "rural" environment in which it is proposed.
The commenters suggested that the proposed project will have a dramatic change on the current character
of the area, irreversibly changing the aesthetic quality of this portion of the City and impacting the City of
Villa Park.
Several commenters suggested that they enjoy a "rural" lifestyle in Orange Park Acres. They indicated
that the nature of the project as a whole, and its impact to the character of the surrounding community has
not been adequately analyzed, and where the analysis has been done, it misstates the project's impact on
that character. The commenters noted that this area has maintained a rural, equestrian character for
decades, and to the extent this project claims to be consistent with this character, that claim is not
supported by the actual project facts. It was their opinion that the Draft EIR does not adequately provide
information and review of how the development will impact the character and compatibility of the
existing, established neighborhoods with this new development.
Commenters noted that the Draft EIR should have carefully analyzed the effects the proposed project
would have on the community's unique character and identify a less intense project with mitigation
measures capable of reducing impacts to below a level of significance in accordance with City and CEQA
criteria. Commenters recommended that such a proposal should have included retaining the land use
plans (i.e., EO General Plan, OPA Plan, and etc.) and designations to ensure compatibility with the
surrounding community and a more substantial dedication of permanent open space lands adjacent to
Santiago Creek to adequately offset the impacts of a proposed development. Please refer to Section 2.5,
Land Use and Planning for additional information regarding land use plans and the proposed project.
In support of the proposed project, several commenters offered their opinion that the proposed plan,
removes the current rock crushing operation. It was their opinion that the proposed project would result
in better air, visual aesthetics and reduced operational noise. They stated that the open space on the
project site is anything but pristine and improvements are welcome and would enhance the community
character.
Page 2.2-4 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.2 Aesthetics
Supportive commenters offered their opinion that the issue of"visual character" is subjective but they did
not see how the DEIR could find that the loss of material crushing and backfill operations and their
associated noise and dust impacts could be a significant and unavoidable impact in comparison to the
completed proposed project.
The supportive commenters suggested that a less than significant aesthetic impact would result with the
project constructed in place of the crushing and backfilling operation. It was their opinion that the
conclusion of the Draft EIR related to project aesthetic impacts is incorrect. Hence, several commenters
suggested that the proposed project represents an aesthetically positive impact.
Character Analysis
As noted above, commenters expressed opinions that the proposed project would substantially improve or
degrade the existing quality of the project site and its surroundings and would enhance the community
character. The Draft EIR notes that the natural and manmade physical features of a community form an
overall impression of an area. This impression is referred to as "visual character." The Draft EIR studied
the visual character as a point of reference to assess whether the proposed project would appear
compatible with the established features of the setting/project area or would contrast noticeably and be
deemed unfavorably with them. Based on the comments to the Draft EIR, it would appear that some
commenters agreed and some disagreed with the findings of the Draft EIR.
The Draft EIR found that the proposed project does not propose changes to the existing visual character
or quality of the surrounding community. (Page 5.1-34 of the Draft EIR) Figure 5.1-13, Communiry
Character Summary has been added to the EIR to provide additional clarity related to the discussion of
the character analysis. Figure 5.1-13, Communiry Character Summary provides the local names, land use,
relative age of construction, density, and other similar characteristics of surrounding areas. Based on
information provided the lots range from 4,500 square feet to over an acre. The neighborhood includes
duplexes to estate lots. The earliest construction occurred in 1925 and has continued until the present.
Entry monumentation ranges from none to elaborate monumentation projects. Street widths range from
22 feet wide to 60 feet wide, with over 10 different paving widths including parking on one or both sides.
Curb styles are either none, rolled andlor square. Sidewalks range from none to both sides. Lighting
ranges from none to tall metal poles. The majority of the community lighting is tall metal poles. The
buildings are both one and two-story. Based on the above information it is responsible to state that there
is no one singular community character in the vicinity of the project site. The community character
within the area is established by its eclectic nature.
Off-Site
The proposed project would change the visual and community character of two off-site areas. The
proposed project would provide off-site improvements to East Santiago Canyon Road and a 2.01 acre area
adjacent to Santiago Oaks Regional Park.
East Santiago Canyon Road
The East Santiago Canyon Road off-site improvements are identified in the Rio Santiago Specific Plan,
on the Tentative Tract Map, and as Project Design Features (PDF's) in the Draft EIR. They are described
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.2-5
Rio Santiago Project SCH No. 2009051072
2.2 Aesthetics
in detail in Section 3.0, Project Description of the Draft EIR. Figure 5.1-14, Rio Santiago Entr�ance
Improvements provides an illustrative of the off-site improvements at the project entrance. Figure 5.1-14,
Rio Santiago Entrance Improvements shows the signalization, lighting, trail crossing, and landscape
median on East Santiago Canyon Road. Figure 5.1-15, Views Along Santiago Canyon Road provides
examples of the existing views along East Santiago Canyon Road in the vicinity of the project.
Specifically, the PDF's that provide for the off-site changes in visual character related to East Santiago
Canyon Road include:
1. PDF TRA-5: This PDF provides that the proposed project will provide two signalized primary
vehicle access points to East Santiago Canyon Road from the project site. The signals will be
provided prior to occupancy of the adjacent Planning Areas.
2. PDF TRA-15: This PDF provides that the proposed project will include a signalized trail
crossing at the main entrance to the project site on East Santiago Canyon Road. The signalized
trail crossing will provided connectivity for to/from recreational trails and the Mara Bradman
Arena by facilitating a street crossing.
3. PDF TRA-16: This PDF provides that the proposed project in conjunction with the development
of adjacent land uses in Planning Areas B, C and D will provide a landscaped raised median in
accordance with City Standards on East Santiago Canyon Road. The raised landscaped median
will be implemented no later than the issuance of the last Certificate of Occupancy for Planning
Area C or D. (Page 3-73 and 3-74 of the Draft EIR)
Page 2.2-6 City of Orange-Response to Comments/Final E/R—December 2013
SCH No. 2009051072 Rio Santiago Project
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2.2 Aesthetics
character of the surrounding community and no mitigation would be required. (Page 5.1-34 of the Draft
EIR)
On-Site
The Draft EIR found that the proposed project would alter the existing visual and community character of
the project site with the elimination of existing on-site current uses. At issuance of the NOP, the project
was being used for materials recycling on approximately 5 acres located currently in the southeastern
portion. The majority of the project site to the south of Santiago Creek was being backfilled and contains
the backfill operations and associated uses. The remainder of the project site was vacant.
As mentioned above, the Draft EIR found that the proposed project may be perceived as substantially
degrading the long-term visual character of portions of the project site, including Planning Area D
(Impact AES-3). PDF AES-1 through PDF AES-6, PDF AES-8 through PDF AES-16, PDF AES-21, and
PDF AES-22, would reduce potential long-term impacts related to the proposed project improvements in
Planning Area D. However, the Draft EIR concluded that the development in this area may be perceived
as substantially degrading the visual character of a portion of Planning Area D. Mitigation Measure AES-
3 would reduce Impact AES-3, however not to a less than significant level. Therefore, an unavoidable
long-term visual impact would occur.
The opinions of commenters related to "rural" character/community character do not change the analysis
or conclusions of the Draft EIR because they do not raise any factually based issues related to the
adequacy of environmental analysis conducted in the Draft EIR. Therefore, no further analysis of this
concern is warranted.
2.2.3 Light and Glare
Commenters expressed concern with the lighting of athletic fields in Planning Area B. In their opinion the
proposed project would create a source of light and glare for the nearby properties, particularly the homes
in Creekside Ranch. Creekside Ranch residences directly face Planning Area B. They stated that in their
opinion the new source of light and glare would adversely affect nighttime views. They requested that
aggressive measures taken to mitigate this issue. Specifically,they requested that the fields not be lighted
and only be available for daylight activities.
Commenters questioned the precise height of the proposed standards and lights for the proposed ball
fields in Planning Area B. They requested information related to the lumens to foot of the light cast.
They requested analysis of the light and glare impacts on existing housing in Jamestown, the Colony and
Mabury Ranch residential areas.
Commenters expressed concern with the conclusions of the Draft EIR related to light and glare. It was
their opinion that there is potential for light and glare impacts, and this impact is unknown because the
exact height of light standards, lumens and operational hours has not been provided.
Short-Term Construction
The Draft EIR found that alter the visual character of the project site would be temporarily impacted
during the short-term site preparation phase of the project by light and glare. Impacts would be related to
construction vehicles located on the project site, along East Santiago Canyon Road related to installing or
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.2-11
Rio Santiago Project SCH No. 2009051072
2.2 Aesthetics
modifying public utilities and water lines, construction materials stared on the project site, and project site
preparation activities that would create daytime glare from vehicles and materials. These activities are
short-term in nature, similar to the existing material recycling and backfilling operations, and would cease
at the completion of the project site preparation. The Draft EIR found that due to the short-term nature of
this activity, impacts are less than significant and no mitigation measures would be required. (Page 5.1-41
of the Draft EIR)
Long-Term Operation
The Draft EIR found that in Planning Area B active recreational uses such as ball fields/parks and other
similar uses would potentially introduce new sources of light and glare. This new source of light and
glare will create a night hue in the area where no lights currently exist. The Rio Santiago Specific Plan
requires that the proposed project limit the outdoor activities in Planning Area B to between 7 a.m. and
10 p.m. Furthermore, PDF AES-8 requires compliance with City's Municipal Code Title 17 Zoning,
Chapter 17.12, General Regulations Applicable to All Districts, Section17.12.030, Lighting, regulates
lighting of the proposed project.
Potential light and glare impacts would be reduced with PDF NOI-2, PDF AES-7, PDF AES-23, and PDF
AES-24, and the requirements of the Specific Plan; however, the impacts would not be eliminated.
Therefore,the following impact would have the potential to occur and mitigation is proposed:
Impact AES-5: The proposed project would have the potential to result in impacts related to
light and glare in Planning Area B.
MM AES-5: The project developer shall use Musco lights or similar products that are
specifically designed to reduce spillage, including shields and louvers. This
lighting shall be detailed on building permits for Planning Area B.
The Draft EIR found that the Rio Santiago Specific Plan outdoor lighting criteria, PDF NOI-2, PDF AES-
7, and Mitigation Measure AES-5 reduce sources of light and glare potential impacts (Impact AES-5) in
Planning Area B, however not to a less than significant level. Therefore, related to Planning Area B, new
sources of substantial light or glare, which could adversely affect nighttime views in the area, would be
anticipated to occur. This is an unavoidable impact of the proposed project. (Page 5.1-44 of the Draft
EIR)
The Draft EIR found in Planning Areas C and D that potential light and glare impacts would be reduced
with PDF AES-7, PDF AES-23, and PDF AES-24, and the requirements of the Specific Plan; however,
the impacts would not be eliminated. Therefore, the following impact would have the potential to occur
and mitigation is proposed:
Impact AES-6: The proposed project would have the potential to result in impacts related to
light and glare in Planning Areas C and D.
MM AES-6: Prior to the issuance of any building permit and as specified in the Specific Plan,
the project applicant shall submit a photometric analysis of Planning Areas C
Page 2.2-12 City of Orange-Response to Comments/Final E/R—December 2013
SCH No. 2009051072 Rio Santiago Project
2.2 Aesthetics
and D for review and approval by the City of Orange Community Development
Department and the City of Orange Police Department. The photometric
analysis shall provide evidence that the lighting design is consistent with the
City of Orange Municipal Code Ordinance 17.12.030 and has been designed to
provide for lighting that is directed, controlled, screened, and/or shaded such
that light and glare would not result in direct illumination on the surrounding
properties or roadways.
The Draft EIR found that the potential light and glare impacts (Impact AES-6) would be reduced with
PDF AES-7, the requirements of the Specific Plan, and Mitigation Measure AES-6, however not to a less
than significant level. Therefore, related to Planning Areas C and D new sources of substantial light or
glare, which would adversely affect day or nighttime views in the area, would be anticipated to occur.
This is an unavoidable impact of the proposed project. (Page 5.1-45 of the Draft EIR)
The opinions of commenters related to light and glare impacts do not change the analysis or conclusions
of the Draft EIR because they do not raise any factually based issues related to the adequacy of
environmental analysis conducted in the Draft EIR. As noted above the Draft EIR identified new sources
of light and glare in Planning Areas B, C, and D as a significant unavoidable impact of the proposed
project. Therefore,no further analysis of this concern is warranted.
2.2.4 Structure Height
Commenters questioned the proposed height allowances noting that homeowners in The Reserve
residential development along the boundary with the proposed project currently have views to the west
and north. They noted that it was not clear from a review of the grading plan (which provides for an
average grade elevation of 400 feet above median sea level), whether the finished grade adjacent to The
Reserve would be higher or lower than the existing grade adjacent to The Reserve. They were unable to
determine from the Draft EIR the degree to which the specific building height allowance of Planning Area
D would impair views of existing homeowners in The Reserve. They noted that grading equal to or lower
than the existing elevation grading would be preferred, in order to minimize adverse impact on views.
Additionally, noted was that single story homes rather than two-story homes would also minimize
negative impact on views.
Commenters expressed concern that the proposed project would include three-story structures in Planning
Area C which in their opinion would not be compatible with the surrounding neighborhoods. It was their
opinion that although the Draft EIR identified that the loss of view shed is a "non-mitigated impact"
(emphasis added) (i.e., Draft EIR notes this is a significant unavoidable impact) and the option of a
restriction to two-stories is not considered. They noted that in their opinion that this should not be
considered as "preservation of community character". Commenters opinioned that the three story
structures and associated density do not seem consistent with the adjacent neighborhoods.
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.2-13
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2.2 Aesthetics
Refer to analysis 2.2-1 Scenic Views and Vistas and 2.2-2 Rural Character/Community Character above.
Commenters have suggested that single story homes in Planning Area D would minimize negative
impacts on views. It should be noted that the City has not established a significance threshold related to
private view impacts. Therefore, the EIR does not address this concern. However, the Draft EIR does
provide a photo-simulation from The Reserve area. Refer to Figure 5.1-2, Photograph Locations Map
and location `B". Location "E" is shown on Figure 5.1-3, Project Site Photographs and Figure 5.1-8,
View Analysis E. Table 5.1-2, Scenic View Analysis provides the location of View E, describes the
location, and provides an analysis of impact. The analysis in Table 5.1-2,Scenic View Analysis states:
The proposed project would alter the view. The near view of Planning Area D would change
from materials recycling to single-family residential development. The mid-range view of the
materials recycling and backfill operations would be eliminated and replaced with single-family
residences (Planning Area D) and age-qualified residences (Planning Area C). No changes to the
distant views would occur. (Table 5.1-2, Scenic View Analysis)
As noted above, the Draft EIR concluded that the development in this area may be perceived as
substantially degrading the visual character of a portion of Planning Area D. Mitigation Measure AES-3
would reduce Impact AES-3, however not to a less than significant leveL Therefare, an unavoidable
long-term visual impact would occur. The City has evaluated a change from two-story to single-story
homes. This change would not alter the analysis presented in Table 5.1-2,Scenic view Analysis in that:
1. The near view of Planning Area D would change from materials recycling to single-family
residential development.
2. The mid-range view of the materials recycling and backfill operations would be eliminated and
replaced with single-family residences in Planning Area D.
3. No changes to the distant views would occur.
Based on this analysis and the threshold established by the City in the Draft EIR no further analysis is
warranted. The opinions of commenters related to three story structures does not change the analysis or
conclusions of the Draft EIR because does not raise any factually based issues related to the adequacy of
environmental analysis conducted in the Draft EIR. Therefore, no further analysis of this concern is
warranted.
Page 2.2-14 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.3 Hazards and Hazardous Materials
Several commenters expressed concerns regarding the potential hazards and hazardous effects from the
project implementation on the proposed site and its surrounding area. The majority of these concerns
related to the following issues:
1. The relationship of the proposed project to the adjacent former Villa Park Disposal Station; and,
2. A concern with potential of buried hazardous materials(i.e., asbestos) on the project site.
Section 3.0, Comments and Responses presents letters submitted during the public comment period for
the Draft EIR and responses to each comment.
Section 5.8,Hazards and Hazardous Materials of the Draft EIR describes existing hazards and hazardous
materials and potential effects from the project implementation on the project site and its surrounding
area. This section of the Draft EIR also identifies mitigation measures to reduce any potentially
significant hazards and hazardous materials impacts and describes the residual impact, if any, after
imposition of the mitigation. The analysis used the following thresholds of significance consistent with
Appendix G of the State CEQA Guidelines:
Threshold HA�A Would the proposed project create a significant hazard to the public or the
environment through the routine transport, use, or disposal of hazardous
materials?
Threshold HAZ-B Would the proposed project 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?
Threshold HAZ-C Would the proposed project emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste within one-quarter mile of an
existing or proposed school?
Threshold HAZ-D Would the proposed project 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, would it create a significant hazard to the public or the
environment?
Threshold HA�E For a proposed project located within an airport land use plan or, where such a
plan has not been adopted, within two miles of a public airport or public use
airport,would the proposed project result in a safety hazard for people residing or
working in the proposed proj ect area?
Threshold HAZ-F For a proposed project within the vicinity of a private airstrip, would the
proposed project result in a safety hazard for people residing or working in the
proposed project area?
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.3-1
Rio Santiago Project SCH No. 2009051072
2.3 Hazards and Hazardous Materials
Threshold HAZ-G Would the proposed project impair implementation of or physically interfere with
an adopted emergency response plan or emergency evacuation plan?
Threshold HAZ-H Would the proposed project expose people or structures to a significant risk of
loss, injury or death involving wildland fires, including where wildlands are
adjacent to urbanized areas or where residences are intermixed with wildlands?
2.3.1 Relationship to Former County Landfill
Exposure to Methane Gas
Commenters have expressed a concern with exposure to methane gases. The Draft EIR concluded that no
long-term operational impacts would be anticipated in Planning Areas A, B, and D because hazards or
hazardous materials identified in these planning areas will be mitigated to a less than significant level
with Mitigation Measure HAZ-1. Potential long-term operational impacts occurring in Planning Area C
include: Vapor intrusion of VOCs into future buildings.
Tait Environmental Services collected five soil vapor samples in Planning Area C that contained methane
at concentrations below one percent by volume. The possibility exists that this methane could infiltrate
buildings in Planning Area C and concentrate in rooms with limited air exchanges. The methane
concentration could exceed its lower explosive limit (5% by volume), creating a potentially explosive
mixture. Tait Environmental Services noted that the need for the remedial actions would be dependent on
final surface cover and final grade elevations for the areas of concern. They noted that the potential need
far remedial action would be reduced, when the distance between the detected methane-containing soil
vapor and the final grade increased. Tait Environmental Services noted that vapor barriers or
passive/active venting systems beneath buildings in Planning Area C would eliminate this concern.
Remedial actions could include mechanical stripping of Trichloroethene (TCE)-impacted soil in the
affected area. Impacts to long-term significant human health risk from TCE-impacted soils and/or
methane to users of residential buildings located in Planning Area C would be potentially significant
(Impact HAZ-2); however, with the incorporation of Mitigation Measure HAZ-2, impacts would be
reduced to less than significant levels.
Location of Habitable Structures
Commenters have expressed a concern with the location of habitable structures adjacent to the 17 acres
where the former Villa Park Disposal Station was located. The former Villa Park Landfill Station was
owned by the County from 1962 to 1966. Orange County Waste & Recycling (OCW&R) maintains the
landfill and monitors the former landfill site in order to ensure the public's safety. The County of Orange
Health Care Agency Environmental Health Division is the Solid Waste Local Enforcement Agency
(LEA) for all cities and unincorporated areas of Orange County. Both OCW&R and the LEA have
commented on the Draft EIR.
The OCW&R noted that, " ...for all occupied structures located with 1,000 feet of the former Villa Refuse
Disposal Station, that these occupied structures be equipped with structural mitigation to prevent landfill
gas accumulation underneath and inside the occupied structures."
Page 2.3-2 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.3 Hazards and Hazardous Materials
The OCWW&R recommended that, "...the Mitigation Monitoring and Reporting Program should
require that design plans for any occupied structures within 1,000 feet of the refuse limit, and structural
systems to prevent gas-related hazards, are required to be reviewed and approved by the LEA." Further,
they recommended that a disclosure statement be added as a mitigation measure. The LEA requested that
the statement would note the location of future homes to the former landfill.
The LEA noted that, "...the lack of detectable methane in soil vapor samples collected fi�om Planning
Area B does not rule out the potential for changes to the current or future off-site methane migration due
to the heterogeneity of subsurface soils or variations in migration pathways that may occur." The LEA
recommendations and comments thereon were as follows:
1. All appropriate methane protection safeguards be taken in Planning Area B. They referred to
California Code of Regulations,Title 27, Section 21190,Postclosure Land Use.
2. Establishing a buffer zone to allow for the installation of additional probes or future remediation
as necessary.
3. The protection of the three off-site Landfill Gas (LFG) monitoring probes on the north and east
perimeter of the former Villa Park Landfill site.
Methane Protection Safeguards
Potential Impact HAZ-2 was identified in the Draft EIR related to Planning Area C and the potential need
for methane protection safeguards. The proposed project could potentially pose a long-term significant
human health risk from TCE-impacted soils and/or methane to users of residential buildings located in
Planning Area C (Impact HAZ-2); however, with the incorporation (see Mitigation Measure HAZ-2),
impacts would be reduced to less than significant levels.
Based on the information provided in comments on the Draft EIR, no new impact has been identified in
Planning Area B related to the need for methane protection safeguards. However, the project applicant
has indicated that all development in Planning Area B will be in accordance with a new project design
feature (PDF) to address the expressed concerns of OCW&R and LEA. In order to clarify this addition
would be implemented, it has been incorporated into the EIR below.
Additional Project Design Features (PDFs)
Page 5.8-9 of the Draft EIR has been amended as noted below to include the additional PDF the applicant
has agreed to implement:
PDF-HAZ-9 Prior to the issuance of any grading permit in Planning Area B the project
applicant shall demonstrate to the satisfaction of the Directors of Public Works
and Community Development that remedial actions, in accordance with adopted
State standards, have been taken on-site or that buildings will include vapor
barriers or passive/active venting systems.
PDF-HAZ-10 Prior to the issuance of any grading permit in Planning Area B the project
applicant shall demonstrate to the satisfaction of the Directors of Public Works
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.3-3
Rio Santiago Project SCH No. 2009051072
2.3 Hazards and Hazardous Materials
and Community Development that three on-site LFG monitoring probes on the
north and east perimeter of the former Villa Park Landfill site will be protected.
PDF-HAZ-ll Prior to the issuance of any grading permit in Planning Area B the project
applicant shall demonstrate to the satisfaction of the Directors of Public Works
and Community Development that utilities that trench immediately adjacent to
the former Villa Park Landfill, will include vapor barriers.
PDF-HAZ-12 Prior to the issuance of any residential building permit, the project applicant
shall demonstrate to the satisfaction of the Director of Public Works and
Community Development that methane monitors will be installed.
BufferZone
The LEA's have requested the provision of a buffer to allow installation of probes ar future remediation
as necessary. California Code of Regulations,Title 27, Section 21190 Postclosure Land Use address land
use requirements on landfill sites. Additionally, LEA Advisory #Sl, July 1998, discusses disposal site
post closure land use issues. It states:
"Disposal site" or "site" includes the place, location, tract of land, area, or premises in use,
intended to be used, or which has been used for the landfill disposal of solid wastes (PRC Section
40122). In practice, this definition means that any property located outside the parcel containing
the solid waste is not subject to the postclosure land use requirements of 27 CCR 21190, even if
the outside property is within 1,000 feet of the waste footprint (27 CCR 21190(c)). This can be
problematic for the CIWMB and LEA because parcel boundaries can be split from the disposal
site, allowing development close to the waste footprint without triggering postclosure land use
controls and approvals.
Local building codes and ordinances can provide enforceable buffer zones controlling land use
development adjacent to disposal sites (e.g., Los Angeles County building codes). Another way
for the LEA to influence the control of postclosure land use development adjacent to disposal site
parcels is to participate as early as possible in the local planning process when rezoning and
building permits come up for issuance. It is also important to note that where the Department of
Toxic Substances Control (DTSC) has jurisdiction over postclosure land use pursuant to
California Health and Safety Code Section 25221 (i.e., hazardous waste sites), it has broad
authority over adjacent land use activities on property outside the disposal area."
A review of the location of the LFG monitoring probes on the north and east perimeter of the former
disposal site indicated that four probes are located outside the former Villa Park Landfill site and on the
project site. Additionally, two probes are located adjacent to the project site on the former Villa Park
Landfill site. The ownership of the probes on the project site is presently unknown. A review of the
Preliminary Title Report for the project site has been accomplished. The Preliminary Title Report does
not discuss the probes on the project site. However, the OCW&R has indicated that they maintain and
monitor probes related to the adjacent landfill site. The project applicant does not have a responsibiliry to
Page 2.3-4 City of Orange-Response to Comments/Final E/R—December 2013
SCH No. 2009051072 Rio Santiago Project
2.3 Hazards and Hazardous Materials
allow the continued use or to protect probes constructed on the project site without their consent. PDF 10
(see above) allows for the probes under the ownership of OCW&R to remain on-site. Additionally,
should any landfill material be found on the project site, it would be the responsibility of the LEA to
remove such material. 27 CCR 20005(c); 27 CCR 20180.
The City is required to consult with the LEA related to land uses adjacent to a landfill site. This has been
accomplished for the proposed project with issuance of the Notice of Preparation (NOP), Notice of
Completion (NOC), and the preparation of this Response to Comments/Final EIR. Additionally,the LEA
was notified of a project scoping meeting and will be notified of all public hearings related to the
proposed project.
The proposed project does not establish specific PDF's to provide a buffer adjacent to the former landfill.
However, land uses of the proposed project to the north of the landfill in Planning Area A are Open Space
—Natural and in Planning Area B are Open Space—Park. These two land uses provide a buffering of the
proposed project from the former landfill. The proposed open space in Planning Area A is described as:
Planning Area A is approximately 50 acres in size (approximately 45 percent of the project site)
and would be retained in its current condition except for infrastructure improvements and native
habitat restoration.
Infrastructure improvements would occur in Planning Area A adjacent to Planning Areas B, C,
and D along the southern edge. These infrastructure improvements include: drainage, flood
control, and multi-purpose trail (including an equestrian fence). These infrastructure
improvements will occur along the south side of the Santiago Creek as stated in Figure 3-4,
Tentative Tract Map. No infrastructure improvements are proposed to occur to the north of
Santiago Creek. Planning Area A will be conveyed to either the City, Orange County Parks, the
Homeowner's Association (HOA), or Orange County Transportation Authority (OCTA) as a
habitat restoration project for the Measure M2 Freeway Environmental Mitigation Program for
permanent public open space preservation. The proposed project within Planning Area A
provides for re-vegetation in the fuel modification zone and for infrastructure improvements.
(Page 3-28,Draft EIR)
Proposed land use to the east in Planning Area B would be Open Space-Park. This is described as,
"...would allow a variety of fee based recreational and community uses including `pay for play' uses."
(Page 3-28, Draft EIR). The Draft EIR further describes future land uses in Planning Area B as:
... Planning Area B would include a multi-purpose facility with a maximum of 81,000 square feet
that may include a combination of the uses (listed below) and shall not exceed two stories in
height. Ancillary uses in support of the above uses are also allowed(including but not limited to
parking lots, bicycle parking, restrooms, and support services such as sandwich shop,juice bar,
coffee, pro shop, etc.). Freestanding commercial uses would not be permitted. (Page 3-29, Draft
EIR)
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.3-5
Rio Santiago Project SCH No. 2009051072
2.3 Hazards and Hazardous Materials
The proposed project does not establish specific PDF's to provide a buffer adjacent to the former landfill.
The area immediately adjacent to the former landfill would be landscaped in Zone 2: Community
Streetscape/Trails/Edges (Figure 3-16, Plant Zones Draft EIR). A community view fence constructed of
tubular steel/solid wood/combo low block wall and tubular steel would be located on the property line
(Figure 3-17, Wall and Fence Plan Draft EIR). The City and the project applicant are not required to
adhere to the recommendations of the LEA related to buffers on private property.
It is important to note that Title 27 does not give LEA the authoriry to impose a 1,000 foot buffer
requirement on the proposed project. Under Section 20005(c) of Title 27, responsibility for enforcing the
regulatory standards of the California lntegrated Waste Management Board was given to the LEA. The
regulatory standards are found in Chapters 1 (Genera�, 2 (Definitions) and 3 (Criteria for All Waste
Management Units, Facilities and Disposal Sites) and applicable portions of Chapter 4 (Documentation
and Reporting for Regulatory Tiers, Permits, WDRs, and Plans) of Title 27. Section 21190 of Title 27 is
found in Chapter 3.
Section 20005(c) states "[t]he standards promulgated by the CIWMB in Chapters 1, 2, 3, and applicable
portions of Chapter 4 shall apply to all disposal sites meaning active, inactive, closed or abandoned . . .
."Nowhere in Section 20005(c) does it state that the standards also apply to non-disposal
sites. Therefore, Section 21190 does not apply to the project site because no portion of the proposed
project site lies within the boundaries or constituted a part of a disposal site.
Please note that this is consistent with the wording of Section 21190. Subsection (d) of Section 21190
states that all proposed postclosure land uses on sites implementing closure or on closed sites shall be
submitted to the LEA. Additionally, please note that there are other references in Subsection (d) and
Subsection (g) of Section 21190 that use the phrases, "[c]onstruction on site" and "on site construction",
respectively, which further demonstrates that Section 21190 was intended to apply only to proposed
development on a disposal site or part of it. Land outside of a disposal site is outside the reach and
applicability of Title 27's regulatory standards, including Section 21190.
Also,based on Subsection(c) of Section 21190, LEA has no stati�~� ven review or approve the
proposed project. The only projects LEA reviews are on-si� � �- :_a uses, i.e., land uses within
the boundaries of the disposal site. Because the pro� ��«�+ aues not involve on-site postclosure
land uses,the LEA neither has the right to review r - , . . ..�e Rio project.
2.3.2 Buried Hazardous Materials
Commenters have expressed a concern with potential of buried hazardous materials (i.e., asbestos) on the
project site.
Asbestos
Commenters have expressed a concern with the potential of asbestos on the project site. The Draft EIR
discusses the potential for impacts related to asbestos on the project site. The Draft EIR noted that no
evidence of asbestos was found and Orange County Health Care Agency (OCHCA) has closed all cases
related to asbestos on the project site. Further, the Draft EIR notes that should asbestos be found on the
Page 2.3-6 City of Orange-Response to Comments/Final E/R—December 2013
SCH No. 2009051072 Rio Santiago Project
2.3 Hazards and Hazardous Materials
project site at a later date, the project applicant would provide asbestos remediation in accordance with
Environmental Protection Agency (EPA), Orange County Health Care Agency (OCHCA), and South
Coast Air Quality Management District(SCAQMD)protocols.
Other Potential Buried Hazardous Materials
Commenters have also expressed a concern with the potential of other buried hazardous materials (i.e.,
cars, etc.) on the project site. While there has been concern expressed with historical placement of
hazardous materials (i.e., cars, etc.) in the former silt ponds on the project site, no factual evidence has
been presented.
The Draft EIR notes that all grading activities related to backfill, mass grading, and establishment of
super pads are considered as project earthwork. The approved, on-going backfill operation currently is
separate and distinct from the proposed project. However, some of this grading would have to occur to
construct the proposed project. Earthwork on the project site would include approximately 2,248,200
cubic yards of material that will be over excavated. A total of 1,100,000 cubic yards of material will be
imported to the site. The imported materials include concrete, asphalt, rock, and soil. Please note that
haul routes for over 30,000 cubic yards of soil require City Council approval. The imported materials
will be crushed on-site. A total of 3,348,200 cubic yards of material both over excavated and imported to
the project site will be blended during the backfilling and grading operations.
All on-site grading would occur in accordance with the City of Orange Grading Manuel (Manuel of
Grading). This Manual of Grading sets forth the rules and regulations to control excavation, grading and
earthwark construction, including cuts and fills. It establishes the administrative procedure for issuance of
permits, sets requirements for approval of plans and inspection of grading construction, and provides
guidelines for enforcement of grading violations. The Manuel of Grading provides for the inspection of
all grading within the City, requires inspection of work, and supervision. If any hazardous materials were
to be uncovered during the grading operations, existing Federal, State, and local protocols would be
anticipated to address the materials if discovered.
Hazardous Materials in Backfill Operations
Commenters have expressed a concern with the potential that hazardous materials are being buried on the
project site during the backfill operations. The Draft EIR notes that to restore previously mined portions
of the site, a portion of the project site is presently being backf'illed as a permitted land use. The existing
backfill operation is not a permanent use. The project site is being over excavated (i.e., removal of
unsuitable materials) and filled in the present backfill operation. The project applicant has indicated that
additional grading permit(s) will be requested from the City to complete backfilling of all previously
mined portions of the project site. The project site was used from 1919 to 1995 for surface mining of
sand, gravel, and other aggregates. Previously mined portions of the project site were used for residue silt
deposition, otherwise known as silt ponds. The backfilling operation addresses both mined and silt pond
areas.
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.3-7
Rio Santiago Project SCH No. 2009051072
2.3 Hazards and Nazardous Materials
The Draft EIR notes that in March 2011, the City issued Grading Permit #2047 related to the backfill
operation. Table 17.32.020, Sand and Gravel District Use Regulations, of the Orange Municipal Code
indicates that backfilling is a permitted use (P)in the S-G(Sand and Gravel)District. In addition, grading
permit(s) will be requested from the City to complete the backfilling of the previously mined portions of
the project site. This approved, on-going backfill operation currently is separate and distinct from the
proposed project. However, some of this grading would have to occur to construct the proposed project.
Table 2.3-1, Summary of Materials Recycling and Backfill Operations provides information related to the
existing materials recycling, and existing and anticipated backfill operation.
All on-site grading that is occurring under Grading Permit#2047 is occurring in accordance with the City
of Orange Grading Manuel (Manuel of Grading). This Manual of Grading sets forth the rules and
regulations to control excavation, grading and earthwork construction, including cuts and fills. It
establishes the administrative procedure for issuance of permits, sets requirements for approval of plans
and inspection of grading construction, and provides guidelines for enforcement of grading violations.
The Manuel of Grading provides for the inspection of all grading within the City, requires inspection of
work, and supervision. If any hazardous materials were to be uncovered during the grading operations,
existing Federal, State, and local protocols would be anticipated to address the materials discovered.
Asbestos
The Draft EIR Section 5.8, Hazards and Hazardous Materials (page 5.8-11), notes that Appendix I,
Environmental Site Assessment Reports, June 7, 2010 letter from Tait on pages 4 and 5 detail the research
on the project site done by Orange County Health Care Agency (OCHCA) regarding asbestos. Sampling
was accomplished by OCHCA June 16, 2008. No evidence of asbestos was found and OCHCA closed all
cases related to asbestos on the project site. However, should asbestos be found on the project site at a
later date, the project applicant would provide asbestos remediation in accordance with EPA, OCHCA,
and SCAQMD protocols. Additionally, soils sampling and analysis was accomplished on the project site
from April 1 l, 1986 to May 16, 2011.
• The Earth Technology Corporation April 11, 1986
• The Earth Technology Corporation June 10, 1986
• Geomatrix Consultants August 2000
• Department of Toxic Substances Control (DTSC) and CRWQCB -LA January 28, 2003
• OCHCA June 16,2008
• Tait Environmental Service, Inc. June 7,2010
• Tait Environmental Service, Inc. Januaryl2, 2011
• Tait Environmental Service,Inc. May 16,2011
Unde�g�ound Storage Tanks(USTJ
The Draft EIR Section 5.8, Hazards and Hazardous Materials (page 5.8-11), notes that Tait
Environmental Services collected 14 soil samples in Planning Areas C and D that contained Total
Petroleum Hydrocarbon — Motor Oi1 (TPH-mo) at concentrations that exceeded the respective
Environmental Screening Levels (ESL). Nine of these samples also contained Total Petroleum
Hydrocarbon—Diesel (TPH-d) at concentrations exceeding the respective ESL. The THPs were recorded
Page 2.3-8 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.3 Hazards and Hazardous Materials
in Planning Areas C and D. They are generally associated with former underground storage tanks and
maintenance buildings. Tait recommends that remedial actions be taken to address potential soil
ingestion and dermal contact risk to future project site users. Tait Environmental Services noted that the
need for the remedial actions would need to be based on final surface cover and final grade elevations for
the areas of concern. They noted that the potential for remedial action would be reduced when the
distance between the detected TPH-impacted soil and the final grade increased. Remedial actions could
include excavation and appropriate off-site disposal. Therefore, the following impact would have the
potential to occur and mitigation is proposed:
Impact HAZ-1: The proposed project could potentially create a short-term significant hazard
impact to the public or the environment through reasonably foreseeable upset
and accident conditions involving the release of hazardous materials into the
environment during ground-clearing and site grading activities.
