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Home My WebLink AboutSR - GPA-2014-02 - ORANGE PARK ACRES COMPROMISE SPECIFIC PLAN EXHIBIT C ,.. rr .w IYI/ .� Response to Comments on the �, Environmental Impact Report ,� Salem Lutheran Church and +� School OPA Compromise Specific Plan *� City of Orange, Orange County, California � State Clearinghouse No. 2011101046 �. r .. � Prepared for: � � Salem Lutheran Church 6500 East Santiago Canyon Road � Orange, CA 92869 i�r City of Orange Community Development Department• Planning Division � 300 East Chapman Avenue � Orange, CA 92866-1591 Phone: 714.744.7220 „� Fax: 714.744.7222 www.cityoforange.org � � Contact: Robert Garcia, Senior Planner � � � � Prepared by: � Michael Brandman Associates 220 Commerce, Suite 200 �,,, Irvine, CA 92602 � Phone: 714.508.4100 � Contact: Jason Brandman, Project Director r � � bfichacl Brandman Associates '"" January 5, 2015 EXHIBIT C RTC FINAL EIR STATE � CLEARINGHOUSE NO.2011101046 DATED 1/5/IS � SALEM LUTHERAN � MARCH 10,2015 CC MTG. � Response to Comments on the Environmental Impact Report ' Salem Lutheran Church and School OPA Compromise Specific Plan City of Orange, Orange County, California " State Clearinghouse No. 2011101046 � Prepared for: Salem Lutheran Church 6500 East Santiago Canyon Road Orange, CA 92869 City of Orange Community Development Department • Planning Division 300 East Chapman Avenue Orange, CA 92866-1591 Phone: 714.744.7220 Fax: 714.744.7222 www.cityoforange.org Contact: Robert Garcia, Senior Planner Prepared by: Michael Brandman Associates 220 Commerce, Suite 200 Irvine, CA 92602 Phone: 714.508.4100 Contact: Jason Brandman, Project Director ,„,a ��^;_ �� '� \licnacl Rrandma❑ �\ssuci�a[c� January 5, 2015 �: ,,.� � � �;. � THIS PAGE INTENTIONALLY LEFT BLANK �` � �� .. �, �> Sa/em Lutheran Church and School OPA Compromise Specific Plan Response to Comments on the Draft EIR Table of Contents �� Table of Contents Section 1: Introduction and Chronology .........................................................................1-1 1.1 - Categories of Participants................................................................................1-2 1.2 - Context of the Timeline Periods.......................................................................1-2 Section 2: OPA Compromise Plan....................................................................................2-1 2.1 - Environmental ImpactAnalysis........................................................................2-2 2.1.1 - Hydrology and Water Quality ............................................................2-7 2.1.2 - Land Use and Planning.....................................................................2-8 ,w:. 2.1.3 - Transportation and Traffic.................................................................2-8 Section 3: Responses to Comments................................................................................3-1 Section 4: The Grayson Traffic Plan ................................................................................4-1 4.1 - Transportation and Traffic................................................................................4-1 4.1.1 - Site Access Issues ............................................................................4-1 4.1.2 - Internal Circulation Issues.................................................................4-9 " 4.1.3 - Orange Park Boulevard at East Santiago Canyon Road Issues.......4-9 4.2 - Hydrology and Water Quality .........................................................................4-10 4.3 -Aesthetics.......................................................................................................4-11 Section 5: Summary of Corrections and Additions to the Draft EIR................................5-1 5.1 - Changes in Response to Specific Comments..................................................5-1 List of Appendices Appendix A: Traffic Impact and Parking Demand Analysis Addendum for the Proposed Salem Lutheran Church and School Project (OPA Compromise Plan) Appendix B: Hydrologic Assessment Report, Revised July 31, 2014 Appendix C: Letter of Support from the Orange Park Association to the Mayor and Orange City Council, June 5, 2014 List of Tables Table 3-1: Response to Comments - Commenter List.........................................................3-1 Table4-1: Sight Line Summary..........................................................................................4-12 List of Exhibits Exhibit 2-1: Conceptual Development Plan..........................................................................2-3 �,� Exhibit 2-2: Water Quality Plan ............................................................................................2-5 Exhibit 4.8-2: Weekday School Circulation Plan..............................................................3-209 > Exhibit 4-1: Annotated Grayson Traffic Plan........................................................................4-3 Exhibit 4-2: Weekday AM Peak Hour Traffic Volumes.........................................................4-5 Exhibit 4-3: Sunday AM Peak Hour Traffic Volumes............................................................4-7 Michael Brandman Associates iii H:AClient(PN-JN)U771A37710001�RTC-FEIIt�37710001 Sec00-02 TOC.doc Sa/em Lutheran Church and School OPA Compromise Specific P/an Tab/e of Contents Response to Comments on the Draft E/R Exhibit 4-4: Line of Sight Key Map.....................................................................................4-13 Exhibit 4-5: Ronk Property Section A-A.............................................................................4-15 Exhibit 4-6: Ronk Property Section B-B.............................................................................4-17 Exhibit 4-7: Rosenow Property Section C-C......................................................................4-19 Exhibit 4-8: Rosenow Property Section D-D......................................................................4-21 Exhibit 4-9: Cunningham Property Section E-E.................................................................4-23 �. Exhibit 4-10: Cunningham Property Section F-F ...............................................................4-25 Exhibit 4-11: Grayson Property Section G-G.....................................................................4-27 xhibit 4-12: rayson Property Section H-H .....................................................................4-29 �: Exhibit 4.8-2: Weekday School Circulation Plan..................................................................5-3 � � � � ��. � � � �� . �� Michae/Brandman Associates ,� H:\Client(PN-1N)�3771\37710001�RTC-FEIFt\37710001 Sec00-02 TOC.doc wfa,.. Sa/em Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments on the DraR E/R /ntroduction and Chronology SECTION 1: INTRODUCTION AND CHRONOLOGY The California Environmental Quality Act(CEQA) Section 15132 states that a Final Environmental Impact Report(EIR) shall consist of the following: (a) The draft EIR or a revision of the draft. (b) Comments and recommendations received on the draft EIR either verbatim or in summary. � (c) A list of persons, organizations, and public agencies commenting on the draft EIR. (d) The responses of the Lead Agency to significant environmental points raised in the review and consultation process. (e) Any other information added by the Lead Agency. Accordingly,this document consists of ' the following sections: �� - Section l: Introduction and Chronology (including processing flow chart) _ - Section 2: OPA Compromise Plan - Section 3: Responses to Comments (including List of Commenters on the Draft EIR, Letters Received, and Responses thereto) - Section 4: The Grayson Traffic Plan (more fully described below) - Section 5: Summary of Corrections and Additions to the Draft EIR The Salem Lutheran Church and School OPA Compromise Specific Plan Draft EIR was circulated for public review beginning on March ], 2012, and ended on Apri123, 2012. The City of Orange (City)received 10 written comments on the Draft EIR that responded primarily to the land use plan in the Specific Plan. These comments are included in Section 3, Responses to Comments,that follows. All comments were received within the 45-day public review period. Attached to the Salem Lutheran Church and School OPA Compromise Specific Plan is a processing flow chart summarizing the chronology of the Salem Lutheran Church and School OPA Compromise � Specific Plan project starting with the original Conditional Use Permit(2213-98)through to the present. The flow chart is divided into three (3)categories and eight(8)timeline periods. Please note that - background information pertaining to the timeline periods identified in the Processing Flow Chart is on file at the City of Orange in the document titled, "Salem Lutheran Church and School OPA ,�, Compromise Specific Plan - Processing Flow Chart Appendix." The Processing Flow Chart has been prepared in the following manner. Michae/Brandman Associates 1-1 H1Client(PN-JN)�3771\37710001�RTC-FEIIi\37710001 Sec01-OO lntroandChrono doc Sa/em Lutheran Church and Schoo/OPA Compromise Specific Plan Chrono/ogy Response to Comments on the Draft EIR 1.1 - Categories of Participants There are three (3)participant groups shown in the flow chart as follows: A. The Applicant—Salem Lutheran Church and School. B. The Community—OPA Real Estate Committee and adjacent neighbors. C. The City of Orange—Community Development Department. 1.2 - Context of the Timeline Periods The following timeline periods are identified in the evolutionary process of the project as summarized below: A. Conditional Use Permit 2213-98: Adopted by resolution on July 14, 1998 this Conditional Use Permit(CUP)allowed for the expansion of the existing church and private school within � a residential zone, including a new parish center(multipurpose building)and classroom ""` buildings and established shared parking of 151 spaces for church and school assemblies. The City Council found that the proposed project is consistent with the City of Orange's � General Plan and, more specifically,the Orange Park Acres Specific Plan, which was adopted as part of the City of Orange's General Plan (CUP 2213-98, Recitals,4b). � � B. Design Review Committee(DRC)2006: On May 17, 2006, the applicant presented a plan to the DRC proposing a 757-seat sanctuary housed in a new worship center having a height of �� 39 feet,to be located east of the existing multipurpose building adjacent to East Santiago '"'� Canyon Road. The plan proposed to relocate the existing preschool to the Fowler House,to � reconfigure the central parking lot and play courts, and to use the existing multipurpose field �� for overflow parking. Public comments expressed concern regarding the use of the Fowler House for a non-residential use,the reconfiguration of the play courts and related noise,the proposed worship center's location and building height of 39 feet, and Frank Lane design. `°'�" C. Cunningham/Rosenow Period: During this time period(September 2008 to May 2011), the applicant met on several occasions with adjacent neighbars(Linda Cunningham, Christine �� Rosenow, and Theresa Sears)to obtain input regarding the project. Concerns expressed by the neighbors included the consideration of site access off East Santiago Canyon Road; circulation and parking;the usage of Frank Lane and separate resident access;the location and size of the proposed worship center and proposed seating capacity of the sanctuary; location and resulting noise from the reconfigured play courts; and conversion of the Fowler � � House to a non-residential use. In addition to meetings with the adjacent neighbor, the applicant met with City of Orange Staff on a number of occasions to illicit their input � regarding the project. In response to the meetings,the applicant prepared numerous studies addressing site access, circulation and parking; alternate worship center locations and related site configuration pertaining to play court orientation and parking; and Frank Lane � 1-2 Michael Brandman Associates ,,,� H�.\Client(PN-JN)�37711i7710001�RTC-FEIIt137710001 Sec01-OO IntroandChrono-doc Salem Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments on the Draft E/R /ntroduction and Chrono/ogy , configuration and enhancements to address church/school and resident access separation. The meetings and the resulting studies culminated in the preparation and submittal of the Working Draft Salem Lutheran Church and School Specific Plan dated April 30, 2011,to the City of Orange Community Development Department. D. Orange Park Acres (OPA) Input: Concurrent with the submittal of the Draft Specific Plan the applicant attended several meetings with the OPA Real Estate Committee to continue to discuss the proposed project. OPA requests included the elimination of the proposed East Santiago Canyon Road entry due to equestrian crossing concerns; demolishing the Fowler House for parking and locating the preschool closer to the existing school buildings; expanding Orange Park Boulevard with an south-bound right-turn lane for exclusive church/school use; provide for vehicular turn-around at the west end of Frank Lane; provide additional directional signage at the intersection of Frank Lane and Orange Park Boulevard; and ongoing thoughts regarding the design and configuration of Frank Lane. In response to this input,the applicant prepared a series of design studies to address each of the OPA requests, which are considered as "development options." As discussed in Section 2, OPA Compromise Plan, of this Response to Comments document, the input received from the OPA resulted in the development of the OPA Compromise Plan. E. Grayson Traffic Plan: On April 19, 2012, the applicant attended a meeting with the OPA Real Estate Committee at which a"Traffic Plan"was presented by Liberty Grayson. The plan included the elimination of the Fowler House for parking and relocation of the preschool near the existing school buildings; separation of the church/school and resident travel lanes; a vehicular turn-around at the west end of Frank Lane; student drop-off and pick-up on the east side and the west side of the existing buildings; maintained the central parking lot and play courts in a configuration comparable to existing conditions; kept the proposed East Santiago Canyon Road