MM HAZ-1: Prior to the issuance of any grading permits, the project applicant shall
demonstrate to the satisfaction of the Directors of Public Warks and Community
Development that remedial actions in accordance with adopted State standards
have been taken on-site, or that the excavation and off-site disposal has occurred.
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.3-9
Rio Santiago Project SCH No. 2009051072
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2.4 Hydrology and Flooding
Several commenters expressed concerns related to potential impacts to hydrology and water quality from
project implementation on the project site and the surrounding area. The majority of these concerns
related to the following items:
1. A concern with the water quality standards, waste discharge requirements, and the water quality
data utilized in the Draft EIR.
2. A concern with groundwater impacts related to on-and off-site water wells.
3. A concern and support for how surface water runoff control and conveyance including:
• The methodology of hydrology analysis.
• The location of flood control protection measures.
• The need for regulatory permits (i.e., CDF&W,RWQCB, County,U.S.F&W, etc.).
4. A concern with potential impacts from dam failure.
5. A concern with backfill operational impacts on Santiago Creek.
Section 5.9, Hydrology and Flooding in the Draft EIR describes potential impacts related to hydrology
and water quality from project implementation on the project site and the surrounding area, which may
result from the construction and operation of the proposed project. This section of the Draft EIR also
identifies mitigation measures to reduce any potentially significant land use and planning impacts and
describes the residual impact, if any, after imposition of the mitigation. The analysis used the following
thresholds of significance consistent with Appendix G of the State CEQA Guidelines:
Threshold HWQ-A Would the proposed project violate any water quality standards or waste
discharge requirements?
Threshold HWQ-B Would the proposed project substantially deplete groundwater supplies or
interfere substantially with groundwater recharge such that there would be a net
deficit in aquifer volume or a lowering of the local groundwater table level (e.g.,
the production rate of pre-existing nearby wells would drop to a level which
would not support existing land uses or planned uses for which permits have
been granted)?
Threshold HWQ-C Would the proposed project substantially alter the existing drainage pattern of the
site or area, including through the alteration of the course of a stream or river, in
a manner which would result in substantial erosion or siltation on-or off-site?
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.4-1
Rio Santiago Project SCH No. 2009051072
2.4 Hydrology and Flooding
Threshold HWQ-D Would the proposed project substantially alter the existing drainage pattern of the
site or area, including through the alteration of the course of a stream or river, or
substantially increase the rate or amount of surface run-off in a manner which
would result in flooding on-or off-site?
Threshold HWQ-E Would the proposed project create or contribute run-off water which would
exceed the capacity of existing or planned stormwater drainage systems or
provide substantial additional sources of polluted run-off?
Threshold HWQ-F Would the proposed project otherwise substantially degrade water quality?
Threshold HWQ-G Would the proposed project place housing within a 100-year flood hazard area as
mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or
other flood hazard delineation map?
Threshold HWQ-H Would the proposed project place within a 100-year flood hazard area structures
which would impede or redirect flood flow?
Threshold HWQ-I Would the proposed project expose people or structures to a significant risk of
loss, injury or death involving flooding, including flooding as a result of the
failure of a levee or dam?
Threshold HWQ-J Would the proposed project expose people or structures to inundation by seiche,
tsunami, or mudflow?
Threshold HWQ-K Would the proposed project potentially impact storm water run-off from
construction activities?
Threshold HWQ-L Would the proposed project potentially impact storm water run-off from post-
construction activities?
Threshold HWQ-M Would the proposed project result in a potential for discharge of storm water
pollutants from areas of material starage, vehicle or equipment fueling, vehicle or
equipment maintenance (including washing), waste handling, hazardous
materials handling or storage, delivery areas, loading docks or other outdoor
work areas?
Threshold HWQ-N Would the proposed project result in the potential for discharge of storm water to
affect the beneficial uses of the receiving waters?
Threshold HWQ-O Would the proposed project create the potential for significant changes in the
flow velocity or volume of storm water run-off to cause environmental harm?
Page 2.4-2 City of Orange-Response to Comments/Final E/R—December 2013
SCH No. 2009051072 Rio Santiago Project
2.4 Hydrology and Flooding
Threshold HWQ-P Would the proposed create significant increases in erosion of the project site ar
surrounding areas?
2.4.1 Water Quality or Waste Discharge
Commenters expressed a concern with the water quality standards, waste discharge requirements, and the
water quality data utilized in the Draft EIR. They requested information related to water quality standards
and waste discharge requirements. A concern with the sewer system and drainage lines related to the
former Villa Park Landfill. Finally, commenters provided water quality data for Santiago Creek that
provides TDS data from surface water samples collected by OCWD from Santiago Creek below the Villa
Park Dam outfall from 1994-2004.
The Draft EIR evaluated construction and operational potential impacts from project implementation on
the project site and the surrounding area, which may result from the construction and operation of the
proposed project. The Draft EIR found that the proposed project would have a less than significant
impact relating to potential violation of any water quality standards ar waste discharge requirements and
no mitigation measures would be required. (Page 5.9-34 of the Draft EIR) Refer to specific responses to
comments to Letters 3, 4 and 5 related to these agencies concerns with water quality and waste discharge
findings of the Draft EIR.
The commenters concerns do not change the analysis or conclusions of the Draft EIR,because they do not
raise any issues related to the adequacy of environmental analysis conducted in the Draft EIR. However,
they are noted and will be provided to the Planning Commission and City Council for consideration.
2.4.2 Water Wells
Commenters expressed a concern with groundwater impacts related to on- and off-site water wells. The
Draft EIR found that the implementation of the proposed project would not substantially deplete or
interfere with groundwater recharge. The proposed project would maintain the existing conditions and
not result in a net deficit of the underlying aquifer or local groundwater table. The potential water quality
impacts to groundwater are discussed in Section 5.9, Hydrology and Water Quality under Threshold
HWQ-A, Water Quality Standards/Discharge Requirements of the Draft EIR. The Draft EIR found that
no impact would be anticipated and no mitigation measures would be required. (Page 5.9-35 of the Draft
EIR) The potential for the proposed project to substantially deplete groundwater supplies or interfere
substantially with groundwater recharge is discussed in Section 5.9, Hydrology and Water Qualiry under
Threshold HWQ-B, Groundwater Supplies/Recharge of the Draft EIR. The Draft EIR found that no
impact would be anticipated and no mitigation measures would be required. (Page 5.9-34 through Page
5.9-35 of the Draft EIR)
Existing Water Well Locations and Use
Commenters expressed concern with the location of water wells on the project site. The project Civil
Engineer (Fuscoe Engineering, Inc.) and the project applicant field surveyed the project site on August 6,
2013. They determined that there are two (2) existing wells on the project site. Further, that the Not-A-
Part parcel does not contain a water well. Figure 5.9-8A,Existing and Proposed Water Well Locations is
added to the EIR to indicate the locations of the existing wells on the project site.
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.4-3
Rio Santiago Project SCH No. 2009051072
2.4 Hydrology and Flooding
Water Well #1 as shown on Figure 5.9-8A, Existing and Proposed Water Well Locations is presently not
in operation. Water Well #1 was historically used in the on-site sand and gravel operation. Water Well
#2 as shown on Figure 5.9-8A, Existing and Proposed Water Well Locations is presently used in the
materials recycling operation. Based on information provided by Hanson Aggregates West, Inc., Water
Well #2 has a total production of approximately four(4) acre feet per month.
Proposed Water Well Location and Use
The project applicant has indicated that these two (2) water wells would be used during the grading
operations for the project site. Once the grading operations are completed, they will relocate these wells
for use in HOA areas for landscaping. The existing wells will be relocated in conformance with the
requirements of all applicable agencies. It is reasonable to assume that the wells would not be located so
as to be effected by the adjacent former landfill. No increase in the histaric water rate use is anticipated.
Pages 5.9-34 and Page 5.9-35 of the Draft EIR are revised as follows:
Short-Term Operation(ConstructionJ
/nfi/tration
Under the existing conditions, infiltration potential is very minimal on-site due to the excessive
silt pond deposits that occurred in the past, bedrock conditions in areas throughout the site, and
existing artificial compacted fill areas from previous grading operations (Appendix K, Water
Qualiry Technical Report). During construction no change in infiltration is anticipated.
Therefore, no impact would be anticipated and no mitigation measures would be required.
Groundwater Use
As previously noted, there are two (2) existing wells on the project site as shown on Figure 5.9-
8A, Existing and Proposed Water Well Locations. Water Well#1 was historically used in the on-
site sand and gravel operation. Water Well #1 is not presently producing water. Water Well #2
is presently producing water. Based on information provided by Hanson Aggregates West, Inc.,
Water Well #2 has a total production of approximately four (4) acre feet per month. The
proposed project would re-activate Water Well #1 and continue the use of Water Well #2 during
construction. The use of groundwater on the project site will be limited to the historic use as
demonstrated to the satisfaction of the Orange County Water District. No increase in amount of
water historically produced by the water wells is anticipated. Therefore, no impact would be
anticipated and no mitigation measures would be required.
Long-Term Operation
/nfi/tration
Under the proposed conditions, the majarity of the site will be subject to silt pond removals and
re-compaction of a clay-based fill to 90% compaction, similar to areas of the site that already
have significant compacted fill areas. Upon completion of the required removal and compaction
process, the majority of the site will have low infiltration potential similar to exisring conditions.
Implementation of the proposed project would not substantially deplete or interfere with
groundwater recharge based on the existing conditions or result in a net deficit of the underlying
Page 2.4-4 City of Orange-Response to Comments/Final E/R—December 2013
SCH No. 2009051072 Rio Santiago Project
2.4 Hydrology and Flooding
aquifer or local groundwater table. T'� .��. �'.:_""""""�`' "'^;�^+ "� `'�c;"""'' . ==''' "�",,:"�'''�
-� r..,t,.,.,�..r-�___-- -a----- � -�---- -
�-^�'+'����:�*:^^^^ �;*������L Therefore, no impact would be anticipated and no mitigation
measures would be required.
Groundwater Use
The proposed project �•��" ~�' �~�'��a� �^�� would re-locate the two existing groundwater wells.
.�. � „�,..o� ,,, . ,;.�.a...,.,, ,,,. „a.,,.,.o.. �,,,,, ��.o o :�.;rb .,ry,,:�,. The potential water
quality impacts to groundwater are discussed in Threshold HWQ-A, Water Quality
Standards/Discharge Requirements. The two water wells would be located in HOA areas and
provide water for landscape areas on the project site. The use of groundwater on the project site
will be limited to the historic use as demonstrated to the satisfaction of the Orange County Water
District. No increase in amount of water historically produced by the water wells is anticipated.
Therefore, no impact would be anticipated and no mitigation measures would be required.
Level of Significance
The proposed project would have a less than significant impact related to groundwater
supplies/recharge and no mitigation measures would be required.
The new information added to an EIR is not "significant" as the EIR has not been changed in a way that
deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental
effect of the project or a feasible way to mitigate or avoid such an effect. Additionally, the new
information would not result in new or substantially increased significant impacts, and therefore no
recirculation is required.
The commenters concerns do not change the analysis or conclusions of the Draft EIR,because they do not
raise any issues related to the adequacy of environmental analysis conducted in the Draft EIR However,
they are noted and will be provided to the Planning Commission and City Council for consideration.
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.4-5
Rio Santiago Project SCH No. 2009051072
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2.4 Hydrology and Flooding
2.4.3 Surface Water Runoff
Commenters expressed concern and support far the methods by which surface water runoff would be
control and conveyed by the proposed project. This concern and support included: 1. The methodology of
hydrology analysis; 2. The location of flood control protection measures; and, 3. The need for regulatory
permits (i.e., CDF&W, RWQCB, County, U.S.F&W, etc.). They expressed a concern with how surface
water runoff and irrigation water would be controlled and conveyed so that no significant impacts to the
former Villa Park Landfill final cover, or existing groundwater monitoring wells would occur.
Commenters expressed concern related to proposed buried riprap retaining wall located beyond the
proposed project boundary on the east side. They noted that the riprap would be encroaching into Orange
County Flood Control District (OCFCD) right-of-way. They noted that any improvement should be
within the proponent's property.
Commenters noted that all work within OCFCD right-of-way would require encroachment permits from
OCPW/County Property Permit Section. They noted that all needed regulatory permits required by
regulatory agencies would need to be obtained by the developer. They indicated that any engineered
improvements to Santiago Creek that are planned to be turned over to OCFCD need to meet OCFCD
criteria and standards, and pass OCFCD inspection. They noted an agreement between OCFCD and
project developer that delineates each party's responsibilities would need to be prepared before design
plans are finalized and permits are obtained from the County.
Commenters noted that the proposed project would require approval from a number of Federal and State
agencies such as the U.S. Army Corps of Engineers, U.S. Fish and Wildlife Services, California
Department of Fish and Wildlife and many others before the City could even consider the project.
Commenters also noted that the proposed project water systems and other measures dealing with
drainage, flooding, storm water run-off and more will improve flooding and run-off prevention
The methodology of the hydrological analysis is provided in the Draft EIR Appendix K,Hydrology Study
Report. The location of flood control protection measures are as shown Figure 3-4, Tentative Tract Map.
The need for regulatory permits is discussed in Draft EIR Section 3.0, Project Description and Section
5.4,Biological Resources.
The Draft EIR found that with the implementation of PDF-HWQ-7, the proposed 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, in a manner which would result in substantial on-site erosion, on-site siltation,
off-site erosion or off-site siltation. A less than significant impact would occur and no mitigation
measures would be required related to the alteration of existing on-site or off-site drainage patterns. (Page
5.9-35 of the Draft EIR)
Further, the Draft EIR found that the proposed project would have a less than significant impact related to
drainage pattern of the site including through the alternation of the course of a stream or river, in a
manner which would result in substantial erosion or siltation on- or off-site and no mitigation measures
would be required. (Page 5.9-35 of the Draft EIR)
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.4-7
Rio Santiago Project SCH No. 2009051072
2.4 Hydrology and Flooding
Refer to specific responses to comments to Letters 3, 4, and 5 related to Agencies concerns with water
quality and waste discharge findings of the Draft EIR. The commenters concerns do not change the
analysis or conclusions of the Draft EIR, because they do not raise any issues related to the adequacy of
environmental analysis conducted in the Draft EIR. However, they are noted and will be provided to the
Planning Commission and City Council for consideration.
2.4.4 Dam Failure
Several commenters expressed concerns related to potential flood hazard in case of catastrophic dam
failure. Commenters expressed concern that flooding sometime in the future would cause property
destruction and a safety concern for the residents of the proposed project. They offered the opinion that
approval of the proposed project would place the City at risk financially for approving a project on a flood
plain. They further stating that Planning Area A could not be developed as it was located within a flood
plain. Commenters opinioned that the proposed planned bank stabilization for Santiago Creek would not
protect the project area in the event of seismically induced catastrophic dam failure upstream.
It was the opinion of commenters that the proposed project would place the elderly and infirmed in the
middle of a dangerous flood plain. It was their opinion that the Santiago and Villa Park Dams are older
structures and that undetected geotechnical flaws in either of these older structures could result in loss of
lives and major property damage downstream at the Rio Santiago site. Finally, it was the opinion
commenters that Santiago Creek has historically flowed all over the project site including underground. It
was their opinion that Santiago Creek over time has been rerouted to accommodate the sand and gravel
operation and that Santiago Creek would now be restored to its original flow.
The Draft EIR evaluated drainage patterns related to flooding and the potential for a significant risk of
loss, injury, or death involving flooding, including flooding as a result of the failure of a levee or dam.
The Draft EIR did not find that Planning Area A could not be developed because of flood plan issues. No
residential development is proposed for Planning Area A. No improvements would occur in Planning
Area A on the north side of the Santiago Creek. Storm water run-off would continue to drain directly to
Santiago Creek by surface sheet flow and overtopping the north bank. The existing drain inlets entering
Santiago Creek from the Mabury Ranch residential community would not be altered.
The Draft EIR found that the proposed project would alter existing drainage patterns on the proposed
project site. Residential improvements would be confined to Planning Areas C and D. All other planning
areas would be reserved as some form of open space or recreational related area use. The Draft EIR
concluded that the proposed project would have a less than significant impact related to alteration of
existing drainage patterns of the project site, including through the alteration of the course of a stream or
river, or substantially increase the rate or amount of surface run-off in a manner which would result in
flooding on-or off-site and no mitigation measures would be required. (Page 5.9-44 of the Draft EIR)
Commenters are correct that there are two (2) dams along Santiago Creek: Villa Park Dam and Santiago
Dam (Irvine Lake). Both are located in the foothill areas of East Orange and are upstream of the project
site. The Santiago Dam is a roller compacted earth and rockfill structure. The construction of the dam
started in 1929 and was completed in 1931. It is owned by the Irvine Ranch Water District and the
Page 2.4-8 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.4 Hydrology and Flooding
Serrano Water District (the former Serrano Irrigation District). The Villa Park Dam that forms the Villa
Park Reservoir was completed in 1963. Villa Park Dam is a flood control dam located downstream from
Santiago Dam. The Villa Park Dam is an earth fill structure owned by the Orange County Flood Control
District.
In the course of the preparation of the EIR,the City consulted all known references related to the potential
odds of seismic activity as a catalyst for dam failure. As of this writing there is no known data that would
provide the potential odds of the potential seismically induced failure of one of the above mentioned
dams. Therefore, at this time it would be speculative to provide the odds of failure. Please refer to
Section 5.9, Hydrology and Water Quality of the Draft EIR page 5.9-51 topic Dam Failure for additional
information.
The Draft EIR agreed with commenters concerns that the proposed project would have the potential to be
in the path of inundation were a dam break to occur, by a form of induction. The Draft EIR found that
with the inclusion of Mitigation Measures HWQ-1 and HWQ-2, the proposed project impact remains a
significant unavoidable impact related to being in the path of inundation were a dam break to occur.
(Page 5.9-57 of the Draft EIR) The commenters concerns do not change the analysis or conclusions of
the Draft EIR, because they do not raise any issues related to the adequacy of environmental analysis
conducted in the Draft EIR. However, they are noted and will be provided to the Planning Commission
and City Council for consideration.
2.4.5 BackfillOperations
Several Commenters expressed concerns with backfill operational impacts on Santiago Creek. They were
concerned with unstable backfill and uncompated fill were being placed on the project site without proper
inspection. Additionally, they were concerned that an unauthorized action related to toxic material clean-
up was occurring on the project site.
Further the commenter expressed a concern that the backfill operation created a hole that filled with
"tainted"water that was pumped into Santiago Creek.
The discussion of the existing backfill operations on the project site is provided as information only. The
backfill operation is not a part of the proposed project. Therefore, no further discussion of this topic is
warranted. The commenters concerns do not change the analysis or conclusions of the Draft EIR,because
they do not raise any issues related to the adequacy of environmental analysis conducted in the Draft
EIR. However, they are noted and will be provided to the Planning Commission and City Council for
consideration.
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.4-9
Rio Santiago Project SCH No. 2009051072
2.5 Land Use and Planning
Several commenters expressed concerns related to land uses and planning issues. The majority of these
concerns related to the following items:
1. The relationship of the proposed project conflicting with applicable plans,policies, or regulations.
This includes consistency of the proposed project with the City's General Plan, Orange Park
Acres Plan (OPA Plan), East Orange (EO) General Plan, Santa Ana River/Santiago Creek
Greenbelt Plan (SARSCGP), Santa Ana River/Santiago Creek Greenbelt Implementation Plan
(SARSCGIP), and Santiago Creek Vision Plan(SCVP).
2. Concerns with potential analysis of conditionally permitted uses.
3. Concerns with potential spot zoning for the project site.
Section 5.10, Land Use and Planning describes potential impacts to land use and planning, which may
result from the construction and operation of the proposed project. This section of the Draft EIR also
identifies mitigation measures to reduce any potentially significant land use and planning impacts and
describes the residual impact, if any, after imposition of the mitigation. The analysis used the following
thresholds of significance consistent with Appendix G of the State CEQA Guidelines:
Threshold LUP-A Would the project physically divide an established community?
Threshold LUP-B Would the project conflict with any applicable land use plan, policy, or
regulation of an agency with jurisdiction over the project (including, but not
limited to the general plan, specific plan, local coastal program, or zoning
ordinance) adopted for the purpose of avoiding or mitigating an environmental
effect?
Threshold LUP-C Would the project conflict with any applicable habitat conservation plan or
natural community conservation plan?
2.5.1 Conflict with Applicable Plans, Policies, or Regulations
Commenters expressed concern that the proposed project would conflict with applicable plans, policies,
or regulation. Section 5.10, Land Use and Planning of the Draft EIR addressed potential impacts to land
use and planning, which may result from the construction and operation of the proposed project. This
section also identified mitigation measures to reduce any potentially significant land use and planning
impacts and described the residual impact, if any, after imposition of the mitigation. The Draft EIR
found:
1. The proposed project would have a less than significant impact related to conflicting with General
Plan policies and goals, and no mitigation measures would be required. (Page 5.10-14, Draft
EIR);
City of Orange-Response to Comments/Final EIR—December 2013 Page 2-1
Rio Santiago Project SCH No. 2009051072
2.5 Land Use and Planning
2. With the inclusion of the text amendment to the OS-P, the proposed project would be consistent
with the proposed General Plan designation. Therefore, the proposed project would have a less
than significant impact and no mitigation measures would be required. (Page 5.10-15,Draft EIR);
3. With the City's approval of the amendments to the OPA Plan and the EO General Plan and the
approval of the Rio Santiago Specific Plan, a less than significant impact would occur and no
mitigation measures would be required. (Page 5.10-16, Draft EIR);
4. The proposed project would have a less than significant impact relating to conflicting with
applicable land use plans, policies, and regulations and no mitigation measures would be
required. (Page 5.10-105, Draft EIR); and,
5. The proposed project would have a less than significant impact relating to conflicting with a
conservation plan and no mitigation measures would be required(Page 5.10-107, Draft EIR).
The Draft EIR found that, "The proposed project would have a less than significant impact relating to
conflicting with applicable land use plans,policies, and regulations and no mitigation measures would be
required." (Page 5.10-105, Draft EIR).
Table 2.5-1, Summary of Applicable Plans, Policies, or Regulations identifies each plan, policy, or
regulation; indicates if it is applicable to the proposed project; and, provides a discussion of the
issue/Draft EIR analysis.
Page 2-2 City of Orange-Response to Comments/Final E/R—December 2013
SCH No. 2009051072 Rio Santiago Project
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2.5 Land Use and Planning
As noted above, several commenters expressed concern that the proposed project would conflict with
applicable plans,policies, or regulations. The Draft EIR states that, "The proposed project would have a
less than significant impact relating to conflicting with applicable land use plans, policies, and
regulations and no mitigation measures would be required." (Page 5.10-105, Draft EIR) Even given
this clear determination, several commenters have expressed concern with the proposed projects
consistency with other plans and programs (i.e., Santiago Creek Greenbelt Vision Plan, Santiago Creek
Vision Plan, Santa Ana River/Santiago Creek Greenbelt Implementation Plan, etc.). As indicated in
Table 2.5-1, Summary ofApplicable Plans, Policies, or Regulations, these plans are not applicable to the
project site. However, commenters have expressed a concern that the proposed project is not consistent
with the "spirit" or"intent" of these plans ar programs, even though they are not applicable to the project
site. Therefore, the following discussion is provided to further clarify.
City's 2010 General Plan
Several commenters expressed concern that the proposed project would conflict with the Land Use
Element related to Open Space Ridgeline citing page LU-23, Goal 6.0 Policy 6.4, and Goal 7.0 Policy 7.1
provided below:
Page General Plan Statement Response
LU-23 The Open Space Ridgeline designation is The project site is not designated as an Open
designed to preserve visually significant Space Ridgeline.
ridgelines and steep hillsides. The City
has adopted a hillside grading policy that
prohibits development of grading on
ridgelines with this designated land use.
(City General Plan Page LU-23)
The Draft EIR evaluates the consistency of the proposed project related to ridgeline views in Section 5.10,
Land Use and Planning in Table 5.10-2, Project Consistency with the City of Orange General Plan.
Additionally, the Draft EIR evaluates project impacts related to scenic vistas in Section 5.1, Aesthetics
subsection Scenic Vistas. Please refer to Master Response 2.10,Aesthetic related to aesthetics issues. As
noted in the Draft EIR in Table 5.10-2, Project Consistency with the City of Orange General Plan the
following goals and policies are addressed.
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.5-11
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2.5 Land Use and Planning
Pages 5.10-24 and 5.10-45 of the Draft EIR have been clarified as noted below:
GoaliObjectives/Policy Project Consis#ency,,
Goa16.0: Advance development activity that is mutually beneticial to both the environment and
the community.
Policy 6.4: Create and maintain open space resources The project retains the Santiago Creek in its
that provide recreational opportunities, existing condition as natural open space,
protect hillside vistas and ridgelines, and greenway and wildlife corridor to preserve the
conserve natural resources. Creek's riparian habitat(Policies 6.4 and 6.7).
The proposed project may not be consistent
with certain portions of this specific policy.
However because Santiago Creek is being
retained in its existing condition, the possible
inconsistency does not rise to the level of a
significant impact. Therefore, the project is
consistent with the overall City General Plan.
Goa17.0: Protect significant view corridors, open space, and ridgelines within the urban
environment.
Policy 7.1: Preserve the scenic nature of significant The Draft EIR indicated that Policy 7.1 was not
ridgelines visible throughout the applicable to the project site. It could be
community. considered that significant ridgelines are
visible throughout the community. Therefore,
it is noted that the proposed project while not
consistent with portions of this specific policy
could be found consistent with the overall City
General Plan.
Related to Policy 6.4 and Policy 7.1 above the proposed project would impact certain portions of views of
distant hillsides from East Santiago Canyon Road. Please see Draft EIR Figure 5.1-11, View Analysis H.
Although the intent of the policy is to prevent physical grading and development on ridgelines, portions
of views of ridgelines may be affected. As a result, the proposed project may present a possible
inconsistency with portions of these specific policies. Because the policy is intended to preserve
significant ridgelines from development and because only portions of view of ridgelines may be affected,
the possible inconsistency does not create a significant impact and the proposed project could be found
consistent with the overall City General Plan. The proposed project provides for the continuation of
portions of the existing distant hillside views from East Santiago Canyon Road. This is accomplished via
Page 2.5-12 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.5 Land Use and Planning
building height limits, setbacks, park and open space areas, and building separations. Therefore, no
further discussion is warranted related to this issue.
Several commenters expressed concern that the proposed project would conflict with the Natural
Resources Element related to Open Space Resources citing page NR-9 and NR-10 provided below:
Open space lands may be set aside for many purposes, including the provision or preservation o£
(1) parks for recreation or wildlife habitat preservation; (2) water resources for groundwater
recharge and support of plant and animal habitat; (3) environmental hazard zones for the
protection of public safety; and, (4) prominent geologic features and scenic resources for the
visual enhancement of the urban environment.
As shown in Figure NR-1, Orange's planning area includes approximately 7,400 acres of open
space, which is about one-third of the planning area's total land area. Open spaces include lands
used as City or County parks, ridgelines, and areas designated as Open Space on the Land Use
Policy Map. The greatest concentration of open space within the planning area is in the Cleveland
National Forest, a portion of which is located within the City's Sphere of Influence. This open
space includes several hundred acres in the Peralta Hills area and several hundred acres in the
hills south and east of Orange Park Acres, consisting of Santiago Oaks Regional Park, Irvine
Regional Park, and Peters Canyon Regional Park. An additional 15,800 acres of open space lies
within the City's Sphere of Influence, east of the planning area.
The open space areas also include a portion of the 37,000-acre reserve area established by the
Centr�al and Coastal Orange Counry Natural Communities Conservation Plan/Habitat
Conservation Plan (NCCP/HCP). This area encompasses portions of Santiago Hills II and East
Orange. Additionally, the Irvine Ranch Land Reserve affects the pattern of developable and
undevelopable land in the eastern portion of the planning area. The reserve stretches from Weir
Canyon near State Route (SR) 91 at the north end of Irvine Ranch, connects with the Cleveland
National Forest along the northeast border of the ranch, continues south to include large regional
open space systems in the northern and southern hillsides of the City of Irvine, and extends to the
Laguna Coast Wilderness Park and Crystal Cove State Park near Laguna Beach. Santa Ana
River/Santiago Creek Greenbelt Plan The Santiago Creek Greenbelt Vision Plan (SCVP)
indicates that the first known public planning effort for Santiago Creek was included as part of a
larger Santa Ana River plan, in March, 1971. The Santa Ana River/Santiago Creek Greenbelt
Plan (SARSCGP) assessed the Santa Ana River and Santiago Creek, as a "link in the tri-county
coast-to-crest greenbelt." The SARSCGP reviewed the natural resources and made proposals in
four geographic segments and provided recommendations for implementation. Santiago Creek
was evaluated as one of the four segments.
Conserving current open spaces and creating new open spaces are important concerns. As
development pressure increases in the hillside areas east of the City, one key to preserving the
quality of life for Orange residents lies in providing open spaces that preserve scenic vistas,
provide habitat for wildlife, and maintain the ecological balance of the area. Additionally,
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.5-13
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2.5 Land Use and Pianning
because most of Orange's open spaces are located adjacent to the many reservoirs and creeks
located within the City, opportunity exists to improve water quality in the region by enhancing
and adding open spaces around these reservoirs and creeks.
To increase the amount of open space within the City, Orange will work with large landowners to
secure open space dedications where feasible. The Ciry will also work with land trusts and
nonprofit agencies to secure grant funds for acquisition and conservation of open space areas.
Where appropriate, this process may include the use of conservation easements, which are
voluntary agreements that allow landowners to limit the type or amount of development on their
property while retaining private ownership of the land. The easement is signed by the landowner,
who is the easement donor, and by a government agency or non-profit organization, which is the
party receiving the easement. The landowner continues to privately own and manage the land,
and may receive tax advantages for having donated the conservation easement. The government
or nonprofit accepts the easement with the understanding that it must enforce the terms of the
easement in perpetuity. After the easement is signed, it is recorded with the County Clerk and
applies to all future owners of the land. (City General Plan Page NR-9 & 10)
Figure NR-1, Open Space Resources in the City's General Plan clearly depicts a portion of the project site
as Open Space. Additionally, this figure shows Santiago Creek in blue. No changes to this section of the
City's 2010 General Plan are required. As noted in the Draft EIR, the proposed project would modify the
2010 City General Plan text and graphics. The modifications would include changing the site from
Resource Area(RA)to Low Density Residential (LDR 2.1-6 DulAc), Medium Density Residential (MDR
15-24 Du/Ac), Open Space Park(OS-P) and Open Space (OS); and, from Low Density Residential (LDR
2.1-6 Du/Ac) to Open Space (OS). The proposed amendment is depicted in Figure 3-7, Existing and
Proposed General Plan Designations. With the inclusion of the changes noted above and implementation
of PDF LUP-4, the proposed project would be consistent with the General Plan. Therefore, the proposed
project would have a less than significant impact and no mitigation measures would be required.
Several commenters expressed concern that the proposed project would conflict with the Natural
Resources Element related to Visual and Aesthetic Resources citing page NR-35 provided below:
Preservation of ridgelines and steep hillsides is an important objective for the City, for both
aesthetic and public safety reasons. To that end, Orange has adopted a hillside grading policy that
prohibits grading on ridgelines designated Open Space Ridgeline on the Land Use Policy Map.
Wherever hillside grading occurs, the policy requires that graded slopes must be contoured and
extensively landscaped with native vegetation or other compatible plant materials.
The largely undeveloped Santiago Hills II and East Orange portions of the planning area have
many scenic resources that include Irvine Lake, grassy valleys, rugged hillsides, rock
outcroppings, and winding canyons. People traveling along Santiago Canyon Road have
spectacular views of these abundant scenic resources. These views should be protected while still
allowing development to occur. As identified on Figure NR-4, the Ciry will work to designate
Page 2.5-14 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.5 Land Use and Planning
Santiago Canyon Road as a City Scenic Highway, and will develop standards for appropriate
treatment of the roadway and its surroundings. (City General Plan Page NR-35)
The project site is not designated as a ridgeline or steep hillside. Therefore, no further discussion is
warranted related to this issue. The proposed project as directed by this section of the City General Plan
"...would protect views while still allowing development to occur." However, the Draft EIR indicates
that with the inclusion of Mitigation Measures AES-1 through AES-3, the project impacts would be
reduced; however, a significant unavoidable impact related to scenic views in the short-term Planning
Area A (Impact AES-1) and Planning Area D (AES-2) and long-term to Planning Areas B,C, and D
(Impact AES-3)would occur. Refer to Master Response 2.2,Aesthetics for additional information.
Santa Ana River/Santiago Creek Greenbelt Plan
The Santiago Creek Greenbelt Vision Plan (SCVP) indicates that the first known public planning effort
for Santiago Creek was included as part of a larger Santa Ana River plan, in March, 1971. The Santa Ana
River/Santiago Creek Greenbelt Plan(SARSCGP)assessed the Santa Ana River and Santiago Creek, as a
"link in the tri-county coast-to-crest greenbelt." The SARSCGP reviewed the natural resources and made
proposals in four geographic segments and provided recommendations for implementation. Santiago
Creek was evaluated as one of the four segments.
The SARSCGP's recommendations for Santiago Creek included:
• Study flood control needs and for feasibility of rehabilitating gravel pits as retention basins and
regional parks, thereby alleviating future needs to line the Creek with concrete to protect adjacent
housing;
• Preserve agriculture;
• Develop, enlarge or connect small parks along the Creek;
• Link the Creek with residential communities by acquiring the abandoned Southern Pacific
Railroad"Tustin Branch"for trail use;
• Extend a trail along the Creek, connecting parks; and,
• Preserve and protect hill settings.
The Santiago Creek Greenbelt Vision Plan (SCVP) indicates that trails were regarded as the single most
important objective of the 1971 corridor plan.
City Council actions related to the Santa Ana River/Santiago Creek Greenbelt Plan (SARSCGP) have
been reviewed. Based on this review, it has been determined that the SARSCGP was not adopted by the
City. At the request of the Orange County Board of Supervisors, the City joined the program providing
one-member from the City Council to represent the City on the Greenbelt Organization Committee; one
City Staff inember to be a rotating member of the Greenbelt Program Plan Committee; and appointment
five citizens to the Orange Greenbelt plan committee. Please refer to City Council minutes April 15,
1972. However, the OPA Plan incorporated certain portions of the SARSCGP and the OPA Plan was
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.5-15
Rio Santiago Project SCH No. 2009051072
2.5 Land Use and Planning
adopted as part of the Land Use Element of the City General Plan. (City Resolution No. 3915 adopted
December 26, 1973) as follows:
ORANGE COUNTY GENERAL PLANNING PROGRAM
Within the Orange County General Planning Program elements have been adopted and have
application to this study:
1. The 1983 Orange County Land Use Element has been adopted and supersedes the Orange
Community General Plan and the Tustin Area General Plan(see Exhibit 4t21 [1983 Land
Use Element]). Not shown on the exhibit is the incorporation of the Santa Ana River -
Santiago Creek Greenbelt Plan. These plans have been used for reference in this planning
study. The Orange Park Acres Specific Plan will be proposed as an amendment to the
1983 Land Use Element. (Page 77 of the OPA Plan)
POLICIES FOR ORANGE PARK ACRES
... 10. Preserve Santiago Creek as a balanced ecological system and riparian area, maintaining
the diversity of plant and vertebrate species while allowing for light recreational use such as
equestrian and hiking trails. Specifically support: the Santiago Creek Greenbelt Proposal by
the County of Orange (Page 101 of the OPA Plan)
The Orange Park Acres Specific Plan proposes the incorporation of that portion of the County
adopted Santa Ana River- Santiago, Creek Greenbelt Plan within the Santiago Creek to the north
and east of this study area. This covers approximately 450 acres of the study area. (Page 118 of
the OPA Plan)
The Plan proposes the incorporation of presently proposed trails within the, Master Plan of
Riding and Hiking Trails for Orange County, the Proposed Orange County Skeletal Bicycle Plan
and the Santiago Creek Project Priority Map. The Plan also depicts the proposed local routes to
form the main trail system for Orange Park Acres to link to these routes. (See Exhibit#33 (Parks,
Trails & Open Spaces) of specific note is the incorporation, of Handy Creek as a trail link. It is
recommended that it be acquired to provide for trails and drainage. (Page 118 of the OPA Plan)
Technical Appendix P, East Orange General Plan and Orange Park Acres Plan Amendments has been
revised on page 118 of the OPA Plan to include statistical revisions. The Draft EIR found that the
proposed project would have a less than significant impact related to conflicting with General Plan
policies and goals, and no mitigation measures would be required. Because the OPA Plan is part of the
City General Plan, certain portions of the SARSCGP are a part of the City General Plan. (Page 5.10-10,
Draft EIR) The proposed project would amend the City's General Plan and remove the project site from
the OPA Plan area. The Draft EIR found that with the City's approval of the amendments to the OPA
Plan and the EO General Plan and the approval of the Rio Santiago Specific Plan, a less than significant
impact would occur and no mitigation measures would be required. (Page 5.10-16, Draft EIR)
Page 2.5-16 City of Orange-Response to Comments/Final E/R—December 2013
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2.5 Land Use and Planning
Santa Ana River/Santiago Creek Greenbelt Implementation Plan
The Santa Ana River/Santiago Creek Greenbelt Implementation Plan (SARSCGIP) was a status report.
The Santiago Creek Vision Plan (SCVP) states that, "This document served as a thorough overview and
update of prior planning efforts, using Orange County's corridor plan of 1971 as a benchmark, while
incorporating known flood protection proposals and other regional projects of interest, such as water
supply and waste treatment(Wells 1976: 2-10)."
The Santiago Creek Vision Plan (SCVP)further states that,
By 1973, "a multi jurisdictional, separate public agency," or joint powers authority, was formed
to coordinate project implementation within Orange County: the Greenbelt Commission. The
commission was comprised of three members of the County Board of Supervisors and Orange
County Flood Control District, two directors of Orange County Water District, and council
members from each of eight cities located within the watershed, based upon acreage in the
planning area: Anaheim (two representatives), Huntington Beach (two), Newport Beach (one),
Orange (four), Santa Ana (two), Villa Park (three) and Yorba Linda (two). Twenty-six citizens
were appointed as members of Santiago Creek Greenbelt Committees that warked to coordinate
planning on a local level. The Board of Supervisors folded the greenway plan into the County's
open space element of its General Plan(Ibid.: 11-15 and 18, citing Resolution No. 74-1151).
The group focus was limited to a reach of Santiago Creek that came to be known as "Lower
Santiago Creek," extending from Villa Park Dam to the Santa Ana River confluence. The corridor
was "arbitrarily defined" as three miles of land centered on the creek. In what may be described
as a project vision,the implementation plan states that the corridor: ...should be viewed as a linear
greenbelt, linking park nodes and significant open spaces by a bicycle, equestrian and hiking trail
system. The river look and atmosphere should be saved or restored as appropriate, with an
emphasis on trees, informal space, and quiet contrast to the surrounding urban texture and"busy-
ness." The demands for open space and recreation should be balanced according to the potential
of the corridor, i.e., some areas of intensive use, some of natural preserve, [others] in-between
(Ibid.: 13). Goals expressed for Santiago Creek at this time (1976) included studying the creek's
adequacy for ongoing flood protection, considering the feasibility of converting sand and gravel
pits as retention basins and new parks, extending and linking the existing smaller parks located
along the creek, developing a continuous recreation trail and preserving or protecting natural
lands on nearby hillsides.
The Greenbelt Commission's implementation plan defined a range of recreational uses and
facilities that could comprise a greenway, including: bicycle and equestrian facilities; state,
regional, natural, community, neighborhood and miniature parks; trail rest stops, park and ride
facilities, water conservation facilities; equestrian centers, golf courses and open space reserves
(Ibid.: 28-30). Santiago Creek is mapped generally as one of four planning areas within Orange
County, with then-vacant lands along the creek identified as "greenbelt corridor" and nearby
lands noted as "impact area." General concepts are presented, such as "Lower Santiago Creek
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.5-17
Rio Santiago Project SCH No. 2009051072
2.5 Land Use and Planning
Regional Park" that was first proposed in the county's 1960 Master Plan of Regional Parks, a
"live stream"extending from Santiago Dam to Walnut Avenue, sand and gravel pit rehabilitation,
and development of a specific plan far Lower Santiago Creek (Ibid.: 32 and 79-82). The
implementation plan also reflects some of the planning conceived by residents or coordinated by
the City of Orange and local Citizen Greenbelt Committees. Equestrian and commuter trails were
proposed from Hart Park to Santiago Oaks Regional Park, each along an edge of the creek. Hart
Park, initially developed in 1933, had just recently been expanded across and south of the creek.
An easterly expansion was now being discussed. Specific opportunities for development of a
recreation facility and community park, the acquisition of open space, possible trail connections,
park-and-ride sites, even a campground were suggested as projects. Nature preserve and
wilderness areas were forecast at a site that had been recently purchased by the county, later
known as Santiago Oaks Regional Park (Ibid.: 8Cr91). The success of this era was attributed to a
strong level of community participation and interest in Santiago Creek, noted by Wells as key to
the implementation of local projects. The city's portion of the Santa Ana River/Santiago Creek
Greenbelt Implementation Plan was approved by the City Council on 18 May 1976. In addition to
charter membership, in the Greenbelt Commission, the city has provided funds and staff hours in
support of the joint study to develop the land use decision model for Santiago Creek and Santa
Ana Canyon. The city's Citizen Greenbelt Committee has been exceptionally active in the
greenbelt program, and has worked closely with the committees of neighboring jurisdictions and
their staffs in the development of greenbelt plans. Members of the committee have attended
numerous meetings with developers regarding planned developments along the greenbelt
corridor; reviewed and provided comments and recommendations to their city's planning
commission and council about the compatibility of plans with the greenbelt, and in general have
been a forceful, constructive influence on maintaining the inertia and quality of the greenbelt
program(Ibid.: 81).
City Council actions related to the Santa Ana River/Santiago Creek Greenbelt Implementation Plan
(SARSCGIP) have been reviewed. The SARSCGIP was accepted by the City Council on May 18, 1976.
The City did not adopt the SARSCGIP. However, the City Council Minutes (May 18, 1976) indicated
that the City approved the implementation of certain project projects identified in the SARSCGIP. Based
on this review, it has been determined that the SARSCGIP was not adopted by the City. While the
SARSCGIP has been utilized as a reference, it is not a City adopted public policy related to the project
site. Therefore, no further action or analysis is warranted.
Santiago Creek Vision Plan
The Santiago Creek Vision Plan (SCVP) is a strategic visioning proposal for the seven-mile corridor in
the City, from William O. Hart Park to Santiago Oaks Regional Park. The SCVP was prepared by the
City, Santiago Creek Greenway Alliance, and the National Park Service Rivers, Trails, and Conservation
Assistance Program with support from the Wildland Conservancy in December 15, 2008. The SCVP
describes a "Vision Plan" for a greenway, multi-purpose trail system and healthy watershed along
Santiago Creek in the City. The primary goals of the SCVP are to:
Page 2.5-18 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.5 Land Use and Planning
1. Develop a continuous multi-purpose trail on the upper bank of the Creek(uplands area).
2. Create a greenway along the creek by restoring the Creek bed and its adjacent uplands with native
trees and shrubs.
3. Maximize ground water recharge by restoring the Creek bed in specific areas.
4. Maintain or improve existing level of flood protection.
The SCVP also provides general guidance on how Santiago Creek, greenway and trail improvements
could be integrated into development proposals. The SCVP was developed as a vision for the future of
Santiago Creek. The SCVP anticipated that following its adoption, more detailed proposals for specific
projects will include evaluation of environmental resources and identification of project impacts. The
SCVP does not obligate the City ar landowners to any immediate actions or land use restrictions. At time
of writing the City's 2010 General Plan, the Natural Resource Element states, "In 1999, the City applied
for, and was granted, technical assistance from the National Park Service Rivers, Trails, and
Conservation Assistance Program to prepare a conceptual master plan for Santiago Creek. The plan,
which is under preparation, will address three major components: recreation trails, open space, and
flood control. The City will continue to work toward completion of the Vision Plan for Santiago Creek,
and will implement its recommendation, consistent with General Plan policies concerning the Creek."
(Page NR-46) The SCVP is intended to facilitate long-term actions and strategic development of
community-based improvements.
The SCVP primary goals are to:
1. Construct a multi-purpose trail system along the Creek bank connecting Santiago Park in Santa
Ana to Santiago Oaks Regional Park. Santiago Oaks Regional Park connects to regional trails
further east and south (e.g., Anaheim Hills Trails, Irvine Regional Park, Weir Canyon and the
Mountains-to-Sea National Recreation Trail and Peters Canyon).
2. Create a greenway (where possible) along the Creek by restoring the Creek bed and its adjacent
uplands with native trees and shrubs.
3. Restore the Creek's natural contribution to groundwater recharge by removal of concrete parking
lots from the Creek bed and replacing non-native plants with soft-stemmed natives.
4. Maintain or improve flood protection goals defined by county officials and the U.S. Army Corps
of Engineers.
The SCVP describes the project site within Section 2.7, Mile 7, Cannon Street Bridge to East End of
Sully-Miller (i.e., former project site owner) Property. The SCVP states that Mile 7 contains the largest
undeveloped parcel of land in the study area. The SCVP describes the project site as:
It is known as the Sully-Miller properties named for the firm that mined this site between 1920
and 1985. It is one of only four sizeable undeveloped parcels of land remaining along Santiago
Creek (the other three are the Yorba site behind Chapman Hospital; the Hurwitz property on the
west side of Cannon Street; and the abutting Villa Park Landfill). A small portion on the
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.5-19
Rio Santiago Project SCH No. 2009051072
2.5 Land Use and Planning
southeast corner is presently (2007) being used for a recycling/crushing facility operated by
Hanson Aggregates. Agricultural field crops have been grown in the past on large portions of the
site that were first mined for sand and gravel, and then filled with silt &om the processing
operations, or with inert materials (rock, asphalt, concrete, etc.). The Villa Park Landfill was a
former gravel pit which was once mined to a depth of about 75 feet (County of Orange 1977).
After removal of the sand and gravel it was used for disposal of household refuse. The disposal
site is still producing significant amounts of inethane gas that is evacuated through a system of
underground wells and pipes exhausting to the atmosphere (County of Orange 2000). Figure 42
is a photograph of the Sully-Miller site looking west from Rattlesnake Peak in Santiago Oaks
Regional Park. The Cannon Street Bridge is seen in the background near the upper left. A
portion of Mabury Avenue is seen along the right. Santiago Creek, visible only as a riparian
corridor, flows generally west past the Villa Park Landfill and under the Cannon Street Bridge.
The creek itself is hidden by the trees in the foreground and eclipsed by the terrain.
Much of the Sully Miller property is covered with a mixture of native and non-native plant
species, as seen in Figure 42 and 43. The trees shown in the photo are mostly native willows. An
unpaved road could provide a good base for the bike path running east from the Cannon Street
Bridge to the vicinity of Handy Creek. The portion of the Sully-Miller site that is on the south
side of the creek is ideal for trails, a greenway and active park use. A 100-foot right-of-way is
recommended for the trail and greenway along the south side of the creek, to the point where the
trail would cross the creek to join an existing segment of the Santiago Creek Trail on the north
side. Much of this area will likely be left undisturbed due to the mitigation that would be
required, should the site become disturbed. (Sully-Miller/Fieldstone Communities 2001).
Abutting this site is a 9.6-acre parcel (now owned by John Martin) that is presently zoned R-1-8
although its development potential may be limited.
The SCVP identifies four potential projects recommended for Mile 7, which are shown in Table 2.5-2,
Santiago Creek Vision Plan Potential Projects—Mile 7.
Table 2.5-2: Santiago Creek Vision Plan Potential Projects—Mile 7
Pro'ect No. Descri tion
7.1 Develop closed landfill as a parking facility for adjacent open space and active park.
7.2 Construct Class I bike path from Cannon Street to Handy Creek confluence.
7.3 Restore land on both sides of trails with native plants as needed.
7.4 Construct recreation trail north from the bike trail to the Mabury Ranch Trail Install pedestrian
brid e across Santia o Creek.
Source: Santiago Creek Vision Plan.
City Council actions related to the SCVP have been reviewed. Based on this review, it has been
determined that the SCVP was not adopted by the City. While the SCVP has been utilized as a reference,
it is not a City adopted public policy related to the project site. Therefore, no further action or analysis is
warranted.
Page 2.5-20 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.5 Land Use and Planning
Planning Area A
Several commenters expressed concern that should the ownership of Planning Area A be transferred to
the County of Orange (County); that the policies of the County's General Plan would then apply to this
portion of the project site. The County does not have a land use plan for Planning Area A. The County
General Plan primarily focuses on the unincorporated area-territory that is not located within a city-the
plan also addresses regional services and facilities provided by the County such as regional parks, roads,
flood control facilities, etc. The majority of the unincorparated area is located in the southern portion of
the County, however there are large parcels of unincorporated property, developed and undeveloped,
located throughout the County. In addition, there are numerous small, unincorporated "islands" of
property spread throughout the central and northern County. In the past ten years, the unincorporated
territory has changed dramatically. Since 1993, three new cities (Laguna Woods, Rancho Santa
Margarita, and Aliso Viejo)have incorporated within Orange County.
Government Code Section 65302 requires that general plans contain seven elements: land use, circulation,
housing, conservation, open space, noise, and safety. This section also allows for the inclusion of other
optional elements in the general plan. Section 65301 provides flexibility in the format of general plans
and allows jurisdictions to combine elements. The County General Plan consists of an introductory
chapter, a demographics chapter, and nine elements: Land Use, Transportation, Public Services and
Facilities, Resources, Recreation,Noise, Safety, Housing, and Growth Management.
The first land use plan far Orange County,the Master Plan of Land Use,was adopted in 1946. The Master
Plan was later amended and refined through the adoption of Area Plans far individual planning areas
throughout the unincorporated area. The first comprehensive update of the Orange County General Plan
was completed in the early 1980s through the General Plan Modernization(GPM) effort. The objective of
the GPM was to streamline the processing of land development projects that were consistent with the
goals and policies adopted by the Board of Supervisors.
A 1999 administrative update to the General Plan was prepared to create a more current and readable
document. This update incorporated new County programs, socioeconomic data, and revised charts,
graphics and maps. In addition, the update included a reformatted text that combined the nine separate
elements into a single document. Sidebar notes, or factoids, were also added to the page margins to
increase reader interest. The 1999 General Plan update deleted both Components I and III.
In 2001 Counry staff amended the County's Housing Element. The State of California certified the
County's Housing Element on January 2002. On March 5, 2002, Orange County voters approved
Measure W, which repealed the aviation reuse designation far the closed Marine Corps Air Station, El
Toro and other provisions enacted by Measure A in 1994. Measure W also amended the Orange County
General Plan to authorize El Toro to be used for non-aviation uses, including a multi-purpose central
park, open space, nature preserve, universities and schools, cultural facilities, and other interim and long-
term uses. As clearly noted above, the County General Plan does not have a land use plan for Planning
Area A.
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.5-21
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It is reasonable to assume that any future use of Planning Area A would be limited to those uses specified
in the City's General Plan. Section 65454, Consistency with General Plan provides that no specific plan
may be adopted or amended unless the proposed plan or amendment is consistent with the general plan.
Section 65455, Zoning, Tentative Map, Parcel Map, and Public Works Project Consistency with Specifzc
Plan provides that no local public works project may be approved, no tentative map or parcel map for
which a tentative map was not required may be approved, and no zoning ordinance may be adopted or
amended within an area covered by a specific plan unless it is consistent with the adopted specific plan.
Finally, Section 65566, Consistency of Acquisitions, Disposal, and Regulation provides that any action by
a county or city by which open-space land or any interest therein is acquired ar disposed of ar its use
restricted or regulated, whether or not pursuant to this part, must be consistent with the local open- space
plan.
Additionally, State Laws require that County policies and programs related to areas such as transportation
and recreation(i.e.,bicycle and equestrian trails)would be applicable.
2.5.2 Conditionally Permitted Uses
Commenters expressed concern with the analysis of conditionally permitted uses. Section 6.4.1,
Conditional Use Permit, Open Space - Park of the Rio Santiago Specific Plan provides a list of uses
allowed in Planning Area B, subject to the approval of approval of a Conditional Use Permit (CUP) in
accordance with the standards of the City of Orange Municipal Code (OMC). Commenters have
expressed a concern with specific "intensive uses" permitted by a Conditional Use Permit (CUP) in
Planning Area B. Stating that the impacts associated with these uses are quantitatively different from
those associated with the proposed YMCA. They provided, as an example, of impact difference that
automobile trips generated by a stadium exceed that of an athletic facility. Additionally, that these
automobile trips are more concentrated in short windows of time before and after an event.
The Draft EIR indicates that Planning Area B would be located in the southwestern corner of the project
site, generally bordered by Santiago Creek on the north, East Santiago Canyon Road to the south and the
closed Villa Park Landfill to the west. The planning area totals 10 gross acres in size (approximately nine
percent of the project site) and would be developed prior to the last occupancy permit in Planning Area C
and D. It would allow a variety of fee based recreational and community uses including "pay-far-play"
uses, such as,but not limited to:
• Sports Activity Field(s)(i.e., softball/baseball),
• Soccer/Lacrosse/Field Hockey Field,
• Court Sport(s),
• Swimming Pool(s),
• Open Turf Area, and
• Athletic Training Center.
The Draft EIR indicates that the proposed sport fields have the potential to be lighted. Planning Area B
would include a multi-purpose facility with a maximum of 81,000 square feet that may include a
Page 2.5-22 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.5 Land Use and Planning
combination of the uses (listed below) and shall not exceed two stories in height. Ancillary uses in
support of the above uses would also be allowed (including but not limited to parking lots, bicycle
parking, restrooms, and support services such as sandwich shop, juice bar, coffee, pro shop, etc.).
Freestanding commercial uses would not be permitted. The following uses would be allowed subject to
the approval of a Conditional Use Permit (CUP) and additional use-specific environmental assessment
and review by the City:
• Archery Range,
• Country Club(s),
• Free-standing Museums and Libraries,
• Stadiums and Grandstands,
• Skate Park,
• Veterinary Clinics and Livestock Animal Hospitals, and
• Daycare with 9 or mare children
The Draft EIR states that the proposed project would alter the existing visual character of Planning Area
B with the elimination of existing on-site current uses [(i.e., the backfilling operation) Page 5.1-36 of the
Draft EIR]. Further, the Draft EIR states that the proposed project, including all the permitted and
conditionally permitted uses would not be perceived as a substantial degradation to the long-term visual
character of portions of the project site and indicating that Planning Area B is substantially degraded by
the current backfilling operation. At issuance of the NOP, Planning Area B was being backfilled and
contained the backfill operations and associated uses. There is no time limit for the completion of the
backfill operation. Additionally, PDF AES-11 through AES-19, and PDF AES-22 would reduce potential
long-term impacts related to the proposed project improvements in Planning Area B. These PDF's would
require compliance with the City's Municipal Code related to landscaping and the establishment of
specific design features to lessen the impact on the visual character of this area. Therefore, a less than
significant long-term visual character impact would occur and no mitigation would be required. (Page
5.1-37 of the Draft EIR)
The Draft EIR does not evaluate the impacts of an archery range, skate park, or daycare with nine (9) or
more children. These uses are directly associated with a YMCA use and are customarily found within
their operations. While commenters noted these use are necessarily more "intensive uses," they are uses
that require the approval of a Conditional Use Permit (CUP) in accordance with the OMC. An archery
range, skate park, or daycare with 9 or more children has been evaluated throughout the EIR in
association with the YMCA as associated uses. Each of these three uses require further evaluation for
potential specific issues once their precise location would be determined (i.e., safety zones for archery
range). Therefore, they would be subject to further discretionary review and approval for a CUP and
further CEQA analyses and review by the City at the appropriate time to review potential issues.
The Draft EIR does not evaluate country clubs; free standing museums and libraries; stadiums and
grandstands; and, veterinary clinics and livestock animal hospitals. County clubs would be associated
with a golf facility. Therefore, since no golf facility could be developed in Planning Area B this potential
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.5-23
Rio Santiago Project SCH No. 2009051072
2.5 Land Use and Planning
use, while conditionally permitted, must be considered speculative. The project applicant has indicated
that free standing museums and libraries would occur within the evaluated 81,000 square feet of
allowable development within Planning Area B. Therefore, they would be subject to the further
discretionary review and approval for a CUP and further CEQA review by the City would be the
appropriate time to review potential issues with these specific uses.
Planning Area B could be utilized as a stadium or grandstand with the approval of a CUP. It would be
speculative to evaluate a stadium or grandstand facility at this time as the exact location and size (i.e.,
number of seats) are unknown. Therefore, hey would be subject to the further discretionary review and
approval for a CUP and further CEQA review by the City would be the appropriate time to review
potential issues with these specific uses.
The approval of the Specific Plan by the City would not represent a commitment to expand the use of the
project site to allow these uses. City approval would establish the requirement that should these specific
uses be considered on the project site that further evaluation (i.e., CEQA & CUP) must be undertaken.
Therefore, while it might be argued that potential for approval of a future conditionally permit use would
exist,there is no commitment to expand uses on the project site at this time.
2.5.3 Physically Divide an Established Community
Commenters expressed concern that the proposed project constitutes "spot zoning"; thereby, physically
diving an established community. The California Planning Guide (An Introduction to Planning in
California)December 2005 Edition defines "spot zoning" as:
The zoning of an isolated parcel in a manner which is inconsistent or incompatible with
surrounding zoning or land uses, particularly if done to favor a particular landowner. A
conditional use permit is not a spot zone.
The Draft EIR indicates that the proposed project would not be developed as an isolated parcel in a
manner inconsistent or incompatible with surrounding zoning or land uses. The Draft EIR indicates that
the project site is located within a developed setting and is adjacent to established residential
communities. Santiago Oaks Regional Park is located to the northeast of the project site. The proposed
project replaces the existing materials recycling operation (i.e. asphalt and concrete crushing) and
backfilling operations land uses with proportions of open space, open space recreational uses, age-
qualified residential, and low density single-family residential uses. The Draft EIR indicates that the
existing use of the project site is inconsistent with the surrounding residential and open space land use.
The proposed project provides PDF LUP-1 through PDF LUP-3 to define the proposed project's
connectivity to the surrounding community. (Page 5.10-11 of the Draft EIR)
The proposed project does not propose to establish or relocate any roadways, which would have the
potential to divide an established community. The proposed project would modify East Santiago Canyon
Road, by providing the addition of road right-of-way adjacent to the project site, and providing a
landscape median for aesthetic and safety purposes.
Page 2.5-24 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.5 Land Use and Planning
The proposed project provides for open space along both sides of Santiago Creek area. This open space
provides a connection for the community to Santiago Oaks Regional Parks. Presently, the project site is
fenced-off from public access. The proposed project and the existing community would be able to access
Santiago Oaks Regional Parks through the trail system provided by the proposed project. The following
recreational trails and/or possible connections are proposed within the project site and are shown in
Section 5.15,Recreation, Figure 5.15-2,Existing and Proposed Trails:
• The proposed project would maintain the Bikeway within East Santiago Canyon Road.
• The proposed project will provide a public multi-use trail adjacent to Santiago Geek that would
allow for linkage to Cannon Street and planned regional trail connectors to the west.
• A public recreation trail currently exists along the north side of East Santiago Canyon Road
adjacent to the existing Reserve neighborhood. The proposed project provides a connection to
this trail and extends it along the project's entire East Santiago Canyon Road frontage.
• At the southwest corner of the project site, a further public trail extension westward by the
adjacent property owner(County of Orange)would be possible.
• The proposed project provides a public recreational multi-use trail extending into the project site
alongside the proposed main entry roadway, providing a connection between East Santiago
Canyon Road and the proposed multi-use trail along the south bank of Santiago Creek.
• PDF-TRA 17, which requires a signal at the main entrance to the project, provides connectivity
from surrounding residential communities and adjacent Mara Bradman Equestrian Arena to the
project trail system.
• A public multi-use trail is proposed along the southern boundary of Planning Area A along the
entire south bank of Santiago Creek.
• At the far western edge of the project site, the multi-use trail would allow for future linkage to
Cannon Street by the adjacent property owner and planned regional trail connectors to the west.
While commenters have expressed a concern that the proposed project would be developed as an isolated
parcel in a manner inconsistent or incompatible with surrounding zoning or land uses, this is not an
accurate statement. The Draft EIR indicates that the proposed project has been designed to be consistent
with the surrounding community by preserving the area's rustic environment and lifestyle as required in
PDF LUP-2. The proposed project provides single-family residential units adjacent to the established
residential communities. The proposed project provides age-qualified housing adjacent to the project
site's single-family uses. Within the proposed project age-qualified area, there will be villas that act as a
transition from the single-family to the age-qualified units.
City of Orange-Response to Comments/Final E/R—December 2013 Page 2.5-25
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2.5 Land Use and Planning
The Draft EIR indicates that the Rio Santiago Specific Plan would establish design requirements to ensure
that the proposed projects scale and massing are consistent with surrounding neighborhoods. Three
examples of design requirements in the Rio Santiago Specific Plan related to massing and scale include:
• Design and site buildings in a manner that respects the project's setting through the use of
appropriate scale and massing of building elements, ample setbacks, and articulation of building
facades by means of offsets, overhands, balconies, style appropriate detailing and other
architectural enhancements.
• The plotting of residences shall be designed in a manner that achieves visual diversity and interest
in the street scene. Such diversity shall be achieved through varying building setbacks,
articulated building massing, or enhanced elevations on residences plotted on corner lots.
• Age-qualified building corners and ends shall step down in scale at highly visible key locations,
softening the building edges and enhancing the street scene and providing articulated edges. One
and two story height limit within 50' of the exterior Planning Area or project boundary. (Rio
Santiago Spec�c Plan)
Additionally, while commenters expressed concern that the proposed project constitutes `spot zoning'',
thereby, physically diving an established community, the Draft EIR indicates that the proposed project
would provide for community connectivity by:
1. The provisions of a multi-purpose building space for use as a community recreational center for
all ages,benefitting the surrounding and all City residents.
2. The provision of recreational facilities, including the multi-purpose building, parks, multi-
purpose trails, and fields;
3. The elimination of community barriers that would include privately owned fenced property; and,
4. The elimination of land used primarily for resource production purposes.
Additionally, the Draft EIR notes that the Rio Santiago Specific Plan indicates that the landscape plan has
been developed to provide seamless edges between residential and open space uses throughout the
community as implemented in PDF LUP-3. The combination of proposed project uses based on the
analysis provided above indicates that the proposed project will join rather that separate the existing
surrounding community. Implementation of the proposed project does not have the potential to divide an
� According to tlte court[.Avenidn Sc��i Jna�i Partnerslaip v. Citr c?f Sun Cle»re:nte,201 CaI.A>>.4t1� 1256 �01 I tl�c essence oI's ot zonin�>is
}1 (- �)]," P �
irrational discriminaCion."Quoting at lengttf from Arcadia Development Co.v.City of Morgan Hill, 197 C�1. App.4th 1526(2011),the cowl
continued: "Spot canrng occi�n�s ti�here a sinall parcel is restricted and giveit lcsser rights than the surrounding property,as where a lot in the
center of a business or commercial district is limitecl to uses tor residential purposes thereby creating an'island'in Che middle of a larger area
devoted to ot�her uses. . . . Usually spot zoning involves a small parcel of land, the larger the property the more difticult it is to sustain an
eillegation of'spot zoiiing. . . . Likewise,�vliere the'spot'is not an islaiicl but is connected oii some sides to a like zone the altegation of spot
zoning is more difiicult to establisli since lines must be drawn at some point. . _ .Even �c�here a small islancl is created in the u�idst o�f less
restrictive z,onine,the zoning rnay l�e u�held where rational reason in die public bene�tit exists for sucli a classiticatiun."
Page 2.5-26 City of Orange-Response to Comments/Final E/R—December 2013
SCH No. 2009051072 Rio Santiago Project
2.5 Land Use and Planning
established community. Therefore, less than significant impacts would occur and no mitigation measures
would be required. (Page 5.10-13 of the Draft EIR)
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.5-27
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2.6 Open Space
Several commenters expressed concern related to open space. A majority of the open spaces concerns
related to land use and planning, and recreation issues. Therefore, they are discussed within Master
Response 2.5, Land Use and Planning and Master Response 2.7, Recreation. The majority of the
commenters concerns not related to land use and planning and recreation issues related to the following
open space items:
1. The proposed project would result in the project specific and cumulative loss of open space for
the local community.
2. The future ownership of Planning Area A.
3. The future use of Planning Area A.
Section 7.0 Alternatives to the Project of the Draft EIR describes a range of alternatives to the proposed
project, or to the location of the proposed project, which would feasibly achieve most of the basic project
objectives, but would avoid or substantially lessen any of the significant effects identified in the analysis.
Section 5.1, Aesthetics of the Draft EIR describes the visual resources on the project site and determines
the potential impacts that may result from implementation of the proposed project. Section 5.15,
Recreation of the Draft EIR describes potential impacts on recreational facilities. Section 5.10,Land Use
and Planning of the Draft EIR describes potential impacts to land use and planning, which may result
from the construction and operation of the proposed project. These sections of the Draft EIR also identify
mitigation measures to reduce any potentially significant land use and planning impacts and describe the
residual impact, if any, after imposition of the mitigation. This analysis used the thresholds of
significance consistent with Appendix G of the State CEQA Guidelines as noted in each of these
respective sections:
2.6.1 Loss of Open Space
Project Specific Loss of Open Space
Several commenters expressed concern that the proposed project would result in a loss of open space for
the local community. The project site historically and presently has been utilized for a variety of land
uses. Historically, the project site was used from 1919 to 1995 primarily for surface mining of sand,
aggregates, and associated ancillary uses. Surface mining activities ceased in 1995 and all ancillary uses
were removed in the same year. Agricultural production intermittently occurred on the project site with
the most recent production occurring from approximately 1993 through 2004. Agricultural production
included fruit orchards and strawberry production. All agricultural uses on the project site ceased in
2004. The project site has also been used intermittently for storage of firewood and green waste
recycling.
The Notice of Preparation (NOP) for the Draft EIR was issued on April 7, 20ll. At the time of the
issuance of the NOP there was no public access to the project site. The project site was fenced with a
chain link fence on all sides with the exception of a portion of the northeastern boundary with Santiago
Regional Park and Santiago Creek. A chain link fence was located approximately 100 feet to the
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2.6 Open Space
northeast of the project site boundary in the Santiago Regional Park. Private controlled access to the
project site occurred from East Santiago Canyon Road from two gated and monitored entrances.
Materia/s Recyc/ing
At the time of the issuance of the NOP, approximately five acres in the southeastern portion of the project
site were being and continue to be used as a materials recycling area. This area includes apparatus for the
crushing of boulders, bricks, rocks, etc. for recycling. The materials recycling area additionally includes
operations that provide for the cement treatment of base materials. Figure 3-5, Materials Recycling in
the Draft EIR provides the present location of the materials recycling area. Material for this operation
originates primarily from off-site sources. Access to the materials recycling area is from a controlled
entrance along East Santiago Canyon Road. Materials generated by this operation have historically been
used on and transported off the project site. The materials generated by this operation at issuance of the
NOP were being taken off-site. Materials recycling will continue on the project site through the
construction of the proposed project until Planning Area D is developed.
Backfi//ing Ope�ation
At the time of the issuance of the NOP, a portion of the project site was being backfilled to restore
previously mined portions of the site. The existing backfill operation is not a permanent use. The project
site is presently being backf'illed in sequentially defined phases. Figure 3-6, Bac�ll Operation in the
Draft EIR provides the location of the backfill operation. The project site is being over excavated (i.e.,
removal of unsuitable materials) and filled in the present backfill operation. The project applicant has
indicated that additional grading permit(s) will be requested from the City to complete backfilling of all
previously mined portions of the project site. As previously noted, the project site was used from 1919 to
1995 for surface mining of sand, gravel, and other aggregates. Previously mined portions of the project
site were used for residue silt deposition, otherwise known as silt ponds. The backfilling operation
addresses both mined and silt pond areas.
In March 2011, the City issued Grading Permit #2047 related to the backfill operation. Table 17.32.020,
Sand and Gravel District Use Regulations, of the Orange Municipal Code indicates that backfilling is a
permitted use (P) in the S-G (Sand and Gravel) District. Additionally, in accordance with Section 3.1,
Grading Permit Exceptions, of the Ciry Grading Manuel backfilling is a permitted use. Grading is a
ministerial (not discretionary) action as defined by the CEQA Guidelines and the City of Orange Local
CEQA Guidelines (page 5 — 6). Per Public Resources Code Section 21080(b)(1), CEQA does not apply
to ministerial actions, therefore, no CEQA environmental review was conducted for the permitted and
existing ministerial approved grading.
The limits of activity established by Grading Permit #2047 are depicted on Figure 3-6, Backfill
Operation. The backfill operation will restore those portions of the project site within the limits of activity
to the elevations approved by Grading Permit #2047. Approved Grading Permit #2047 provides that
2,000 cubic yards of material will be cut in addition to the over excavation. A total of 223,000 cubic
yards of material will be imported to the site. The imported materials include concrete, asphalt, rock, and
Page 2.6-2 City of Orange-Response to Comments/Final EIR—December 2013
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2.6 Open Space
soil. The imported materials will be crushed on-site. A total of 225,000 cubic yards of material,both cut
and fill,will be blended during this approved backfilling operation.
In addition, grading permit(s) will be requested from the City to complete the backfilling of the
previously mined portions of the project site, as described below in 3.8,Demolition and Grading Concept
in the Draft EIR. Since the issuance of the NOP, the project applicant has submitted additional
applications far backfill. As of this writing,no action has been taken by the City.
As noted in Section 3.0, Project Description of the Draft EIR this approved, on-going backfill operation
currently is separate and distinct from the proposed project. However, some of this grading would have
to occur to construct the proposed project. Therefore, as a practical result, from the date of project
approval the backfilling and grading will become project site preparation activities and, as such, are
analyzed as part of the construction phase of the project.
Therefore,while several commenters expressed concern that the proposed project would result in a loss of
open space for the local community indicating that in their opinion that the project site is all open space,
Planning Areas A, B, C and D were at the time of the issuance of the NOP being utilized for both
materials recycling and backfill operations. Additionally, the existing backfill operation is not a
permanent use. While open in character,neither use would be considered as traditional open space. If the
project were to be approved Planning Area B would designated Open Space-Park(Private) and a portion
thereof would be utilized for recreational play fields that could be considered open space. Planning Area
A would be considered as traditional open space and would continue as an Open Space area, if the
proposed project were to be approved.
Cumu/ative Loss of Open Space
Several commenters expressed concern that the proposed project and related projects would result in a
cumulative loss of open space for the local community. The potential for cumulative loss of open space is
addressed in two methods in the Draft EIR. First, related to potential cumulative conflict with applicable
plans, policies, or regulations and conservation plans. Second, related to impacts from increased use of
neighborhood and regional recreational facilities. The latter is discussed in Master Response Section 2.7,
Recreation.
Cumulative Conflict with Applicable Plans,Policies,or Re�ulations
The Draft EIR found that the proposed project, when combined with the related projects, would not result
in significant impacts related to conflicting with applicable plans, policies or regulations. The analysis
indicates that the related projects and the proposed project would have less than significant impacts
related to conflicting with applicable plans, policies or regulations. Should the Villa Park Self-Starage
project require an amendment to the Orange County General Plan, the approval of the amendment by the
Orange County Board of Supervisors would result in conformance with that Plan.
Consequently, there would be no incremental or combined effects of the proposed project related to
conflicting with applicable plans, policies or regulations, when viewed in connection with the effects of
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.6-3
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past projects, the effects of other current projects, and the effects of probable future projects. Therefore,
there would be no incremental effect which could be cumulatively considerable and no mitigation
measures are required.
Cumulative Conflict with Conservation Plans and Area Plans
The Draft EIR found that the proposed project, when combined with the related projects, would not result
in significant impacts related to conflicting with conservation plans. Based on the above referenced
analysis the related projects and the proposed project would have less than significant impacts related to
conflicting with conservation plans.
Should the Villa Park Self-Storage project require an amendment to the Orange County General Plan, the
approval of the amendment by the Orange County Board of Supervisors would result in conformance
with that plan. Additionally, each of the related projects is required to be consistent with the Orange
County Central Section Natural Communities Conservation Plan/Habitat Conservation Plan
(NCCP/HCP). Therefore, no cumulative considerable conflicts with conservation plan would be
anticipated.
Please note that, Commenter's expressed concern that the proposed project was inconsistent with the area
plans. Please refer to Master Response Section 2.5.1, Conflict with Applicable Plans, Policies, or
Regulations for detailed information.
Consequently, there would be no incremental or combined effects of the proposed project related to
conflicting with conservation plans, when viewed in connection with the effects of past projects, the
effects of other current projects, and the effects of probable future projects. Therefore, there would be no
incremental effect which could be cumulatively considerable and no mitigation is required.
The Draft EIR found that related to conflicting with applicable plans, policies, or regulations and
conflicting with conservation plans and policies,the proposed project does not have a significant potential
to have a cumulatively considerable incremental effect. Therefore, while all of the related projects in
some manner would reduce the amount of open space, this loss is planned for in applicable plans
including conservation plans and policies.