entry; proposed Frank Lane to be egress only for the church and school; and proposed a horse trail overlaid on a bio-swale down the middle of Frank Lane. The applicant reviewed the plan and presented their response to the OPA Real Estate Committee on May 7, 2012. Several concepts from the Grayson Traffic Plan were incorporated into the projects development options including the elimination of the Fowler House in lieu of parking; the relocation of the preschool closer to the existing buildings; student drop-off and pick-up on � the east side and west side of the existing buildings; separate resident and church/school travel lanes; a vehicular turn-around at the west end of Frank Lane; and maintaining the central parking lot and play court configuration comparable to existing conditions. A full analysis of the Grayson Traffic Plan is in this Response to Comments document. F. City of Orange Development Options: Over the past 4 years,the applicant had ongoing discussion with OPA, neighbors, and City staff regarding the project. Several options were addressed during these discussions, including the following project refinements: elimination of the proposed Santiago Canyon Road entry; demolition of Fowler House and replacement Michae/Brandman Associates 1-3 H�\Client(PN-!N)�3771\37710001�RTGFEIR\37710001 Sec01-OOlntroandChrono-doc Sa/em Lutheran Church and School OPA Compromise Specific Plan Chrono/ogy Response to Comments on the Draft E/R of Fowler House footprint with additional parking areas; relocation of preschool closer to existing buildings and away from westerly property boundary; expansion of the west side of Orange Park Boulevard to accommodate an exclusive church/school southbound right-turn lane onto Frank Lane; incorporation of a vehicle turn-around at the western end of Frank Lane; incorporation of additional directional signage at Frank Lane and Orange Park Boulevard, defining resident-only travel lanes and church/school travel lanes; Frank Lane separation method (traffic buttons, enhanced pavement, median, fence, or combination � thereo�; worship center building height lowered pursuant to Design Review Commission (DRC); and incorparation of DRC conditions. G. City of Orange/OPA/Salem Church: The City of Orange facilitated a total of six(6) Salem Liaison Committee Meeting during 2013, with the first meeting taking place on May 16, 2013 and the last meeting occurring September 23, 2013. Discussion items included the ° following: request for reduction in seating capacity of sanctuary; sufficient on-site parking; demolition of the Fowler House in lieu of parking and relocation of preschool; addition of � turn lane on Orange Park Boulevard; deletion of Santiago Canyon Road access; Frank Lane to be separated for resident and Salem traffic; and inclusion of vehicle turn-around at west end of Frank Lane. "�" H. Orange Park Association Settlement Agreement: The applicant and the Orange Park Association have been cooperatively working together over the last several years towards a � compromised plan. The result of this ongoing cooperative effort is a plan referred to as the �... OPA Compromise Plan (herein referred to as the"project")and discussed below. As part of � the OPA Compromise Plan, the changes have been made to the proposed project, as described in the Letter of Support from the Orange Park Association to the Mayor and Orange City Council, dated/executed June �, 2014 (Appendix C) and as outlined in Section 2, "" OPA Compromise Plan, of this Response to Comments document. � 1-4 Michae/Brandman Associates � H\Client(PN-.RV)�3771U7710001UtTGFEIR�37710001 Sec01-OO IntroandChrono.doc � Sa/em Lutheran Church and Schoo/OPA Compromise Specific P/an Response to Comments on the Draft EIR OPA Compromise P/an SECTION 2: OPA COMPROMISE PLAN As indicated in the Processing Flow Chart included as part of the Salem Lutheran Church and School OPA Compromise Specific Plan,the applicant and the OPA have been cooperatively working together over the last several years towards a compromise plan. The result of this ongoing cooperative effort is a plan referred to as the OPA Compromise Plan(herein referred to as the "project")(E�ibit 2-1) and discussed below. As part of the OPA Compromise Plan,the changes have been made to the proposed project, as described in the Letter of Support from the Orange Park Association to the Mayor and Orange City Council, dated/executed June 5, 2014(Appendix C) and outlined below: • Reduction of the seating capacity of the Sanctuary from 757 to 590 fixed seats, excluding special events. • Parking for Project to be confined to Project site, except for(i) additional parking on the site of the Fowler House(see item below) and(ii)other offsite venues that Salem has used for special event parking. The offsite venues referred to in section(ii) does not apply to City and County streets in the Orange Park Acres neighborhood adjacent to the Project site. Salem will continue to enforce its "good neighbor"policy,which endeavors to ensure that Salem's congregation and attendees do not park on City and County streets. • Demolition of the Fowler House in order to provide additional parking and relocation of the preschool away from the westerly property boundary. • Improvement of the west side of Orange Park Boulevard to accommodate an exclusive southbound right turn lane onto Frank Lane for the church and school use. Salem shall use best efforts to endeavor that such improvements will be completed as soon as possible following the commencement of construction of either the Sanctuary or School facilities. The Orange Park Association acknowledges that such roadway improvements will require approvals from the City or the County of Orange ("County")and that Salem cannot guarantee how quickly the City or County will act to approve such roadway improvement plans. The Orange Park Association shall provide any and all documentation requested by Salem to demonstrate the Orange Park Association's support of such roadway improvements. • The inclusion of a demand light for equestrians at the intersection of Orange Park Boulevard and Frank Lane, which improvements shall be completed as soon as possible following the commencement of construction of either the Sanctuary or School facilities. • Incorporation of additional directional signage at Frank Lane and Orange Park Boulevard to define residents only travel lanes and church/school traffic lanes, which improvement shall be completed prior to the issuance of the occupancy permits for either the Sanctuary or School facilities. r�� Michael Brandman Associates 2-� H-\Clien[(PN-JN)�3771\37710001�RTC-FEIIL\37710001 Sec02-OOOPACompromisePlaadoc Sa/em Lutheran Church and School OPA Compromise Specific Plan OPA Compromise Plan Response to Comments on the Draft EIR • Lowering of the Worship Center building height to 36 feet as recommended by the City of Orange Design Review Board(DRC). • Incorporation of a hammerhead turnaround at the west end of Frank Lane per City standards, which improvement shall be completed prior to the issuance of occupancy permits for either the Sanctuary or School facilities. • Provision of"TYPE AY"(as depicted in Caltrans Standard Plans, U.S. Customary Units, 2010 edition)raised pavement markers to separate Frank Lane into separate lanes for residents and Salem Church traffic, which improvement shall be completed prior to the issuance of occupancy permits for either the Sanctuary or School facilities. - • Prior to the commencement of construction of the Sanctuary and School facilities, Salem to coordinate with OPA's Trail Subcommittee to ensure appropriate protections of horse trail on w� Project site. • Incorparation of the following provision into the Salem Lutheran Church and School Specific "" Plan: "No application far a building permit, use permit, variance, or any other entitlement authorizing development or construction inconsistent with this Specific Plan shall be approved, � or deemed to be approved through inaction, by the City of Orange or any officer ar employee thereof." � As a result of the above changes, including the approximately 22 percent reduction in the seating �� capacity of the new Sanctuary, all environmental impacts evaluated in the Draft EIR will be similar in � nature or be reduced based on the decreased intensity of the project. A discussion of the changes is � provided below. � 2.1 - Environmental Impact Analysis �, Based on the nature of the OPA Compromise Plan, potential impacts related to Aesthetics, '""� Agricultural and Forestry Resources, Biological Resources, Cultural Resources, Geology and Soils, °�• Hazards and Hazardous Materials, Mineral Resources, Population and Housing, Public Services, ,�, Recreation, and Utilities and Service Systems are expected to be similar to what was analyzed in the Draft EIR. .�,. As it relates to impacts associated with Air Quality, Greenhouse Gas Emissions, and Noise, effects will be comparable in terms of level of significance to those impacts identified in the Draft EIR, albeit .� reduced in magnitude. As addressed in the Traffic Impact Analysis and Parking Demand Analysis Addendum (Appendix A)prepared for the currently proposed project, the OPA Compromise Plan will result in up to 413 AM peak-hour trips for a typical Sunday church service, representing a 30 "`° percent net trip reduction in the number of AM peak-hour trips analyzed in the Draft EIR. � Z-2 Michael Brandman Associates „�. H:\Client(PN-JN)�771�i7710001ULTC-FEIIt\37710001 Sec02-OOOPACompromisePlan.doc � Z H I � r N � aa w - ;;' F �'' tW 2 Orenge Vark Boulevard __ _1 z - � �"� F ;� -�� _ C 0U _ ,�_ 1 � � z � •— � � F � = X � aa ;; ' ° � ^ � � ' , ��j/�� LLI �♦_ F .. -. � .— __�_ ...— .;_...'__ '"—"'-. (_) V � ' �.. ..� "" __ � -. .-_�- - --- -- ------- ----- -. �.- . � o Z - a - � � ° .� " � '� � �z `` � �. ;� i � � � , � � �O 8 � w1;�� j- Q =� � ' ` .. 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I I, I � :? �w 7�� •�'a -- __, : i�' a � $ � �I � � 3 3 d U N� ,�ny �,69'41Z M.SS,tC.9lN � c y N� � �� C o N .. �., � . vi — d � C Q � W O S � � o � � �� . � o 0 7 �� U I� �n �� M � � � � .� THIS PAGE INTENTIONALLY LEFT BLANK �� . �: � Salem Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments on the Draft EIR OPA Compromise Plan In general, the project's generation of air quality, greenhouse gas, and noise emissions are related to project-generated traffic and the exhaust and noise emissions from those vehicles. Thus, because of the reduction in peak-hour trips, it can be assumed that vehicle exhaust emissions and noise will also be reduced. Therefore,the project's air quality, greenhouse gas,and noise impacts will be incrementally reduced when compared with those impacts analyzed in the Draft EIR. Lastly, while still anticipated to experience similar and/or incrementally reduced impacts,the potential effects associated with Hydrology and Water Quality, Land Use and Planning, and Transportation and Traffic are further addressed and evaluated below. 2.1.1 - Hydrology and Water Quality Construction of the proposed project pursuant to the OPA Compromise Plan will still be required to prepare a Stormwater Pollution Prevention Plan (SWPPP)and incorporate both onsite and offsite best � �� management practices (BMPs) designed to contain and collect any onsite pollutants before they can be conveyed offsite and into downstream waters. As addressed in Draft EIR Impact 4.5-1, following implementation of the SWPPP and BMPs, short-term construction impacts related to hydrology and water quality impacts would remain less than significant. Regarding long-term operational impacts, as addressed in the Water Quality Management Plan (WQMP)prepared for the project,the majority of the stormwater flows originating on the project site (approximately 5.6 acres) were to be directed toward the East Santiago Canyon Road driveway, with � a small portion of the site (approximately 0.04 acre)continuing to flow to Handy Creek. Under this previously proposed scenario, flooding condition along Frank Lane would have been eliminated. However, consistent with the"Single Site Access" alternative analyzed in the Draft EIR,there would be no driveway from Santiago Canyon Road, and as a result, stormwater flows will not have a direct outlet onto the roadway as previously proposed. As a result, a private storm drain system is proposed for the project(Exhibit 2-2). This storm drain system will pick up the majority of the project site and convey flow toward Santiago Canyon Road where it will be picked up in and existing 36-inch reinforced concrete pipe (RCP)within Santiago Canyon Road. This 36-inch RCP conveys flows to the Handy Creek reinforced concrete box culvert under Santiago Canyon Road. This storm drain system will alleviate flooding which has occurred within the private drive westerly of the project site. No significant increases in peak flow or runoff volume will occur due to development. Modeled peak runoff for the project remains relatively the same for the 10-year and 25-year High Confidence Events and decreases approximately 1 percent during the 100-year High Confidence Event. Therefore,the �` project's hydrology and water quality impacts will be similar when compared with those impacts analyzed in the Draft EIR. Michae/Brandman Associates 2-7 H�.\Client(PN-JN)�3771\37710001�RTC-FEIR\37710001 Sec02-OO OPACompromisePlan doc Sa/em Lutheran Church and Schoo/OPA Compromise Specific Plan OPA Compromise P/an Response to Comments on the Draft E/R 2.1.2 - Land Use and Planning The only substantive changes from the previous site plan analyzed in the Draft EIR and the currently � proposed site plan is the removal of the Fowler House. Additionally,the Santiago Canyon Road driveway is no longer included on the site plan,although this configuration was previously evaluated in Section 7 of the Draft EIR as the"Single-Access Alternative." Similar to other environmental '�"" impacts discussed above,removal of the Fowler House would result in impacts similar to those analyzed in the Draft EIR. Moreover, removal of the Santiago Canyon Road access would also result in impacts comparable to the less than significant tra�c/circulation impacts identified in the Draft EIR, as further detailed below. 