2.6.2 Future Ownership Planning Area A
Several commenters expressed concern that the proposed project would result in ownership of Planning
Area A by the County of Orange (County), rather than the City. The commenters expressed a concern
that the project applicant �vasn't transferring this land to the City. They noted that the Ciry has been
determined to be deficient in park land. Commenters further noted that there is no approval or acceptance
on record by the County related to Planning Area A. At this time, the City has not taken action to accept
or reject Planning Area A.
Planning Area A is in the northern portion of the site and fully encompasses Santiago Creek. Most of
Planning Area A lies north of Santiago Creek; however, a small portion is located along the south side of
the Creek. The location of Santiago Creek within Planning Area A is depicted on Figure 3-11, Planning
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2.6 Open Space
Areas in the Draft EIR. It is bordered by Mabury Avenue and the Mabury residential community to the
North, and on the South by Planning Areas B, C, and D. Planning Area A is approximately 50 acres in
size (approximately 45 percent of the project site) and would be retained in its current condition except
for infrastructure improvements and native habitat restoration.
The Draft EIR states that Planning Area A will be conveyed to either the City, Orange County Parks, the
Homeowner's Association (HOA), or Orange County Transportation Authority (OCTA) as a habitat
restoration project for the Measure M2 Freeway Environmental Mitigation Program for permanent public
open space preservation. The proposed project within Planning Area A provides for re-vegetation in the
fuel modification zone and for infrastructure improvements. The proposed project does not provide for
the restoration of Santiago Creek, but also does not preclude it. The Rio Santiago Specific Plan states
that,
... Planning Area A, the Santiago Creek Greenway Reserve Open Space, the developer will
provide for the restoration (by removal of the existing chain link fence, modification of the
vegetation, and re-vegetation in the fuel modification zone to the southeast of the project site with
appropriate landscape materials) and maintenance in a natural condition as public open space...
Planning Area A shall provide the opportunity for the potential expansion of and connection to
Santiago Oaks Regional Park, located east of the project site. Potential future recreational trail
connection to the west towards Cannon Street could also be made. (Rio Santiago Specific Plan,
Chapter 3)
As noted above, the City has not taken action to accept or reject Planning Area A. The City may or may
not choose to accept Planning Area A based on comments at future public hearings, the recommendation
of the City Planning Commission and other factors. The Commenter's concerns do not change the
analysis or conclusions of the Draft EIR, because they do not raise any issues related to the adequacy of
environmental analysis conducted in the Draft EIR. However, they are noted and will be provided to the
Planning Commission and City Council for consideration.
2.6.3 Future Use of Planning Area A
Several commenters questioned if Planning Area A could be developed in the future or should be
considered as a non-developable area. The potential for future development in the City is governed by the
City's General Plan. Related to Planning Area A there are three key documents. The City General Plan,
the 1975 East Orange (EO) General Plan, and the Orange Park Acres Plan (OPA Plan). The following
describes briefly these three documents and describes the Draft EIR alternatives that evaluated no
development and development under the existing City General Plan related to Planning Area A.
City General Plan
The City General Plan was adopted in March 2010. The City General Plan includes the following
Elements: Land Use, Circulation & Mobility, Growth Management, Natural Resources, Public Safety,
Noise, Cultural Resources & Historic Preservation, Infrastructure, Urban Design, Economic
Development, and Housing. The City General Plan provides goals, policies, and programs intended to
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2.6 Open Space
guide future land use and development decisions within the City. The City General Plan designates
Planning Area A as Open Space (OS); Resource Area (RA); and, Low Density Residential (LDR 2.1-6
Du/Ac). The existing City General Plan designations for Planning Area A are depicted in Figure 3-7,
Existing and Proposed General Plan Designations in the Draft EIR.
1975 East Orange (EO) General Plan
Portions of the project site are also within the 1975 East Orange (EO) General Plan area. This includes
portions of Planning Areas A, B, and C. The existing EO General Plan designates these areas as
"Regional Park." Approximately 14.4 acres of the EO General Plan is located within Planning Area A.
The proposed project designates the project site within EO General Plan for Open Space (OS) in Planning
Area A, Open Space Park (OS-P) in Planning Area B, and Medium Density Residential (MDR) in
Planning Area C. The OS and OS-P designations are consistent with the EO General Plan. The MDR is
not consistent; however,the proposed project is requesting a General Plan Amendment.
Orange Park Acres (OPA) Plan
The Orange Park Acres Plan (OPA Plan) was adopted on December 26, 1973. Portions of the proposed
project site are currently within the Orange Park Acres (OPA) Plan area. This includes portions of
proposed project Planning Areas A, C and D. The existing OPA Plan designates these areas as"Santiago
Greenbelt Plan." Approximately 11 acres of the OPA Plan is located within Planning Area A.
The proposed project designates the project site within the OPA Plan for Open Space (OS) in Planning
Area A, Medium Density Residential (MDR) in Planning Area C, and Low Density Residential (LDR) in
Planning Area D. The OS designation is consistent with the OPA Plan. The MDR and LDR are not
consistent; however,the proposed project is requesting a General Plan Amendment.
Alternatives Analysis
The Draft EIR evaluated Alternative 1: No Project Alternative— No Development, Alternative 2: No
Project Alternative - Development Under the Existing General Plan, and Alternative 5: All Recreation
Alternative These three alternatives are discussed below related to potential uses of Planning Area A.
Please refer to Master Response Section 2.10,Alternatives for detailed information.
A/ternative 1:No Project A/ternative—No Deve%pment
Alternative 1: No Project Alternative—No Development evaluated what would be reasonably expected to
occur on the project site in the foreseeable future, if the proposed project were not approved. The City is
not aware of any plans for development of the project site other than the proposed project. The
environmental conditions existing at the time the Notice of Preparation (NOP) was published would be
assumed to continue, subject to changes resulting from reasonably projected contraction or expansion of
the existing uses. The City Attorney has stated that the materials recycling (i.e., asphalt and concrete
crushing) would require approval of an amended Conditional Use Permit for expansion. Table 7-1,
Summary of No-Project Alternative—No Development in the Draft EIR provides a statistical summary of
the land uses anticipated under this alternative. Figure 7-1, No Project Alternative —No Development in
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2.6 Open Space
the Draft EIR depicts a schematic of the land use under this alternative. Under this alternative,
approximately 85% of Planning Area A would be anticipated to remain vacant and 15% would be
anticipated to remain as on-going backfill operations.
A/ternative Z.•No Project A/te�native-Deve%pment Under the Existing Gene�a/P/an
Alternative 2: No Project Alternative - Development Under the Existing General Plan Alternative
evaluated the development of the project site for uses permitted under the City's existing General Plan
and Zoning. The City General Plan Policy Map designates the project site as Resource Area, Low-
Density Residential, and Open Space. The existing City General Plan Policy Map is depicted in Figure 3-
7, Existing and Proposed General Plan in the Draft EIR. The City's current Zoning Map designates the
portion of the project site north of Santiago Creek as R-1-8 (Single-family Residential), with the
remainder of the project site designated S-G (Sand and Gravel Extraction). The existing zoning district
classifications are depicted in Figure 3-10,Existing and Proposed Zoning Districts in the Draft EIR
Table 7-2, Summary of No Project Alternative —Development Under Existing General Plan and Zoning
in the Draft EIR, provides a statistical summary of the land uses anticipated under this alternative. Figure
7-2, No Project Alternative — Development Under Existing General Plan and Zoning in the Draft EIR,
depicts a schematic of the land use under this alternative. Under this alternative, approximately 38-acres
of Planning Area A would be anticipated to remain vacant and 12-acres would be anticipated to develop
with a potential total of 17 homes. The Draft EIR states the following related to Planning Area A.
North of Santiago Creek
Land uses permitted in the RA, OS, and LDR (Low Density Residential) designations would be
developed to the north of Santiago Creek with access from Mayberry Avenue. A total of 17
single-family residences would be constructed on approximately 12 acres(11%) of the area to the
north of Santiago Creek. The minimum lot size would be approximately 8,000 square feet.
These residences would not be restricted in regards to occupant age. Improvements to this
portion of the project site and the adjacent public street would occur. Additionally,
approximately 38 acres to the north and south of Santiago Creek are designated RA (described
above)and Open Space(OS). These 38 acres are zoned in S-G(described above).
Drainage and water quality improvements would be provided to meet all City requirements. City
park requirements would be met through the payment of fees. Material feedstock for operations in
this area would continue to originate from off-site sources.
Santiago Creek
No changes to Santiago Creek would occur under this alternative. For the purpose of this
alternative,no flood improvements to protect the residential uses on the north side of the Santiago
Creek were assumed. If this alternative were to be selected, the need for flood control
improvements, if any,would need to be determined. (Page 7-5 through 7-6 of the Draft EIR)
Therefore, for the purposes of this EIR,Planning Areas A is analyzed as a potentially developable area.
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2.6 Open Space
A/ternative 5.•A//Recreation A/ternative
Alternative No. 5 — All Recreation Alternative evaluates the development of the project site with a
mixture of open space and active recreational uses. Under this alternative, Planning Area A would be
developed as Open Space, with natural, passive and active areas. Additionally, Planning Areas B, C, and
D, would be developed with active open space. This alternative would also include internal streets, open
space and recreation areas, and equestrian and bicycling riding, and hiking trail linkages along East
Santiago Canyon Road and Santiago Creek. No flood control improvement to Santiago Creek would be
provided in this alternative. While this alternative is described as the "All Recreation Alternative," this
alternative should be considered both open space and recreational in nature. This alternative would allow
for similar uses that are proposed in the EO General Plan and the OPA Plan.
The information and concerns expressed above related to open space do not change the analysis or
conclusions of the Draft EIR because it does not raise any issues related to the adequacy of environmental
analysis conducted in the Draft EIR No further response is necessary.
Page 2.6-8 City of Orange-Response to Comments/Final E/R—December 2013
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2.7 Recreation
Several commenters expressed concern that that the proposed project would potentially impact
recreational facilities. The majority of these concerns related to the following issues:
1. Commenters had concerns related to parks:
• The proposed project would result in the City privatizing or selling public parks sites.
• Parks in Pla��ning Areas A and F3.
• The former Villa Park Landfill should be included in the development plan and related to
recreation.
• The proposed project would offer residents immediate access to Orange County Regional
Parks. This is addressed as both a concern and benefit below.
• The need for active and passive recreational open space in the community.
• The Mara Brandman Horse Arena is not discussed in the Draft EIR.
• Identification of what agency would ultimately be responsible for the management and
maintenance of the recreational area(refer below to Table 5.15-6,Recreational Areas.
2. Commenters had concerns related to trails:
• The ultimate responsible for the management and maintenance of the multi-purpose trails.
• The riming of the construction of the proposed public multi-puipose t�-ails.
• The safety of equestrian trails at their intersection with vehicular traff c.
• Trail connections: the multi-purpose trail connecti�n to the Santiago Oaks Regional Park and
to Cannon Street; and,additionally,with the bicycle trail connection to Cannon Street.
Section 5.15, Recreation describes potential impacts on recreational facilities. This section of the Draft
EIR also identifies mitigation measures to reduce any potentially significant recreation impacts and
describes the residual impact, if any, after imposition of the mitigation. The analysis used the following
thresholds of significance consistent with Appendix G of the State CEQA Guidelines:
Threshold REC-A Would the proposed project increase the use of existing neighborhood and
regional park or other public park facilities such that substantial physical
deterioration of the facilities would occur or be accelerated?
Threshold REC-B Does the proposed project include recreational facilities or require the
construction or expansion of recreational facilities which might have an adverse
physical effect on the environment?
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2.7 Recreation
2.7.1 Parks
Public Parks
Gene�a/P/an Text Amendment
Several Commenters expressed the concern that the proposed project would result in the City privatizing
or selling public parks sites within the community. This concern deals with the proposed change to the
General Plan Text. A discussion of the consistency of the proposed project with the City's General Plan is
provided in Master Response 2.5,Land Use and Planning. The Draft EIR states,
Open Space -Park
The proposed project would modify the Open Space — Park (OS-P) General Plan designation as
noted below. The City General Plan Open Space—Park designation is described as:
Public lands used for passive and active recreation. Includes all parklands owned and
maintained by the City of Orange, as well as parks operated by the County." (City of
Orange General P1an, Table LU-1).
Land uses within this designation are described as follows:
The Open Space Park designation refers to public and/or nrivate lands used for passive
and active recreation. This includes all parklands owned and maintained by the City of
Orange, ��parks operated by the County non-nrofit organizations and nrivate
landowners(Proposed Amendment to City of Orange General Plan,Page LU-22).
There are proposed changes to the General Plan text for Open Space Park and are noted above in
s�'rl� and underline. The proposed text changes allow for private recreation, such as a
YMCA or other private pay for use facilities to be permitted on Open Space Park General Plan
designation.
With the inclusion of the text amendment to the OS-P, the proposed project would be consistent
with the General Plan designation. Therefore, the proposed project would have a less than
significant impact and no mitigation measures would be required. (Page 5.10-15, Draft EIR)
Commenters are not correci in stating that the proposed project includes a General Plan text amendment
that would amend the General Plan's description of the "Park" land use designation. The amendment to
the City General Plan "Text"would amend the"Open Space—Park"(OS-P)description. The City General
Plan presently only designates land as OS-P that is owned and maintained by the City or County. The
proposed text changes allow for private recreational users, such as a YMCA or other private pay-for-use
facilities to own land designated as OS-P by the City General Plan.
Commenters have expressed a concern that the proposed amendment would impact approximately 20
public properties currently with the OS-P designation and any future properties that would be so
designated. The concern was stated that the text amendment would allow the City to sell existing Park
land to private owners planning to operate the park on a"pay—to-play"basis. These owners could develop
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2.7 Recreation
any of the intense active recreational uses allowed under the current Park designation. Some of these uses
may have significant environmental impacts on local streets and neighboring communities. While the
amendment could potentially allow for a change in ownership, a change in ownership would not change
any existing use or potential future use. CEQA requires the City to evaluate the significance of the
environmental effect of a proposed project. Commenters concerns with the potential sale of City public
park land to private individuals who might choose to exclude the public and allow the City to raise funds
in an economic downturn are speculative. CEQA requires only the analysis of effects that are reasonably
foreseeable and not changes that are speculative in nature. It is the opinion of the City that commenters
concern is not valid and is speculative in nature. Therefore, no further analysis of this concern is
warranted.
Acquisition of Future Parks
Additionally, commenters have expressed a concern that the proposed amendment would impact the
City's acquisition of future parks. Commenters have noted that in their opinion, if privately owned land
"used for passive and active recreation" counts as parkland, as the proposed amendment would allow,
then the City's exiting parkland acreage would increase substantially. They note that this would in their
opinion increase the ratio of parkland to persons, resulting in a corresponding decrease in the number of
acres the City would need to acquire to reach the General Plan standards. They note that this would in
their opinion mean that lands that would have been acquired for parks before the General Plan
amendment may instead be developed in the future.
Please refer to Public Park, General Plan Text Amendment discussion above related to the proposed
modifications to the Open Space — Park (OS-P) General Plan designation. While the amendment could
potentially allow for changes in the acquisition of future public parks, CEQA requires the City to evaluate
the significance of the environmental effect of a proposed project. Commenters concerns with the
potential that would allow for changes in the acquisition of future public parks in the City are speculative.
CEQA requires only the analysis of effects that are reasonably foreseeable and not changes that are
speculative in nature. It is the opinion of the City that commenters concern is not valid and is speculative
in nature. Therefore,no further analysis of this concern is warranted.
Table 5.15-4, Project Applicant Park Land Dedication Offer vs. City Standards is provided in the Draft
EIR. This table shows the project applicant's proposed offerings including open space, potential
recreation use on Planning Area B,trails, linear park, and other amenities. This table includes the project
applicant's argument column demonstrating why the project applicant believes each offering should and
may be accepted by the City Council in accord with the OMC. The City Staff position is provided in the
adjacent column, which explains City Staffls reasons why the project applicant offerings (with exception
of the potential 50% credit in Planning Areas C and D,may not be accepted pursuant to the OMC.
The City's Municipal Code requires that the proposed project comply with one of the following:
• Payment of City Park Fees(Quimby fees);
• Dedication of land to the City that meets City requirements; or,
• A combination of fees and land dedication.
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2.7 Recreation
Orange Municipal Code (OMC) Section 16.60.070A.2 requires, "...at the time of the tentative tract or
parcel map approval, the Planning Commission shall recommend to the City Council, as a part of such
approval, whether to require a dedication of land within the subdivision, the payment of a fee in-lieu
thereof, or a combination of both." The project applicant has offered dedication of property for park and
recreation purposes. The project applicant's opinion is that the project's proposed open space, potential
private recreation use on Planning Area B, trails, linear "park", and other amenities identified in Table
5.15-4, Project Applicant Park Land Dedication Offer vs. City Standards fully satisfy the parkland
dedication requirements of the OMC. Acceptance of the applicant's opinion would be contingent on the
City Council agreeing that the offerings meet the OMC definitions and codes pertaining to park land.
City Staff"s opinion is that the project applicant offerings do not meet the OMC requirements for park
land as explained in Table 5.15-4, Project Applicant Park Land Dedication Offer vs. Ciry Standards.
Depending on the facilities to be shown at the time detailed development plans of Planning Area C are
approved in the future, pursuant to OMC Section 16.60.090D, there is potential for a maximum of fifty
(50) percent park credit for privately owned parkland in Planning Areas C and D. However, until such
time as detailed development plans are submitted and approved, City Staff believes that the project
applicant still must provide in-lieu park fees and/or parkland meeting the OMC requirements. City Staff's
disagreements with the project applicant are outlined with reference to OMC sections in Table 5.15-4,
Project Applicant Park Land Dedication Offer vs. City Standards. Any such combination of park land
dedication or park fees payment is possible and, with City Council approval of the appropriate factual
findings for compliance with the OMC, any such combination will alleviate the impact on parks that
could be created by the proposed project because either improved park facilities would result from fees to
handle the increased project population or, land would be provided for the park needs of the increased
project population. As a result of the City Council determination for the method of compliance with the
OMC, with appropriate factual findings for compliance with the OMC, a less than significant impact is
anticipated resulting from the proposed project and no mitigation measures would be required.
The Draft EIR analyzes City requirements for parkland related to the proposed project. The Draft EIR as
noted above, goes beyond CEQA requirements analysis by providing a detailed discussion of the City
Staff and project applicants opinions related to the OMC requirements for park land dedication. CEQA
requires only the analysis of effects that are reasonably foreseeable and not changes that are speculative in
nature. It is the opinion of the City that commenter's concern is not valid and is speculative in nature.
Therefore, no further analysis of this concern is warranted.
Planning Area A
Several commenters expressed concern with the ultimate responsibility for the management and
maintenance of Planning Area A. A concern was expressed regarding why the project applicant��asn't
transfen�itlg Plalining Area A to the City if the City-needs parks and open spacE. There was a coneel-�1 that
thei-e was na discussion of the City's decision not ta �ccept Planning Area A. Additionally, there was a
cancern with the status of the County's"appjroval or acceptance" of Planning Area A.
The Draft EiR states that,
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2.7 Recreation
Planning Area A will be conveyed to either the City, Orange County Parks, the Homeowner's
Association (HOA), or Orange County Transportation Authority (OCTA) as a habitat restoration
project for the Measure M2 Freeway Environmental Mitigation Program for permanent public
open space preservation. The proposed project within Planning Area A provides for re-vegetation
in the fuel modification zone and for infrastructure improvements. (Page 3-28 of the Draft EIR)
At the time of the writing of this document the City has not fonnally rejected the acceptance of Planning
Area A. However, the City Staff has recommended that Plaiming Area A not be accepted for dedication
to the City. Additionally, as of the writing of this document the County has not approved or accepted
dedication of Planning Area A. As noted above, should the County, OCTA, and the City all decline to
accept the offer of dedication of Planning Area A, the property would be transferred to the HOA.
Planning Area A would be restricted to, "permar7erat public open space preservation". Therefore, no
further analysis of this concern is warranted.
Planning Area B
Several commenters expressed concerns and opinions related to Planning Area B recreational use
including: 1. The opinion that the project description did not provide a detailed analysis of the impacts to
the environment of development in Planning Area B; 2. The concern that Planning Area B could
e�ventually be turned into additional home sites; and, 3. A support far Planning Area B �nd the potenti�l
that it could provide intergenerational op}�ortunities unique to tlle area.
Detai/ed Project Description
Section 3.0,Project Description of the Draft EIR area indicates that Planning Area B will,
Allow a variety of fee based recreational and community uses including "pay-for-play" uses, such as, but
not limited to:
• Sports Activity Field(s)(i.e., softball/baseball),
• Soccer/Lacrosse/Field Hockey Field,
• Court Sport(s),
• Swimming Pool(s),
• Open Turf Area, and
• Athletic Training Center.
Sport fields have the potential to be lighted. Planning Area B would include a multi-purpose facility
with a maximum of 81,000 square feet that may include a combination of the uses (listed below) and
shall not exceed two stories in height. Ancillary uses in support of the above uses are also allowed
(including but not limited to parking lots, bicycle parking, restrooms, and support services sueh as
sandwich shop, juice bar, coffee, pro shop, etc.). Freestanding commercial uses would not be
permitted. The following uses would be allowed subject to the approval of a Conditional Use Permit
(CUP) and additional use-specific environmental review by the City:
• Archery Range,
• Country Club(s),
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2.7 Recreation
• Free-standing Museums and Libraries,
• Stadiums and Grandstands,
• Skate Park,
• Veterinary Clinics and Livestock Animal Hospitals, and,
• Daycare with 9 or more children (Page 3-28 through 3-29 Draft EIR).
This section of the Draft EIR further indicates that Planning Area B totals 10 gross acres in size
(approximately nine percent of the project site). Finally, that this area would be developed prior to the
last occupancy permit in Planning Areas C and D. Planning Area B is depicted on Figure 3-4, Tentative
Tract Map; and, statistically in Table 3-2, Rio Santiago Planning Area Summary. Additionally, several
figures (i.e.,Figure 3-14 Master Circulation Plan,Figure 3-15,Landscape Framework, Figure 3-16,Plan
Zones, and Figure 3-17, Wall and Fence Plan) provide further definition of Planning Area B. Based on
the above, the City has determined that Section 3.0, Pf•oject Descri�tiot� of the Dtaft FIk provides a
sufficiently detailed description of development proposed in Planning Area B to provide for a meaningful
analysis. Therefore, no further analysis of this concern is warranted.
Change in Land Use
Several commenters expressed concerns and opinions that Planning Area B could eventually be turned
into additional home sites. If the proposed project were approved, the conversion of Planning Area B to
home sites would require:
1. Amendment to the City General Plan;
2. Amendment to the Rio Santiago Specific Plan;
3. Tentative Tract Map; and,
4. Site Plan and Architectural Design Review.
Appropriate documentation would be required under the State CEQA Guidelines and Local CEQA
Guidelines. CEQA requires only the analysis of effects that are reasonably foreseeable and not changes
that are speculative in nature. The commenter's concern has been addressed by this response. Therefore,
no further analysis of this concern is warranted.
/nte�generationa/Rec�eationa/Opportunities
Several commenters expressed an opinion that Planning Area B would provide intergenerational
recreational opportunities unique to the area. This information does not change the analysis or
conclusions of the Draft EIR because it does not raise any issues related to the adequacy of environmental
analysis conducted in the Draft EIR. Therefore,no further analysis of this concern is warranted.
Former Villa Park Landfill
Several commenters expressed the opinion that the County-owned land on the corner on East Santiago
Canyon Road and Cannon Street(former Villa Park Landfill) should be included in the development plan
and utilized for recreation. They noted that the closed former Villa Park landfill should be included in the
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2.7 Recreation
development plan. Commenters stated that the City needs additional park space. It was their opinion that
the former Villa Park Landfill should be used for park and recreational space for the general public.
Commenters suggested a redesign of the proposed project to enable use of the former Villa Park Landfill
as an extension of the proposed project. It was noted that the proposed project includes Planning Area B
OS-P (Park) which is adjacent to the landfill. Commenters suggested that Planning Area D could be
expanded to accommodate larger lot sizes; Planning Area C moved west to overlap Planning Area B; and,
Planning Area B moved entirely over the former Villa Park landfill. They suggested that this would
allow for the proposed use of Planning Area B and for a park open to the public located on the former
Villa Park Landfill. They noted that the former Villa Park Landfill is an existing eyesore in this beautiful
neighborhood and should be cleaned up and put to good use for the benefit of the residents of the
proposed project and the general public.
The former Villa Park Landfill site is under the ownership of the County and not the project applicant.
This information does not change the analysis or conclusions of the Draft EIR because it does not raise
any issues related to the adequacy of environmental analysis conducted in the Draft EIR. No further
response is necessary.
Regional Park Impacts
Several commenters expressed concern that the proposed project would offer residents immediate access
to Orange County Regiona] Parks, if high density zoning were allowed. This was expressed as both a
beneft of the proposed project and a concern of the proposed project. Additionally, opinions were
expressed tllat this loss of recreational opportunity and impact of high density zoning would diminish
sun•ounding City of Orange and Villa Park homeowner's property values.
A concern was expressed that the proposed project would increase the use of regional parks in the area.
Further that the proposed project would require construction of various recreational facilities that would
have substantial impacts and have an adverse physical effect on the environment and potentially to
regional parks.
The Draft EIR indicates that PDF REG1 through PDF REGS require the proposed project to include
open space and parks that reduce the projects impact on existing recreational facilities and the
construction or expansion of recreational facilities and provide a link for recreation uses along Santiago
Creek. Refer to Public Parks— General Plan Text Amendment above, for detailed information regarding
park dedication requirements. The Draft EIR concluded that impacts on open space/parks would be
anticipated to have a less than significant impact due to land and amenities provided and/or payment of
park fees and no mitigation measures would be required. Land and amenities proposed by the project
applicant are provided on Table 5.15-6,Recreational Areas and Table 5.15-7, Trails.
Access to Santiago Oaks Regional Park would be provided by a future connection via a Multi-Use Trail
proposed along the southern boundary of Planning Area A along the south bank of Santiago Creek. The
multi-use trail would be used by pedestrians, equestrians and bicyclists. The multi-use trail would be a
20-foot wide tread comprised of a 10-foot paved area, 4-foot wide decomposed gravel equestrian tread,
and a 2-foot wide decomposed granite tread for joggers. This area would also be used by Orange County
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2.7 Recreation
Flood Control and the City Fire Department to access the Santiago Creek. The trail would include a
border on one side of a split-rail ar pipe fence with access points at key locations along the perimeter of
the adjacent Planning Areas. At the far western edge of the project site, the Multi-Use Trail location
would allow for future linkage to Cannon Street and planned regional trail connectors to the west. The
trail has been designed to meet County of Orange Standard for a 20-foot right-of-way easement width
from the Regional Riding and Hiking Trails Design Guidelines. The trail has been designed to County
standards, as City Staff has informed the project applicant the City does not intend to take ownership of
Planning Area A, including the multi-use traiL The 2010 City General Plan Circulation and Mobility
Element, indicates that implementation of the Santiago Creek Trail is considered a high priority. This
trail is illustrated Figure 5.15-2,Existing and Proposed Trails in the Draft EIR.
The Draft EIR makes the following finding:
Therefore, based on the information presented above, the impacts on open space/parks would be
anticipated to have a less than significant impact and no mitigation measures would be required.
(Page 5.15-19 of the Draft EIR)
This information and concerns expressed above does not change the analysis or conclusions of the Draft
EIR because it does not raise any issues related to the adequacy of environmental analysis conducted in
the Draft EIR. No further response is necessary.
City Parkland Requirements 8 Deficiencies
Several commenters expressed concern with the need for active and passive recreational open space in the
community. Figure 5.15-4, Proposed Public Open Space Amenities shows the proposed project's
offering of public open space amenities. Figure 5.15-5, Proposed Private/Semi Private Open Space
Amenities shows the proposed project's offering of private/semi private open space amenities. A concern
that the proposed project does not offer public free open space and only plans for a privately owned park
was expressed. Clarification ti�as requested related to tlie City Staff's and project applicant's positions
related to the City requirements for the dedication of park land.
Refer to Public Parks — General Plan Text Amendment in this master response comment, far detailed
information regarding park dedication requirements. The Draft EIR concluded that impacts on open
space/parks would be anticipated to have a less than significant impact and no mitigation measures would
be required. The information and concerns expressed above does not change the analysis or conclusions
of the Draft EIR because it does not raise any issues related to the adequacy of environmental analysis
conducted in the Draft EIR. No further response is necessary.
Mara Brandman Horse Arena
Several commenters expressed concern that the 3.7 acre extension of the Mara Brandman Horse Arena
that would be donated by the landowner as part of the approval of the proposed project was not discussed
in the Draft EIR. A concern that the donation is part of the Rio Santiago Development Agreement was
expressed. Please note that the Mara Brandman Horse Arena and extension area is not part of the
proposed project.
Page 2.7-8 City of Orange-Response to Comments/Final E/R—December 2013
SCH No. 2009051072 Rio Santiago Project
2.7 Recreation
No change to the existing land use of the 3.7 acres is proposed. Therefore, no impacts or mitigation
measures are required. The information and concerns expressed above does not change the analysis or
conclusions of the Draft EIR because it does not raise any issues related to the adequacy of environmental
analysis conducted in the Draft EIR. No further response is necessary.
Parks Management and Maintenance
Several commenters expressed concern with the ultimate agency responsible for the management and
maintenance of the recreational areas. Refer to Table 5.15-6,Recreational Areas that have been added to
the EIR to clarify each area; timing; and, responsibility for management and maintenance. The
information and concerns expressed above does not change the analysis or conclusions of the Draft EIR
because it does not raise any issues related to the adequacy of environmental analysis conducted in the
Draft EIR. No further response is necessary.
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.7-9
Rio Santiago Project SCH No. 2009051072
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2.7.2 Trails and Bikeways
Trail Management and Maintenance
Several commenters expressed concern with what entity will responsible for the management and
maintenance of the three new public multi-purpose trails. Refer to Figure 5.15-3, Trails and Bikeways
and Table 5.15-7, Trails and Bikeways that have been added to the EIR to clarify the location of each
trail; type of trail or connection; timing of construction; and, responsibility for management and
maintenance.
Page 2.7-12 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
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2.7 Recreation
The clarification Table and Figures added to an EIR related to parks and trails is not "significant" as the
EIR has not been changed in a way that deprives the public of a meaningful opportunity to comment upon
a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an
effect. Additionally, the clarified would not result in new or substantially increased significant impacts,
and therefore no recirculation is required.
The commenters concerns do not change the analysis or conclusions of the Draft EIR,because they do not
raise any issues related to the adequacy of environmental analysis conducted in the Draft EIR. However,
they are noted and will be provided to the Planning Commission and City Council for consideration.
Trail Construction Timing
Several commenters expressed concern with the timing of the construction of the proposed public multi-
purpose trails. C'ommenters offered an opinion that the ideal time to canstruct an o�f'f-site underpass
connection to Cannon Street would be during grading and construction of thc trail on the project site. As
the commenters noted this is not an ETR related issue. Refer to Figure 5.15-3, Trails and Table 5.15-7
Trails that have been added to the EIR to clarify the location of each trail; type of trail or connection;
timing of construction; and, responsibility for management and maintenance. The information and
concerns expressed does not change the analysis or conclusions of the Draft EIR because it does not raise
any issues related to the adequacy of environmental analysis conducted in the Draft EIR. No further
response is necessary.
Equestrian Trail Safety
Several commenters expressed concern with the safety� of ec�uestrian trails at their intersection with
vehicular traffic. Commenters ex�ressed concerns with the existing equestrian crossing at Orange Park
Boulevard and Santiago Canyon Road. A concern ���it11 tl�e potential etfect of'the proposed praject on
existing equestrian uses in the commt�mity has not been addressed aciequately. It was the opinion of
commenters that equestrians are always adversely affected by an increase in traffic and population as are
bikers and hike.rs. Crossing Santiago Canyon Road or riding on the trail along side of it on horseback is
dangerous. An increase in tr•affic �nd congestion will make it even more so. They questioned if the new
signalized light proposed for the intersection of Nicky Way and Santiago Canyon Road would provide for
an equestrian crossing as well.
The commenters concerns for equestrian and bicycle safety are noted. The proposed project included
PDF TRA-10, TRA-11, TRA-12, TRA-16, and TRA-15, PDF LUP-1, PDF REC-1, and REC-7 to reduce
or eliminate potential impacts. The proposed project would establish an internal pedestrian system that
will include both on-street sidewalks and off-street paths. On-site vehicular connectivity will be provided
between Planning Areas C and D to allow easier access to the signalized intersection / primary access
point. Additionally PDF TRA-17, requires that the proposed project include a signalized trail crossing
that will provide connectivity far to/from recreational trails and the existing Mara Brandman horse arena.
The proposed project would provide for Santiago Creek to be maintained for a multi-purpose trail system.
The proposed project would provide public transit, bicycle, and pedestrian facilities that meet or exceed
all City Standards. The proposed project will include a signalized trail crossing at the main entrance to the
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.7-19
Rio Santiago Project SCH No. 2009051072
2.7 Recreation
project site on East Santiago Canyon Road. The signalized trail crossing would provide connectivity
to/from recreational trails and the Mara Bradman Arena.
The proposed project would include recreational and open space opportunities within Planning Area A.
This will include multi-purpose recreational trails, Santiago Creek, and open space. The multi-purpose
recreational trails would be available upon completion of construction of the residential units within
Planning Areas C and D. The proposed project would include on-site regional and multi-purpose trails
and neighborhood trails. These trails will provide connectivity between the project site and the adjacent
community and within the project site neighborhoods. The recreational trails would be available upon
completion of construction of the residential units within Planning Areas C and D. The proposed project
will include approximately 1.3 miles of on-site regional and multi-purpose trails. These trails would
provide connectivity between the project site and the adjacent community. The proposed on-site regional
trails would have the potential to be accessed from existing and proposed off-site public trails. The
proposed perimeter regional trail along Santiago Creek will implement a portion of the proposed City and
County Master Plan of Trails. The proposed trails have been designed to meet either City or County
Standards.
Equestrian Faci/ities
There are no existing equestrian facilities on the project site. The Mara Bradman Arena is located across
East Santiago Canyon Road from the project site. There is an equestrian trails on the south side of East
Santiago Canyon Road from the Mara Bradman Arena across the street from the project site, that travel
east to an existing north-south equestrian trail on Orange Park Boulevard. Existing and proposed
equestrian facilities on and in the vicinity of the project site are described in detail in Section 5.14,
Recreation of the Draft EIR.
The Draft EIR found that the proposed project would facilitate the use of equestrian transportation.
Therefore, with the implementation of the PDF's noted above, no impact on equestrian facilities would
occur and no mitigation measure would be required.
Bicyc%Faci/ities
There are no existing bicycle facilities on the project site. The City's General Plan Circulation Element
identifies Santiago Canyon Road as a Class II Bikeway. Class II Bikeways are on-road routes delineated
by painted stripes. The proposed project would not eliminate this bikeway. The proposed project
includes on-site trails that would link to off-site trails providing an alternative from of transportation.
Please note that the proposed project includes a trail adjacent to the bikeway along East Santiago Canyon
Road on the project site. In addition, the recreational component will provide bicycle racks supporting
this alternative form of transportation.
The Draft EIR found that the proposed project would facilitate the use of alternate transportation methods.
Therefare, with the implementation of the PDF's noted above, no impact on bicycle facilities would occur
and no mitigation measure would be required.
Page 2.7-20 City of Orange-Response to Comments/Final EIR—Decem6er 2013
SCH No. 2009051072 Rio Santiago Project
2.7 Recreation
The information and concerns expressed above does not change the analysis or conclusions of the Draft
EIR because it does not raise any issues related to the adequacy of environmental analysis conducted in
the Draft EIR. No further response is necessary.
Trail Connections
Several commenters expressed concern with future trail connections. The specific concerns are addressed
below.
Santiago Oaks Regiona/Park Trai/Connection—Mu/ti-Purpose Trai/
Several commenters expressed concern that the trail should connect to the north side of Santiago Creek
Commenters expressed concern that the connection from the project site to the Santiago Oaks Regional
Park would be the County of Orange's responsibility. Commenters noted that there is an existing path
along the north bank of Santiago Creek (the Mabury Ranch Trail), which continues all the way down to
Santiago Oaks Recreational Park. They noted that the proposed multi-purpose trail along the south side of
Santiago Creek could provide for a means to cross the Santiago Creek and connect to the Mabury Ranch
TraiL It was the opinion of several commenters that the proposed project should provide this connection,
rather than merely leave it to others to build a crossing.
Cannon St�eet Bridge Connection—Mu/ti-Purpose Trai/
Several commenters expressed concern that the proposed multi-purpose trail along Santiago Creek ends
without connecting to Cannon Street. It was their opinion that the trail should connect to Cannon Street
and the existing bike path on the west side of Cannon Street. They noted that this could be accomplished
with an underpass along Santiago Creek, where it flows under Cannon Street. It was their opinion that
without this connection, the utility of the trail is basically eliminated. They stated that the proposed
project should provide for this connection, rather than merely leave it to others to build an underpass in
the future.
Cannon Street Connection—Bike Trai/
Several commenters expressed concern th�t the bicycle trail conneetion from the project site to Cannon
Street should be accomplished with the proposed project.
Refer to Figure 5.15-3, Trails and Table 5.15-7, Trails that have been added to the EIR to clarify the
location of each trail; type of trail or connection; timing of construction; and, responsibility for
management and maintenance. The bicycle trail connection fron� the project site to Cannon Street would
be accomplished by others, as it is not of the project site. The information and concerns expressed does
not change the analysis or conclusions of the Draft EIR because it does not raise any issues related to the
adequacy of environmental analysis conducted in the Draft EIR. No further response is necessary.
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.7-21
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2.8 Transportation and Traffic
Several commenters expressed concerns related to potential impacts to transportation and traffic from
project implementation on the project site and the surrounding area. The majority of these concerns
related to the following items:
1. Concerns related to the scope of the transportation and traffic analysis including the methodology
of analysis and mitigation measures.
2. Concerns related to intersection within the City of Villa Park and the effect of their downgrading
of Villa Park Road.
3. Concerns were expressed for the existing and future traffic conditions analysis including:
a. Santiago Canyon Road (congestion, speed, and signalization); intersections of Santiago
Canyon Road (Cannon Road, Orange Park Boulevard, and Meads Road) and intersection of
Meads Avenue and Windes Road;
b. Addition of traffic signals to East Santiago Canyon Road;
c. Congestion during school seasons;
d. Elderly drivers, delivery trucks, and medical vehicles being added to the community roads;
e. Current traffic effects of the"materials recycling operation"; and,
£ Safety concerns that the increase traffic will create additional accidents.
4. A concern was expressed related to expanding the proposed project to add a connecting road
between Serrano and Santiago Canyon Road.
5. A concern with the lack of public transportation in the project vicinity.
6. A concern was raised related to the evacuation the elderly.
7. A concern was raised related to the transportation and traffic analysis of Related Projects (i.e.
Irvine Company, Salem Lutheran, etc.).
8. A concern was raised related to the analysis of non-vehicular traffic (pedestrian, bicycle, and
equestrian).
9. A concern was raised related to the Transportation System Improvement Program(TSIP) fees and
the City's Capital Improvement Program(CIP).
Section 5.16, Transportation and Traffic in the Draft EIR identifies the existing setting regarding
transportation/traffic and potential effects from project implementation on these resources. This section
of the Draft EIR also identifies mitigation measures to reduce any potentially significant land use and
planning impacts and describes the residual impact, if any, after imposition of the mitigation. The
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.8-1
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2.8 Transportation and Traffic
analysis used the following thresholds of significance consistent with Appendix G of the State CEQA
Guidelines:
Threshold TRA-A Would the project conflict with an applicable plan, ordinance or policy
establishing measures of effectiveness for the performance of the circulation
system,taking into account all modes of transportation including mass transit and
non-motorized travel and relevant components of the circulation system,
including but not limited to intersections, streets, highways and freeways,
pedestrian and bicycle paths, and mass transit?
Threshold TRA-B Would the project conflict with an applicable congestion management program,
including, but not limited to level of service standards and travel demand
measures, or other standards established by the county congestion management
agency for designated roads or highways?
Threshold TRA-C Would the project result in a change in air traffic patterns, including either an
increase in traffic levels or a change in location that results in substantial safety
risks?
Threshold TRA-D Would the project substantially increase hazards due to a design feature (e. g.,
sharp curves or dangerous intersections) or incompatible uses (e.g., farm
equipment)?
Threshold TRA-E Would the project result in inadequate emergency access?
Threshold TRA-F Would the project conflict with adopted policies, plans, or programs regarding
public transit, bicycle, or pedestrian facilities, or otherwise decrease the
performance or safety of such facilities?
2.8.1 Caltrans
A commenter (Caltrans) expressed a concern with the scope of the transportation and traffic
analysis including the methodology of analysis and mitigation measures. The study area for the
(revised) January 7, 2013 Traffic Impact Analysis (TIA) for Rio Santiago was scoped and
developed in conjunction with the Lead Agency, the City of Orange, and follows the traffic
impact analysis criteria for the affected jurisdictions of the Cities of Orange and Villa Park, the
Orange County Congestion Management Program (CMP), and Caltrans. In addition, the study
area for the TIA included the facilities listed in the NOP comments from Caltrans. Pages 4 — 8
of the TIA list the analyzed Caltrans facilities, and provides Caltrans significance criteria.
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SCH No. 2009051072 Rio Santiago Project
2.8 Transportation and Traffic
The TIA for the proposed project analyzed the following Caltrans facilities:
• SR 55 southbound ramps/Katella Avenue
• SR 55 northbound ramps/Katella Avenue
• SR 241-SR 261 southbound ramps/Santiago Canyon Road
• SR 241 northbound ramps/Santiago Canyon Road
• SR 55 freeway mainline, north of Katella Avenue
• SR 55 freeway mainline, south of Katella Avenue
All of these Caltrans facilities were analyzed in the TIA using the Highway Capacity Manual
(HCM) methodologies for their respective facility-type. All of the LOS tables and worksheets
analyzed under the HCM are provided in the Appendix of the TIA. In addition, all significance
criteria and mitigation measures (if required) are based on Caltrans' Guide of the Preparation of
Tra�c Impact Studies.
The traffic analysis scenarios analyzed in the (revised) January 7, 2013 Traffic Impact Analysis
(TIA)for Rio Santiago was scoped and developed in conjunction with the Lead Agency, the City
of Orange, and are listed on pages 8—9 of the TIA, and include:
• Existing Condition (2010—2011)
• Existing plus Project
• 2017 Opening Year Baseline
• 2017 Opening Year plus Project
• 2030 General Plan without Project
• 2030 General Plan with Project
Daily, a.m. and p.m. peak hour traffic conditions were analyzed in the TIA for each of those
scenarios listed above.
Commenters were concerned that the mainline segments of SR 241 and SR 261 were not
analyzed in the TIA since the proposed project trip distribution and assignment, shown on
Figures 3 (page 17) and 4 (page 18) of the TIA, respectively, are less than 10 peak hour trips on
both freeways (or four percent or less of the project trip distribution). The addition of project
trips to these mainline freeway segments would not be measurable and therefore would not
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2.8 Transportation and Traffic
significantly impact baseline levels of service (LOS). The intersections of the SR 241-SR 261
southbound ramps/Santiago Canyon Road (intersection #21) and SR 241-SR 261 northbound
ramps/Santiago Canyon Road (intersection #22) have been analyzed using the HCM
methodology for all six analysis scenarios.
Commenters were concerned that the proposed project will be paying its fair-share to the City of
Orange's Traffic Impact Fee (TIF) program. Please note that the proposed project has a less than
significant impact related to Caltrans facilities. Therefore, sharing of fees is not relevant for the
proposed project.
Commenters were concerned that the TIA determined that the proposed project would not significantly
impact any Caltrans facilities. However, the proposed project will be paying its fair-share to the City's
TIF program. Please note that the proposed project has a less than significant impact related to Caltrans
facilities. Therefore, sharing of fees is not relevant for the proposed project.
The TIA determined that the proposed project would not significantly impact any Caltrans facilities.
However, as previously noted, the proposed project will be paying its fair-share to the City's TIF
program.
This information does not change the analysis or conclusions of the Draft EIR because it does not raise
any issues related to the adequacy of environmental analysis conducted in the Draft EIR. Therefore, no
further analysis of this concern is warranted.
2.8.2 City of Villa Park Concerns
A commenter (City of Villa Park) expressed a concern that a significant number of vehicles will
pass through the City of Villa Park (CVP) from Interstate-55 (I- 55) Freeway. CVP noted that
this is the major vehicular corridor in the eastern portion of Orange County. The CVP requested
that the Draft EIR address the Level of Service (LOS) at all major intersections from I-55 to the
project site. The study area for the (revised) January 7, 2013 Traffic Impact Analysis (TIA)for
Rio Santiago was scoped and developed in conjunction with the Lead Agency, the City of
Orange, and analyzed all major intersections and roadway segments on Katella Avenue-Villa
Park Road-Santiago Canyon Road. The intersections and roadway segments analyzed in the City
of Villa Park include:
• Center Drive/Villa Park Road
• Lemon Street/Villa Park Road
• Hewes Street/Villa Park Road (County jurisdiction)
Page 2.8-4 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.8 Transportation and Traffic
• Villa Park Road, Wanda Road to Center Drive
• Villa Park Road, Center Drive to Lemon Street
� Villa Park Road, Lemon Street to Hewes Street
• Villa Park Road, Hewes Street to Cannon Street (County jurisdiction)
The CVP also requested information related to the impacts that are expected from the proposed
project from the downgrading of Villa Park Road by the City of Villa Park from 6 lanes to 4
lanes. The following are the LOS results of the downgraded Villa Park Road roadway segments
for each of the plus-project analysis scenarios:
• Existing plus Project
o Villa Park Road, Wanda Road to Center Drive: LOS B with 0.029 V/C increase.
o Villa Park Road, Center Drive to Lemon Street: LOS B with 0.029 V/C increase.
o Villa Park Road, Lemon Street to Hewes Street: LOS B with 0.033 V/C increase.
• Opening Year 2017 plus Project
o Villa Park Road, Wanda Road to Center Drive: LOS C with 0.029 V/C increase.
o Villa Park Road, Center Drive to Lemon Street: LOS C with 0.029 V/C increase.
o Villa Park Road, Lemon Street to Hewes Street: LOS D with 0.033 V/C increase.
• General Plan Year 2030 plus Project
o Villa Park Road, Wanda Road to Center Drive: LOS E with 0.019 V/C increase.
o Villa Park Road, Center Drive to Lemon Street: LOS E with 0.013 V/C increase.
o Villa Park Road, Lemon Street to Hewes Street: LOS E with 0.011 V/C increase.
However, as stated in the TIA:
"...per direction of the City Engineer of Villa Park, those downgraded segments were
analyzed at the peak hour level by the forecast operations of their end intersections (i.e.,
intersections on either end of the segment). Based on review of the intersection LOS, the
only impacted roadway segment would be Villa Park Road, Santiago Boulevard to Center
Drive. The other two downgraded Villa Park Road segments would operate with
satisfactory LOS in the peak hour as their intersections are forecast to operate at LOS D
or better. However, since the proposed project would not significantly impact the
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2.8 Transportation and Traffic
Santiago BoulevardJVilla Park Road intersection (V/C contribution of less than 0.010
V/C in both peak hours), the proposed project would not have a significant impact to the
downgraded roadway segments on Villa Park Road when analyzed with the peak hour
end-intersection methodology..." (Page 60 of the TIA)
This information does not change the analysis or conclusions of the Draft EIR because it does
not raise any issues related to the adequacy of environmental analysis conducted in the Draft
EIR. Therefore, no further analysis of this concern is warranted.
2.8.3 Traffic Conditions Analysis
Commenters expressed concerns with the analysis of existing and future traffic conditions including:
a. Santiago Canyon Road (congestion, speed, and signalization); intersections of Santiago Canyon
Road (Cannon Road, Orange Park Boulevard, and Meads Road) and intersection of Meads
Avenue and Windes Drive;
b. Addition of traffic signals to East Santiago Canyon Road;
c. Congestion during school seasons;
d. Elderly drivers, delivery trucks, and medical vehicles being added to the community roads;
e. Current traffic effects of the"materials recycling operation"; and,
£ Safety concerns that the increase traffic will create additional accidents.
Related to issues "a," "b," and "c" above, please refer to Section 5.16, Transportation and Traffic in the
Draft EIR, which identifies the existing setting regarding transportation/traffic and potential effects from
project implementation on these resources. This section of the Draft EIR also identifies mitigation
measures to reduce any potentially significant land use and planning impacts and describes the residual
impact, if any, after imposition of the mitigation. Also, please also refer to Traffic Impact Analysis Rio
Santiago, prepared by Vista Environmental, dated January 7, 2013, as provided in Technical Appendix N,
Tra�c Impact Analysis,to this Draft EIR.
For the Draft EIR discussion on intersection level of service,please refer to Section 5.16, Transportation
and Tra�c of the Draft EIR, which discusses in detail congestion, speed, and signalization of East
Santiago Canyon Road in the vicinity of the proposed project. Related to specific intersections please
refer to Table 5.16-8, Existing plus Project Intersection Levels of Service•, Table 516-12, Opening Year
2017 Condition Intersection Level of Service Summary; Table 5.16-15, Opening Year 2017 plus Project
Intersection Levels of Service; Table 5.16-18, General Plan 2030 Condition Intersection Level of
Service Summary; Table 5.16-21, General Plan 2030 plus Project Intersection Levels of Service, and ,
Table 5.16-25, Opening Year 2017 Plus Construction Phase Intersection Levels of Service.
Page 2.8-6 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.8 Transportation and Traffic
The Draft EIR found that with the implementation of PDF TRA-1, TRA-2, TRA-3, TRA-5, TRA-6, LUP-
1, REG1, REC-6 and REC-7 and MM TRA — 1, payment of TSIP fees, and the project applicant's
construction of roadway segments and intersections in the City, the project's impacts on intersection
levels of service would be reduced to a less than significant level. Implementation of Mitigation Measure
TRA-3, intersections for Opening Year 2017 plus Project(Impact TRA-2)would be reduced to a less than
significant level. With the inclusion of Mitigation Measure TRA�, roadway segments for Opening Year
2017 plus Project (Impact TRA-3) would be reduced to a less than significant level. Implementation of
Mitigation Measure TRA-5, intersections for General Plan 2030 plus Project (Impact TRA-4) would be
reduced to a less than significant level. With the inclusion of Mitigation Measure TRA— 6, roadway
segments for General Plan 2030 plus Project (Impact TRA-5) would be reduced to a less than significant
level. However, due to the fact that these improvements are not presently included in the City's CIP and
may not be constructed when needed to mitigate the impacts; Impacts TRA-1 through TRA-5 are
considered significant and unavoidable. The construction of the mitigation measure provided above will
not create additional impacts. All of the mitigation measures will be constructed within rights-of-way as
provided by the City's Circulation Element.
Related issue "d" aboveelderly drivers, delivery trucks, and medical vehicles being added to the
community, these vehicles are all addressed within the traffic generation rates utilized in the Draft EIR.
Related to issue "e" above, the current traffic from the materials recycling and backfill operations is
evaluated in the Draft EIR. As stated in the Draft EIR:
Materia/s Recyc/ing
Approximately five acres in the southeastern portion of the project site are used as a materials
recycling area. This area includes apparatus for the crushing of boulders, bricks, rocks, etc. for
recycling. The materials recycling area additionally includes operations that provide for the
cement treatment of base materials. Material for this operation originates primarily from off-
site sources. Access to the materials recycling area is from a controlled entrance along East
Santiago Canyon Road. Materials generated by this operation have historically been used on and
transported off the project site. The materials generated by this operation at issuance of the NOP
were being taken off-site. Materials recycling will continue on the project site through the
construction of the proposed project until Planning Area D is developed.
Backfi//ing Operation
To restore previously mined portions of the site(south of Santiago Creek), a portion of the project
site is presently being backfilled. The project site is presently being backfilled in sequentially
defined phases. The project site is being over excavated (i.e., removal of unsuitable materials)
and filled in the present backfill operation. The applicant has indicated that grading permit(s)will
be requested from the City to complete backf'illing of all previously mined portions of the project
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2.8 Transportation and Traffic
site. The project site was used from 1919 to 1995 for surface mining of sand, gravel, and other
aggregates. Previously mined portions of the project site were used for residue silt deposition,
otherwise known as silt ponds. The backfilling operation addresses both mined and silt pond
areas.
In March 2011, the City issued Grading Permit #2047 related to the backfill operation. Table
17.32.020, Sand and Gravel District Use Regulations, of the Orange Municipal Code states that
backfilling is a permitted use (P) in the S-G (Sand and Gravel) District. Additionally, in
accordance with Section 3.1, Grading Permit Exceptions, of the City Grading Manual backfilling
is a permitted use. Grading is a ministerial (not discretionary) action as defined by the CEQA
Guidelines and the City of Orange Local CEQA Guidelines (page 5—6).
The backfill operation will restore those portions of the project site within the limits of activity to
the elevations approved by Grading Permit #2047. Approved Grading Permit #2047 provides
that 2,000 cubic yards of material will be cut in addition to the over excavation. A total of
223,000 cubic yards of material will be imported to the site. The imported materials include
concrete, asphalt, rock, and soil. The imported materials will be crushed on-site. A total of
225,000 cubic yards of material, both cut and fill, will be blended during this approved
backfilling operation. In addition, grading permit(s) will be requested from the City to complete
the backfilling of the previously mined portions of the project site. Approximately 57 acres of the
project site are included in the backfilling operation.
This approved, on-going backfill operation currently is separate and distinct from the proposed
project. However, most of this grading would have to occur to construct the proposed project.
Therefore, as a practical result, from the date of project approval the backfilling and grading will
become project site preparation activities.
The existing uses currently on the project site generate over 500 daily truck trips, plus employee
trips. Based on traffic counts collected at the site's driveways in late-October/early-November
2010, approximately 591 daily vehicle trips (from both trucks and passenger cars), 63 a.m. peak
hour vehicles trips (34 inbound and 29 outbound), and four p.m. peak hour trips (four inbound
and zero outbound)were generated from the site.
Based on data provided by the project applicant, approximately 29 percent of the existing site
traffic is related to minerals recycling activities on the project site. The remaining 71 percent of
site traffic is related to the backfill operations on the project site. This includes both truck and
passenger-car (employees) trips generated from the project. (Pages 5.16-20 and 5.16-21 of the
Draft EIR)
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SCH No. 2009051072 Rio Santiago Project
2.8 Transportation and Traffic
Related to issue "f' above, the Draft EIR evaluated if the proposed project would substantially increase
hazards due to a design feature or incompatible use. Related to site access the Draft EIR found that based
on the information presented above and the PDF's, a less than significant impact would be anticipated and
no mitigation would be required. (Page 5.16-66 of the Draft EIR)
Related to sight distance the Draft EIR found that with the provision of the minimum American
Association of State Highway and Transportation Officials (AASHTO) sight distances at the two new
signalized intersections, bicyclists and pedestrians on Santiago Canyon Road (especially ones travelling
in the westbound directions) would be seen by drivers attempting to turn in to, and out of, the project site
at both signalized access locations. These drivers would have adequate decision time to determine their
maneuvers through the intersection(s). Therefore, based on the information presented above and the
PDF's a less than significant impact would be anticipated and no mitigation would be required. (Page
5.16-66 of the Draft EIR)
Related to street dimensions (cross-sections) the Draft EIR found that compliance with the City's
Standard Engineering Plans and Specifications and the Rio Santiago Specific Plan for internal roadways,
pedestrians and bicyclists would be served as they travel within the components of the proposed project.
Therefore, based on the information presented above and the PDF's a less than significant impact would
be anticipated and no mitigation would be required. (Page 5.16-67 of the Draft EIR)
It should be noted that since the preparation of the Draft EIR the City's Standard Engineering Plan and
Specification have changed. As proposed in the Rio Santiago Specific Plan, Section T-T does not comply
with these revisions. Additionally, the City's Design Review Committee (DRC) has recommended to the
City Council specific standards related to streets in the proposed project. The proposed revisions to cross
section in the Specific Plan based on the recommendations of the DRC do not affect the conclusion of the
Draft EIR. With the approval of the Specific Plan the City would accept the therein proposed roadways
designs. Therefore,no impact would occur and no mitigation measures would be required.
Related to emergency access the Draft EIR found that emergency access would be provided to/from
Planning Area A. Access will continue to be available to/from Mabury Avenue north of Santiago Creek.
The County of Orange maintains a dirt road off the project site that presently provides access to/from the
project site south of Santiago Creek (Draft EIR page 3-33). Additionally, no uses are proposed in
Planning Area A that would require substantial emergency access.
Emergency access to/from Planning Area B would be available only from the signalized intersection on
East Santiago Canyon Road. Emergency access to/from Planning Area C and D would be provided
to/from East Santiago Canyon Road and the multi-purpose trail along Santiago Creek. Implementation
of the proposed project would not have the potential to result in significant impacts related to emergency
vehicular access. Therefore, based on the information presented above, the Fire Master Plan, the project
design review process going on concurrent with the review of this Draft EIR, and the PDF's, a less than
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significant impact would be anticipated and no mitigation would be required. (Page 5.16-68 of the Draft
EIR)
This information does not change the analysis or conclusions of the Draft EIR because it does
not raise any issues related to the adequacy of environmental analysis conducted in the Draft
EIR. Therefore, no further analysis of this concern is warranted.
2.8.4 Addition of Serrano Road and Santiago Canyon Road
Commenters requested that the Draft EIR evaluate the extension of Serrano Avenue to Santiago Canyon
Road to reduce existing traffic congestion and mitigate traffic impacts of the proposed project.
The TIA and Draft EIR analyzed short-term (2017) and long-term (2030) horizon years which take into
account existing and planned roadways on the City's General Plan Circulation Element and the Orange
County Master Plan of Arterial Highways (MPAH). An addition or extension of Serrano Avenue is not
planned by the City and/or County in either the short-term and long-term harizon years. Therefore, the
TIA and Draft EIR appropriately analyzed and mitigated for the future traffic conditions consistent with
the Circulation Element, MPAH, and the Orange Transportation Analysis Model (OTAM).
The commenters concerns do not change the analysis or conclusions of the Draft EIR, because
they do not raise any issues related to the adequacy of environmental analysis conducted in the
Draft EIR However, they are noted and will be provided to the Planning Commission and City
Council for consideration.
2.8.5 Public Transportation & Elderly Transportation
Commenters expressed concerns with the lack of public transportation in the vicinity of the proposed
project. This concern also included the lack of transportation for the age-qualified residents of Planning
Area C. The Draft EIR found that the proposed project would increase demand for public transit
facilities. While there are no transit services available in the immediate project vicinity, the Orange
County Transportation Authority (OCTA) operates two bus routes with stops approximately two miles to
the west and to the southeast of the project site. OCTA Bus Route 54 is a route approximately two miles
southeast of the project site. This route is known as the Garden Grove to Orange route via Chapman
Avenue. OCTA Bus Route 167 is a route approximately two miles west of the project site. The Specific
Plan provides that the operation of Planning Area C shall establish a shuttle services for the age-qualified
residents.
Commenters have opinioned that the proposed age-qualified housing is not an appropriate use at this
location because there is no public transportation. The City's General Plan Circulation Element is the
adopted policy related to alternate forms of transportation. The City's General Plan requires the proposed
project to include the potential for municipal fixed-route bus turnouts. However, as noted above,
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2.8 Transportation and Traffic
Santiago Canyon Road is not a designated bus route by the OCTA. Implementation of the proposed
project would not preclude the future installation of a bus turnout, if Santiago Canyon Road would be so
designated by the OCTA in the future with a bus turnout proposed in the vicinity of the project site.
Therefore, implementation of the project does not have the potential to conflict with adopted alternate
forms of transportation related to transit service and no impact would occur and no mitigation measures
would be required. (Page 5.16-69 of the Draft EIR)
This information does not change the analysis or conclusions of the Draft EIR because it does
not raise any issues related to the adequacy of environmental analysis conducted in the Draft
EIR. Therefore, no further analysis of this concern is warranted.
2.8.6 Evacuation of the Elderly
Commenters expressed concerns related to the evacuation of the elderly in case of an emergency. The
proposed project includes PDF HAZ-8, which requires that Individualized Emergency Evacuation Plans
(EEP) shall be prepared for each planning area by the project applicant to the satisfaction of City
Emergency Responder Department reviewing Staff. The EEP shall be based on initial anticipated
occupancy of the planning area. The EEP shall be reviewed and revised every five years or when a
significant change in structure use occurs within a planning area. The EEP shall be reviewed by the
Directors of Community Development and Public Works and approved by the Police and Fire
Departments prior to the occupancy of the first structure in each individual Planning Area.
Additionally Mitigation Measure HWQ-2 requires that Emergency Evacuation Plans be submitted to the
City for review and approval prior to building permits for the single- family and age-qualified residences.
Page 5.9-53 to 5.9-56 detail specific requirements that would be set into the evacuation plans for the
residences, which include operations and management programs, flooding program, access/egress routes,
emergency management training program, and resident emergency management guide.
This information does not change the analysis or conclusions of the Draft EIR because it does not raise
any issues related to the adequacy of environmental analysis conducted in the Draft EIR. Therefore, no
further analysis of this concern is warranted.
2.8.7 Related Projects Traffic Analysis
Commenters expressed concerns related to the transportation and traffic analysis of Related Projects (i.e.
Irvine Company, Salem Lutheran, etc.). Table J on page 35 of TIA lists all of the cumulative projects that
were assumed in the Opening Year 2017 traffic analyses which include the Salem-Lutheran Church and
School expansion; and the Rancho Santiago College expansion. As confirmed with City Staff, there was
no development anticipated for the East Orange Specific Plan (Irvine Company) in 2017. However,
buildout of the East Orange Specific Plan was included in the General Plan 2030 analysis, which includes
the build-out of all land uses within the modeled area. Pages 47 to 49 of the TIA discuss the 2030 traffic
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2.8 Transportation and Traffic
model assumptions used in the TIA. Therefore, the future scenarios of the TIA include traffic from new
developments in the area.
This information does not change the analysis or conclusions of the Draft EIR because it does not raise
any issues related to the adequacy of environmental analysis conducted in the Draft EIR. Therefore, no
further analysis of this concern is warranted.
2.8.8 Non-Vehicular Traffic Analysis
Commenters expressed concerns related to the analysis of non-vehicular traffic (pedestrian, bicycle, and
equestrian). The Draft EIR evaluated project impacts related to pedestrian, bicycle, and equestrian
transportation facilities in the vicinity of the proposed project. The Draft EIR found that:
Pedest�ian Faci/ities
There are no existing pedestrian facilities on the project site. There are continuous sidewalks
along East Santiago Canyon Road on the south side of the roadway where there are existing
residential developments, from Cannon Street to the proposed project's residential access
intersection. West of the project site, there is a continuous sidewalk on the south side of East
Santiago Canyon Road along the property of the Salem Lutheran Church to the intersection at
Orange Park Boulevard. There are no sidewalks on the north side of Santiago Canyon Road,
along the proposed project's southern boundary. There are curb and gutter along the north side of
the roadway with a dirt walking path.
The proposed project would provide curb, gutter, and sidewalk on the project site along Santiago
Canyon Road. Additionally, the proposed project would provide curb, gutter, and sidewalk on
the interior private streets on the project site. Pedestrian trails are proposed to augment sidewalks
on the project site. A multi-purpose trail system is proposed throughout the project site. Please
refer to Section 5.15, Recreation for detailed discussion of pedestrian paths provided. Therefore,
with the implementation of the PDF's noted above, no impact on pedesh-ian facilities would occur
and no mitigation measure would be required.
Bicyc%Faci/ities
There are no existing bicycle facilities on the project site. The City's General Plan Circulation
Element identifies Santiago Canyon Road as a Class II Bikeway. Class II Bikeways are on-road
routes delineated by painted stripes. The proposed project would not eliminate this bikeway. The
proposed project includes on-site trails that would link to off-site trails providing an alternative
form of transportation. In addition, the recreational component will provide bicycle racks
supporting this alternative form of transportation. The proposed project would facilitate the use
of alternate transportation methods. Therefore, with the implementation of the PDF's noted
above,no impact on bicycle facilities would occur and no mitigation measure would be required.
Page 2.8-12 City of Orange-Response to Comments/Final E/R—December 2013
SCH No. 2009051072 Rio Santiago Project
2.8 Transportation and Traffic
Equestrian Faci/ities
There are no existing equestrian facilities on the project site. The Mara Bradman Arena is located
across East Santiago Canyon Road from the project site. There is an equestrian trails on the south
side of East Santiago Canyon Road from the Mara Bradman Arena across the street from the
project site,that travel east to an existing north-south equestrian trail on Orange Park Boulevard.
Existing and proposed equestrian facilities on and in the vicinity of the project site are described
in detail in Section 5.14, Recreation. The proposed project would facilitate the use of equestrian
transportation. Therefore, with the implementation of the PDF's noted above, no impact on
equestrian facilities would occur and no mitigation measure would be required. (Page 5.16-70 of
the Draft EIR)
This information does not change the analysis or conclusions of the Draft EIR because it does not raise
any issues related to the adequacy of environmental analysis conducted in the Draft EIR. Therefore, no
further analysis of this concern is warranted.
2.8.9 Transportation System Improvement Program
Commenters expressed concerns related to the Transportation System Improvement Program (TSIP) fees
and the City's Capital Improvement Program(CIP).
Transportation System Improvement Program (TSIP)
As indicated in the Draft EIR, the proposed project is subject to TSIP Fees pursuant to Chapter 15.41 of
the Municipal Code and California Government Code section 66000 et seq. The City has established the
Transportation Systems Improvement Program ("TSIP") for imposition of development impact fees to
ensure the construction of transportation facilities and expansion of services and other infrastructure to
meet and accommodate new residential development projects. The City TSIP imposes fees to finance
transportation facilities required by new development in order to avoid adversely impacting existing
transportation facilities. Compliance with the TSIP in accordance with all provision of Municipal Code
Chapter 15.41 ensures construction of TSIP facilities to mitigate impacts to transportation facilities.
The proposed project will be required to pay the City's TSIP fees pursuant to Chapter 15.41 of the
Municipal Code. Based on the data provided in Table 5.16-10, TSIP FEE for Proposed Project, the
proposed project would be required to pay an estimated total TSIP fees of$373,572.00 (as of the date of
this report). The City established the TSIP fees based upon the costs generated through the need for new
transportation facilities and other capital acquisition costs required, incrementally, by new development
within the City. The TSIP fees established under Chapter 15.41 of the Municipal Code are
designed to not exceed the reasonable cost of providing transportation facilities occasioned by new
development projects within the City. The City has found that the TSIP fees established shall bear a
rational relationship to the reasonable cost of providing transportation facilities occasioned by new
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.8-13
Rio Santiago Project SCH No. 2009051072
2.8 Transportation and Traffic
development projects within the City. Further, the TSIP fees are consistent with the goals and objectives
of the City's General Plan and are designed to mitigate the impacts caused by new development
throughout the City. Finally, the City has found that the TSIP fees are necessary in order to help finance
the required transportation facilities and to insure that new development pays a fair share of the cost
thereof. The proposed project lies entirely within Area C of the TSIP. The applicant would pay the
project's fair-share of the circulation system improvements noted above.
Capital Improvement Program (CIP)
The City has adopted a Capital Improvement Program (CIP). The City's CIP provides for the financing
and construction of circulation system improvements within the City. While all the off-site improvements
noted above are consistent with the City's General Plan Circulation Element, they are not presently
included within the City's CIP. The City's CIP does not provide all circularion improvements planned to
occur in future years.
The City's CIP provides for the financing and construction of circulation system improvements within the
City. While the improvements noted in the Draft EIR related to the proposed project are consistent with
the City's General Plan Circulation Element, they are not presently included within the City's CIP. The
City's CIP does not provide all circulation improvements planned to occur in future years.
Implementation of Mitigation Measure TRA� in the Draft EIR would mitigate roadway segments
(Impact TRA-3) to a less than significant level. However, due to the fact that these improvements are not
presently included in the City's CIP and may not be constructed when needed to mitigate the impact; this
impact is considered significant and unavoidable in the Draft EIR. (Page 5.16-42 of the Draft EIR).
This information does not change the analysis or conclusions of the Draft EIR because it does not raise
any issues related to the adequacy of environmental analysis conducted in the Draft EIR. Therefore, no
further analysis of this concern is warranted.
Page 2.8-14 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.9 Cumulative Impacts
Several commenters expressed concerns related to the cumulative impacts of the proposed project and
related projects:
1. The impacts of related project were not evaluated.
2. The related projects potential effects were not considered in the Draft EIR analysis.
Section 6.0, Cumulative of the Draft EIR analyzes potential cumulative impacts and describes the
potential changes in environmental conditions that result from the incremental impact of the proposed
project added to the impacts from other past,present, and reasonably foreseeable probable future projects.
The State California Environmental Quality Act (CEQA) Guidelines Section 15130,provides that an EIR
shall discuss the cumulative impacts of a project "when the project's incremental effect is cumulatively
considerable." Section 15065(a) (3) of the State CEQA Guidelines describes "cumulatively considerable"
as follows:
"Cumulatively considerable" means that the incremental effects of an individual project are
significant when viewed in connection with the effects of past projects, the effects of other current
projects, and the effects of probable future projects."
Section 15130 further states that an adequate discussion of cumulative impacts necessarily includes either
of the following elements:
(A) A list of past, present, and probable future projects producing related or cumulative
impacts, including, if necessary, those projects outside the control of the agency, or
(B) A summary of projections contained in an adopted general plan or related planning
document, or in a prior environmental document which has been adopted or certified,
which described or evaluated regional or areawide conditions contributing to the
cumulative impact. Any such planning document shall be referenced and made available
to the public at a location speczfied by the lead agency.
2.9.1 Related Projects
Commenters expressed concern that the Draft EIR did not evaluate all related projects in the cumulative
analysis. The list of related projects was provided in Table 6-2, Related Projects in the Draft EIR This
table provides summary details on related projects that were used in the cumulative analysis (this list also
was provided in Section 4.0, Environmental Setting of the Draft EIR). All of the related projects are
located in the City, or nearby unincorporated territory within the County of Orange (County) and are
identified on Figure 6-1,Related Projects of the Draft EIR.
The City maintains a list of related projects that includes past, present, and reasonably foreseeable
probable future projects. Far this list the City determined projects that would potentially produce related
or cumulative effects. At the time of the issuance of the Notice of Preparation of the EIR, the City
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.9-1
Rio Santiago Project SCH No. 2009051072
2.0 Master Responses
Community Development Department and Public Works Department were contacted to define the list of
related projects. These Departments were re-contacted in August 2013 related to any changes that could
potentially affect the Related Project List. The City based on this review further determined that no
changes were necessary. Therefore,no further analysis of this concern is warranted.
2.9.2 Evaluation of Cumulative Impacts
Commenters expressed concern that the Draft EIR did not evaluate related project's effects correctly in
the cumulative analysis. As noted above, the Draft EIR in Section 6.1.3, Sources indicates the sources
that were used in the consideration and discussion of the potential cumulative environmental impacts.
Secrion 6.3, Evaluation of Cumulative Impacts of the Draft EIR addressed each of the 17 topical
environmental factors referenced in the State CEQA Guidelines. The analysis for each environmental
topic was accomplished in the following manner:
1. The analysis summarizes the proposed project and related projects and identifies impacts at the
project-level of detail;
2. The analysis then discusses impacts that would result when the effects of the individual projects
are viewed collectively;
3. The analysis addresses whether the proposed project's incremental contribution to a potentially
significant impact is cumulatively considerable. If not, the analysis ends. If it is, the analysis
continues to Items 4 and 5 (below);
4. The analysis then determines the proposed project's relative contribution to the significant
cumulative effect; and,
5. The analysis then determines whether mitigation measures applicable to the proposed project or
related projects can reduce the cumulative impacts, or whether new mitigation measures
consistent with the CEQA Guidelines can be feasibly implemented to reduce or eliminate the
significant cumulative effect.
The Draft EIR in Section 6.13, Sources indicates the sources that were used in the consideration and
discussion of the potential cumulative environmental impacts. The City has determined that these
sources are appropriate for the cumulative analysis of impacts. Further, the commenters have not
provided evidence that the sources are not appropriate ar that other data exists. Therefore, no further
analysis of this concern is warranted.
Page 2.9-2 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.10 Alternatives
Several commenters expressed concerns related to alternatives to the proposed project. The majority of
these concerns related to the following items:
1. The City should consider additional alternatives to the proposed project beyond those provided in
the Draft EIR.
2. The Draft EIR alternatives do not accurately portray the impacts of Alternative 2: No Project-
Development Under the Existing General Plan and Zoning.
3. Issues and opinions were expressed related to each of the alternatives presented in the Draft EIR.
Section7.0, Alternatives of the Draft EIR describes proposed alternatives to the proposed project, and
potential effects of implementing the alternative on the project site and its surrounding area. The analysis
used Section 15126.6, Consideration and Discussion of Alternatives to the Proposed Project of the State
CEQA Guidelines and the City Local CEQA Guidelines, which establishes the requirements for project
alternatives and their consideration. State CEQA Guidelines Section 15126.6 requires that an EIR contain
a description of "...a range of reasonable alternatives to the project, or to the location of a 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."