2.1.3 - Transportation and Traffic A Traffic Impact Analysis and Parking Demand Analysis Addendum(TIA Addendum)(Appendix A) � was prepared for the OPA Compromise Plan to address the potential traffic and parking impacts associated with the proposed project as described in the Specific Plan compared to the 712-seat sanctuary scenario analyzed in the City-approved T'raffic Impact and Parking Demand Analysis `�' Report dated August 20, 2010. As evaluated in the TIA Addendum,the Santiago Canyon Road access has been eliminated, which has been addressed as a Project Alternative in the DEIR, an , , exclusive southbound right turn lane on Orange Park Boulevard at Frank Lane has been added, and the updated parking supply consists of approximately 186 surface parking spaces plus ]OS overflow parking spaces for a total of approximately 291 parking spaces. '"'` Based on the TIA Addendum for the proposed project, no traffic impacts would be created and � adequate parking will be provided consistent with the City-approved Traffic Impact and Parking Demand Analysis Report. As part of the proposed project, Salem Lutheran Church and School has £ agreed to implement a number of traffic- and transportation-related modifications to the project as +� outlined in the Letter of Support from the Orange Park Association to the Mayor and Orange City �,. Council dated/executed June 5, 2014. � � .�. 2-8 Michael Brandman Associates � Hf:\Client(PN-7N)�3771�37710001�R7'C-FEIR\37710001 Sec02-OOOPACompromisePlan.doc wi��. Salem Lutheran Church and School OPA Compromise Specific Plan Response to Comments on the Draft EIR Responses to Comments SECTION 3: RESPONSES TO COMMENTS The Salem Lutheran Church and School OPA Compromise Specific Plan Draft Environmental Impact Report(Draft EIR) was circulated for public review beginning on March 1,2012, and ended on April 23, 2012. The City of Orange(City) received 10 written comments on the Draft EIR that are listed below in Table 3-1 that responded primarily to the land use plan in the Specific Plan. All comments were received within the 45-day public review period. Table 3-1: Response to Comments -Commenter List Letter Na Sender Date Letter 1 State of California,Governor's Office of Planning and Research March 1,2012 Letter 2 County of Orange,Orange County Clerk-Recorder Not dated Letter 3 County of Orange,Orange County Clerk-Recorder Not dated Letter 4 County of Orange,OC Public Works March 27,2012 Letter 5 Keith and Linda Cunningham March 6,2012 Letter 6 Charles Leffler March 4,2012 Letter 7 Laura Thomas Apri123,2012 Letter 8 Christine Rosenow April 23,2012 Letter 9 Orange Park Association Apri123,2012 Letter 10 Tom Grayson,et al. Apri123,2012 Section(§) 15l 32 of the State CEQA Guidelines requires Final EIRs respond to comments regarding significant environmental points raised during the 45-day public comment period on the Draft EIR. The comment letters reproduced in the following pages follow the same order of presentation and organization as described in Table 3-1 above. For example,the response to Letter 1 follows Letter 1. In addition, Letter 10 contained the Grayson Traffic Plan. Responses to this plan are discussed in Section 4, The Grayson Traffic Plan, of this document. The following responses to comments take into consideration the currently proposed project, known as the OPA Compromise Plan, which is discussed in Section 2 of this Response to Comments document. Michael Brandman Associates 3-1 H�\Client(PN-JN)�3771\37710001UtTC-FEIli\37710001 Sec03-00 Responses.doc .�„ � �, �� THIS PAGE INTENTIONALLY LEFT BLANK � � �� . LETTER 1 Page 1 of 1 4o�F`��pc P1i(khy�,C.}� •��.�• -„rl�'O �` . �.: ,, S'I'A'1'F. UF CAL7PURNIP. �' ,k • y' �5 F'�� Go��r�l�c�r�',S UFIiIC;E of�PLANNIN(J AND K�S�AI:CH ��.�� - � ��••, �'��EOf CA4�f�P�\r �e�roi ' . }:�pyc�: Tl)h1lTNU G.RROI�'�JI�. p�y:�:�--pr: c°`'':n"°„ Memorandum Date: March 1, 2012 To: AII Reviewing Agencies From: Scott Morgan, Director Re: SCl I #2011101046 Salem Lutheran Church and School Specific Plan The Lead Agency has con�ected some inforn�ation regarding the above-mcntia�ed project, Please see the attached tnaterials for more specific information and note that the �-� rcview period has been extended to end on April 23, 2012. Al) other project information remains the same. cc: Robert Garcia City of Orange—Community Development Dept. 300 East Chapman Avenue Orange, CA 92866 i 40010th St7�eet f'.0.B�x 3044 Sacramentu,Califurni� 95612•3044 (91G)44;�UG13 FI�a(9l(,)37.3-309 ES �ti��a��.o�;r'.ca.gnv � � � � � <:� � THIS PAGE INTENTIONALLY LEFT BLANK #% � � �. ,� � �. Salem Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments on the Draft EIR Responses to Comments Letter 1 - State of California, Governor's Office of Planning and Research Response to Comment 1-1 This comment acknowledges that the California State Clearinghouse received corrected information regarding the proposed project and that the public review period had been extended. Michae/Brandman Associates 3-5 H.\Clien[(PN-IN)�3771\37710001�RTGFEIR�37710001 Sec03-00 Responses doc � � � � � � � � M.� � THIS PAGE INTENTIONALLY LEFT BLANK ° � � � ,� �: � �� y.:»s-. LETTER 2 �� Page 1 of 1 • ••. Tom Daly ' . Ors�nge County Clcrlc- Recordcr � ' ; v ; •' Ui•ange County CleyIc-Recor•der's Office y 12 Civic Center Plaza, Room 106,P.O. Box 238, Sauta Ana, CA 92702 wei�; ww�v.oc,ca.gov/recorder/ PHONE (714) 834-5284 FAX (714) 834-25t)0 CITY OF ORANGE CNIC CEN1'ER 300 E CHAl'MAN AVL'• ORANGE,CA 92666 Office of thc Orangc County Clei•k-Rccorder Memorandum SUBJEC'I': NOTICE OF AVAILAI3ILI1'Y The attached notice was received, filed and a copy was posted an 02/22/2012 lt remnincd posted f'or 30(thirty)dnys. Tom Daly Orange Co�mty Clerk-Recorder In and for the County of Orange By; PRISCILLA GONZALEZ Deputy Public Resoucce Code 21092.3 2_� The notice required pursuant to Sections 21080,4 and 21092 foi•an environmental impact reuort shall Ue posted in tl�e ofPice of tlie County Clerk of eacli couiity *** in which the project will be located�nd shall remain posted for a period of 30 days. The notice reqUiredpursuant lo Section 21092 for a negative declaration shall bc so posted for a period of 20 days,unless othcrwise ccquircd by law to be posted for 30 days.Thc County C(erk shall post notices within 24 hors of receipt• 1'ublic Resouree Code 21152 All notices filed pursuant lo this section shall be available foi•public inspection,and sl�all be ' posted*** wlHiin 24 hours of receipt in the office of the Co�mty Clerk. Each notice shall remain posted for a period of 30 days. ***Thereafter,the clerk sl�all return the notice to the local lend agency***within a notAtion of �- thc period it was posted.The local lend agcncy shall rctain tl�e notice foc not lcss than ninc monil�s. Additions or changes by underline; deletions Uy "`*"` � � ��. � �. � � � THIS PAGE INTENTIONALLY LEFT BLANK � � �. «� � � � � � � � � � �� Salem Lutheran Church and School OPA Compromise Specific Plan Response to Comments on the Draft EIR Responses to Comments Letter 2 - County of Orange, Orange County Clerk-Recorder Response to Comment 2-1 This comment acknowledges that the Orange County Clerk-Recorder received, filed, and posted the Notice of Availability for the Draft EIR on February 22, 2012. �: Michael Brandman Associates 3-9 H\Client(PN-JN)�3771\37710001�RTC-FEIIt�37710001 Sec03-00 Responsesdoc � � � � � � � �. � THIS PAGE INTENTIONALLY LEFT BLANK �k � � � � � � � � � LETTER 3 Page 1 of 1 � °• To►n Daly . Oran�;c County Cle►•Ic-ltecordca� ,1 �.J�� •� �1':III�C COUIIfY Cieric-Recoi•der's Of!'ice XZ Ci��ic Cente�•Pls�za,Room 106,P.O. Box 238, Sa�it� An�,CA 92702 �veU;�vw�v.oc.cn.gov/recorder/ I'HONL ('714) t334-5284 FAX(714) 834-2500 , CITY OI�ORANG� ; CNIC CEN'1 LIt 300 L�CI-IAPMAN AVE ORANGE,CA 92666 ; , Uffice of the Oran6e Cowity Clcrk-Recorder nZemornndwn � SUBIF.C"I': NOTTCr Or I:X�MPTION Tlie ntl�ched notice was received, �1I0(�AIICI A CO�Y\y�1S Z)OStCCI OIl 03/02/2012 It rcmnined posted i'or 3U(thirty)dnys. Tan Dnly Orangc Coutity Clcrk-Rccorder In anci for the County oF Orange I3y; PRISCILLA GON"LALGZ Deputy Public Resource Code 21092.3 The notice reqtiired pursu�nt lo Sectio»s 2108U.4 and 21 U92 for an eiivicounieiital iui�a� ct repc>rt 3-1 sl�all be posted in Ihe oflice of the County Clerk of each couuty***in which tlie project�vill Ue locatcd�nd shall rem�iu posted for a period of 30 days.The no(ice required pursuant to Seclion 21092 for a negative declar�ition shall be so posted for a period of 20 days,unless olhenvise required by law to Ue posted for 30 d�vs.The County Clerk shall post notices within 24 hors of receinl• PuUlie Resource Code 21152 /\I1 notices filed puisu�nl to lhis seclion slin(1 be sivailai�le fa�public inspecliou,ancl shall be posted'"** �vithin 24 huurs of receipt in the of'fice ol'llte County Clerk. Each nolice shall reni<�in posted for a period of 30 days. '"**'1'hcrcatler,the clerk shflll rehirn tl�e nolice lo the loc�l lend�gency**'�wiUyin�notation of the period it�vas postcd,The local lc�cl agency shall retain the notice f'or not less th�u ninc W months. Additions or eh<mges by underline;delelions by'�"�* � � � � �: � � �= � � THIS PAGE INTENTIONALLY LEFT BLANK �� 3 Sa/em Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments on the Draft E/R Responses to Comments Letter 3 - County of Orange, Orange County Clerk-Recorder Response to Comment 3-1 This comment acknowledges that Orange County Clerk-Recorder received, filed, and posted a revised and extended Notice of Availability for the Draft EIR on March 2, 2012. Michae/Brandman Associates 3-13 H�.\Client(PN-IN)�3771\37710001�RTGFEIIt�37710001 Sec03-00Responses-doc � � � � � � � �_. � � � � � THIS PAGE INTENTIONALLY LEFT BLANK �` � � � � � � � � � � � LETTER 4 Page 1 of 1 Jess A. Carbn/al,Dlrecfar r , o u n r� c e c o u ra � v 300 N.Flower Slreel • Sante Ana,CA PubllcWorks PO (iox4040 Sanla/1na,CA 92702-4048 Ou� Coniuwnlly. Ou� Coniwlln�cnl. "Celephone: (714)834•2300 Fax: (714)034-5188 NCL 12-001 March 27, 2012 Mr. Robert Garcia,Associate Planner City of Orange 300 East Chapman Avenue Orange,California 92866 SUBJECT: Cliange to Notice of Availability(NOA)for the Draft Environmental Impact Report for tl�e Salem Lutheran Church and School Project(State Clearinghouse No.2011101046)and Extension of Review Period Dear Mr. Garcia: Tiie County of Orange has reviewed the Change to Notice of Availability(NOA)for tl�e Draft Environmental Impact Report for the Salem Lutheran Church and School Project(State Clearinghouse No. 2011105046)and Extension of Revlew Period and offers the following comrnent: Flood Pro�rarns/SAR/Trails: SARP/Trails reviey/ed the subject DEIR and offer the fqlfowing: 1. Install a (heavy) broom-finish concret�e surface(for the crosswallc)where Frank Lane crosses tl�e Orange Park Acres Boulevard Traillandlwhere the proNosed cul-de-sac(off Santiago Canyon 4-1 Road)will cross the Santiago/Villa Park Road Trail.Asphalt (as a trail surface)is not desirable and can become slippery for horses under a variety of conditions including when it is wet or oily.� 2. Insure there is good line-of-sigl�t for cars entering and leaving Frank Lane(off Orange Park Acres Boulevard)and the proposed cul-de-sac(off Santiago Canyon Road)and for trail users who will 4_2 cross those roadways. Should you have any questions please contact leff Didanan at�794) 647-3927. Sincerely, . � I /,f -�� i�� j 1��; Micl�ael E3alsamo Manager, OC Community Development OC Public Worlcs/OC Planning 300 North FlowPr Street Santa Ana, California 92702-4048 Michael_[3alsamo��c��w.oc�ov.coni cc: 1ef(Dickrnan, Flooci/SAR/Trails � �:, � �„ � � � ��. .,. THIS PAGE INTENTIONALLY LEFT BLANK � � � � � � � �. � Salem Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments on the Draft EIR Responses to Comments . Letter 4 - County of Orange, OC Public Works Response to Comment 4-1 This comment recommends the use of a heavy broom-finish concrete surface for the proposed equestrian trail crosswalks located where Frank Lane intersects with Orange Park Acres Boulevard and where the East Santiago Canyon Road entrance crosses East Santiago Canyon Road and Villa Park Road Trail, as the use of asphalt is undesirable and potentially hazardous to equestrian users. Consistent with the "Single Site Access" alternative analyzed in the Draft EIR,there would be no driveway from Santiago Canyon Road; as a result, it would not cross the existing equestrian trail along East Santiago Canyon Road. The existing crossing across the entrance of Frank Lane currently � consists of concrete adjacent to Orange Park Boulevard that is visible in Site Photograph l 0 of Exhibit 4.1-1b ofthe Draft EIR's Section 4.1, Aesthetics. The recommendations regarding the broom finish within the comment will be incorporated as a part of the proposed project. Response to Comment 4-2 This comment recommends that a good line-of-site be established for both automobiles entering and exiting the proposed project at either the East Santiago Canyon Road or Frank Lane entrances, as well as for the equestrian users who must cross these entrances. Consistent with the"Single Site Access" alternative analyzed in the Draft EIR,there would be no driveway from Santiago Canyon Road, and as a result, this comment as it related to the East Santiago Canyon Road driveway is no longer applicable. A review of the project's improvements at the Frank Lane entrance shows that new landscaping would be installed at this driveway. These landscape improvements would be at a height and setback that would not impede line-of-sight for either automobiles or equestrian users. Moreover, staffwill provide a final review of all site plans, including landscaping plans, prior to the issuance of building permits, ensuring that any improvement installed at or adjacent to this entrance would comply with the City's standards and would not constitute a public hazard. Therefore, no further analysis or revision is required. Michae/Brandman Associates 3-17 H�.\Client(PN-1N)13771\37710001U2TGFEQLl37710001 Sec03-OOResponses.doc �� .,. � � � � THIS PAGE INTENTIONALLY LEFT BLANK � � � � �. � �� LETTER 5 ` Page 1 of 2 I{eith and Linda Cunningham 6501 E. Gray Lane Urange, CA 92869 714/G33-9994 March 6, 2012 City of Orange ATTN: Mr. Garci� Pla�u�ing Department 300 r. Chapman Avenue Qrange, CA 92866 Dcar Mr. Garcia: Rcccntly, I received Salem's newest expansion plan proposal provided to us tlu•ough the OPA e-tree email. There are some points thAt need to be addressed. I don't know if you are aware,but Salem and its 8 neigl�bors, are tlie sole owners of Franlc Lane; please refer to the property deeds. Jn 1998, the City falsely t�pproved a stripping plan of Franlc Lane. I brought it to the City's attention in 2007 that Fraiilc Lane 5-1 is A privately owned street, and the City has no authority to appt•ove unilaterally 1ny changes unless it is voted on by the o��mers. Since then, the City and Salem have never re-stripped Fra�ilc Lane or approved any other alterations. Salem's new pians now show them completely taken over Franlc Lane and dictating to its neighbors how it will be used. Salem does not l�ave any legal rights to unilaterally alter l�rank Lane. Frank Lane usage is votcd on by thc homcowners' ��ho own Franlc Lane; a 5-2 private street. How is Salem aUle to ha��e a bigger ent��ancc? Ho�i� is Salem able to use more of Frank l.,ane? How is Salen� allowed to confiscate our priv�►te property? I 5-3 There is NU turnaround at the very end of Frank Lane for iire t��icics and/or emergency vehicles; safety issue. There is an emergency tui•narotind located before the)�owler house, but not at the very end of Frank Lane; safcty issuc. How is any emergency vchicic ablc to turnaround? Their only option will be to back out. Is tl�e City willing to ass�m�e tliis liability??? I'LCASC NOTE: By lativ, "rire Ls�nes" ��re 20ff in widtl�, ar�d for :� des�d-end sh•eel, 5-4 it is muudatory for a 38' tw•nnroimd if tl�c roAd is longcr thau 150ft in length, whicL it is. It is more ti�An 400ft in tengtli. The proposed plan for the end of Frank Lane is not 20fi across and there is aUsolutely NO turnaroi�nd. I cannot believe the City would take on this liability. In addition, I cannot believe the Fire Marshall would approve this. LETTER 5 • Page 2 of 2 We have never approved this plan. Nor have we ever seen a plan. In addition,we have NEVER approved Salem's conversion of the Fowler house(residential)into their preschool(business). No re-zoning has ever been approved. For Salem's hired hands to `� say they were working with the neighbors is not true. We had a few meetings, Christine 5-5 and I, and they asked us what the problems were. They never came back to us with a plan. They never wanted to show us a plan,and they call that"worlcing with the '"�' neighbors," That is not true, Again,we NEVER EVER approved any plan. On a side nota, I also brought to your attention the other day that Salem is out of � compliance on their CUP. They are now allowing 2lanes into their facility off of Orange _ Park Blvd entering onto Frank Lane, and they are still allowing their parents to line up 5-6 early and completely block Franlc Lane and Orange Park Blvd, and still nothing is done. � If Salem's 185 seat church plus its facility is unable to comply with their current CUP from 1998,how does a large version of Salem solve the problem? 5-� � Sincerely, � � �,:, Linda Cunningham � CC: Mayor Cavecche °°'�" City Council; Mr. Bilodeau,Mr.Dumitru, Mr. Whitaker,Mrs. Smith Mr.De Berry,City Attorney "�` Laura Thomas, OPA President �� .�. � � � .. � � Salem Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments on the Draft E/R Responses to Comments _ Letter 5 - Keith and Linda Cunningham Response to Comment 5-1 The comment identifies the ownership of Frank Lane and notes an existing condition. The proposed project includes redesigning Frank Lane to provide access for both the Salem Lutheran Church and School and the residential properties as described in Section 3, Project Description, subsection 3.4.4, Project Characteristics, of the Draft EIR consisting of two closely spaced but separate entrances, one for church and school use, and one for residents only. The 44-foot private drive for Salem Lutheran Church and School will include 2 to 4 travel lanes with adjoining parking(inbound versus outbound usage of the lanes depends on the day and/or time of day). During weekday school drop-off and pick- up periods,two ingress and two egress lanes will be provided. One egress lane will be for right-turns onto Orange Park Boulevard and one egress lane will be for left-hand turns onto Orange Park Boulevard. During Sunday church services, one ingress and one egress lane will be provided. This redesign will correct the re-striping oversight. Response to Comment 5-2 The comment expresses concern regarding the exclusive use of Frank Lane by Salem Lutheran Church and School and determining how the neighbors would use this roadway. The redesign of Frank Lane including the proposed improvements provides for vehicular access for both the Salem Lutheran Church and School and the residential properties and is in direct response to the neighbors' request for a separation. The proposed redesign would not interfere with the rights of the adjacent residential properties because the existing easements will remain unchanged and the residents would continue to be able to use their respective easements. The southerly portion of Frank Lane would be reserved for the exclusive use of the residents and not for the use of the Salem Lutheran Church and School. Moreover,the improvements would be located on the portion of Frank Lane owned by Salem Lutheran Church and School and would provide for a more efficient traffic flow and not � physically restrict access to the residents' portion of Frank Lane from Orange Park Boulevard. Response to Comment 5-3 See Response to Comment 5-2. Response to Comment 5-4 This comment expresses concern that no turnaround is provided at the westernmost terminus of Frank Lane and the width of Frank Lane would not comply with the standards set forth by the City of Orange Fire Code (Chapter 15.32 of the City's Municipal Code)following development of the proposed project. While § 503.2.1, Dimensions, of the City Municipal Code states: Fire apparatus roads shall have a[n] unobstructed width of not less than 20 feet(6096 mm), and shall have an unobstructed vertical clearance of not less than 13 feet 6 Michael8randman Associates 3-21 H-\Client(PN-JN)�3771\37710001UiTGF8IR�37710001 Sec03-00Responses.doc Sa/em Lutheran Church and School OPA Compromise Specific P/an Response to Comments Response to Comments on the Draft E/R inches(4115 mm)",the section continues to provide three exceptions, one of which states, "Divided fire access roads shall be in accordance with Section 503.2.1.2." Section 503.2.1.2, Divided Fire Access Roads, states, "Divided fire access roads shall � be subject to review and approval by the fire code official. Each lane shall be a minimum width of 14 feet. �� Both the northern (project)and southern(residential)portions of the divided Frank Lane would be at �„F minimum 14 feet wide consistent with the City Municipal Code. Additionally, a"hammerhead" turnaround consistent with City of Orange Fire Department standards will be constructed at the � western terminus of Frank Lane to aid in the movement of large vehicles such as fire trucks. As "'" addressed in this Municipal Code §,the City of Orange Fire Chief or their representative would �-n� provide a final review of all site plans, including circulation plans, prior to the issuance of building � permits, ensuring that any circulation improvements conducted as part of the project would comply � with the standards established by the City's Fire Cc�de. Therefore,the project would comply with this element of the City's Fire Code. '"�' � Response to Comment 5-5 � This comment states that rezoning of the portion of the proposed project currently zoned R-1-40 ,� (Single-Family Residential)to SP/P-I(Specific Plan/Public Institutional)has not been approved, and that the public has not approved this rezoning. Note that the proposed project is consistent with the � Orange Park Acres Specific Plan("OPA Plan")and has been operating at a similar capacity in "" accordance with Conditional Use Permit(CUP)2213-98. The Fowler property is not part of CUP � 2213-98 and therefore is made part of the proposed project. ,fi As explained in Section 4.6, Land Use and Planning, page 4.6-1 of the Draft EIR, an application to �'"' rezone the property is being processed as part of the project. The decision to either approve or deny °- the request for property rezoning will ultimately be determined by the City of Orange. As further set ,,,� forth below, however,the proposed zone change is appropriate and necessary because the project site's current zoning is inconsistent with its designation under the OPA Plan. � The project site("Site") is located within Orange Park Acres, an area of the CiTy governed by the . OPA Plan, which the City adopted in 1973. Despite the fact that it is entitled in a"specific plan,"the � OPA Plan is not a specific plan at all, but rather is part of the City's General Plan. Specifically, as clearly set forth in the resolution adopting said plan, it was intended to be"the land use element of the general plan"of the Orange Park Acres area(City of Orange Resolution No. 3915). Accordingly,the ""` Site's zoning is required to be consistent with the OPA Plan (California Government Code § 65860 - ["city zoning ordinances shall be consistent with the general plan")). � The OPA Plan recognized the Site's existing(in 1973)use for church purposes, which it classified as ' a"Public/Quasi-public"use(OPA Plan, pp. 42-43). Furthermore, it designated the entire � 3-22 Michae/Brandman Associates �„ H�.\Client(PN-JN)l37'71\37710001UtTC-FEIR\37710001 Sec03-00 Responseadoc �, Sa/em Lutheran Church and Schoo/OPA Compromise Specific P/an Response to Comments on the Draft E/R Responses to Comments approximately 6 acre Site for such "Public/Quasi-public"use on a going forward basis(see OPA Plan, pp. 113, 121-122). As explained by the OPA Plan,the "Public/Quasi-public" land-use category includes church and school uses, as well as reservoirs and cemeteries(OPA Plan, pp. 117-18; see also pp. 121-122). The City's Code also defines churches to include"church schools"and similar uses (OMC § 17.04.022). Thus,the existing(and proposed)use of the Site as a church and school is precisely that contemplated by the OPA Plan. Nonetheless, despite the fact that the OPA Plan has always designated the Site, including the Fowler property, as "Public/Quasi-public,"a designation that allows churches and schools without a CUP,the Site was previously zoned inconsistently as "residential,"a designation that requires a CUP for church use. The proposed Project would make the zoning consistent with the OPA Plan by rezoning the Site from residential to Specific Plan/Public and Institutional"("SP-PP'). Because churches, including church schools, are permitted without a CUP in the SP-PI zone, it will no longer be necessary for Salem Lutheran Church and School to operate under a CUP once the Site is rezoned. Instead, the use of the Site will be governed by a Specific Plan, which will impose various requirements and restrictions on the design and operation of the church and school, including by incorporating the operational restrictions contained in Salem Lutheran Church and School's current CUP. The purpose of such a specific plan is to implement a general plan by providing more specific reyuirements consistent with such plan. (California Government Code § 65450 ["After the legislative body has adopted a general plan, the planning agency may . . . prepare specific plans for the systematic implementation of the general plan. . ."].) Thus,the proposed Specific Plan would implement the OPA Plan for the Site and effectively replace the CUP as the document governing the use of the Site. Moreover,the use of a specific plan as the governing land use at the Site is consistent with the process used for similar"institutional"uses within the City, including Chapman University and St. John's Lutheran Church and school. Thus,the specific plan process is the appropriate mechanism for requesting approval of the Project. Response to Comment 5-6 The comment pertains to current conditions and not the proposed project;however,the comment is duly noted. Response to Comment 5-7 It will no longer be necessary for Salem Lutheran Church and School to operate under a CUP once � the Site is rezoned. Instead, the use of the site will be governed by a Specific Plan, which will impose various requirements and restrictions on the design and operation of the church and school, including by incorporating the operational restrictions contained in Salem Lutheran Church and School's current CUP. In addition, implementation of recommended mitigation measures from the Draft EIR will provide control. Michael Brandman Associates 3-23 H�.\Client(PN-JN)�3771\37710001�RTGFEIIL�37710001 Sec03-00 Responses.doc � � �, � �.: � �„ .r� � �,. THIS PAGE INTENTIONALLY LEFT BLANK �� LETTER 6 Page 1 of 1 Robert Garcia From: Charles Leftier(charfeslefFlerQymail.comJ Sent: Sunday,March 04,2012 7:36 AM To: Robert Garcia SubJect: SALEM UEIR � The items of concern are TRAFFIC,TRAFFIC,TRAFFIC,followcd by thc PCSs left in the road due to all the idling engines.The PCBs run off into the Creek and Drinking Water in the Bond Pit as well as ovcrflowing s-� to the Pacific.Sure cancer causing PCBs are not being tackled for a few years.No reason to get out ahead of it and do somettu ri t. Next is I�TOISE,traffic noise,achool noise�event no�se.We a ow t ere are ex�s mg ec� e vio a tons and how does that et resalved with the changes and expansionT I 6-2 Following that is PARKIN�C'i.Seriousty,if I am clocked 100 MPH nn w en pu e over , was onfy doing 25 MPH does it Ily?Salem repeatedly violates its parking regulations as documented by the Gray Lane neighbors.Proper parkiag requircd with a tnargin for extreme situations is fair to neighbors and s-3 should be requtred.If one can be exempt from the Law,strike the Law for it is useless and[aequitable. T6e enormity of the new Worship Center is obscene an the site.The smail local Church in the couatry now aims to be the Crystal Cathedra!East? When does tUe first skyscraper go up ia downtown I s-a Orange? Thc Specific Plan for the 61/2 Acres...so do I need a Specific Plan fa•my l 1/4 Acres?The OPA Specific Plan has been over ridden and decimated by the City to be used in whetever light the current d veloper de jour desires.So while I take this with a LARGE Grain of Salt,I am put off by the attempt to tep outside the normal.The OPA Specific Plan was put in place when,as now there was a large disparlty between County/City praperties In the Community.Salem is in the City aad Salem Specific Plan leaves s-5 unanswered questions which I would like addressed.Start with WHAT IS TH�POINT OF IT?How would it allow Sriem to sklrt CIty Regulation,Oversight,F.ntorcemeut or gain undue privilege?Woutd t6e benefits of such a Plan not be extended to all Orange Residents?If the answer to this last question is Yes.thea no Specific Plan is needed.If the answer is No,tden uo Specific Plaa is needed. I have seen changes tn the Salem Plan recently as a member of the OPA It/E Committee thut,while they generate some approval of the new directioa fn Planning leave me wondering why such o moviug s-s target is in process wlth the City. T6aok you, C6arles Leffler 10693 ORANGE PARK BL. ORANGE,CA.92869 i �, � � � � � � � �.. THIS PAGE INTENTIONALLY LEFT BLANK °� .