2.10.1 Additional Alternatives
Commenters expressed concern that the proposed project should consider additional alternatives to the
proposed project beyond those provided in the Draft EIR. As indicated in the Draft EIR, the State CEQA
Guidelines require EIRs to describe a range of alternatives to the proposed project, or to the location of
the proposed project, which would feasibly achieve most of the basic project objectives, but would avoid
or substantially lessen any of the significant effects identified in the analysis. Additionally, an EIR may
only consider alternatives that are feasible. Even within all of these parameters, an EIR is not required to
consider every conceivable alternative to a proposed project. However, alternatives may be considered
even if they would impede, to some degree, the attainment of project objectives or be more costly
(provided that they remain economically feasible). The analysis contained in this section includes an
analysis of each identified alternative with respect to each of the environmental issues evaluated for the
proposed project
CEQA provides that a project cannot be approved, if there are feasible alternatives that would
substantially lessen its environmental effects. The City may reject alternatives as infeasible, if based on
substantial evidence in the record; the decision-makers find the alternatives are impractical or undesirable
from a policy standpoint. [California Native Plant Society v. City of Santa Cruz(2009) 177 Cal. App. 4th
957]
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.10-1
Rio Santiago Project SCH No. 2009051072
2.10 Alternatives
Open Space/Recreational
Commenters requested that an alternative be presented in the EIR that would allow far the project site to
stay "open space/recreational". The open space nature of the project site is discussed in Master Response
2.6, Open Space. Additionally, it should be noted that the project site is not presently utilized for any
recreational uses.
Alternative No. 5 —All Recreation Alternative was provided in the Draft EIR (Page 7-1 through 7-13)
This alternative evaluates the development of the project site with a mixture of open space and active
recreational uses. Under this alternative, Planning Areas A, B, C, and D and would be developed with
active recreational uses. This alternative would also include internal streets, open space and recreation
areas, and equestrian and bicycling riding, and hiking trail linkages along East Santiago Canyon Road and
Santiago Creek. No flood control improvement to Santiago Creek would be provided in this alternative.
While this alternative is described as the "All Recreation Alternative," this alternative should be
considered both open space and recreational in nature.
Residential Alternative
Commenters requested that an alternative be presented in the EIR that would allow far the project site to
be developed as an alternative that preserves the character of the surrounding area that is compatible with
the"rural"residential land use densities of the surrounding community.
Related to the commenters opinion on the "rural" residential land use densities of the surrounding
community, refer to Master Responses 2.2, Aesthetics and 2.5, Land Use and Planning. Additionally,
note that Figure 5.1-13, Community Character Summary has been added to the EIR to provide additional
clarity related to the discussion of the character analysis. Finally, note that Figure 5.1-13, Community
Character Summary provides the local names, land use, relative age of construction, density, and other
similar characteristics of surrounding areas. A review of these figures indicates that there is no
overwhelming/predominant "rural"residential land use density in the surrounding community (emphasis
added).
The Draft EIR does not evaluate a single-family residential land use alternative for the entire project site.
However, this development concept is within the range of alternatives evaluated. Table 2.10-1, Summary
of Single Family Residential Alternatives indicates where single-family residential land uses were
evaluated in the Draft EIR.
Figure 7-8B, Residential Development Alternative—B has been added to the Draft EIR. The Draft EIR
did not evaluate a single-family residential land use alternative for the entire project site. However, this
Alternative - B includes the development of the project site as a single-family residential development.
All residential development would be located south of Santiago Creek in Planning Areas B, C,and D.
Alternative 8: Residential Development Alternative - B would be the same as the existing Alternative 8:
Residential Development Alternative in regards to including: private internal streets, open space and
recreation areas, equestrian and bicycle riding, and hiking trail linkages along East Santiago Canyon Road
and Santiago Creek. Alternative 8: Residential Development Alternative - B would provide for
residential development Planning Area B and Neighborhood Park in Planning Area C. Project site
Page 2.10-2 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.10 Alternatives
geology would allow this alternative. Flood control improvement to Santiago Creek would be provided
in this alternative similar to the proposed project and extended along Santiago Creek in Planning Area B.
This alternative would include development of the project site as a gated residential community with a
maximum of 196 single-family homes. The minimum lot size would be 6,000 square feet. These
residences would not be age-restricted. Table 7-8B, Summary Residential Development Alternative - B,
has been added to the Draft EIR. This table provides a statistical summary of the land uses anticipated
under this alternative.
This alternative would allocate residential development to Planning Area B and provide a centralized park
facility between Planning Area C and Planning Area D. No significant other changes would occur.
The new information added to an EIR is not"significant" as the EIR has not been changed in a way that
deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental
effect of the project or a feasible way to mitigate or avoid such an effect. Additionally, the new
information would not result in new or substantially increased significant impacts, and therefore no
recirculation is required.
Table 2.10-1: Summary of Single Family Residential Alternatives
Alternative No. 2 Aiternative No. 8
Planning Units i Units/'
Area Gross Gross'
�ar�d Use Square Acres Land Use �quare Acres
Fe�t �'eet
Residential 17 units 12 acres
p Natural Open
Resource Area 0 50 acres
Open Space 0 38 acres Space
Active
Recreational
(i.e.,pool,
B Resource Area 0 10 driving range, � 10 acres
tennis,putting
green,soccer
fields,and
baseball)
Residential Units
C Resource Area 0 16 and Open Space 66 units 16 acres
/Recreation
Residential Units
D Resource Area 0 34 and Open Space 130 units 34 acres
/Recreation
Source:Draft EIR.
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.10-3
Rio Santiago Project SCH No. 2009051072
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2.10 Alternatives
Table 7-8B: Summary Residential Development Alternative -B
Planning Units i
Alternative No. 8B , Gross Percent
Area Existing Land Use Square Acres of Site
Land Use Feef
Natural Open Space Vacant(85%)&Backfilling 0 50 acres 45%
``� (15%)
B Residential Units and B—Backfilling(100%)
Neighborhood Park o 78 units 26 acres 24%
& C= Backfilling(80/o)&
C Other�(20%)
Residential Units and Open Vacant(85%)&Materials 118 34 acres 31%
� Space/Recreation Recycling(15%) units
Total 196 110 100%
units acres
1. Existing land use percentages are estimates only.
2. Other includes project entrance gate, drive,parking, and staging.
Source:KTGY Group, September 2012.
The commenters concerns do not change the analysis or conclusions of the Draft EIR because they do not
raise any issues related to the adequacy of environmental analysis conducted in the Draft EIR. However,
they are noted and will be provided to the Planning Commission and City Council for consideration.
Agricultural Production
Commenters requested that an alternative be presented in the EIR that would allow for the project site to
be developed for agricultural use. Commenters noted that portions of the project site have been used for
agricultural production in the past. It was their opinion that the project site is a logical location for
growing due to its proximity to a water source. They noted that agricultural is an important resource
especially as locally grown food becomes a coveted commodity and is a high priority for many. The
Draft EIR does not analyze the possibility of reintroducing food production on the project site.
Agricultural production intermittently occurred on the project site with the most recent production
occurring from approximately 1993 through 2004. Agricultural production included fruit orchards and
strawberry production.
As previously noted, the State CEQA Guidelines only require EIRs to describe a range of alternatives to
the proposed project, or to the location of the proposed project, which would feasibly achieve most of the
basic project objectives,but would avoid or substantially lessen any of the significant effects identified in
the analysis. Additionally, an EIR may only consider alternatives that are feasible.
Even within all of these parameters, an EIR is not required to consider every conceivable alternative to a
proposed project. It is noted that alternatives may be considered even if they would impede, to some
degree, the attainment of project objectives or be more costly (provided that they remain economically
feasible). The analysis contained in this section includes an analysis of each identified alternative with
respect to each of the environmental issues evaluated for the proposed project. An agricultural alternative
would potentially meet only one project objective as noted in Table 2.10-2, Comparison Agricultural
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.10-5
Rio Santiago Project SCH No. 2009051072
2.10 Alternatives
Alternative and Project Objectives. It is unknown agricultural production would be a financially feasible
alternative. As noted above, recent agricultural production ceased on the project site in 2004. The
potential far agricultural use of the project site in an economically feasible manner to the project applicant
is speculative.
Additionally, it should be noted that agricultural production is regulated under the California Food and
Agricultural Code and parts of the Health and Safety Code, Labor Code, and Business and Professions
Code (field warkers and structural pest control). The Department of Pesticide Regulation for California
sets pesticide use buffers and/or other conditions (i.e., SCAQMD). By law, specific conditions are set for
the use of pesticides on agricultural crops where those crops are adjacent to "sensitive areas" such as
schools(within '/4 mile),wildlife and endangered species habitat,aquatic areas, and occupied residences.
Table 2.10-2: Comparison Agricultural Alternative and Project Objectives
Project Objective Meet
Ob'ective
To convert a degraded site used for the mining, crushing, and recycling of
OBJ-1 aggregate materials into a planned community providing a mix of natural No
o en s ace,recreation,a e- ualified and sin le-famil housin o ortunities.
OBJ-2 To expand open space and recreational opportunities on-site through the
clusterin of buildin s within limited areas of the ro'ect site. No
To provide inter-generational uses which will encourage active social,
OBJ-3 recreational, and occupational interaction between planned community No
residents and visitors.
To provide an open space and trail network adjacent to Santiago Creek's
OBJ-4 riparian habitat, including public trails with connections to trails and parks,
along with a variety of public and private recreational opportunities that do No
not currentl exist in the East Oran e area.
To provide a local community amenity in the form of multi-purpose facilities
OBJ-5 that may house among other related uses a recreation center, an autism center, No
and/or a YMCA facilit as well as a swimming center, and mnasium.
OBJ-6 To provide local residents within the larger context of a mixed market rate
development a wide ran e of recreational op ortunities. No
To provide age-qualified residential opportunities in Planning Area C to
OBJ-7 respond to changing residential market demographics and help meet the No
demand for a e- ualified livin in the Cit of Oran e.
To provide on-site recreational and volunteer service opportunities, as well as
OBJ-8 facilities to provide health and wellness services, for residents of the age- No
ualified develo ment within the ro'ect.
To provide single-family residences opportunities to respond to residential
OBJ-9 market demographics and help meet the demand for housing in the City of No
Orange.
To provide a circulation system that will minimize adverse effects on local
OBJ-10 residential neighbarhoods and encourage pedestrian, equestrian, and bicycle No
circulation throu hout the lanned communit .
OBJ-11 To lessen the noise, air quality, and traffic impacts from materials recycling
and backfillin o erations. Yes
OBJ-12 To preserve Santiago Creek and its surroundin wetland and riparian habitat. No
Source: Vista Community Planners(V�s'ra)
Page 2.10-6 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.10 Alternatives
2.10.2 Alternative 2: No Project Alternative — Development Under Existing General Plan
and Zoning
Commenters expressed concern that the uses in the Draft EIR for Alternative 2-No Project-Development
Under the Existing General Plan and Zoning could not be achieved as a CUP would not be granted.
Additionally, Commenters expressed concern that Alternative 2- No Project- Development Under the
Existing General Plan and Zoning should reflect the 1975 East Orange (EO) General Plan, Orange Park
Acres (OPA) Plan, and Santa Ana River Santiago Creek Greenbelt Plan. These two concerns are
discussed below.
Conditional Use Permit(CUP)
Commenters indicated that an expanded sand and gravel operation would require an extended/expanded
CUP which may ar may not be granted. They noted that noise, buffer requirements, etc. in their opinion
are not existent or being enforced now. It was further their opinion that Alternative 2- No Project-
Development Under the Existing General Plan and Zoning should have been defined as the existing uses
on the project site with the sand and gravel operation.
The Draft EIR evaluated what would be "reasonably" (emphasis added) expected to occur on the project
site in the foreseeable future, if the proposed project were not approved. The Draft EIR noted that the
City is not aware of any plans for development of the project site other than the proposed project. The
environmental conditions existing at the time the Notice of Preparation (NOP) was published would be
assumed to continue, subject to changes resulting from reasonably projected contraction or expansion of
the existing uses.
Alternative 1: No Project Alternative—No Development evaluates what would be reasonably expected to
occur on the project site in the foreseeable future, if the proposed project were not approved. Alternative
2: No Project- Development Under the Existing General Plan and Zoning evaluates the development of
the project site for uses permitted under the City's existing General Plan and Zoning. The City General
Plan Policy Map designates the project site as Resource Area, Low-Density Residential, and Open Space.
The City's current Zoning Map designates the portion of the project site north of Santiago Creek as R-1-8
(Single-family Residential), with the remainder of the project site designated S-G (Sand and Gravel
Extraction).
The Draft EIR states, "The City Attorney has stated that the materials recycling (i.e., asphalt and
concrete crushing) would require approval of an amended Conditional Use Permit for expansion."
[Emphasis added(Page 7-3 of the Draft EIR)] Therefore,while it might be argued about the potential for
approval of a future Conditional Use Permit, the potential for continuation of the existing conditions on
the project site under either scenario is evaluated.
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.10-7
Rio Santiago Project SCH No. 2009051072
2.10 Alternatives
1975 East Orange (EO) General Plan, Orange Park Acres (OPA) Plan, and Santa Ana River
Santiago Creek Greenbelt Plan
1975 East Orange(EO) General Plan
Commenters requested that an alternative be presented in the EIR that would establish the project site as
designated in the 1975 East Orange (EO) General Plan. Portions of the project site are located within the
1975 East Orange (EO) General Plan. Approximately 40.3 acres of the project site are located within the
boundaries of the 1975 East Orange (EO) General Plan. There are approximately 1,900 total acres in the
EO General Plan. The project site is approximately two-percent of the overall EO General Plan acreage.
The existing EO General Plan designates the project site as "Regional Park." Please refer to Draft EIR
Figure 5.10-1,Project Site within EO General Plan, shows what part of the proposed project is within the
EO General Plan.
The Draft EIR found that with the removal of the proposed project area from the OPA Plan and the EO
General Plan, all land use allocations, improvements, development standards, lines for the proposed
project would be under one specific plan(the Rio Santiago Specific Plan) as implemented in PDF LUP-4.
With the implementation of PDF LUP-4, the proposed project would amend the City's General Plan by
removing the project site from the East Orange (EO) General Plan and the Orange Park Acres Plan.
The Draft EIR found that the proposed project would establish new designations for the project site on the
City's General Plan. These changes eliminate potential conflicts with any applicable land use plan,policy,
or regulation. Therefore, with the City's approval of the amendments to the OPA Plan and the EO
General Plan and the approval of the Rio Santiago Specific Plan, a less than significant impact would
occur and no mitigation measures would be required.
Orange Park Acres (OPA) Plan
Commenters requested that an alternative be presented in the EIR that would establish the project site as
designated in the Orange Park Acres (OPA) Plan. The Orange Park Acres Plan (OPA Plan) was adopted
on December 26, 1973. Approximately 56.45 acres of the project site are presently located within the
boundaries of the existing OPA Plan. There are approximately 1,794 total acres in the OPA Plan. The
project site is approximately three-percent of the overall OPA Plan acreage. The OPA Plan designates this
area as "Santiago Greenbelt Plan." Please see discussion below related to the SARSCGBP. Please refer
to Draft EIR Figure 5.10-2, Project Site within OPA Plan, shows what part of the proposed project is
within the OPA Plan.
The Draft EIR found that with the removal of the proposed project area from the OPA Plan and the EO
General Plan, all land use allocations, improvements, development standards, lines for the proposed
project would be under one specific plan(the Rio Santiago Specific Plan) as implemented in PDF LUP-4.
With the implementation of PDF LUP-4, the proposed project would amend the City's General Plan by
removing the project site from the East Orange (EO) General Plan and the Orange Park Acres Plan.
The Draft EIR found that the proposed project would establish new designations for the project site on the
City's General Plan. These changes eliminate potential conflicts with any applicable land use plan,policy,
or regulation. Therefore, with the City's approval of the amendments to the OPA Plan and the EO
Page 2.10-8 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.10 Alternatives
General Plan and the approval of the Rio Santiago Specific Plan, a less than significant impact would
occur and no mitigation measures would be required.
Santa Ana River, Sanfiago Creek Greenbelt Plan of 1971(SARSCGP)
Commenters requested that an alternative be presented in the EIR that would establish the project site as
an open space-passive recreational alternative area compatible with the Santa Ana River, Santiago Creek
Greenbelt Plan of 1971(SARSCGP). The SARSCGP is further discussed in Master Response Section
2.5,Land Use and Planning.
The SARSCGP addresses public equestrian and human trails, and the need to protect the watershed and
its habitat value. A specific SARSCGP alternative is not presented in the EIR. However, the concept of
an open space-passive recreational alternative compatible with the SARSCGP was evaluated by the
proposed project and included in multiple alternatives.
It should be noted that CEQA Guidelines section 15126.6(a) states that an EIR shall describe a reasonable
range of alternatives which would feasibly attain most of the basic objectives of the proposed project. As
noted below, a specific SARSCGP alternative would not attain most of the basic objectives of the
proposed project. And such an alternative would not be feasible because of the conflicting and
overlapping land use designations of the General Plan, the East Orange General Plan and the Orange Park
Acres Plan. Because a specific SARSCGP alternative would not meet the minimum requirements of
CEQA compliance, it need not be included in the EIR. However, for purposes of full public discussion
and disclosure, additional information regarding such an alternative is presented below.
Evaluation of Development Under the 1975 East Orange (EO) Genera/ Plan, Zoning, Orange Park
Acres (OPA) Plan, and Santa Ana River Santiago Creek Greenbelt Plan
Although development of the project site for uses permitted under the existing City's General Plan,
Zoning, 1975 East Orange (EO) General Plan, Orange Park Acres (OPA) Plan, and Santa Ana River
Santiago Creek Greenbelt Plan (SARSCGP) would not meet minimum CEQA requirements, this section
discusses the potential impacts of such an alternative.
The City General Plan Policy Map designates the project site as Resource Area, Low-Density Residential,
and Open Space. The existing City General Plan Policy Map is depicted in the Draft EIR on Figure 3-7,
Existing and Proposed General Plan. The City's current Zoning Map designates a portion of the project
site north of Santiago Creek as R-1-8 (Single-family Residential), with the remainder of the project site
designated S-G (Sand and Gravel Extraction). The existing zoning district classifications are depicted in
the Draft EIR on Figure 3-10,Existing and Proposed Zoning Districts. Figure 7-2,No Project Alternative
—Development Under Existing General Plan and Zoning in the Draft EIR depicts a schematic of the land
use under the existing City General Plan.
The EO General Plan designates the project site as "Regional Park." The SARSCGP designates the
project site as an open space-passive recreational area. Table 2.10-3, Summary of Development- General
Plan, Zoning, EO General Plan, and OPA Plan (SARCRGBP)provides a summary of potential land uses.
This Table 2.10-3, Summary of Development - General Plan, Zoning, EO General Plan, and OPA Plan
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.10-9
Rio Santiago Project SCH No. 2009051072
2.10 Alternatives
(SARCRGBP) demonstrates the confusing and overlapping land use designations. The City's General
Plan designates the project site as Resource Area(RA), Low Density Residential (LDR 2.1-6 Du/Ac), and
Open Space (OS). Please refer to Draft EIR Figure 3-7, Existing and Proposed General Plan
Designations. The Zoning on the project site is S-G (Sand and Gravel Extraction) and R-1-8 (Single-
Family Residential 8,000 s.f.). Please refer to Draft EIR Figure 3-10, Existing and Proposed Zoning
Districts. Please refer to Draft EIR Figure 5.10-1, Project Site within EO General Plan, shows what part
of the proposed project is within the EO General Plan and Draft EIR Figure 5.10-2, Project Site within
OPA Plan shows what part of the proposed proj ect is within the OPA Plan.
It should be noted that development of the project site consistent with all of the above plans is not feasible
as the plans overlap proposed land uses. In fact, the proposed project would resolve the overlapping
differences and create a feasible plan protection of open space and parks conceptually consistent with the
SARSCGP. Table 2.10-3, Comparison Summary of Development - General Plan, Zoning, EO General
Plan, & OPA Plan (SARSCGBP)and Project Objectives provides a comparison of the major components
of each plan (i.e., Open Space, Open Space/Passive Recreation, Regional Park, Resource Area, and Low
Density Residential development land uses with project objectives. Table 2.10-4, Comparison Summary
of Development - General Plan, Zoning, EO General Plan, & OPA Plan (SARSCGBP) and Project
Objectives demonstrates that this alternative would not meet most of the basic objectives of the proposed
project as required by CEQA Guidelines section 15126.6(a).
The development of the project site consistent with all of the above plans would potentially meet only
three project objectives as noted in Table 2.10-4, Comparison Summary of Development- General Plan,
Zoning, EO General Plan, & OPA Plan(SARSCGBP)and Project Objectives. As a result, this alternative
would not feasibly attain most of the basic objectives as required by the CEQA Guidelines. For
information purposes only, Table 2.10-5, Impact Summary Comparison Development - General Plan,
Zoning, EO General Plan, & OPA Plan (SARSCGBP) provides a comparison of the impacts of the
proposed project to each alternative arranged by topical environmental issue area.
Table 2.10-6, Santa Ana River, Santiago Creek Greenbelt Plan and Project Alternatives Comparison
provides a summary of the SARSCGBP recommend�?�^r�:, u,�d each project alternative. Table 2.10-6,
Santa Ana River, Santiago Creek Greenbelt Plan anclPr-oj�c�f�r'ternatives Comparison demonstrates that
this alternative would have the same or greater impacts in a large majority of the environmental issues
analyzed in connection with the proposed project.
As a result, a specific SARSCGBP alternative would not satisfy CEQA Guidelines section 15126.6(a) to
feasibly attain most of the basic project objectives and it would not significantly reduce the number of
impacts relative to the proposed project.
The commenters concerns and the additional information presented in this Master Response do not
change the analysis or conclusions of the Draft EIR because they do not raise any issues related to the
adequacy of environmental analysis conducted in the Draft EIR In addition, the information presented
(1) does not identify a new significant environmental impact, (2) does not identify a substantial increase
Page 2.10-10 City of Orange-Response to Comments/Final E/R—December 2013
SCH No. 2009051072 Rio Santiago Project
2.10 Alternatives
in the severity of an impact, and (3) does not identify a feasible project alternative considerably different
from others previously analyzed which would clearly lessen the significant environmental impacts of the
project. However, the comments are noted and will be provided to the Planning Commission and City
Council for consideration.
2.10.3 All Draft EIR Alternatives
Commenters expressed opinions related to each of the alternative presented in the Draft EIR.
Commenters' opinions are noted in each individual letter. The information and opinions expressed do
not change the analysis or conclusions of the Draft EIR because it does not raise any issues related to the
adequacy of environmental analysis conducted in the Draft EIR. No further response is necessary.
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.10-11
Rio Santiago Project SCH No. 2009051072
2.10 Alternatives
Table 2.10-3: Summary of Development -General Plan, Zoning, EO General Plan, 8�OPA Plan
(SARSCGBP)
Planning Existing Land a OPA Plan EO General
Area Use' General Plan Zoning (SARSCGBP)3 PIan3
Open
OS Space/Passive Regional Park
Recreation
A Vacant(85%)& s� Not within OPA Regional Park&
Backfilling(15%) RA Plan. Not within EO
General Plan.
Not within OPA Regional Park&
LDR RI-8 Plan. Not within EO
General Plan.
B Backfi�lling � SG Not within OPA Regional Park
(100/o) Plan.
Backfilling Open Regional Park&
C (80%) &Other� RA SG Space/Passive Not within EO
Recreation&Not
�20%� within OPA Plan. General Plan.
Vacant(85%) &
Materials �pen Not within EO
D RA SG Space/Passive
Recycling Recreation General Plan.
(15%)
1. Existing land use percentages are estimates only.
2. Other includes project entrance gate, drive,parking, and staging.
3. SARSCGP designates 56.45 acres for Open Space/Passive Recreation and EO Genera/ Plan designates 40.3 acres for
Regional Park. The remainder of the project site(approximately 13.25 acres)would be designated for R-1-8,000 development
and Resource Area.
Source:KTGY Group and Vista, September 2013.
Page 2.10-12 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.10 Alternatives
Table 2.10-4: Comparison Summary of Development-General Plan, Zoning, EO General Plan,�
OPA Plan(SARSCGBP)and Project Objectives
Projec#�bjective ; Mee#`
Ob`ective �
To convert a degraded site used for the mining, crushing, and recycling of aggregate
OBJ-1 materials into a planned community providing a mix of natural open space, recreation, No
a e- ualified and sin le-famil housin o ortunities.
OBJ-2 To expand open space and recreational opportunities on-site through the clustering of No
buildin s within limited areas of the roject site.
OBJ-3 To provide inter-generational uses which will encourage active social, recreational, and No
occu ational interaction between lanned communit residents and visitors.
To provide an open space and trail network adjacent to Santiago Creek's riparian habitat,
OBJ-4 including public trails with connections to trails and parks,along with a variety of pubiic No
and rivate recreational o ortunities that do not currentl exist in the East Oran e area.
To provide a local community amenity in the form of multi-purpose facilities that may
OBJ-5 house among other related uses a recreation center, an autism center, and/or a YMCA No
facilit as well as a swimmin center,and mnasium.
OBJ-6 To provide local residents within the larger context of a mixed market rate development No
a wide ran e of recreational o ortunities.
To provide age-qualified residential opporiunities in Planning Area C to respond to
OBJ-7 changing residential market demographics and help meet the demand for age-qualified No
livin in the Cit of Orange.
To provide on-site recreational and volunteer service opportunities,as well as facilities to
OBJ-8 provide health and wellness services, for residents of the age-qualified development No
within the ro'ect.
OBJ-9 To provide single-family residences opportunities to respond to residential market yes
demo ra hics and hel meet the demand for housin in the Cit of Oran e.
OBJ- To provide a circulation system that will minimize adverse effects on local residential
10 neighborhoods and encowage pedestrian, equestrian, and bicycle circulation throughout No
the lanned community.
OBJ- To lessen the noise, air quality, and traffic impacts from materials recycling and yes
11 backfillin o erations.
OBJ- To preserve Santiago Creek and its surrounding wetland and riparian habitat. Yes
12
Source: Vista Community Planners(V�STn)
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.10-13
Rio Santiago Project SCH No. 2009051072
2.70 Alternatives
Table 2.10-5: Impact Summary Comparison Development-General Plan, Zoning, EO General Plan,
&OPA Plan SARSCGBP
General Plan,
Topical Environmental Issue Pro�aosed Project �ning,Efl General
Plan,,&OPA Pian
' SARSCGBP'
Aesthetics-Plannin Area A Short-Term Visual) SIG Increased/Greater
Aesthetics-Plannin Area D Short-Term Visual) SIG Avoided/Reduced
Aesthetics-Plannin Area B,C,&D(Lon -Term Visual) SIG Increased/Greater
Aesthetics-Plannin Area A(Lon -Term Li ht&Glare) LTS Increased/Greater
Aesthetics-Planning Area B (Lon -Term Li ht&Glare) SIG Same/Similar
Aesthetics-Plannin Area C&D (Lon -Term Li ht&Glare) SIG Increased/Greater
A 'culture Resources LTS Same/Similar
Air Qualit (NOx and VOC SIG Same/Similar
Air Qualit (PM10 and PM 2.5) LTS Same/Similar
Biolo ical Resources(least Bell's vireo habitat) LTS lncreased/Greater
Biological Resources (southern cottonwood - willow riparian LTS Increased/Greater
forest)
Biolo ical Resources(jurisdictional features) LTS Increased/Greater
Biolo ical Resources(ra tor and son bird nests) LTS Increased/Greater
Biological Resources(re ulated trees) LTS Increased/Greater
Cultural Resources(archaeolo ical resources) LTS Increased/Greater
Cultural Resources( aleontolo ical resource LTS Increased/Greater
Cultural Resources(human remains) LTS Same/Similar
Geolo y and Soils LTS Same/Similar
Greenhouse Gas Emissions LTS Same/Similar
Hazards and Hazardous Materials(materials release) LTS Increased/Greater
Hazards and Hazardous Materials(Planning Area A) LTS Increased/Greater
H drology and Water Quality(Dam Inundation) SIG Avoided/Reduced
Land Use and Planning LTS Same/Similar
Mineral Resources LTS Same/Similar
Noise LTS Increased/Greater
Po ulation and Housing LTS Avoided/Reduced
Public Services-Fire LTS Same/Similar
Public Services-Police LTS Same/Similar
Public Services-Schools LTS Avoided/Reduced
Public Services-Parks LTS Avoided/Reduced
Public Services-Other Services LTS Same/Similar
Recreation LTS Avoided/Reduced
Trans ortation and Traffic(segments) SIG Same/Similar
Trans ortation and Traffic(intersections) SIG Same/Similar
Trans ortation and Traffic(roadway se ments) SIG Same/Similar
Trans ortation and Traffic(intersections) SIG Same/Similar
Trans ortation and Traffic(se ments) SIG Same/Similar
Utilities and Service Systems LTS Same/Similar
Note:
'Alternative 9,Altemative Site Location includes a summary of worst case impact from both the project site and the alternative site.
Z Hazards are summarized by location as the alternative site contains two landfills.
3 Worse-case is depicted on table.
Abbreviations:
NI=No Impacts
LTS=Less Than Significant and Less Than Significant with Mitigation
SIG=Significant
X—Increased/Greater
XX—Avoided/Reduced
Page 2.10-14 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
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2.11 Public Participation Process
Several commenters expressed concerns related to the Draft EIR public participation process. The
majority of these concerns related to the following items:
1. The availability of the Draft EIR on the City website.
2. The potential for the Design Review Committee (DRC) of the City to consider the proposed
project prior to the receipt of comments on the Draft EIR.
3. The potential need to recirculate the Draft EIR to comply with the CEQA.
Appendix A to the Draft EIR describes the public participation process for the preparation of the Draft
EIR that included the Notice of Preparation(NOP). Appendix A to this Response to Comments describes
the public participation process for the Draft EIR that included the Notice of Completion (NOC) and
Notice of Availability(NOA) of the Draft EIR.
Secrion 15087,Public Review of Draft EIR of the CEQA Guidelines provides that,
(a) The lead agency shall provide public notice of the availability of a draft EIR at the same
time it sends a notice of completion to the Office of Planning and Research....
Section 15087 further provides that notice of the Draft EIR shall be given in the following manner,
Notice shall be mailed to the last known name and address of all organizations and individuals
who have previously requested such notice in writing, and shall also be given by at least one of
the following procedures:
(1) Publication at least one time by the public agency in a newspaper of general circulation in the
area affected by the proposed project. If more than one area is affected, the notice shall be
published in the newspaper of largest circulation from among the newspapers of general
circulation in those areas.
(2) Posting of notice by the public agency on and off the site in the area where the project is to be
located.
(3) Direct mailing to the owners and occupants of property contiguous to the parcel or parcels on
which the project is located. Owners of such property shall be identified as shown on the
latest equalized assessment roll.
Related to the availability of the Draft EIR available Section 15087 provides that,
(� Public agencies shall use the State Clearinghouse to distribute draft EIRs to state agencies for
review and should use area wide clearinghouses to distribute the documents to regional and
local agencies.
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.11-1
Rio Santiago Project SCH No. 2009051072
2.11 Public Participation Process
(g) To make copies of EIRs available to the public, Lead Agencies should furnish copies of draft
EIRs to public library systems serving the area involved. Copies should also be available in
offices of the Lead Agency.
(h) Public agencies should compile listings of other agencies, particularly local agencies, which
have jurisdiction by law and/or special expertise with respect to various projects and project
locations. Such listings should be a guide in determining which agencies should be consulted
with regard to a particular project.
(i) Public hearings may be conducted on the environmental documents, either in separate
proceedings or in conjunction with other proceedings of the public agency. Public hearings
are encouraged,but not required as an element of the CEQA process.
2.11.1 Availability of Draft EIR
Commenters expressed concern that the Draft EIR was not accessible on the City website and therefore
not available. Section 15087 of the State CEQA Guidelines provided above establishes the requirements
far the availability of a Draft EIR. Section 15105, Public Review Period for a Draft EIR or a Proposed
Negative Declaration or Mitigated Negated Declaration, establishes that the public review period for a
Draft EIR shall not be less than 30 days nor should it be longer than 60 days except under unusual
circumstances. This section further indicates that when a Draft EIR is submitted to the State
Clearinghouse for review by state agencies, the public review period shall not be less than 45 days, unless
a shorter period, not less than 30 days, is approved by the State Clearinghouse.
The City's Local CEQA Guidelines provide that,
After completion of the draft EIR, a Notice of Completion (NOC) and the appropriate number of
copies of the EIR shall be filed with the State Office of Planning and Research in accordance with
CEQA Guidelines Section 15085 to begin the public review period. The State Clearinghouse
transmittal form serves as the NOC. A public Notice of Availability (NOA) for public review of
the draft EIR shall be prepared and distributed at the same time the NOC is sent, in accordance
with CEQA Guidelines Section 15087.
The NOA shall include a description of the project, project location, start and end dates for the
public review period during which written public comments will be accepted, contact name and
address (including email address) where written comments can be submitted, address where
copies of the EIR are available for public review, the date time and location for any scheduled
public meetings or hearings, and a list of significant environmental effects anticipated to result
from the project. The NOA and the EIR shall be distributed (via any method of transmittal that
provides a record of receipt) to all responsible agencies, trustee agencies, other agencies with
jurisdiction by law over resources affected by the project, adjacent cities, and the County of
Orange. If the project is a project of"statewide, regional or area wide significance" (as defined in
CEQA Guidelines Section 15206), the NOA and the EIR shall also be distributed to affected
transportation planning agencies (CEQA Guidelines Section 15086). In addition, for certain
Page 2.11-2 City of Orange-Response to Comments/Final E/R—December 2013
SCH No. 2009051072 Rio Santiago Project
2.11 Public Participation Process
projects, water agencies consulted during the NOP process are also required to receive the NOA
and EIR(CEQA Guidelines Section 15083.5)
The NOA shall be direct mailed to any person who has requested(in writing)to be notified of the
project review, and shall be otherwise made available to the public by all of the following three
methods:
i. Publication in a local newspaper;
ii. Onsite posting; and,
iii. Direct mailing to owners and occupants of properties within 300 feet of the project
site. (Exception: In the case of a General Plan Amendment or zoning ordinance
amendment that does not involve a map change to a specific property, direct mailing
and onsite posting is not required.)
The NOA is filed with the Orange County Clerk to begin the public review period. The public
review period for an EIR shall be a minimum of 45 days. The public review period may be 60
days at the discretion of the Community Development Director. Any requests to shorten the
required review period must be made by the Community Development Director to the State
Clearinghouse. The State Clearinghouse-established review period for state agencies and the
general public review period for the EIR should be coordinated whenever possible. (Pages 13
through 14,Local CEQA Guidelines)
The Draft EIR was made available to in accordance with both the State CEQA Guidelines and Local
CEQA Guidelines. Appendix A of this Response to Comments provides the State Clearinghouse
notification, Notice of Availability (NOA), the Notice of Completion (NOC), and notification list far the
Draft EIR. The NOA states that the DEIR was hereby made available for public review and comment.
The public review period for the document received a State-mandated 45-day public review period. The
public review period began on May 16, 2013,and ended on July 1, 2013. Written comments were invited
on the DEIR and requested that they be submitted in writing to the Lead Agency Contact(City). The end
of the comment period was established in the NOA as no later than 5:00 PM on July l, 2013. The NOA
noted that any written comments received after this deadline were not required to be accepted and would
be accepted at the discretion of the City. The NOA stated the locations of copies of the Draft EIR were
available and instructions how to access the Draft EIR on the City's website. The Draft EIR was posted
for public review on the City's website.
During the public review period the City Staff assisted the public with their review of the Draft EIR.
While not included as a part of the public recard, this included responding to questions at the public
counter at Community Development Department, phone calls, and responses to electronic
communications. The City Clerk's office provided assistance with access to the Draft EIR on the City's
website. Additionally, electronic copies of the Draft EIR were available for purchase at the Community
Development Department counter. It is noted that the City's efforts related to availability of the Draft
EIR exceeded the requirements of CEQA. The City has efforts have been to, "...demonstrate to an
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.11-3
Rio Santiago Project SCH No. 2009051072
2.11 Public Participation Process
apprehensive citizenry that the agency has, in fact, analyzed and considered the ecological implications of
its action. (People ex rel. Department of Public Works v. Bosio, 47 Cal.App. 3d 495.)
2.11.2 Design Committee Review of Draft EIR
Commenters expressed concern that the Design Review Committee (DRC) of the City would consider the
proposed project prior the receipt of comments on the Draft EIR. The close of the comment period for the
Draft EIR was July 1, 2012. The proposed project was scheduled for DRC prior to the close of the review
period; however, it was continued and re-noticed. The DRC held public hearings on August 7, 2013 and
October 2, 2013. There is no requirement for the DRC to review the final EIR.
2.11.3 Need for Draft EIR Recirculation
Commenters expressed concern of the potential need to recirculate the Draft EIR to comply with the
CEQA. One commenter expressed a concern that their Notice of Preparation (NOP) comments were not
addressed. One commenter expressed their opinion that the Draft EIR does not describe the proposed
project; analyze its impacts; and, consider meaningful alternatives and mitigation measures.
Appendix A, Public Participation Process of the Draft EIR, includes a list of all comments received on
the proposed project related to the Notice of Preparation. Within this appendix all written comments
were divided into Agency and neighbar letters. Each section includes a table that listed the letters,
summary of comments, and the section of the Draft EIR where the issue was evaluated. Additionally, the
comments from the previous NOP (2009) were also included in Appendix A, Public Participation
Process and detailed out in a similar format.
Some commenters expressed the opinion that recirculation of the Draft EIR was required because on the
fact that the Draft EIR fails to adequately evaluate the project's environmental impacts. Noting that it
was their opinion that:
• The Draft EIR fails to analyze the full development potential of the proj ect.
• The Draft EIR analysis of project alternatives is legally inadequate.
In light of the information provided in response to public review comments, the City considered the need
to recirculate the EIR pursuant to CEQA. CEQA Section 15088.5(e)requires that an EIR which has been
made available for public review, but not yet certified, be recirculated whenever significant new
information has been added to the EIR. The entire document need not be recirculated, if revisions are
limited to specific portions of the document. The recirculated portions or document must be sent to
responsible and trustee agencies far consultation and fresh public notice must be given in the manner
provided for a Draft EIR. New information is not presumed to be significant simply because it is new.
Indeed, pursuant to State CEQA Guidelines Section 15088.5:
New information added to an EIR is not "significant" unless the EIR is changed in a way that
deprives the public of a meaningful opportunity to comment upon a substantial adverse
environmental effect of the project or a feasible way to mitigate or avoid such an effect . . . that
the project's proponents have declined to implement.
Page 2.11-4 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.11 Public Participation Process
State CEQA Guidelines, § 15088.5(a):
In arder to be"significant,"the new information must constitute one of the following:
(1) A new significant environmental impact would result from the project or from a new
mitigation measure proposed to be implemented.
(2) A substantial increase in the severity of an environmental impact would result unless
mitigation measures are adopted that reduce the impact to a level of insignificance.
(3) A feasible project alternative or mitigation measure considerably different from other
previously analyzed would clearly lessen the environmental impacts of the project, but the
project's proponent decline to adopt it.
(4) The draft EIR was so fundamentally and basically inadequate and conclusory in nature that
meaningful public review and comment were precluded.
(State CEQA Guidelines, §15088.5(a)(1)-(4);Laurel Heights II, 6 Ca1.4th at 1120.)
Neither the additional analyses provided in the Section 2.0, Master Responses, and Section 3.0, Response
to Comment, nor any project design feature nor mitigation measures discussed or amplified in the
responses to comments results in new or substantially increased significant impacts, and therefore no
recirculation is required. It is common, and in most cases necessary, for responses to comments to
amplify and elaborate on the analysis of an EIR. Such amplification, however, does not constitute
significant new "information" unless it triggers one of the four categories described in State CEQA
Guidelines Section 15088.5(a). State CEQA Guidelines Section 15088.5(b)provides that"recirculation is
not required where the new information added to the EIR merely clarifies or amplifies or makes
insignificant modifications in an adequate EIR." [emphasis added]. The responses to comments and
associated analysis properly fall within State CEQA Guidelines Section 15088.5(b) and do not implicate
State CEQA Guidelines Section 15088.5(a).
City Staff expressed concern that these new project design features or mitigation measures could be
construed as "significant new information" requiring recirculation. However, simply adding project
design features or mitigation measures does not trigger recirculation. Instead, the test is whether new
information added to an EIR changes the document in a way that deprives the public of a meaningful
opportunity to comment upon a substantial adverse environmental effect of the project. None of the
project design features or mitigation measures or the analysis in the responses to comments identities a
substantial adverse environmental effect of the proposed project not identified in the Draft EIR.
Therefore,recirculation is not required.
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.11-5
Rio Santiago Project SCH No. 2009051072
2.12 Biological Resources
Several commenters expressed concern related to biological resources. A majority of the biological
resource concerns related to the following items:
1. A concern with the need for a long-term habitat management plan.
2. Concerns with the impacts of the proposed project on biological resources.
3. Concerns with the impacts of the proposed project on jurisdictional waters and wetlands.
4. Concerns with the impacts of the proposed project on policies and ordinances.
Section 5.4, Biological Resources of the Draft EIR describes the existing biological resources at the
project site and potential effects from the proposed project implementation. This section also identifies
mitigation measures to reduce potentially significant impacts and describes the residual impact, if any,
after imposition of the mitigation. This analysis used the thresholds of significance consistent with
Appendix G of the State CEQA Guidelines, regulations of CDFW and the USFWS, and thresholds set
forth by the City:
Threshold BIO-A Would the project 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?
Threshold BIO-B Would the project have a substantial adverse effect on any riparian habitat or
other sensitive natural community identified in local or regional plans,policies,
or regulations or by the California Department of Fish and Wildlife or U.S. Fish
and Wildlife Service?
Threshold BIO-C Would the project have a substantial adverse effect on Federally protected
wetlands as identified by Section 404 of the Clean Water Act(including,but not
limited to marsh,vernal pool, coastal,etc.)through direct removal, filling,
hydrological interruption, or other means?
Threshold BIO-D Would the project interfere substantially with the movement of any native
resident or migratory fish or wildlife species or with established native resident
or migratory corridors, or impede the use of native wildlife nursery sites?
Threshold BIO-E Would the project conflict with any local policies or ordinances protecting
biological resources, such as a tree preservation policy or ordinance?
Threshold BIO-F Would the project conflict with the provision of an adopted Habit Conservation
Plan,Natural Community Conservation Plan,or other approved local,regional,
ar State habitat conservation plan?
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.12-1
Rio Santiago Project SCH No. 2009051072
2.12 Biological Resources
2.12.1 Long Term Habitat Management Plan
Several Commenters expressed concern that the Draft EIR does not address the long-term habitat land
management plan for the proposed open space area. They opined that this information is not included and
must be disclosed and analyzed in order to properly evaluate the impacts to the wildlife, riparian habitat
and protected wetlands.
The Commenter comments that the project does not include a long-term habitat management plan for
proposed open spaces areas are noted. Please refer to Section 2.6, Open Space Subsection 2.6.2 Future
Ownership of Planning Area A for a detailed discussion of this long-term ownership of the open space
area on the project site to remain natural.
2.12.2 Biological Resource Impacts
Several Commenters expressed concern that the proposed project would result in significant impacts to
biological resources. Commenter's concerns related to biological resources generally may be grouped
into the following issues areas:
1. Sensitive species were not correctly evaluated and impacts mitigated;
2. Impacts to riparian and aquatic habitats were not discussed properly;
3. Interference with native resident or migratory fish ar wildlife species;
4. The cumulative impacts to biological resources; and
5. Impacts to a riparian corridor between the Park and the OCWD groundwater recharge pits
downstream.
The Draft EIR concluded that the proposed project, inclusive of Project Design Features and Mitigation
Measure BIO-1, would have less than significant impacts to sensitive wildlife species including impacts
to least Bell's vireo (Page 5.4-66 of the Draft EIR). Additionally, the Draft EIR concluded that the
proposed project, inclusive of Project Design Features and Mitigation Measure BIO-2, would have less
than significant impacts to sensitive plant species (Page 5.4-69 of the Draft EIR).
In addition to this master response, please refer to specific responses to each concern and opinions
expressed in Letters 21, 23, and 70 related to the biological resource impacts of the proposed project. The
opinions of the commenters related to impacts of the proposed project on biological resources do not
change the analysis or conclusions of the Draft EIR because they do not raise any factually based issues
related to the adequacy of environmental analysis conducted in the Draft EIR. Therefore, no further
analysis of this concern is warranted.
2.12.3 Jurisdictional Waters and Wetlands
Several commenters expressed concern with the impacts of the proposed project on jurisdictional waters
and wetlands. The Commenters noted that the Draft EIR acknowledges permanent and temporary
impacts to federally protected wetlands. Mitigation Measure BIO-3 calls for mitigating the permanent
Page 2.12-2 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.72 Biological Resources
impacts to USACE/RWQCB jurisdictional "waters of the U.S."/"waters of the State" and CDFW
jurisdictional streambed and associated riparian habitat at no less than a 2:1 ratio and restoring areas that
are temporarily impacted to pre-project conditions (i.e., pre-project contours and revegetate with native
species). The Commenters stated that, "CEQA does not distinguish between temporary and permanent
environmental impacts. All impacts to wetlands should be mitigated at a 2:1 ratio." The Commenters
further stated that, "All natural communities should be restored with native species unless the EIR
provides evidence that nonnative vegetation provides sufficient habitat for wetland restoration purposes."
The Draft EIR concluded that the proposed project, inclusive of Project Design Features and Mitigation
Measure BIO-3, would have less than significant impacts to jurisdictional features and wetlands (Page
5.4-70 of the Draft EIR). Additionally, the Draft EIR concluded that the proposed project, inclusive of
Project Design Features and Mitigation Measure BIO-4, would have less than significant impacts related
to interfering substantially with the movement of any native resident or migratory fish or wildlife species
or with established native resident or migratory corridors, or impede the use of native wildlife nursery
sites as the proposed project avoids impacts to Santiago Creek (with the exception of 0.05 acre of
permanent impact and 0.71 acre of temporary impact resulting from the installation of storm drain outlets,
and 1.13 acres of southern cottonwood-willow riparian forest [0.29 acre permanently impacted for
geotechnical slope stabilization, 0.84 acre within Fuel Modification Zones C and D] and 0.10 acre of rock
outcrop/cattail stand [within Fuel Modification Zones C and D] within the off-site portion of the study
area) (Page 5.4-76 of the Draft EIR). Mareover, areas within Fuel Modification Zones will contain
vegetation that would function as habitat that wildlife could utilize (Fuel Modification Zones C and D
will remain as native vegetation and Fuel Modification Zone B will be predominantly native).
Please refer to specific responses to each concern expressed in Letters 21, 23, and 70 related to
jurisdictional waters and wetlands impacts of the proposed project. The Draft EIR noted that there will be
no temporary impacts to wetlands. As stated on Page 5.4-69 of the Draft EIR, all permanent and
temporary impacts associated with the installation of the storm drain outlets will avoid wetland areas by
exclusion fencing during construction; therefore, no wetlands will be impacted (permanently or
temporarily)within the on-site portion of the project site.
The Draft EIR indicated that less than 0.01 acre of wetland will be permanently impacted within the off-
site portion of the project site by the proposed project for geotechnical slope stabilization. Impacts to off-
site wetlands will be mitigated at a 2:1 ratio. Although no temporary impacts to wetlands will occur,
temporary impacts will occur to U.S. Army Corps of Engineers (USACE), Regional Water Quality
Control Board (RWQCB), and CDFW jurisdiction that would warrant vegetation "with native species,
where appropriate." This statement does not mean that non-native vegetation can be planted, but that
natives will be planted where suitable based on site conditions and consistent with returning an area to
pre-proj ect conditions.
The project applicant is processing applications for permits from regulatory agencies as noted on Page 3-
26 and 3-27 of the Draft EIR. These permits include:
• Regional Water Quality Control Board(RWQCB)-for Section 401 certification
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.12-3
Rio Santiago Project SCH No. 2009051072
2.12 Biological Resources
• State of California, Department of Fish and Wildlife — for issuance of Section 1602 and 2081
permits
• United States Army Corps of Engineers (USACE)—for issuance of Section 404 permit
• United States Fish and Wildlife Service(USFWS)—for Section 7 consultation
The State of California, Department of Fish and Wildlife (CDFW) related to their permit authority have
requested clarification related to flow diversion during construction and fuel modification details.
Figure 5.4-11A, Impacts to lISACE / RWQCB Jurisdictional Features; Figure 5.4-11B, Impacts to
ZISACE/RWQCB Jurisdictional Features•, Figure 5.4-11C, Impacts to CDFW Jurisdictional Features;
Figure 5.4-11D, Impacts to CDFW Jurisdictional Features; and, Figure 5.4-11E, Permanent Impacts to
USACE/RWQCB Jurisdictional Features provides clarification of the temporary and permanent impacts
to jurisdictional waters and wetlands provided to the CDFW. These figures indicate that temporary
impacts have been significantly reduced. Temporary impacts to USACE/RWQCB jurisdiction have been
reduced from 0.30 acre to 0.10 acre; however, there will now be 0.05 acre of temparary impacts to
wetlands. Temporary impacts to CDFW/LBV have been reduced from 0.71 acre to 0.26 acre. However,
permanent impacts to USACE/RWQWB waters have increased from 0.01 acre to 0.14 acre (and increased
by 66 linear feet) based on the most recent storm drain design. Permanent impacts to CDFW/LBV have
increased from 0.10 acre to 0.14 acre (and 66 linear feet). Page 5.4-74 of the Draft EIR has been
amended to updated Figure 5.4-11, Impacts to Jurisdictional Features. There were no changes to
CDFW/LBV fuel modification impacts.' The following universal changes are made to the EIR.
�It should be noted that fuel modification activities are typically regulated by CDFW and not USACE/RWQCB. Fuel modification impacts are
separate from permanent impacts because fuel modification impacts do not result in an alteration of the streambed;therefore,mitigation
requirements for fuel modification activities may be required by CDFW at a lower impacts-to-mitigation ratio. Thus,fuel modification
impacts are considered separately.
Page 2.12-4 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
2.12 Biological Resources
Table 5.4-6b: Impacts to Natural Communities (LBV)
I.BV Temporary LBV Permanent LBV Fuel Modi�cation
Im ac#s Im acts Im acts
Acres/% Acres/% Acres/%
Draft EIR 0.71 0.34 0.84
Revisions to Draft 0.26 0.38 0.84
EIR
Difference -0.45/-63% +0.04/+11% 0/0%
Table 5.4-7b: Impacts to Jurisdictional Features
USACE/RWQCB Tempo�ary Impacts USACEiRWQC6 Permanent
Im acts ;
Acres/% Feet/% Acres/% Feet/%
Draft EIR 0.30(0.05) 411 OA1 (<0.01) 140
Revisions to Draft E1R 0.10 250 0.02 <0.01) 206
Difference -0.20(+0.05)/-66% -161 /-39% +0.01 (0)/+100% +66/+47%
�0%)
COFW Temporary CDFW Permanentlmpac#s CDFW Fael Moditication
Im acts `lm acts
Acres/% Feet/% Acres/% Feet/°/a Acres/% Feet/%
Draft EIR 0.71 411 010(<OA1) 190 0.43 379
Revisions to Draft 0.26 420 0.14(<0.01) 256 0.43 379
E1R
Difference -0.45/- +9/+2% +0.04(0)/ +66/+35% 0/0% 0/0%
63% +40%(0%)
Source: PCR Services Corparation
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.12-5
Rio Santiago Project SCH No. 2009051072
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2.12 Biological Resources
Temporary impacts to wetlands on-site will be restored to pre-project conditions (i.e.,pre-project contours
and revegetate with native species which will be mapped in detail prior to grading to determine the plant
composition within the temporary impact footprint). Returning temporary impact areas to pre-project
conditions is consistent with the USACE's definition of "temporary impacts" and ensures compliance
with the "no net loss of wetlands" policy under the Clean Water Act (CWA). Other resource agencies,
such as the RWQCB and/or CDFW, generally define temporary impacts similarly to the USACE during
their respective permitting processes. Therefore, temporary and minimal adverse impacts to wetlands do
not typically warrant mitigation at a 2:1 ratio. However, during the regulatory permitting process, the
resource agencies may request additional mitigation for temporary impacts to wetlands if deemed
necessary.
The opinions of the commenters related to impacts of the proposed project on jurisdictional waters and
wetlands do not change the analysis or conclusions of the Draft EIR because they do not raise any
factually based issues related to the adequacy of environmental analysis conducted in the Draft EIR.
Therefore,no further analysis of this concern is warranted.
2.12.4 Policies and Ordinances
Several commenters expressed concern that the proposed project would result in impacts to adopted
policies and ordinances. Specifically, concerns were raised related to the City's Tree Preservation
Ordinance. It was the opinion of the commenters that the Municipal Code provision was specifically
intended to prevent proposals such as the Rio Santiago Project from destroying the ecological value of a
site without a clear plan to remedy the destruction.
The Draft EIR concluded that the proposed project, inclusive of Project Design Features and Mitigation
Measure BIO-1, would have less than significant impacts to conservation plans (Page 5.4-81 of the Draft
EIR). Please refer to response to Letter 21.
The Draft EIR found that a total of 323 trees were surveyed within the project site, of which 302 trees are
within the project development footprint and off-site areas of the project site (and 21 will be avoided). It
should be noted that only those trees within the project footprint ar within the immediate vicinity of the
project footprint were surveyed. [Please see Figure 5.4-7, Impacts to Sensitive Plants Species, for the
limits of gading (i.e., development footprint).] The trees within the project footprint comprise only a
small fraction of the trees within the project site boundary. Most the trees on the project site would be
avoided by the proposed project. There are several hundreds of trees within the creek area that remain as
is and are outside the development footprint. The impacts are not considered "large scale tree removal."
Of the 302 trees that will be impacted, 228 trees are located on-site and 74 are located off-site. No trees
within Santiago Creek would be impacted by the proposed project, with the exception of those trees
within Santiago Creek which will be impacted by the storm drain outlets, the majority of the trees on-site
that will be impacted are scattered and therefore provide a lower ecological value as habitat. These
scattered trees also include a large number of non-native tree species (e.g., bottlebrush (Callistemon
citrinus)and gum tree (Eucalyptus globulus)).
City of Orange-Response to Comments/Final EIR—December 2013 Page 2.12-11
Rio Santiago Project SCH No. 2009051072
2.12 Biological Resources
Of the 74 trees within the 2.01-acre off-site area that will be impacted, 48 trees are within Fuel
Modification Zones C and D and will be left in place but will be subject to thinning. Any potential
impacts to regulated trees are considered potentially significant. MM BIO-5 would reduce impacts to a
less than significant level (see page 5.4-79). Prior to the issuance of any grading permit that would
impact any trees, a City permit shall be obtained. The City requires a 1:1 mitigation replacement ratio for
all trees that would be removed by the proposed project. Replacement of regulated trees to be removed
will be accomplished on-site and/or on public off-site lands at the discretion of the City. In addition, for
those trees within Santiago Creek (both on- and off-site) that will be impacted, which include a large
number of native trees species that comprise a part of a woodland, mitigation is prescribed for sensitive
plant communities (i.e., southern cottonwood-willow riparian farest) at a 1:1 ratio, sensitive wildlife (i.e.,
least Bell's vireo) at a 3:1 ratio, and jurisdiction (i.e., CDFW) at a 2:1 ratio to mitigate for the loss of
functions and values provided by these individual trees comprising a woodland community. The City
Municipal Code provides for an overall comprehensive approach to the compliance with the City's Tree
Ordinance. "�he City Municipal Code Section 12.32.110B provides far replacement of trees within a 90
period. Approval of the Specific Plan by the City would replace this existing City Code for the project
site and establish a tree removal/replacement plan for the project site.
The information and concerns expressed above related to biological resources do not change the analysis
or conclusions of the Draft EIR because they do not raise any issues related to the adequacy of
environmental analysis conducted in the Draft EIR. No further response is necessary.
Page 2.12-12 City of Orange-Response to Comments/Final E/R—December 2013
SCH No. 2009051072 Rio Santiago Project
-..—
LETTER 1
6��EOF P���
E�L tli r 8�
Q���p`'.�:v��:�'��F� � 4 .
�;, STATE OF CALIF{3RNIA � * '�
M w
` W� : � GovEx�aR's UFFlc� o,�P�Nr���� REs�Rcx ��f''� �
C,��#�p�`P STATE CLEARINGH(�USE AI�TD PLANNING UNIT '���CAUF��
EDMUND G.BROWN JR. ��'�
GovERrroR � Du�crox
�
J�m�28,20I3 �� , `��, '��
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�
Chad�rtlieb i
r
Gitv of�range,�omnlunity Developn�ent Department =:� �
`� _�� , � ��
304 E. ChapXnan�venue - .� �
Qrange,Cfi 928b6
Subject: Rio SanCiago Pr�ject �—
SCH#: 2049051072
Dear Ghad Ortlie.b:
The.State Clearin�hous�submitted the above nanl�d Draft EIR to seleeted state agencies for review. Th�
review periad ciosed on June 27,Zt?13,and no state agencies submitted comnlents by that date. This letter
aclalowledges that you have coi��plied with the State Clearin�bouse review requiren�e.nts for draft
en��irot�mental documents,pursuant to the Calif�i�nia Environn�enta] Quality Aci.
l . l
1'lease call#lze State Cleari�ghause at(916)445-0613 if you have any questions regarding the
envir�mnental review process. If y��u have a qu�-stion about the above-nam�d project,pleass refer to the
ten-di�it State Clearinghouse nwnber when contactin�this af£'ice.
Sincerely,
ott Morgan
Director, State Clearinghouse
140010th Street P.O.Box3044 Saeramento,California 95812-3044
(916j 445-Ob13 FAX{916)323-3018 wvvw,opr.ca.gov
Document Details Repart
State'Clearinghouse Data Base
5CH# 2009651072
Project Title Rio Santiago Project
Lead Agency Orange, City of
Type EIR Draft EIR
Description This DE1R evaluates the potential en�ironmenfal impacts of#he Rio Santiago project proposed for
development by JM1 Properties/Santiago Partners, LLC. The proposed project contains approximately
110 acres on-site and 2.09 acres oif-site.
Lead Agency Cantact
Name Chad Ortlieb
Agency City of Orange, Community Development Department
Phone (714)744-7237 Fax (714} 744-7222
emai! cortlieb@cityoforange.org
Address 300 E. Chapman A�enue
City Orange Sfafe CA Zip 92866
Project Location
Counfy Orange
Cify Orange
Region
Lat/Long 33°48' S9"N/ 19 7°47' 19"W
Cross Streefs N. side of Santiago Canyon Rd. between Orange Park Bivd east& Cannon St on the west,&S. of Mab
Parcel No. 370-�11-08;093-280-07,17,30&31;093-280-27&29;370-041-12&25;370-141-19;370-011-18,29&22
Township Range Section 8ase
Proximity to:
Highways Hwy 261
Airports No
Railways No
Waterways Santiago Creek, Handy Creek
Schools Linda Vista ES,Santiago MS,EI Modena HS,EI Dorado HS,Cerro Villa
Land Use Z: Sand and Gravel (SG), SFR(R-1-8)
Projectlssues Agricultural Land;Air Quality;Archaeologic-Historic; Biologicaf Resources; Drainage/Absorption;
Forest Land/Fire Hazard; Flood Plain/Flooding; Geologic/Seismic; Minerals;Noise; Population/Housing
Balance; Public Services; Ftecreation/Parks; Schools/Universities; 5ewer Capacity; Soil
Erosion/Compaction/Grading; Solid Waste;Toxic/Hazardous;Traffic/Circulation; Vegetafion;Water
Quality; Water Supply; Wetland/Riparian; Growth Inducing, Canduse; Cumulative Effects;Other
Issues; AestheticNisual; Septic System
Reviewing Resources Agency; Department o#Conservation; Department of Fish and Wildlife, Region 5; Office of
Agencies �-{istoric Preservation; Department of Parks and Recr.eafion; Department of Water Resources;Office of
Emergency Management Agency, Gafifornia;Califomia Highway Patrol; Caltrans, District 12;
Department of Housing and Community Development; Regional Water Quality CQn#rol Board, Region
8; Department of Toxic Substances Control; Nafive American Neritage Commission
Date Received 05/14/2013 Start of Review 05/14/2013 End of Review 06/27/2013
/''F %
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J�./�./'.,�/�.3"5�L l/f. '�.
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. - . . 1 n ...—V'r�„�
Note: Blanks in data fields result fram insu�cl�n����cF�a�a��`���,,
,
3.0 Comments and Responses
LETTER 1
Date: June 28,2013
Scott Morgan
Director
State Clearinghouse
Response to Comment 1.1
The Commenter's statements related to complying with the State Clearinghouse review requirements for
draft environmental documents, pursuant to California Environmental Quality Act are noted.
Additionally, it is noted that no state agencies have submitted comments to the State Clearinghouse at
time of the letter. This information does not change the analysis or conclusions of the Draft EIR because
it does not raise any issues related to the adequacy of environmental analysis conducted in the Draft EIR.
However, it is noted and will be provided to the Planning Commission and Ciry Council for
consideration. No further responses are necessary.
City of Orange-Response to Comments/Final EIR—December 2013 Page 3-5
Rio Santiago Project SCH No. 2009051072
LETTER 2
MARK A. REFOWITZ
CQUNTY OF �RANGE DIRECTOR
�'�°��b�����,. HEALTH CARE AGENCY DAVID M. SOtJLELES, MPH
''�`:�`"`�> DEPUTY AGENCY DIRECTdR
REGULATORY HEALTH SERVICES RICHARD SANCHE2,REHS, MPH
ENVlRONMENTAL HEALTH DIRECTOR
ENVIRONMENTAL HEALTH
MAiL�NG ADDRESS:
��'�:j'���,����.�� 1241 E.DY�R RQ.,#120
SANTA ANA,CA 827Q5-5611
� �����c„`������ TELEPNONE:(714}433-6000
y�a��r���> FAX:(714}754-1732
, E-MAIL:a�P���,i,h�a.,�eh�.c?�m
�-' �x�``
� t _ '`°�.
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,
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,� ~;�
June 3, 2013 ����_,
�
;�
__ ,
�. __ 3 e�
Chad Ortlieb, Senior Planner �' ` � � � �
�
City of Qrange = � ��
Planning Division � �� �`
300 East Chapman Avenue
Orange, CA 92866 '. ,
Subject: 1Votice of Draft Enviranmental Impact Report far Proposed Rio Santiaga
Praject(SCH Na. 2409051072), Orange, CA
Dear Mr. Ortlieb,
The Orange County Health Care Agency Environmental Health Division is the Solid Waste
Local Enforcement Agency (LEA) for all cities and unincorporated areas of Orange County.
Pursuant to Public Resources Code (PRC} Sections 43020, 43021, and 44002, and the California
Code of Regulations (CCR), Title 14 and Title 27. It is the intent of the LEA to protect public
health, safety, and the environment through the enforcement of State re�ulatians applicable to
open and closed salid waste faczlities.
The LEA has a concern that some of the proposed development structures and utilities (sewer
lines, �vater lines, etc.) in Planning Area B will be situated in close praximity ta the former Villa
Park Disposai Station. This former disposal sit� encom�asses approximately 17 acres and is
lacated at the north east corner of Santiago Canyon Road and Cannon Street_ Landfill gas (LFG)
is currently extracted from extraction we11s and discharged through a flaring system with
approval from the South Coast Air Management District. LFG inonitoring probes are installed 2•1
around the perimeter af the former landfill, three of which, along the north and east perimeter,
are Iocated c�n the proposed Rio Santiago project property. T�e LEA's concern is that LFG
migration offsite (af which methane may range from 45%-64°10} is possible, due to the very high
porosity of the soil in this area. State regulations permit same migration of LFG offsite, as long
as the methane concentrations remain beiow the 5°lo regulatory limit by voluine in air.
The draft EIR has essentially concluded that no rnethane protection measures are necessary far
the proposed YMCA building and utilities due ta the absence of detectable methane in soil vapar
samples callected in 1'lanning Area B. Conversely, the draft EIR recommends methane
2.2
Mr. Chad Ortlieb
June 3, 2413
Page 2 of 2
protection measures in Planning Area C, due to low levels of inethane faund in soil vapor
samples in t11is area. Planning Area C is located farther away frorn the former disposal site than
Planning Ar�a B. Generally, the potential risk of rnethane migration becames lower the farther
away you are from a disposal site. In additian, the lack of detectable methane in soil vapor
samples collected from Planning Area B does not rule out the potential for changes to the current
or future offsite methane migratian due to the hetero�eneity of subsurface soils or variations in
migration pathways that may occur.
The LEA recommends that all appropriate methane protection safeguards be tal:en in Planning
Area B to mitigate any potential risks associated with the project in regards to the adjacent
former dispasal site. Please refer to the attached Califarnia Code af Regulations, Title 27,
Section 21190, Fostclosure Land Use, which requires certain safeguards be taken if structures are 2.3
built v�Tithin a disposal site's baundary. The �roposed Rio Santiago Project should eonsider the
fallowing precautians: a geomembrane between tlle cancrete floor slab atid subgrade; utility
trench dams, periodic methane gas monitaring inside all buildings and underground utilities;
subsurface venting systems beneath each building; and autamatic metllane sensars beneath and
inside each building, etc.
The LEA also recommends protecting the three offsite LFG monitaring probes an the north and 2 4
east perimeter of t11e former disposal site, and establishing a buffer zone to a11ow for the
installation of additianal probes or future remediation as necessary.
The LEA is available to participate in future meetings with the developer to discuss the landfill
gas migration issue ar to review and cornment on any proposed plans which implement 2.5
rnitigation measures for the development project.
Finally, the LEA requests to ve included on all future notices re�arding this praposed
develapment.
If you have any questions, ar if we can be of assistance, please do not hesitate to contact me at
(714) 433-6270, ar James Strozier at{714) 433-b273,
Sincerely,
K t Cro , REHS
Supervising Hazardous Waste Specialist
Solid Waste Local Enforcement Agency
Environmental Heaith
cc: Dianne Ohiosumua, CalRecycle(Riverside)
Virginia Rosales, CalRecycle (Sacramento)
John Arnau, C?C Waste&Recycling
Cindy Li, SARWQCB
David Jones, AQMD
Anthany Martinez, Environmental Health
21190. CIW1VI.g_ postclosure Land Use. (T14:Section 17796} ,'.
(a)Proposed postclosure land uses shall be deszgned and maintained to:
(1)protect public health and safety and prevent damage to structures, roads, utilities and gas
rnonitoring and control systems;
(2}prevent public contact with waste, landfill gas and leachate; and
(3)prevent landfill gas explosions.
(b} The site design sha11 consider one or more proposed uses of the site toward which the
operator will direct its effarts, or sha11 show development as open space, graded to harmonize
with the setting and landscaped with native shntbbery or 1ow maintenance ground cover.
(c}A11 propased postclosuz-e lancl uses, other than non-irrigated open space, on sites
implementing closure or on closed sites shall be submitted to the EA, RWQCB, local air district
and local land use agency. The EA shall review and approve proposed postclosure land uses if
the project involves structures within I,000 feet of the disposal area, structures on top of waste,
modification of the low permeability layer, or irrigation over waste,
(d) Construction on the site sha11 maintain the integrity of the final cover, drainage and erosion
control systems, and gas monitoring and control systems. The owner or operator shall
demonstrate to the satisfaction of the EA that the activities will not pose a tl�u-eat to public health
and safety and the environment. Any proposed modification or replacement of the low
permeability layer of the final cover shall begin upon approvai by the EA, and the RWQCS.
(e) Construction of structural improvements on top of landfilled areas during the postclosure
period shall meet the following conditions:
(1) autornatic methane gas sensors, designed to trigger an audible alarm when methane
concentrations are detected, shall be installed in all buildings;
(2) enclosed basement construction is prohibited;
(3) buildings shall be constructed to mitigate the effects of gas accumulation, which may include
an active gas collection or passive vent systems;
(4)buildings and utilities shail be constructed to mitigate the effects of differential settlement.
All utility connections shall be designed with flexible connections and utility collars;
(5) utilities shall not be installed in or below any low permeability layer of final cover;
(6}piIings shall not be installed in or through any bottom liner unless approved by the RWQCB;
(7) if pilings are installed in or through the low permeability layer of fnal cover, then the low
permeability layer must be repIaced or repaired; and
(8}periodic methane gas monitoring shall be conducted inside ail buildings and underground
utilities in accordance with section 20933 of Article 6, of Subchapter 4 of this Chapter.
(f}The EA may require#hat an additional soil layer or building pad be placed on the final cover
prior to construction to protect the integrity and function of the various layers of final cover.
(g} All on site construction witlain 1,000 feet of the boundary of any disposal area shall be
designed and consiructed in accordance with the following, or in accordance with an equivalent
design which will prevent gas migration into the building, unless an exemption has been issued:
(1) a geomembrane or equivalent system with low permeability to landfill gas shall be installed
between the concrete floor slab of the building and subgrade;
(2} a permeable layer of open graded material of clean aggregate with a minimum thickness of
12 inches shall be installed between the geomembrane and the subgrade or slab;
(3) a geotextile filter shall be utilized to prevent the introduction of fines into the permeable
layer;
(4}perforated ventzng pipes shall be installed within the permeable layer, and shall be designed
to operate without clogging;
(5)the venting pipe shall be constructed with the ability to be connected to an induced draft
exhaust system;
(6} automatic methane gas sensors shall be installed within the permeable gas layer, and inside
the building to trigger an audzble alarm when rnethane gas concentrations are detected; and
(7)periodic methane gas monitoring sha11 be conducted inside all buildings and underground
utilities in accordance with Article 6, of 5ubchapter 4 of this chapter (section 20920 et seq.).
3.0 Comments and Responses
LETTER 2
Date: June 3, 2013
Kathry Cross, REHS
Supervising Hazardous Waste Specialist
Solid Waste Local Enforcement Agency
Environmental Health
Response to Comment 2.1
The Commenter's statements related to concern of the proposed development structures and utilities in
Planning Area B situated in close proximity to the former Villa Park Landfill are noted. The potential for
landfill gas (LFG) migration from the former Villa Park Landfill site is possible. For this reason a LFG
system was installed at the former Villa Park Landfill site. It is the site owner's (County of Orange
monitored by OC Waste & Recycling) responsibility to ensure that LFG at concentrations that potentially
could result in hazardous conditions (i.e., at or above the lower explosive limit) do not migrate beyond the
site's boundaries. If the current LFG collection system is not meeting this standard, the former Villa Park
Landfill site is the responsible party to ensure that the standard is met. It is not the responsibility of the
proposed project owner to monitor the LFG. This information does not change the analysis or
conclusions of the Draft EIR because it does not raise any issues related to the adequacy of environmental
analysis conducted in the Draft EIR. However, it is noted and will be provided to the Planning
Commission and City Council for consideration. No further responses are necessary.
Response to Comment 2.2
The Commenter's statements related to methane protection are noted. The Local Enforcement Agency
(LEA) is correct. Subsurface conditions could change (especially during site re-development) that could
result in different migration pathways. Please refer to Master Response Section 2.3, Hazards and
Hazardous Materials, Subsection 2.3.1, Relationship to Former County Landfill for further discussion of
the relationship with the landfill and the proposed project. Based on the information provided in
comments on the Draft EIR, no new impact has been identified in Planning Area B related to the need for
methane protection safeguards. However, the project applicant has indicated that all development in
Planning Area B will be in accordance with a new project design feature (PDF) to address the expressed
concerns. In order to clarify this addition would be implemented, it has been incorporated into the EIR
below.
Page 5.8-9 of the Draft EIR has been amended as noted below to include the additional PDF the project
applicant has agreed to implement:
PDF-HAZ-9 Prior to the issuance of any grading permit in Planning Area B the project
applicant shall demonstrate to the satisfaction of the Directors of Public Works
and Community Development that remedial actions, in accordance with adopted
State standards, have been taken on-site or that buildings will include vapor
barriers or passive/active venting systems.
Page 3-10 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
3.0 Comments and Responses
PDF-HAZ-IO Prior to the issuance of any grading permit in Planning Area B the project
applicant shall demonstrate to the satisfaction of the Directors of Public Works
and Community Development that three on-site LFG monitoring probes on the
north and east perimeter of the former Villa Park Lan�ll site will be protected.
PDF-HAZ-11 Prior to the issuance of any grading permit in Planning Area B the project
applicant shall demonstrate to the satisfaction of the Directors of Public Works
and Community Development that utilities that trench immediately adjacent to
the former Villa Park Landfill, will include vapor barriers.
PDF-HAZ-12 Prior to the issuance of any residential building permit, the project applicant
shall demonstrate to the satisfaction of the Director of Public Works and
Communiry Development that methane monitors will be installed.
Response to Comment 2.3
The Commenter's statements related to appropriate protection safeguards in Planning Area B are noted.
Please refer to Master Response Section 2.3, Hazards and Hazardous Materials, Subsection 23.1,
Relationship to Former Counry Landfill for further discussion of the relationship with the landfill and the
proposed project. Based on the information provided in comments on the Draft EIR, no new impact has
been identified in Planning Area B related to the need for methane protection safeguards. However, the
project applicant has indicated that all development in Planning Area B will be in accordance with a new
project design feature (PDF)to address the expressed concerns. In order to clarify this addition would be
implemented, it has been incorporated into the EIR below.
Page 5.8-9 of the Draft EIR has been amended as noted blow to include the additional PDFs (PDF HAZ-9
to HAZ-12)the project applicant has agreed to implement(see above).