� ��. � � �� :�, � �, � Sa/em Lutheran Church and Schoo/OPA Compromise Specifc P/an Response to Comments on the Draft E/R Responses to Comments Letter 6 - Charles Leffler Response to 6-1 This comment primarily expresses concern that constituents of concern such as polychlorinated biphenyls (PCBs)resulting from the proposed project's traffic would enter a local creek and the drinking water supply in the Bond Pit west of the project site and eventually overflow from this facility into the Pacific Ocean. �� PCBs are primarily associated with industrial applications(i.e., electrical transformers)but were banned by the federal government in ]977. PCBs in automotive applications are limited to brake fluids and tire manufacturing. The addition of the new right turn lane along Orange Park Boulevard would improve circulation both internally and on local roads. Thus,the number of vehicles queuing and idling would decrease compared with the existing condition. The addition of this new turn lane, which would improve traffic flow compared with the existing conditions, would lower the potential for traffic-related water pollution. The project's short-term construction and the long-term operations water quality impacts are addressed in Draft EIR Section 4.5, Hydrology and Water Quality, including impacts associated with the potential for the conveyance of constituents into local stormwater collection infrastructure. As addressed by Draft EIR Section 4.5, Hydrology and Water Quality Impact 4.5-1, short-term construction activities could generate pollutants such as increased silt, ground rubber, oils from automobiles, debris, litter, chemicals, dust, and dissolved solids related to grading, excavation, building construction, and painting. In order to minimize short-term construction related impacts,the project would be required to prepare a Stormwater Pollution Prevention Plan(SWPPP)and deploy a minimum of best management practices(BMPs). The BMPs would be designed according to � accepted industry standards and with guidance from the California Stormwater Best Management Practice Handbook, Construction, 2009 Edition. Per the Draft EIR,with deployment of the BMPs and implementation of the SWPPP under the new reyuirements including the risk assessment, minimum Risk Level requirements, development of a construction site monitoring program, and mandatory site inspections, short-term impacts would be � reduced to less than significant. Additionally,the Draft EIR Section 4.5, Hydrology and Water Quality, also addresses long-term operations water quality impacts. The Draft EIR states that the project would incorporate a range of BMPs, including infiltration galleries, into the design of the facility. As a Priority Project,the project must comply with the Orange County Drainage Area Management Plan (DAMP) and the City of Orange Local Implementation(LIP)requirements. Compliance reyuires the preparation of a Water Quality Management Plan (WQMP)to protect the receiving water bodies within the City. A Preliminary WQMP(Appendix F.2,Preliminary Water Quality Management Plan:November 11, Michael Brandman Associates 3-27 H1Client(PN-IN)�3771\37710001UtTGFEIR�37710001 Sec03-OOResponses-doc Salem Lutheran Church and School OPA Compromise Specific Plan Response to Comments Response to Comments on the Draft E/R 2011, of the Draft EIR) was prepared for the project in conformance with the City's LIP and Countywide DAMP and a Final WQMP will be prepared prior to issuance of final development permits. The Final WQMP will include measures that the project would incorporate to contain surface runoff, and any pollutants potentially conveyed within runoff,to the project site. Based on the existing condition, which includes no BMPs for water quality,the project conditions with the deployment of BMPs would represent a significant improvement over the existing condition. Based on the reliance on infiltration BMPs, which provide the highest quality of treatment,the project � would not violate water yualiTy standards. � Response to Comment 6-2 This comment expresses concern that the existing use does not comply with noise standards set forth � by the City of Orange, and that the proposed project does not reduce those impacts. In part,this comment references the existence of an existing issue, not an issue that would be caused or worsened by the proposed project. Noise impacts are addressed in Section, 4.7,Noise, of the Draft EIR. Draft � EIR Section 4.7,Noise, Table 4.7-3, Existing Noise Levels at Nearby Sensitive Receptors, provides � the existing noise levels at adjacent properties near the project site (Section 4.7,Noise, Exhibit 4J-1 � on page 4.7-5) and identifies those sensitive receptors (residences)that exceed the CiTy's noise �� standards. Existing noise levels at these nearby receptors,representing existing conditions, can be attributed to numerous unique elements, including, but not limited to,traffic on local roadways, ""� neighboring residential activity,the existing use on the project site, rooftop mechanical equipment, ��-�-A aircraft overflights, mature tree attenuation,and natural ambient(i.e., background)noise. � The Draft EIR addresses the potential to exceed the City's noise standards and determined that with ��`�� incorporation of Mitigation Measure NOI-1 (Draft EIR Section 4.7,Noise) during the demolition ,� phase of the construction activities,temporary exceedance of noise level thresholds established by ,,,. City would be avoided. Mitigation Measure NOI-1 involves the installation of a temporary sound wall prior to demolition activities, specifically stating: � Prior to the initiation of demolition activities a minimum 8-foot high temporary � sound wall shall be constructed along the north side of Frank Lane from the existing classrooms to the existing parking lot with the play court overlays. The sound wall shall have a minimum STC 12 rating, which is equivalent to '/z"plywood and the '� sound wall shall be maintained through the completion of grading activities. �.; Long-term noise impacts associated with operations of the project were found to be less than significant and were addressed in the Initial Study (Appendix A,Notice of Preparation, Initial Study, and Comment Letters, of the Draft EIR) prepared for the project prior to the Draft EIR. The Initial � Study concluded that the operations phase of the proposed project would not result in noise increases � over the existing conditions since the proposed land use would be the same as the existing land use, � 3-28 Michae/Brandman Associates �, H.\Client(PN-JN)13771\37710001�RTC-FEIR\37710001 Sec03-00 Responses.doc ° Salem Lutheran Church and Schoo/OPA Compromise Specific P/an Response to Comments on the Draft EIR Responses to Comments „„ with similar traffic conditions and onsite activities. Additionally,the Noise Impact Analysis prepared for the proposed project(Appendix G,Noise Impact Analysis, of the Draft EIR) examined long-term, operations-related noise and determined the noise impacts would be less than significant in regards to onsite operational noise. The Noise Impact Analysis analyzed potential noise generated by the proposed parking lots,the playground,the sanctuary, and the fellowship reception area, determining that noise produced at any of these locations would not exceed the City of Orange noise standards. Response to Comment 6-3 This comment expresses concern over the proposed circulation and parking plan. A Traffic Impact Analysis and Parking Demand Analysis Addendum (TIA Addendum) (Appendix A)was prepared for the OPA Compromise Plan to address the potential traffic and parking impacts associated with the proposed project as described in the Specific Plan compared with the 712-seat sanctuary scenario analyzed in the City-approved Traffic Impact and Parking Demand Analysis Report dated August 20, 2010. As evaluated in the TIA Addendum,the Santiago Canyon Road access has been eliminated, which has been addressed as a Project Alternative in the DEIR; an exclusive southbound right turn lane on Orange Park Boulevard at Frank Lane has been added; and the updated parking supply consists of approximately 186 surface parking spaces plus 105 overflow parking spaces for a total of approximately 291 parking spaces. Based on the TIA Addendum for the proposed project, no traffic impacts will be created and adequate parking will be provided consistent with the City-approved Traffic Impact and Parking Demand Analysis Report. As part of the proposed project, Salem Lutheran Church and School has agreed to implement a number of traffic and transportation-related modifications to the project as outlined in the Orange Park Association Letter of Support dated/executed June 5, 20l 4. Response to Comment 6-4 This comment expresses concern over the size of the proposed project's Worship Center. Refer to Section 4.1, Aesthetics, ofthe Draft EIR that discusses the Aesthetics topical environmental issue, and Section 6.0 of the Salem Lutheran Church and School OPA Compromise Specific Plan, which discusses design guidelines. Response to Comment 6-5 This comment raises questions regarding the need for the proposed specific plan. The comment seems to suggest that the site is too small for a specific plan. Pursuant to California Government Code § 65450 et seq.,the City is authorized to prepare a specific plan for any part of the area covered by its General Plan. There is no minimum acreage required in order to process a specific plan. The project site("Site") is located within Orange Park Acres, an area of the City governed by the OPA Plan, a document that serves as "the land use element of the general plan"for the Orange Park Acres (see City of Orange Resolution No. 3915). Accordingly,the Site's zoning is required to be Michae/Brandman Associates 3-29 H:\Client(PN-JN)�3771�37710001UtTGFEIRU7710001 Sec03-00 Responses.doc Salem Lutheran Church and School OPA Compromise Specific Plan Response to Comments Response to Comments on the Draft E/R consistent with the OPA Plan. (California Government Code §) 65860 ["city zoning ordinances shall be consistent with the general plan"].) Nonetheless, despite the fact that the OPA Plan has always designated the Site, including the Fowler property, as"Public/Quasi-public,"a designation that allows churches and schools without a CUP,the Site is zoned as "residential,"a designation that requires a CUP for church use. Should the City approve the proposed zone change, a CUP will no longer be � necessary for a church and church school use on the site. Instead,the use of the Site will be governed .. by a Specific Plan, which will impose various requirements and restrictions on the design and ,�« operation of the church and school, including by incorporating the operational restrictions contained in Salem Lutheran Church and School's current CtJP. The purpose of such a specific plan is to implement a general plan by providing more specific requirements consistent with such plan °'� (California Government Code § 65450 ["After the legislative body has adopted a general plan,the �-_. planning agency may . . . prepare specific plans for the systematic implementation of the general � plan."]). Moreover,the use of a specific plan as the governing land use at the Site is consistent with the � process used for similar"institutional"uses within the City, including Chapman University and St. �,; John's Lutheran Church and school. Thus,the specific plan process is the appropriate mechanism for requesting approval of the Project. `� �: Response to Comment 6-6 � This comment expresses concern regarding the commenter's opinion that the project is a"moving target." To the contrary, as noted in §) 15002(j) of the State CEQA Guidelines, CEQA encourages �. the public process: Public Involvement. Under CEQA, an agency must solicit and respond to comments � from the public and other agencies concerned with the project. � The public, including members of the Orange Park Association Board, has been engaged in this project through the distribution of public notices and community meetings. Moreover,the proposed project is the only proposal being reviewed at this time. The Draft EIR, Salem Lutheran Church and -*� School OPA Compromise Specific Plan and this Response to Comments document are all available for review at the City of Orange Community Development Department, Planning Division. � � � � 3-30 Michae/Brandman Associates H�\Client(PN-IN)\3771\37710001�RTGFEIIL\37710001 Sec03-00 Responses.doc � LETTER 7 ,�; Page 1 of 2 � '. �/�� ;` 1.�.l._id � � �,�+ ^��t� f-• ,`�'' • ". � � � � f �G��"�VE� � ','..,� �._�. APR 2 3 2012 � � -� �v� ' �`�, ` , � `,� � i�r�� - _//��i�ir. �' ..�`� � ' 714.264.4242, 714.744.5255Fax � ��''=%'��t�-, ., ' s l,aura��lauratho�7�as.co�n � . . 7211 C. Clydesdale Ave. Orange Pa�•k Acres, Ca. 928G9 April 23, 2012 City of Urange Community Development Department, Planning Division 300 L. Cllapman Ave. Orange, Ca. 92866 Attention: Ivi��. Robert Garcia,Assaciate Planner R�: Di•aft Envii•onmental lmpact Kepoi-t DE1R No. 1827 - 1 l Dcar Mr. Garcia, Salem ti•affic, safety, and noise has long impacted the convnunity. The nature of this com.munity embraces the equestrian and i-ural ainbiAnce, much diffe�•ent � � that othcr Orangc ncighborhoacis where churchlschools, such as Salem currently exist, `� who may seelc exJ�ansion. 