This information does not change the analysis or conclusions of the Draft EIR because it does not raise
any issues related to the adequacy of environmental analysis conducted in the Draft EIR. However, it is
noted and will be provided to the Planning Commission and City Council for consideration. No further
responses are necessary.
Response to Comment 2.4
The Commenter's statements related to protecting the three offsite LFG monitoring projects and a buffer
zone are noted. Please refer to Master Response Section 2.3, Hazards and Hazardous Materials,
Subsection 2.3.1, Relationship to Former County Landfill for further discussion of the relationship with
the landfill and the proposed project. The LEA's has requested the provision of a buffer to allow
installation of probes or future remediation as necessary. California Code of Regulations, Title 27,
Section 21190 Postclosure Land Use address land use requirements on landfill sites. Additionally, LEA
Advisory #51,July 1998,discusses disposal site post closure land use issues. It states:
"Disposal site" or "site" includes the place, location, tract of land, area, or premises in use,
intended to be used, or which has been used far the landfill disposal of solid wastes (PRC Section
City of Orange-Response to Comments/Final EIR—December 2013 Page 3-11
Rio Santiago Project SCH No. 2009051072
3.0 Comments and Responses
40122). In practice, this definition means that any property located outside the parcel containing
the solid waste is not subject to the postclosure land use requirements of 27 CCR 21190, even if
the outside property is within 1,000 feet of the waste footprint (27 CCR 21190(c)). This can be
problematic for the CIWMB and LEA because parcel boundaries can be split from the disposal
site, allowing development close to the waste footprint without triggering postclosure land use
controls and approvals.
Local building codes and ordinances can provide enforceable buffer zones controlling land use
development adjacent to disposal sites (e.g., Los Angeles County building codes). Another way
for the LEA to influence the control of postclosure land use development adjacent to disposal site
parcels is to participate as early as possible in the local planning process when rezoning and
building permits come up for issuance. It is also important to note that where the Department of
Toxic Substances Control (DTSC) has jurisdiction over postclosure land use pursuant to
California Health and Safety Code Section 25221 (i.e., hazardous waste sites), it has broad
authority over adjacent land use activities on property outside the disposal area."
A review of the location of the LFG monitoring probes on the north and east perimeter of the former
disposal site indicated that four probes are located outside the former Villa Park Landfill site and on the
project site. Additionally, two probes are located adjacent to the project site on the former Villa Park
Landfill site. The ownership of the probes on the project site is presently unknown. A review of the
Preliminary Title Report for the project site has been accomplished. The Preliminary Title Report does
not discuss the probes on the project site. However, the OCW&R has indicated that they maintain and
monitor probes related to the adjacent former Villa Park Landfill site. PDF 10 (see above) allows for the
probes under the ownership of OCW&R to remain on-site. The project applicant does not have a
responsibility to allow the continued use or to protect probes constructed on the project site without their
consent.
The Ciry is required to consult with the LEA related to land uses adjacent to a landfill site. This has been
accomplished with issuance of the Notice of Preparation (NOP), Notice of Completion (NOC), and the
preparation of this Response to Comments/Final EIR. Additionally, the LEA was notified of a project
scoping meeting and will be notified of all public hearings related to the proposed project.
The proposed project does not establish specific PDF's to provide a buffer adjacent to the former landfill.
However, land uses of the proposed project to the north of the landfill in Planning Area A are Open Space
—Natural and in Planning Area B and Open Space—Park. These two land uses provide a buffering of the
proposed project from the former landfill. Please refer to Master Response 2.3, Hazards and Hazardous
Materials Based on the information provided in comments on the Draft EIR, no new impact has been
identified in Planning Area B related to the need for methane protection safeguards. However,the project
applicant has indicated that all development in Planning Area B will be in accordance with a new project
design feature (PDF) to address the expressed concerns of OCW&R and LEA. In order to clarify this
addition would be implemented; it has been incorparated into the EIR below.
Page 3-12 City of Orange-Response to Comments/Final E/R—December 2013
SCH No. 2009051072 Rio Santiago Project
3.0 Comments and Responses
Additional Project Design Features (PDFs)
Page 5.8-9 of the Draft EIR has been amended as noted below to include the additional PDF the applicant
has agreed to implement:
PDF-HAZ-9 Prior to the issuance of any grading permit in Planning Area B the project
applicant shall demonstrate to the satisfaction of the Directors of Public Works
and Community Development that remedial actions, in accordance with adopted
State standards, have been taken on-site or that buildings will include vapor
barriers or passive/active venting systems.
PDF-HAZ-10 Prior to the issuance of any grading permit in Planning Area B the project
applicant shall demonstrate to the satisfaction of the Directors of Public Works
and Community Development that three on-site LFG monitoring probes on the
north and east perimeter of the former Villa Park Landfill site will be protected.
PDF-HAZ-11 Prior to the issuance of any grading permit in Planning Area B the project
applicant shall demonstrate to the satisfaction of the Directors of Public Works
and Community Development that utilities that trench immediately adjacent to
the former Villa Park Landfill,will include vapor barriers.
PDF-HAZ-12 Prior to the issuance of any residential building permit,the project applicant shall
demonstrate to the satisfaction of the Director of Public Works and Community
Development that methane monitors will be installed.
The proposed open space in Planning Area A is described as:
Planning Area A is approximately 50 acres in size (approximately 45 percent of the project site)
and would be retained in its current condition except for infrastructure improvements and native
habitat restoration.
Infrastructure improvements would occur in Planning Area A adjacent to Planning Areas B, C,
and D along the southern edge. These infrastructure improvements include: drainage, flood
control, and multi-purpose trail (including an equestrian fence). These infrastructure
improvements will occur along the south side of the Santiago Creek as stated in Figure 3-4,
Tentative Tract Map. No infrastructure improvements are proposed to occur to the north of
Santiago Creek. Planning Area A will be conveyed to either the City, Orange County Parks, the
Homeowner's Association (HOA), or Orange County Transportation Authority (OCTA) as a
habitat restoration project for the Measure M2 Freeway Environmental Mitigation Program for
permanent public open space preservation. The proposed project within Planning Area A
provides for re-vegetation in the fuel modification zone and for infrastructure improvements.
(Page 3-28, Draft EIR)
City of Orange-Response to Comments/Final EIR—December 2013 Page 3-13
Rio Santiago Project SCH No. 2009051072
3.0 Comments and Responses
Proposed land use to the east in Planning Area B would be Open Space-Park. This is described as,
"...would allow a variety of fee based recreational and community uses including 'pay fo�play" uses."
(Page 3-28, Draft EIR). The Draft EIR further describes future land uses in Planning Area B as:
... Planning Area B would include a multi-purpose facility with a maximum of 81,000 square feet
that may include a combination of the uses (listed below) and shall not exceed two stories in
height. Ancillary uses in support of the above uses are also allowed (including but not limited to
parking lots, bicycle parking, restrooms, and support services such as sandwich shop,juice bar,
coffee, pro shop, etc.). Freestanding commercial uses would not be permitted. (Page 3-29, Draft
EIR)
The proposed project does not establish specific PDF's to provide a buffer adjacent to the former landfill.
The area immediately adjacent to the former landfill would be landscaped in Zone 2: Community
Streetscape/Trails/Edges (Figure 3-16, Plant Zones Draft EIR). A community view fence constructed of
tubular steeUsolid wood/combo low block wall and tubular steel would be located on the property line
(Figure 3-17, Wall and Fence Plan Draft EIR). The City and the project applicant are not required to
adhere to the recommendations of the LEA related to buffers on private property.
The above information does not change the analysis or conclusions of the Draft EIR because it does not
raise any issues related to the adequacy of environmental analysis conducted in the Draft EIR. However,
it is noted and will be provided to the Planning Commission and City Council far consideration. No
further responses are necessary.
Response to Comment 2.5
The Commenter's statements related to participate in discussions regarding landfill gas migration and
mitigation measures is noted. This information does not change the analysis or conclusions of the Draft
EIR because it does not raise any issues related to the adequacy of environmental analysis conducted in
the Draft EIR. However, it is noted and will be provided to the Planning Commission and City Council
for consideration. No further responses are necessary.
Page 3-14 City of Orange-Response to Comments/Final EIR—December 2013
SCH No. 2009051072 Rio Santiago Project
LETTER 3
lgnacfa�.O+choa,P.E.,lntenm Director
30Q N. Fiower Street
�� � Santa Ana,CA 92703
��'�� .:� ����������������k.7 Santa Ana,CA 92 02-4Q48
tnfegrity, Accountability, Service, Trust Telephone: {714)667-8800
Fa�c: (714)967-0596
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June 24, 2Q13
Mr. Chad Ortlieb, Senit�r Pianner, Planning Division � _ ��
City ofi�Jrange � �E ��`
3d0 East Chapman Avenue ��
Qrange, California 92866
SUBJECT: Notice of Availability (NOA� & Notice of Cornp�ction�I�IQ�j 4f'a Draft Environmental
Impact Repart (DEIR} for the Rio Santiago� Praje�ct �(State Clearinghouse No.
20Q9051072)
Dear Mr. Ortlieb;
The Caunty of Orange has reviewed the I�otice of Availability & Notice of Completion af a Draft
Environmental lmpact Report for the Rio Santiago Project (State Clearinghause No. 2009051072}
and offers the following comments;
FloodISAR/Trails:
1. Da not describe a Class I Bikeway as a "trail". Trails have dirt or decampased granite surface.
3.1
2. Please limit the use af this word "trail" anly to a "riding and hiking trail". A strict use af
words is needed to differentiate the paved, aff-road Class I Bikeway from a decomposed
granite riding and hiking trail.
3. Do not describe the trail and bikeway as a "trail". Please refer to each route separately. 3•2
4. 1`he name af the Clas� I (paved, off-raad) Bikeway proposed along Santiago Creek is the 3.3
Santiago Creek Regional Class I Bikeway.
5. The name of the trial along Santiago Creek {from Irvine Regional Park ta its proposed
terminus at Cannon Street) is the 5antiago Creek Regional Riding and Hiking TraiL This trail is
located on the north side af Santiago creek inside Santiago Oaks Regional Park. Once the
trial exits Santiago Oaks Regional Park it then follows west along an Orange County Flaod
Control District levee service road west to a point where it must cross�antiago Creek (by way 3.4
af a new trail bridge)to the connect with a new length of this trail on the south of the creek.
To connect bath lengths of the regianal trail (the existing length ta the proposed length) the
project will need to design, permit and construct a new riding and hiking trail bridge to span
Santiago Creek. Currently there is na safe trail crossing of Santiago Creek. Once the #rail
crosses Santiaga Creek from the north side to the south side it will then parallel the Class I
Bikeway to the western edge of the project boundary.
Additionally, highlighted excerpts from the draft EIR {5.15 Recreation — attachment 1) has been 3.5
enclosed to assists you in addressing the comments. The attached `woad fence detail' (attachment
2)will also aid in addressing comments.
Flaod Pro�rams•
1. The hydrology studies—Rational Method and Small Area Unit liydrograph—presented in the
above snentiened Report were based on 2-year and 100-year High Confidence (HC} storm 3.6
events. A 100-year HC flow rate is usually used for design af flood control facilities but not for
mitigation measures.
2. The determination of project impacts and assaciated mitigation measures require Expected
Value (EV) analysis for existing versus developed conditions for the 2, 5, 10, 25, 50 and 100- 3 7
year storm events per the �range County Nydrology Manual (OCHMj. Any increase in runoff
should be appropriately mitigated.
3. In the hydrologic models of the Report, the existing land use was assumed as Public Park.The
aerial phofio shows the area to be undeveloped, barren. It is recommended for modeling 3•8
purposes to assume undeveloped land use for existing conditions.
4. Based on the subrnitted informatian, the low loss rate fractions seem to be incarrect. Please 3 9
check the calculations and revise as appropriate.
5. Since the City of Orange (City) is responsible for land use planning and deveiopment within
its municipal limits, the City should review and approve all lacal hydrology and hydraulic
analyses including the needed 1d0-year flood protection for the proposed development. 3.10
Proposed flood protection features should not worsen the existing conditions including
erosion and scour of embankment of natural watercourse or shift flooding problems
downstrearn or upstream of the project site.
6. The design of the proposed drainage facilities for the project site must be accomplished
concurrently with regulatory permits (and/or conservation easement requirements). 7his is
to ensure that the design of the detention basins (if any) and other flood control facilities 3.11
incorporate any conditions or mitigation measures restrictions on maintenance activities that
may result from the regulatory permits.
7. Figure 4 of Fuscoe Report "Planning Area A Improvements" shows proposed buried riprap
training wall located beyond the proposed project boundary on the east side and
encroaching into Orange County Flood Control District (OCFCD} right-of-way. Any
improvement should be within the proponent's property. Further discussion needs to be 3.12
provided on what the project proponent's plans regarding that area are and what the
justificatian is to include the riprap outside of its property.
8. All work (if any) within OCFCD right-of-way, including Handy Creek {E08S06) right-of-way will
require encroachment permits from OCPW/County Property Permit Section. Far informatian
regarding permit application, please visit our web site http://www,ocplar�nin�.net1. 3.13
Technical reviews and approvals for the praposed work will be accomplished through the
permit prQcess,
9. The proposed project developer should appiy and secure all needed regulatory permits for(i)
the construction of the proposed impravements and {ii) the future maintenance of 3.14A
constructed facilities by �CFCD. Responsibility for any mitigatian required by regulatory
agencie5 will need to remain with the developer.
10. If any engineered improvemen#s (inciuding stone placement and materials used in
improvements) ta Santiago Creek reach is to be turned over ta QCFCD for ownership or
maintenance need to meet OCFCD criteria and standards, and pass OCFCD inspection. An 3.14B
agreement between OCFCD and project developer that delineates each party's
responsibilities needs to be prepared befare design plans are finalized and permits are
obtained from the county.
Environmental Resaurces:
1. EIR Page 5.9-38 states "it is widely accepted that events less than 5-year flood have limited 3.15
discharge and hence transport capacity (s�aur) cansequences on the Creek". We da not
concur, and suggest tne statement is speculative.
2. EIR Page 5.8-11 and Section 4.2.2 of the Phase II Environmental Site Assessment note there is
a potential for contaminants from past leaks of fuel and/or oils on the site to end up at or
near the surface after project grading. The ESA �tates that "the need for the remedial 3.16
actions will depend on final surface cover and final grade elevations for the areas of concern.
Remedial actions could include excavation and off-site disposal".
Page 2 of the Tait 2fl10 response ta City of Orange camments on the Phase 1 ESA indicates
the City was reevaluating closure determination far eight farmer USTs due to praposed
land use changes". It is nat however clear whether this determination was to be made by 3.17
the City ar the Regianal Board, and the 2009 Regional Baard NOP comment letter does not
suggest they were aware ciosure determination was being reconsidered.
Mitigation Measure HAZ-1 on EIR Page 5.8-11 states that "Prior to the issuance of any
grading permits the project applicant shall demonstrate to the satisfactian of the Directors of 3.18
Public Works and Community Development that remedial actions in accordance with
adopted State standards have been taken an-site, or that the excavatian and aff-site disposal
has occurred."
EIR Appendix I (Enviranmental Site Assessment Reports) indicates that the Santa Ana
Regional Water Quality Control Board required no further action on the contaminated soils in
1998, presumably on the basis of a cited 1996 closure report which can no longer be Iocated.
It seems a fair canclusion that the Santa Ana Regiona! Board required no further actiQn on 3.19
the basis af those soils not removed then remaining where they were. As the Phase II ESA
notes, this is no longer the case. After project grading, soils with some measure of
contaminatian may be present at or near the surface.
This discussion is based on Enuironmental Screening Levels develaped by the San Francisco
Bay Regional Water Quality Contro! Board in 2008. However, the Screening Levels used are
for human health, and do nat address the question af how far above human health
standards surface contamination needs to be reduced to in order to protect the biological
values af immediately adjacent surface waters from cantaminants being carried in runoff. 3.20
For example,the environmental screening levels used in the Phase II Assessment were 83000
micrograms per liter/kilogram for TPH gasoline and TPH diesel and 370000 micrograms per
liter/kilogram far TPH motor ail. However, Aquatic Habitat Goals in the current San
Francisco ESL document af May 2013 are a far less 500 micrograms per liter/kilogram for TPH
gasoline and 640 micrograms per liter/kilogram for TPH diesel and TPH motvr oil.
Thus, any "remedial actians" or "excavation and off-site disposal" would be based an
screening levels hundreds of time less sensitiv� than those associated with protection of
aquatic habitat. There seems iittle basis ta conclude that this Mitigation Measure would 3.21
assure any remaining contamination at the surface, after grading, is not subsequently
carried by runaff into,and to the detriment of, Santiago Creek.
Therefore, cansultation with the Santa Ana Regional Water Quality Contral Board prior to
clearance by the City's Directars of Public Works and Community Development in the 3•22
Mitigation Measure is recommended to address this concern.
3. Finally, the referenced ESLs fram the San Frar�cisco Regional Board were updated in May
2013: http`1/www waterboards ca c�v/rwc�c�2 waterissu�sfprt��ramslESl.A 3.23
Caver Memc� May 201.3. pdf, and any differences should be examined in the EIR.
OC Parks:
5.15 Recreation
The discussion of the trails and bikeways needs to be revised to better explain existing and
plannedJproposed trails and bikeways, both internal and external to the project.The comments 3.24
and revised text submitted by OC Flood are very helpful in carrecting errors and providing
accurate information.
Realistic connectivity of trails and bikeways, particularly a regional riding and hiking trail
between the project site and Santiago Oaks Regional Park, through intervening Orange 3.25
County Flood Cantral District property, needs to be addressed.
Caunty Propertv P�rmits:
This project surraunds OCFCD Handy Creek Storm Channel (E08S06). Any impravements that affect 3.26
this area will require review for County Property Permit Encroachment Permits.
HCA/Environmental Heal#h:
1. Work with Orange County Health Care Agency {OCHCA) Industrial Clean-up, as needed, for
remediation of all .identified areas af Total Petraleum Hydrocarbons impacted soil within the 3.�.
project site.
2. Refer to the letter dated June 3, 2013 (accompanying this Memo} from the �olid Waste Local
Enfarcement Agency with OCNCA to the City of drange regarding concerns with proposed
development activities of the project site being in close proximity to the former Villa Park Disposal 3•28
Station.
If you have any questions or need clarification please do not hesitate to call me at (714) 667-3211.
Sincerely,
��
..�..,�. °�---
Po1in Modan ou, Manager
Strategic Land Planning
OC Public Works/OC Planning Services
300 North Flower Street
Santa Ana, California 92702-404�
Pc�iin.Mo�anlou��cptine.c�c��u,cc�m
cc: Medhi Sobhani, Manager, OC Public Works/OC Engineering/Flood Programs
Mahrooz Ilkhanipaur, Manager, OC Public Works/OC Planning Services/
Permit Application & Processing
leff Dickman,Trail Coordinatar, OC Public Works/OC Engineering/OC Flood/SARJTrails
Chris Crompton, Manager, OC Public Works/OC EngineeringJEnvironmental Resources
Christine Lane, Hazardous Waste Specialist I!1/FfCA/Environmental Health
Harry Hugging, Manager, �C Public Worksf OC Parks
�. �,�:
�'��r���f��� �..��;�� , ����
5.15 Recreatian
5.15.1 Introduction
Purpose
The purpose of this section is to identify any potential impacts on recrcational facilities.This
section also identifies mitigatian measures ta reduce any potentially significant recreational
impacts and describes the residual impaet,if any,after imp�sition of the mitigation.
Sources
The fallawing saurces were used in c�nsideration and discussion of the potential environtnental
impacts:
•Ciry of Orange ARunicipal Code.
�Commuters.Strategzc Flan,Orange Couniy Tr�nsr`t Authority's(OCTA),2Q09_
•General I'Icrn:Circulation&Mobility Section, City of Qrange,March 2010.
z , . � ' . , . r���#` . �;��:,. .
� t�r�n�e C'oue�l� Trae���cat�tats'�ir�1�,ut4�c�r�t�=('a�ea�ntptet�E�ik��ay:�Str�te�ic�t�t�
� {�c�ernEr� t�4`�r�n�E Bi3cc���3 1'1������a
� �'auz�ty c�ft)r�r��,�ast�r�'I�n�F�t�gi�a��t i�c�re�taac��t l�ic�ira��ssd�ii�in�'�'r�ni�s
(itcc�r�ti+ae�Elemrt�8 t�t il���r�a�r�l�'I:�a�}
•Master Plan for Park Frzcilities,Recreation,ond Communih�Services, City of Orange,
Novembar 2009.
•Orange Park�lcres Plan,City of Orange,December?3, 1973.
•Rio Santiago Speciftc Plan, City of Orange,Qctober,2011.
•Table 2:E-5 City/County Census Population and Housing Counts, 4/1/2010, State of California
Department of Ninance.
�1975 East Orange(EO)Ceneral Flan,City of t7range,Au�ntst 19'75.
•Comments received during the public comn�ent periods and scoping meetings.These comments
are conCained in Appendix Ay Public Participation Process.
Plaaned Qpen SpacelParks/Arenas
A ride-in only arena is proposed to be located at the Ridgeline Equestrian�;states site.The azena
consists of 0.45 acres and will be approximately 1.3 miles south of the proposed project.This
project has beei�appraved throu�h the City;however,it has not been developad.
�xisting City and Counfy'Trails
An existing riding and hiking recreational trail(trai(}follows currently exists along the north side
of East Santiaga Ganyon Raad adjacent to the Reserve neighborhood�This�xisting recreational
multi-purpose trail is camposed of surfaced with decomposed granite.Trail users and is available
for include pedestrians,equestrians,and mauntain bicycle riderskers.This trai(is i1lusTratcd on
the City's 201�General Plan,Figure CM-3 Plan for Recreational Trails and Bikeways.
An existing recreation multi-purpose trail,the Santiago Creek Regional Riding and Hiking Trail,
is locatedexists off-site and north of Planning Area A,adjacent to the south edge of East Mabury
Avenue.This trail is maintained by the Mabury Homeowners Association,County of Orange,and
the City of Orange.'T'liis trail has an unauthorized cannection from the Mabury neighborhoad
crossing Santiago Creek to Santiago Oal:s Regional Park ta the east and to the City to the west.
The crossang is available when Santiago Creek has low flaws.The crassing of Santiago Craek is
presently an unautharized trespass onta prrvate property.This Santiago Creek Regional Riding
and Hiking tTrail is illustratcd on the City's 2p1 D General Plan,Figure CM-3 Plan foa•
Recreational Traits and 13ikeways and the County of Orange,Master Plan of Major Regronal
Riding&Hiking Trails.s and Ofj=Road Paved I3zketivays Plan.The crossing of 3antiago Creek is
presently utilized as an unauthorized trail trespassuig on private praperty.
Class II(on-road)bike lanes exist on northbound and saut6bound Cannon Street and eastbound
and westbaund Santiago Canyon Road adjacent to the project site as depicted an Figure CM-3
Plan,for Recreational Traits and�3ike�vays,Ciry's 201(1 Gen�ral PCan,Figure CM-3 Plan for
Recreational Trails antl Bikeways.Figure 5.15-2,Fxisting and Pro�oserl Trails identifies existing
Ciiy and County of Orange trails in the vicinity of the project site,respeciively.
_...._ __. ,
�'lanned City and Gounty Trails_____ __ ... __________,. ____ -- Formatted;Font coior:nuco ��)
Figure 5.15-2,Existing and Proposed Traits identifies exishiig City and County of Orange trails
_._� _._...._ _..-----_..__ . _
and Class I Bikewaysln thc vic�mty of the project site;respectively.The Oran�e Park Acres _ �ormatted:Fonc co�or:nuto
(OPA)Plan and the 1475 East Orange(EO)Generai Plan proposed trails are similar to the �
proposed trails in the City's 2010 General Plan.Per the City's 2010 Genera!Plan,Figure CM-3
Plan for Recreatio�zal Trails and Bikeways,there is a proposed Class I Bikeway(Qff-Sheet}to be
located on the norCherly and westerly edges of Planning Area A.There are also praposed
recreational trails ta be located along East Ssntiago Canyon Road adjacent to the project site and
the easterly boundary of the project site.Objective 4 of the Froject Applicant established
objectives(located in Section 3.0,Project Description)proposed project states:
OBJ-4'I'o provide an open space and trail network adjacent ta Santiago Creek's riparian habitat,
including pubiic trails with connections to trails and parks,along with a variety of public and private
recreational opportunities that do not currendy e�st in the East Orange area - ---,
Per the County of Orange's�Bikeway Plan and OCTA's Commuter Bikeways'�tratag�c Plan _ ._ -'� Farmaaea:Font color.Aum ��
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�Lla�or Riding&Hikin Traits and CJ -Road Paved Brkew s Plan asch 2�08,there is a Formatted Font cobr:Auto ?
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proposed off-road pa�ed bikeway south of Santiago Creek through the project site. , Formatted:Font color:Auto��_
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�County of Orange's�,Bikeway Plan and Master Plan of Regional Riding and Hiking Trails ,- =�
- -- - Formatted:Font mlor:Auto
�ecreational Trails Master Pian -" �- --�
-- - --- ---- - -- � --- - --� -� - -- -- - - �- � - -
The Bikeway and Tra.il p1ans,�1Za)or Riciing&Hikm�Trails and Off-Road Paved_Bikeways_Plan __. -�� Formatted:Font mbr:auto
-- - -- - W�. ��
are,a comprchensive,�long-range�lannin�documents„wlnch describe„�or trail setting,alignments, �-- Formatted:Fant co�or.nuco �
- - - --
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standards,and locations.The two�lans;were�s desrgned for a broaci spectrum of usars inciuding i` r-c,rmattea:r-ont cobr:auto J
commuter aud reereational�rail bicyclists,hikers�oggers,and equestrians and mountain bicycle � ��
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riders, - - - __. - ' �,, _.._. �
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DR REC-1 The ptoposed projact will include recreational and open space apportuni� ��rmatted Table ��'
within Planning Area A.`This wi((inolude multi-parposea recreationai trail -�������-�"���"�" `��" ��
aud a Class I Bikeways,Santiago Creek,and passive open spacc and natural
open spaca.The recreational and open space areas ui Planning Area A will be
maintained by Owner until and if donated m the Counry or other public
agency.
, _.,..�..�...............___.. --�
, e proposed_project will include approximately 1.3 miles of on-site regiona(and,ridin�and _ _ _�„� ��armatt+ed.Font 11 pt,rront mbr,Auto �
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hiking trails and a Class 1 Bikeway�nulb-purpose Formattea:Font:il pt �'
,pubhc ttails.The�bilceway and,�e trails will provide connectivzty between the project srte and the_ ,� �' ��Formatted:Font:il pt,Font cabr.Aum �
adjacent community.T'he propased on-stte regional trails will have the potential to be accessed ___ �
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fram existing and praposed off-site public trails.The Class I,recreational B�keway and separake_ ` ' Pormatted:Fon�Times New Roman,ll pt, ",'
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recreational�rails wi[I beprovided as stateddescribet�belaw: -- _._�
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implement�a portio of the proposec�City anld County��ail?),traal alang Santiago Creek will ` 1��o�matted:Fanr.il pt '
� r Planpf Trails.This temporary � '� ' Formatted:Font:Times New Roman 11 p[���
(bikeway?)�rail along Plaunirrg Area A shall be canstructgd at issuance of 50%of Cerkificates af ' � �, �nt cobr,num � �
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Occupancy af either Planning Area C ar D,whichever occurs first,for the eniire tength of this r•armatted:Font:rirr�New Roman,li pt,
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trail on the , �.; Font cabt:Auto ;
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ro ect srte.The r�ltimate rmanecrt mu}tl- u ose xecreafional trail al
on Santia�o Creek shall �; ,; �
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be constructed at issuance pf 5Q°/a of Certificates of Oce�pancy of the adjacent land use as ', Formatted:Font:Times New Roman,il pt,
development ocaurs(e.g.,ulYimate multi-purpose recreational trail adjac�nt to Planning Area D ��'� ����r:auto 1
would be built as develapment occurs in this area).,The ultimate(permanent)Planning Area B __ ����, Parmattea:Forrt�Times New Roman,li p� �
adjacent trail segment shall be conslructed prior to development on Planning Area Ii. ' '., Font wior.nuto
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�A meandering mulfi-pwpose r�creation decomposed�ranite�trail will oonneet the proposed trail_ , .-`,, Formatted:�nt:(oefault)rimes rvew ;
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along rast Santiago Canyon Road ta the trail south of Santiago Creek,This ultimate(permanent) � ,,'•, Roman,ii pt,Font calor:auto
, _______ _;
trail shalt be constructed at issuance of 50%of Certificates of Occupancy of Planning t�rea D. �' Formatted:Font:(default)Times New
•A meanderin multi- ur ose recreation decom osed anite a�I will be rovided alon East_ �.`, ��an,Font color.nur�
B P P P � �T _. P _ _ _ _.__�_ ,.�.— ;
Santiago Canyan Road.A temporary trail ti�ll be provided along East Sanriago Canyan Road '`� Pormatted:Font:(�efault)T;mes rvew �
shall be constructed ai issuance of 50%af Certificates of Occupancy of either Planning Area C or ' �aman,Font cr�or:auka�
D,whichever occurs first,fpr fhe cnClre length Qf this trail on the project site�The ultimafe �� Fa►marted:Font:(Detauit)rimes New �
(permanent)multi-purpose recreational trail along East Santiago Canyon Road shall be ',�� Roman,ii pt,Font color:Auto �}
constructed at issuance of 50%of Gertificates of Occupancy of the adjacent]and use as `, wrmatt�;Fpnt:il pt
develapment occurs(e.g.,ultimate multi-purpose recreational trail adjac�nt to Planning Area D '',� Formatted:Font:(De�auit)Times rvew �
would b�buiit as development occurs in this area).The ulfimate(permanent}planning Area B '�'� R«nan,li pt
adjacent trail segment sl�all be constructed prior to development on Planning Area B. .'•,� rwrmatted:Defauit,Adjust space between�
_ _- e.. - ---- - --� __.,
'�'� Latin and Asian te�ct,Adjust space between E
A recreation trail currently exisfs atong the north side of East Santiago Canyan Road adjacent to �� ��an text ana n�mbers �
the existing Reserve neighborhood and east of the project site.The existing trail provides far a Pu�natted:Font:{�e�ault}Times New Roman
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the project and the projeet extends the ttail along the project's entire East Santiago Canyon Road ',, �,,,,atted:Font:ii pt
frontage as illustrated on Figure 5.15-2,F.xistir�g and Proposed Trails.This would be a 10-faot ', �atted:Font:u pt �
w�ide recreation 4rai1 tread separated from�ast Santiaga Canyan Road by a 6-foot wide ---�. --�
landscaped patkway mease�red from the back of curb,all within an 1%'wide trail easement.This ��"atted:Font coior.au�o � �
portion af the recreation trail would use decomposed granite and would be avaitable far
pedestrians,equestrians,and mountain bicycle riderskers internal and eacternal to the project.Thz
surface wi[1 b�in accordance with City standards on recreational trails.At the southwest corner of
the project site,a further e�ctension westwatd by the adjacent property owner(County of Orange)
�vould be possible.Implementation of this section of recreational trai]is consistent with the City
of Orvige proposed Recreational Trail,as illustrated in Figure 5.15-2,Existing and Proposed
Trails.
The proposed project implements a multi-purpose recrearional trail extending into the project site
alongside the proposed main entry roadway,and shall provide a connection between Easl �
Santiago Canyon Road and the proposed multi-nse recreational trail along the south bank of
Santiago Creek.PDF-TRA 1 shall provide a connection for surrocuiding communities and the
Mara Bradman hHarse aArena to the main entry trail sys[em.A 10-foot wide recreation trait tread
of decomposed granite on one sicie oP tt►e street,separated from the back of the main en{ry
roadway sidewalk by a 6-foot wide planting azea is proposed,all within an 18'wide trail
easement.
An ofC-site recreation trail,the Santiago Creek Regional Rzding and I-liking Trail,exists north of
Planning Area A adjacent to the south edge of East Mabury Avenuc.The City's General Plan
shows this trail as wider than its current configuration.This widening could occur on the project
site or adjacent properties to the north.The proposed project would not preclude the
implementation of a wider trail.Additionally,this traiE has an unauthorized connection from#he
existing Mabury neighborhood crossing Santiago Creek Co Santiago Oaks Regionai Park to the
east aind to the City to the west.This trail is illustrated on Figure 5.15-2,Fxisting and Proposed
Trails.The trail is an existing Coun#y riding and hiking trail,a proposed City Class I off street
bicycle trail,and an existing City recreational trail[1"he sentence dces not read well—please
rewrite].The existing trai]is located off-site.Future trail locations alignments are generally
depicted;however,these routes may be located on the project site including a potential
connection across Santiago Creek.As noted above the project applicant has offered(in fee?)
Planning Area A to the City,County,Orange County Transportation Auihority(OCTA},or SOlc3
Non-Profit Organization.The proposed project woutd�iot preclude the implementation of the
futute trails.
A Mui#i-UseRiding and Hiking Trail and Bikeway[?j is proposed along the southern boundary of
Planning Area A along the south bank of Santiago Creek The trail multi-use trail would be used
by pedestrians,and equestrians and the paved bikeway by bicyclists and pedestrians.The total
width of the paralleI multi-use trail and bikeway woutd be a 205-fooeet wide. The tread would
include comprised of a 10-foot paved surface and a area,lU 4-foot wide decomposed gravel
swface sepazated by a 3 foot buffer.equestrian tread,and a 2-foot wide decomposed granite tread
for joggers.This area would also be used by Orange County Flood Control District and Orange
County Fire Authority fo access the Santiago Creek.The trail and bikeway would include a wood
border on one side of a split-rail or pipe fcncc with access points at key locations along the
perimeter of the adjacent Planning Areas.At Lhe far western edge of the project site,the bikeway
and trai)are planned to Multi-Use Trail lceatiou would allow far future undercross linkage to
Cannon Street and connect with the planned Santiago Creek Class I Bikeway at the existing
regional trail and bikeway staging faciliiy.trail connectors to tfie west.'I'he trai(has been designed
to meets the County of Orange Standard Regional Riding and Hiking Trail Design Guideline for
an urban riding and hikiug trail.The minimum trail tread width is 210-fcct,with three feet of a
parallel shoulder,for a totai width of 16 feet.00t right-of-way easement width from the Regional
Riding and Hilcing Traits Desdgn Guidelines.The trail has been designed to County standards,
as City 5taff has informed the project applicanl that the City does not intend to accepttake
ownership of Planning Area A,including the multi-use bikeway and trail.
According to the 2010 City General Plan Circulation and Mobility Element, implementation of
the Santiago Creek Trail and bikeway is considered a high priority.This trail is illustrated Pigtue
515-2,Existing and Proposed 7'rails.The SanYiago Creek Class I Bikeway Trail is pa�ed
between Cannon Sireet Tustin Street to the western City limit that continues to Main Place Mall
and the Discovery Science Center,however the 2010 General Plan does not state if the rauie e
trail section within the project site would be paved.The County of Orange and OCTA both
proposes a n Class I(paved,off-road)Off-Road paved Bikeway along the south side of Santiago
Crcek.In the approximate location of ihe planned Class I County Off-Road Bikeway,the
proposed project will provides for aconstruct a paved Ctass I multi-purpose trailBikeway.The
The exisling Santiago Creek tRiding and Hiking Trail,located to the northeast of.the project site
within the Sa�ltiago Oaks Regional Park,is a natvral surface route and presently is not paved.
Less than significant impacts are anticipated as the proposed trail(trail or bikeway or both?)will
be developed in accordance with County Standards for Riding and Iliking Trails and Ctass I
bikeways.
Glass II bike lanes exist on northbound and southbound Cannon Street as well as eastbound and
westbound East Santiago Canyon Road adjacent to the project site.The proposed project does not
propose any improvements io Cannon Street.Additionally,the proposed project would not
change the eastbound Class II bike lane on East Santiago Canyon Road.'I'he proposed project
would provide additional right-of-way along East Santiago Canyon Road adjacent to the project
site.The proposed project would provide for a Class II bike 3ane within right-of-way for
westbound East Santiago Canyon Road as depicted on Figure 3-4,1"entative Tract Map.Map.
As indicated above,in PDF ItEC-1 and PDF REC-5 through PDF R�C-7,the proposed project
allows for the implementation of all project tzails per the Specific Plan.No impact is anticipated
as the proposed multi-purpose recreational trailCIass I Bikeway adjacent to Santiago Creek will
be developed in accordance with County Standards.PDF REC-6 through PDF REC-8 reduce this
potential impact to a less than significant level by the provision of 1.62 miles of on-site regional
and multi-purpose trails.Therefore,based on the information presented above,the impacts on
trails would be anticipated lo have a less than significant impact and no mitigation measures
would be required.