1Ceeping in mind that primary clifference, it is impoi�tant to view the impacts with a perspective that results in compatibi(ity. � Traffic 7-2 • Safety • Pacicing • Noise � Salem opet•ates undel• a C'LIP with residential zoning. lt should remain the same. This is a residential community witl�in the Orange Parlc Acres Specific Plan. 7'he CUP should 7_3 maximize its ca}��city. The purpose of a co�iditiot�al use pei'lillf IS fOC IlOflCO11fOI•tnitig use:. LETTER 7 � Page 2 of 2 Page 2. �" Salem must come to grip with the size of its land envelope. T 7"3 CONT'"" Traffic currently impacts the community. Frank Lane, Orange Park Blvd. and Sa.ntiago Canyon Rd. This issue has not been resolved in the past and escalate with 7_4 '�" expansion. These vehicles are not contained on the footprint of area Salem but, on public and residential streets. � Aesthetics: The conceptual plan i•eviewed by the Design Review Committee seemed to be 7_5 confusing as to what exactly Salem is proposing. ,� Refer to the minutes of March 7, 2012 DRC meeting: 25 Pages of minutes were devoted � solely to the Salem project. � lt appears the goal is to only achieve a"specific plan" on a site that is already established � and outgrown its space. The notion of a specific plan would suggest free rein tn build 7_6 � without responsibility to be within guidelines and compatibility with the Orange Park Acres Specific Plan. Not to say confusing to those responsible to give future approvals. �` � The impacted Frank and Gray Lane neighbors have spent numerous hours to find a . positive solution. Tts known as the Resident's Plan. This alternate plan addresses: � � Tra�c - a tra�c flow alleviating public and residential streets �_� �� • Safety - equestriai�trail; safety element within Salem traffic circulation � • Parking - appropriate amount of permanent parking • Noise - quieting thru landscaping �"�` � I would ask the Planning Commission review and consider the positives that could led to , compatibility in Orange Park Acres. � Since•ely, M�� . � �� aura Thomas Resident °�' � � Salem Lutheran Church and Schoo/OPA Compromise Specific P/an Response to Comments on the Draft EIR Responses to Comments � Letter 7 - Laura Thomas Response to Comment 7-1 � This comment does not specifically address the proposed project, but is duly noted. Response to Comment 7-2 This comment expresses the commenter's belief that it is important to review potential traffic, parking, safety,and noise impacts when analyzing compatibility. The Draft EIR analyzes each of these topics in Draft EIR Section 4.4, Hazards and Hazardous Materials; Section 4.7,Noise; and Section 4.8,Transportation and Traffic. Response to Comment 7-3 This comment expresses the commenter's opinion that Salem Lutheran Church and School should continue to operate under a CUP with Residential zoning. As addressed in Response to Comment 5- 5, the project site("Site")is located within Orange Park Acres, an area of the City governed by the OPA Plan, a document that serves as "the land use element of the general plan"for the Orange Park `� Acres (see City of Orange Resolution No. 39]5). Accordingly,the Site's zoning is required to be ° consistent with the OPA Plan(California Government Code § 65860 ["city zoning ordinances shall be consistent with the general plan"].) Nonetheless, despite the fact that the OPA Plan has always designated the Site, including the Fowler property, as "Public/Quasi-public," a designation that allows churches and schools without a CUP,the Site is zoned as "residential,"a designation that requires a CUP for church use. The proposed Project would rezone the Site from residential to Specific ��`� Plan/Public and InstitutionaP'("SP-PP'). Because churches, including church schools, are permitted without a CUP in the SP-PI zone, it will no longer be necessary for Salem Lutheran Church and School to operate under a CUP once the Site is rezoned. Instead,the use of the Site will be governed by a Specific Plan, which will impose various requirements and restrictions on the design and operation of the church and school, including by incorporating the operational restrictions contained " in Salem Lutheran Church and School's current CUP. The purpose of such a specific plan is to implement a general plan by providing more specific requirements consistent with such plan. (California Government Code § 65450 ["After the legislative body has adopted a general plan,the planning agency may . . . prepare specific plans for the systematic implementation of the general plan. . ."].) Thus,the proposed Specific Plan would implement the OPA Plan for the Site and effectively � replace the CUP as the document governing the use of the Site should it be adopted. Moreover,the use of a specific plan as the governing land use at the Site is consistent with the process used for similar"institutionaP'uses within the City, including Chapman University and St. John's Lutheran Church and school. Thus,the specific plan process is the appropriate mechanism for requesting approval of the Project. Michae/Brandman Associates 3-33 H�.\Client(PN-1N)U771\37710001�RTGFEIR�37710001 Sec03-OOResponses.doc Sa/em Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments Response to Comments on the Draft EIR Response to Comment 7-4 This comment expresses concern over project-related traffic potentially impacting the local = circulation network. A TIA Addendum (Appendix A)was prepared for the OPA Compromise Plan to address the potential traffic and parking impacts associated with the proposed project as described in the Specific Plan compared with the 712-seat sanctuary scenario analyzed in the City-approved Traffic Impact and Parking Demand Analysis Report dated August 20, 2010. Based on the TIA Addendum for the proposed project, no traffic impacts will be created and adeyuate parking will be °�` provided consistent with the City-approved Traffic Impact and Parking Demand Analysis Report. As part of the proposed project, Salem Lutheran Church and School has agreed to implement a number ,�, of traffic and transportation-related modifications to the project as outlined in the Orange Park Association Letter of Support dated/executed June 5, 2014. �.. Response to Comment 7-5 This comment pertains to the City of Orange Design Review Committee (DRC) review of the .� proposed project on March 7, 2012. Section 3, Project Description, subsection 3.6, Reyuired Public ,, Agency Approvals and Requested Entitlements, of the Draft EIR identifies required public agency � approvals and required entitlements, which includes approval of DRC Case No. 4538-11. The Design Review Committee met on March 7, 2012 and recommended the item be continued for discussion at a future DRC meeting. The DRC continued the discussion at the April 18, 2012 meeting and •� unanimously recommended approval of Case No. 4538-11 to the Planning Commission. This action is consistent with the required approval identified in the Draft EIR. Draft EIR Section 4.1, .,� Aesthetics, includes a discussion related to light and glare and retention of existing trees and new trees. This analysis included parking lot lighting, security lighting, and temporary lighting of the ' multipurpose field. � Response to Comment 7-6 � This comment expresses concern that the proposed Specific Plan will not require consistency with the OPA Plan. As more fully addressed in Responses to Comment 5-5 and 7-3,the purpose of the �� proposed Specific Plan is to implement the OPA Plan, and thus will require that the design and '"" operation of the Site is consistent with the OPA Plan. In addition,the Specific Plan will incorparate the operational restrictions contained in Salem Lutheran Church and School's current CUP. Thus, the „�, proposed project is consistent with the OPA Plan and the City of Orange General Plan. Section 7 of the Salem Lutheran Church and School OPA Compromise Specific Plan provides development standards and regulations, landscaping standards, and a parking management plan. Section 8 contains � the procedures for administration of the Specific Pl��n and estimated phasing for the development. ` " Implementation of the Specific Plan will be carried out by site plan reviews. Compliance with the .�; mandatory provisions of Sections 7 and 8 of the Specific Plan eliminates confusion regarding future �.,, approvals. .� �: 3-34 Michae/Brandman Associates H�.\Client(PN-IN)\3771\37710001�RTC-FE[It\37710001 Sec03-00 Responses.doc � � Sa/em Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments on the Draft EIR Responses to Comments Response to Comment 7-7 The comment does not pertain to the proposed project;however,the comment is duly noted. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document for an evaluation of the Grayson Traffic Plan. Michael Brandman Associates 3-35 H:\Client(PN-JN)�3771\37710001V2TGFE[R�37710001 Sec03-OOResponses.doc � � �; � � � �;.;, � THIS PAGE INTENTIONALLY LEFT BLANK � .� � � �. � � � � � �: � � � � LETTER 8 . Page 1 of 2 `�" Robert Garcia From: Christine Rosenow[rosemom(�sbcglobal.netJ Sent: Monday,April 23,2012 1:50 PM To: Robert Garcia Subject: Salem DEIR Mr.Garcia, , I am greatly concerned about Salem Lutheran Church and Schools pla�as submftted to the City. I am against the pian as g_� a whole. Traffic is a huge issue that directly affects the nearby residents and community. The convergence of traffic produced at Frank due to Salem's buslness use block residents from getting to and from their homes. Other sites have a lane you can 8_2 go around their stand still traffic but not Salem. O�ange Park Bivd is routinely block and causes frustration and a dangerous situatlon for all. I myself own a 10 by 150 foot portion on Frank Lane which i am responsible to maintain. It is not fair to a home owner to piace the burden of mainCaining a piece of road that a business uses to excess. The previous City Council errored In including this lane in the 1998 plan. Retired traffic engineer 7am Mahood informed us that Salem isn't even supposed to be using Frank Lane but in fact have their own separate driveway. Due to errors, oversights and mislnformation, 8-3 Salem has created a problem that needs to be fixed before an accident happens. In 2005 a vote was taken asking Salem not to use the residential 20 feet, Not only have they ignored this request they have continued to maintain and fix their driveway while letting the residential side fail into disrepair from their continued misuse. I adamantly protest the prop�sed use of the playfield as any type of parking lot. This is excessive use and shows that the s(te has a shortage of safe,lighted and stripped parking. What other church/school uses their grass field where children play as a parking lot on a regular basis. By Salem's own count of 2.28 people per car,once the proposed church is at 8-4 579b capacity they wfll have to use the grass as parking. Not only is this unsightly but not safe. As of the last two sound studies,Salem is out of compfiance with their noise levels for their school. This should be rectified before the schoot/church is allowed to move forward. I am forced to hear screaming children In excess of what Salem reported to their sound engineers play behind my home. lust last week Salem had a wedding and besides the 8-5 guest sounds we had to hear for 10 minutes the honking of hours announcing the bridal couple. The proposed size of the church Is far too great for the size. Safem lacks the congregation to support it but also the land. Even if you add the Fowler home,parking is an issues as is the amount of people that come to the site, The site 8-6 isn't really that big and their overuse is taxing to all. I am against he conversion of a home into a preschool and the addition of the 1 acre prope�ty as part of the church/school. Home owners were never informed that the church/school still had a claim in the property and neighbors bu(Id homes and lives knowing this was a residential lane and not a business. Furthermore, Increasing the �� preschool from the current 3,000 feet to the proposed 6000 feet(which Craig Olsen promised they were not going to 8-� do)opens the school to the potential of increasing enroliment which would further harm the community. I think that the exit/entry point off of Santfago is a necessary and important step but would caution that It fs a soluti�n that needs to go a step further. 1 believe a well rounded solution is to make Salem's Driveway which parallels Frank lane an entrance only. This would solve the huge cross traffic congestion problem on Frank and OP Blvd and would allow $-$ nelghbors to exit Frank Lane safely. Salem and the City made some major missieps in allowing Salem to grow to the size that it is. The hardship that the school/church places upon residence should be mitigated effectively with competent fixes that lets Salem and the 8-9 i LETTER 8 Page 2 of 2 community co-exist in relative peace. This new plan will make the current bad sltuation horr(ble and has a direct impact /�8_9 on our home values. � coN� Christine Rosenow 6523 E Gray Lane � � � �, � �_ � � s�n �. � �� w � 2 � � Sa/em Lutheran Church and Schoo/OPA Compromise Specific P/an Response to Comments on the Draft E/R Responses to Comments Letter 8 - Christine Rosenow Response to Comment 8-1 This comment is duly noted and will be forwarded to the decision-making bodies. Response to Comment 8-2 This comment expresses concern over project-related traffic potentially impacting the local circulation network. A TIA Addendum (Appendix A) was prepared for the OPA Compromise Plan to address the potential traffic and parking impacts associated with the proposed project as described in the Specific Plan compared with the 7]2-seat sanctuary scenario analyzed in the City-approved Traffic Impact and Parking Demand Analysis Report dated August 20, 2010. Based on the TIA Addendum for the proposed project, no traffic impacts will be created and adequate parking will be provided consistent with the City-approved Traffic Impact and Parking Demand Analysis Report. As part of the proposed project, Salem Lutheran Church and School has agreed to implement a number of traffic and transportation-related modifications to the project as outlined in the Orange Park Association Letter of Support dated/executed June 5, 2014. Additionally,the proposed project redesign of Frank Lane involves two closely spaced but separate entrances, one for use by the project and one dedicated for residential use only. As illustrated in Draft EIR Section 4.8, Transportation and Traffic, Exhibit 4.8-2, Weekday School Circulation Plan (page 4.8-11), and Draft EIR Exhibit 4.8-3, Sunday Church Circulation Plan(page 4.8-13), residential ingress and egress along the southern dedicated portion of Frank Lane would be able to proceed safely and efficiently following development of the project. Response to Comment 8-3 This comment expresses concern over project-related traffic potentially impacting residential access along Frank Lane. As addressed in Response to Comment 8-2,the proposed project redesign of Frank Lane involves two closely spaced but separate entrances, one for use by the project and one dedicated for residential use only. Residential ingress and egress along the southern dedicated portion of Frank Lane would be able to proceed safely and efficiently following development of the project. Rights to use Frank Lane for ingress and egress purposes are governed by a series of recorded ,� easements. Specifically,the southernmost 20 feet of the eastern 470 feet of Salem Lutheran Church and School's property is burdened by roadway easements held by certain of its neighbors, as is the southernmost ]0 feet of the more western portion of the property. Conversely, Salem Lutheran " Church and School's property is benefited by roadway easements in the northern 10 to 16 feet of its neighbors' property. The project will not change the existing easements, but as addressed in Response to Comment 8-2,the proposed project redesign of Frank Lane involves two closely spaced but separate entrances, one for use by the project and one dedicated for residential use only. Michae/Brandman Associates 3-39 H-\Client(PN-JN)�3771�37710001UtTGFEIIt�i7710001 Sec03-OOResponses.doc Salem Lutheran Church and School OPA Compromise Specific Plan Response to Comments Response to Comments on the Draft E/R Residential ingress and egress along the southern dedicated portion of Frank Lane would be able to proceed safely and efficiently following development of the project. Response to Comment 8-4 This comment expresses concern over the proposed secondary use of the proposed multipurpose field " as a temporary overflow parking lot during highly-attended events. Accarding to § l 734.050, Parking Plan Reyuired, of the City of Orange Zoning Ordinance: ,�, A plan of all proposed parking facilities shall be approved prior to construction by the Community Development Deparhnent. The plan shall clearly indicate the �M proposed development, including a summary of required parking, location, size, shape, design, curb cuts, curbs, lighting, landscaping, signs, and other features of the proposed parking facility. � This Parking Plan would generally consist of overflow parking on the multipurpose field on the �"" eastern portion of the project site, which would add 105 parking spaces, for a total parking supply of .F. 291 spaces. The need for overflow parking is anticipated based upon recent past attendance records � of events, including holiday church services (Easter, Christmas, etc.), school graduations, special school-related events and services (e.g., opening school year church service, Christmas programs, �� grandparents day),and funerals and weddings. Overflow parking on the multipurpose field would be "'�"� set up prior to the event and is anticipated to fulfill the parking need. �. Additionally,the comment expresses concern over potential contaminants left behind from vehicles � parking on the multipurpose field/overflow parking lot. As addressed in Draft EIR Section 4.4, '�"` Hazards and Hazardous Materials: „�„ The use of the multipurpose field for overflow parking of motor vehicles on an intermittent basis would pose an insignificant risk to recreational users of the field. "�"` The minor amounts of fluids from vehicles that may infiltrate into the grass surface - would not be a hazard for users the following day. In addition,the frequent mowing ,,� and removal of clippings would reduce any long-term build-up of pollutants on the surface. In the event of a major leak or spill, special clean up measures would be required.' W`w Per§ 17.34.140, Maintenance and Operation of Temporary Parking Areas, of the City's Zoning ,� Ordinance,temporary parking lots are a permitted use pending approval of a site plan, and shall be evaluated based on numerous criteria, including defnition,time limits on use, site plan submission, and specific development standards. As such, a site plan would be prepared that would show '�� Fuscoe Engineering,December 20,2012. 3-40 Michael Brandman Associates H�.\Client(PN-JN)�3771\37710001�RTC-FEDi\37710001 Sec03-00 Responses-doc � Salem Lutheran Church and School OPA Compromise Specific Plan Response to Comments on the Draft EIR Responses to Comments consistency with the aforementioned criteria. The Parking Management Plan will allow the multipurpose field to be used without requesting City approval each time. Response to Comment 8-5 This comment expresses concern over project-related operations noise potentially impacting neighboring residences. As addressed in Response to Comment 6-2, long-term noise impacts associated with operations of the project were found to be less than significant and were addressed in the Initial Study (Appendix A,Notice of Preparation,Initial Study, and Comment Letters, of the Draft EIR)prepared for the project prior to the Draft EIR. The Initial Study concluded that the operations phase of the proposed project would not result in noise increases over the existing conditions since the proposed land use would be the same as the existing land use, with similar traffic conditions and onsite activities. Additionally,the Noise Impact Analysis prepared for the proposed project (Appendix G,Noise Impact Analysis, of the Draft EIR) examined long-term, operations-related noise and determined the noise impacts would be less than significant in regards to onsite operational noise. The Noise Impact Analysis analyzed potential noise generated by the proposed parking lots,the playground,the sanctuary, and the fellowship reception area, determining that noise produced at any of these locations would not exceed the City of Orange noise standards. Response to Comment 8-6 This comment expresses concern over the size of the proposed project's Worship Center. Please note that the proposed project is consistent with the OPA Plan and has been operating at a similar capacity in accordance with CUP 2213-98. In addition, a study conducted to determine the visibility of the proposed Worship Center from neighboring properties demonstrates that the proposed Worship Center will be barely visible(depending upon the specific location) from neighboring residences (see Exhibits 3-4 through 3-12 in Section 4, The Grayson Traffic Plan, of this document). Section 7 of the Salem Lutheran Church and School OPA Compromise Specific Plan provides development standards and regulations, landscaping standards, and a parking management plan. Section 8 contains the �� procedures for administration of the Specific Plan and estimated phasing for the development. Implementation of the Specific Plan will be carried out by site plan reviews. Compliance with the mandatory provisions of Sections 7 and 8 of the Specific Plan eliminates confusion regarding future approvals. � Response to Comment 8-7 This comment expresses concern over the proposed conversion of the Fowler House into the °� proposed preschool facility. The Fowler House will be removed and replaced with a new parking area. An approximately 7,505-square-foot(sq ft) preschool building and associated 7,921 sq ft play area will be built adjacent to the western portion of the existing Classroom Building B. Similar to the remainder of the project site, and as more fully addressed in Response to Comment 5-5,the OPA Plan designates the property where the Fowler House is located as Public/Quasi-Public, a designation that Michael Brandman Associates 3-41 H-.\Client(PN-JN)\3771\3"7710001ViTC-FEIIL�37710001 Sec03-OOResponses.doc Sa/em Lutheran Church and School OPA Compromise Specific Plan Response to Comments Response to Comments on the DraR E/R the allows churches and schools as a matter of right. The proposed project, including the use of the Fowler property as a parking area, is thus consistent with the OPA Plan. The proposed relocation of the preschool as part of the OPA Compromise Plan will not affect the capacity as evaluated in the � Draft EIR and will not impact the overall enrollment cap as identified in the existing CUP. While the project will provide additional room for the preschool, no significant increase in preschool enrollment is anticipated or permitted as part of the proposed project. To the contrary, only a slight increase in the preschool occupancy cap, from 101 to 105 students, is proposed (see Specific Plan, p. � 4-13, Table 4.3). Moreover,the proposed project would not allow Salem Lutheran Church and School to increase overall student enrollment, as the Specific Plan contains the same limits on � maximum student enrollment and maximum number of students on campus at one time(726 and 611, respectively)as the current CUP(see Specific Plan., p. 4-14, Table 4.3). Those limits are also included in a restrictive covenant previously recorded against the property, which will be unaffected � by the proposed project. Thus,the proposed project would have no effect on overall student enrollment levels and no more than a nominal effect on preschool enrollment. �. Response to Comment 8-8 A� � This comment expresses concern over project-related traffic potentially impacting residential access � along Frank Lane. As addressed in Response to Comment 8-3 with the proposed project's planned improvements, residential ingress and egress along the southern dedicated portion of Frank Lane '"" would be able to proceed safely and efficiently following development of the project. ��' Response to Comment 8-9 �" � This comment does not specifically address the proposed project, but is duly noted. � �� . � � � � 3-42 Michae/Brandman Associates H.\Client(PN-IN)�3771\37710001�RTC-FEllt\37710001 Sec03-00 Responses.doc LETTER 9 Page 1 of 5 �� !t � �\ ��, li.^ �� ,� �'� _ ��c�ivEo �-�`�, �� APR 2 3 2012 �,� �^ � � � �` . ORANGF.PARI( ASSOCIATION ' 'll `';: PO fiOX 2293 '�'�'�� ,�,� `,-� OIiANCI„CA 9285) �• �' April 23, 2012 City of Orange Community Development Department, Planning Division 300 East Chapman Avenue Orange,California 92866 Attention: Mr. Robert Garcia,Associate Planner Response to Draft Environmentai Impact Report DEIR No. 1827-11 Dear Mr.Garcia: Thank you for the opportunity to present comments on an important change that is about to take place in Orange Park Acres. The change represents another threat to erode the OPA community's equestrian and rural lifestyle. 9-1 Tlie Orange Park Association is a SO year old non-profit corporatian that supports and protects the rural lifestyle in Orange Park Acres,an 84 year old community. After a long review af the DEIR by memb�rs of the Association's Board, its Rea) Estate Committee, its Traffic Committee, and conversations with its membership and affected residents and neigl�bors, the Association's Board believes that 1) The current state of the proposed project is confused and needs profound clarification; I 9-2 ,.m 2) A Salem Lutheran Specific Plan is unneeded, unwarranted and hostile to the 1973 Orange Park Acres I 9-3 :� Specific Plan; 3) A zoning change on the 6 acre property from R-140 to SP-PI, as requested by tiie Salem Specific Plan, creates an imbalance between the ideals of the Orange Park Acres S�ecific Plan, the immediate 9-4 ,� neighborhood and the long range intents of the church's management; 4) Anything other than a small community based church is better placed elsewhere; I 9-5 Page 1 of 5 LETTER 9 rz Page 2 of 5 Mr.Robert Garcta,Assoclate Pianner Response to Draft Environmental Impact Report DEIR No.1827-11 Dated April 23,2012 5) 7he current traffic situation in the vicinity of Orange Park Boulevard, Frank Street and Santiago Canyon I g_6 � Road ls unsafe,unsustalnable,untenable and wili increase if the project is approved; 6) Sound levels are currentiy at unacceptable leveis and need to be rectified; I 9-� .,� 7) A zone change for the Fawler property is contrary to the history of the property and the Orange Park Acres Specific Plan, I 9-$ 8) The designs in Yhe DEIR fail to understand and conflict with the equestrian and rural nature of Orange °°�° ParkAcres,and; I 9�9 9) The design in the DEIR does not remedy the serious and unsafe drainage that causes extreme water I g-10 runoff to the neighboring properties. ""� In suppore of our conclusfons,the Orange Park Association Board offers the following comments and facts. � The Orange Park Acres Specific Plan was developed in 1973 and has served the community �� well for almost 40 years. In 2011,the Orange City Councii and its staff began dismantling the � Specific Plan,diminishing its value. Now,Salem lutheran Is requesting a Specific Plan for its 6 acre property.JMI Real Estate is requesting its own Specific Plan for a 38 acre portion of g_�� `�' the Sully Milier property that is in Orange Park Acres. How valuable is a Specific Pian that is � modified at every instance7 How small a property can have a Specific Plan? Awarding the church its own Specffic Plan sets a precedent for future actions in the communiry. These � requests are contradictory to the Orange Park Acres Speciflc Pian, creating confusion of .� which pian has superseding authority. �, The DEIR trumpets how weN the proposal meets the standards set forth in the OPA Specific �" Plan. 7hat being the case, it's hard to understand why the property needs its own Speclfic 9-12 ,�,, Pian. It is a little too late to enact a Salem Specific Plan that should create cohesiveness when the site has been built out with mismatched architecture and materials. "" It's not clear at this time what benefits accrue to the church and tts congregation if the property ls rezoned to SP-PI (Speciflc Plan/Pubi(c and Institutionai). It has not been 9-13 � explained what the �e-zoning means and what it aliows. Does the re-zoning increase the � value of the land7 Does it provide for a stepping stone to commercial development7 � The DEIR proposes a significant increase in the size of the church's congregation. It's not at `" ail clear how the additional congregation wiil be attracted, when the increase wiil be ,�, achieved or where they will come from. If the increase comes from East Orange, the g_14 increase in traffic on Santiago Canyon Road Is a cause for concern.There are currentiy eight (8)new churches beginning in the City. What will Salem Lutheran's leadership do to attrect � � Page 2 of 5 LETTER 9 Page 3 of 5 Mr.Robert Garcia,Associate Planner Response to Draft Envl�onmental Impact Report DEIR No.1827-11 Dated Apr1123,2012 new congregants? It's not known. It's not known why the proposed size of the new sanctuary is what it is or how long it will take to fili the seats. Without question,these risks g_14 are burdens on the church's leadership and congregation. However, the community should CONT have an understanding of what the church's leadership is planning; the community cannot help but be affected. Currently,both the church and school are wetl below capacity and yet there are parking and traftic issues with the low attendance. With the proposed size of the sanctuary, current 9-15 issues will be compounded well beyond what the community and Salem can handle. The equestrian tifestyle defines Orange Park Acres. The proposed entrance on Santiago Canyon Road accompiishes several things,yet fails to alter the traffic congestion in the area. The proposal removes trail fencing on Santiago Canyon Road and replaces it with a driveway onto the property. The tratl fencing is there for the protection of horse and rider. 12,000 9-16 cars per day pass the property at 55 miles per hours. Removing trail fencing paralleling Santiago Canyon Road creates an unsafe, unwanted and unneeded condition. No other safe trail was offered in the DEIR. It's likely that east bound arrivals wiil enter on Santiago Canyon Road if the queue for that lane is short. if the queue fs long, most arrivals will end run the queue and turn right onto Orange Park Boulevard, as happens today. IYs unlikely that anyone will be able to exit on Santiago Canyon Road into other than the right turn lane. So, most eastbound arrivals will 9-�� exit north on Orange Park Boufevard and turn west onto Santiago Canyon Road. In essence, this does littie to improve the traffic situation, and makes it worse on both sides of Orange Park Boulevard. A larger congregation means more worship times, more funerals, wedding and other planned events at the location.This means more traffic at times of the day inconsistent with school arrlvals and departures. It's not clear how this traff(c wfll be handled and where 9-18 n� visitors will park. Today, at peak times, visitors park on the grass field or surrounding neighborhood streets, impacting neighbors right to park their vehicies and horse trailers. ° There is doubt that the City's guldeline for arriving car occupancy (4/vehicle) is proper for the Salem Lutheran congregation. Professional samplings of arriving cars indicate that there are far fewer occupants (2.28/vehitle). This correlates to more cars entering the property 9_19 and more parking needed. Once the church hits 57Yo capacity, parking on the grass field wili be mandatory. Using the grass piay field as a parking lot is not an aesthetic,safe or sanitary option.Clearly,the site has inadequate permanent,safe,well lighted parking. Page 3 of 5 LETTER 9 """ Page 4 of 5 Mr.Robert Garcta,Associate Pianner Response to Draft Environmental Impact Report DEIR No.1827-11 Dated April 23,2012 r The proposal does Ifttle to resolve the current tmpact that has created a dispute between � the church and its neighbors regarding the use and maintenance of Frank Street. 7hese are 9 20 property encroachments, rights-of-way disputes and parking disagreements where the ,�„ church and Frank Street abut each other. IYs not at all dear that the City's process to approve the DEIR will find a solution to the ,��, current traffic situation and will address any aspect of the projecYs future traffic increases. The Planning Commission can greatly benefit in the approvai process, by requiring a more in 9-21 depth traffic review,perhaps thru the Traffic Commission. � Most of the surface water drains west to Frank Street. There is a significant runoff that � floods properties to the west,including the arena site. 9-22 ,� �� ?he house that will be remodeled into the proposed preschool currently has water and mold conditions resulting from inadequate drainage. Moid condltions should be remediated 9-23 '"�' immediately,for health reasons. �• A church any larger than the current one is a burden on the community. The property is not � capable of handling much more than what is on it.The proposal is attempting to place a size �°� 13 faot into a size 8 shoe. It won't fit. Who suffers? ...the neighborhood, the community 9-24 � and the rural lifestyle of the area. A larger church outlives the usefulness of the property. A better solution ts to move the ,� church o�the school or both to a sultable location elsewhere.That would be a great loss for the community. A larger,grander church and its incumbent traffic are a far greater loss of �� the agriculturai heritage and the current equestrian Iifestyle of the area. Orange Park Acres .� has a rural community feel;a larger church wilM not add to the existing ambience. 9-25 ��. More unknowns are easy to find.7he new building is 24,000 square feet,5 times the size of ^� the existing church. Why Is this massive size (ncrease necessary? How will the additionai ,,, space be used by the church leadership?When will the space be used? With the relocating of the church offices to the new building, how wiil the now unused space in the gym """ building be used? These are important questions that need to be answered and have not -� been.The community wants to knowl � The Fowler property was once part of ihe church property.When short on funds,the church ° sold the property. The current zoning of R-140 on the property is consistent with the OPA � Specific Plan and the Board sees no need ta change it. There seems to have been an 9�26 � Page 4 of 5 LETTER 9 Page 5 of 5 Mr,Robert Garcia,Associate Pianner Response to Draft Environmenta)Impact Report DEIR No.1827-ii Dated AprO 23,2012 oversight with regards to removing the public/quasi public designation from the General 9-26 and Specific Plan. The direct neighbors and community should not be the victirn of this CONT oversight. The noise generated by the school, its students and the traffic is documented to be higher than the city standard. The new plan broadens the footprint and does nothing to reduce the noise. Placing a pre-school at the back of the property as suggested causes signi�icant 9 2� increases in no(se to several of the neighbors, most of whom purchased thefr homes, prlor to the church's existence when the land adjoining was residential use only. Our comments are submitted respectfully and in the spirit of continued coope�ation between the City of Orange, County of Orange, the projecYs developers, the parishioners and management of 9_28 Salem Lutheran Church and the residents of Orange Park Acres. On April 19, 2012 Salem representatives were presented an alternate plan by the neighboring residents. This plan is known as the "Resident's Plan." The Orange Park Associat(on would ask the 9_29 Planning Commission to consider this alternate Resident's Plan. It addresses many aspects of our concerns. In summary, the Board feeis that an expanded place of worship on the corner of Santiago Canyon Road and Orange Park Boulevard is contrary to the needs of the community,further corrupts the OPA Specific Plan, makes g-30 a difficuit traffic situation dangerous, is a misuse of the propert�s usefulness and (s yet to be justified to the propert�s nelghbors. Respectfully, �i Laura Thomas President Orange Park Association Page 5 of 5 � � �. � � � THIS PAGE INTENTIONALLY LEFT BLANK � � �,- � �. � � � �. Sa/em Lutheran Church and Schoo/OPA Compromise Specific P/an Response to Comments on the Draft E/R Responses to Comments • Letter 9 - Orange Park Association Response to Comment 9-1 This comment does not specifically address the proposed project, but is duly noted. Additionally, since the time that this comment was authored,the project applicant and the Orange Park Association have agreed on a compromise project proposal, referred to as the OPA Compromise Plan,which is discussed in Section 2 of this Response to Comments document. • Reduction of the seating capacity of the Sanctuary from 757 to 590 fixed seats, excluding special events. • Parking for Project to be confined to Project site, except for(i)additional parking on the site of the Fowler House (see item below) and(ii) other offsite venues that Salem has used far special event parking. The offsite venues referred to in section(ii) does not apply to City and County streets in the Orange Park Acres neighborhood adjacent to the Project site. Salem will continue to enforce its "good neighbor"policy, which endeavors to ensure that Salem's congregation and attendees do not park on City and County streets. • Demolition of the Fowler House in order to provide additional parking and relocation of the preschool away from the westerly property boundary. • Improvement of the west side of Orange Park Boulevard to accommodate an exclusive southbound right turn lane onto Frank Lane for the church and school use. Salem shall use best efforts to endeavor that such improvements will be completed as soon as possible following the commencement of construction of either the Sanctuary or School facilities. The Orange Park Association acknowledges that such roadway improvements will reyuire approvals from the City or the County of Orange ("County") and that Salem cannot guarantee how yuickly the City or County will act to approve such roadway improvement plans. The Orange Park � Association shall provide any and all documentation requested by Salem to demonstrate the Orange Park Association's support of such roadway improvements. • The inclusion of a demand light for equestrians at the intersection of Orange Park Boulevard and Frank Lane, which improvements shall be completed as soon as possible following the commencement of construction of either the Sanctuary or School facilities. • Incorporation of additional directional signage at Frank Lane and Orange Park Boulevard to define residents only travel lanes and church/school traffic lanes, which improvement shall be completed prior to the issuance of the occupancy permits for either the Sanctuary or School facilities. � Lowering of the Worship Center building height to 36 feet as recommended by the City of Orange Design Review Board(DRC). Michae/Brandman Associates 3-49 H�.\Client(PN-JN)�3771\37710001ULTC-FEIItl37710001 Sec03-OOResponses.doc Sa/em Lutheran Church and School OPA Compromise Specific P/an Response to Comments Response to Comments on the DraR E/R • Incorporation of a hammerhead turn around at the west end of Frank Lane per City standards, which improvement shall be completed prior to the issuance of occupancy permits for either ��.: the Sanctuary or School facilities. • Provision of"TYPE AY"(as depicted in Caltrans Standard Plans,U.S. Customary Units,2010 � edition)raised pavement markers to separate Frank Lane into separate lanes for residents and Salem Church traffic, which improvement shall be completed prior to the issuance of occupancy permits for either the Sanctuary or School facilities. """' • Prior to the commencement of construction of the Sanctuary and School facilities, Salem to coordinate with OPA's Trail Subcommittee to ensure appropriate protections of horse trail on '�" Project site. • Incorparation of the following provision into the Salem Lutheran Church and School Specific '""� Plan: "No application for a building permit, use permit,variance, or any other entitlement authorizing development or construction inconsistent with this Specific Plan shall be approved, �„�,F or deemed to be approved through inaction, by the City of Orange or any officer or employee thereof." � � Because of the above changes, including the reduction in the seating capacity of the new Sanctuary, �' the final Project will be even less impactful than indicated by tye Draft EIR. Additionally, as a result �, of the cooperative process between Salem and the Orange Park Association,the Orange Park Association has now expressed its support for the proposed project and has withdrawn all of its prior � objections to the proposed project. Orange Park Association's prior comments are nonetheless �' addressed below. -�� Response to Comment 9-2 This comment expresses concern over the current state of the proposed project and the need for � clarification. Section 2 of this Response to Comments document provides a detailed project description of the OPA Compromise Plan and the chronology of the project,which included meeting �� with neighbors and Orange Park Association Board members. Additionally, refer to Response to '"'" Comment 7-5 for a discussion regarding the City Design Review Committee recommended approval to the Planning Commission. ,-,, Response to Comment 9-3 This comment expresses concern over the proposed project's consistency with the OPA Plan. The � OPA Plan is part of the City of Orange General Plan, which constitutes the Land Use Element for the OPA Plan. The purpose of the Specific Plan is to implement the OPA Plan for the project site. As .� addressed in Response to Comment 5-5,the proposed project is consistent with the OPA Plan. In � addition, Salem has agreed to address Orange Park Association's concerns about inconsistencies � between the OPA Plan and the General Plan Land tJse Map by agreeing to seek a General Plan 3-50 Michae/Brandman Associates „�� H�.\Client(PN-JN)�3771\37710001�RTC-FEIR\37710001 Sec03-OOResponses.doc �,.;;; Salem Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments on the Draft EIR Responses to Comments _ Amendment to amend the Site's designation on the General Plan Land Use Map, in order to make such designation consistent with the OPA Plan. Response to Comment 9-4 This comment expresses concern over the proposed project's consistency with the OPA Plan. As addressed in Response to Comment 5-5,the proposed project is consistent with the OPA Plan. In addition, Salem has agreed to address Orange Park Association's concerns about inconsistencies between the OPA Plan and the General Plan Land Use Map by agreeing to seek a General Plan Amendment to amend the Site's designation on the General Plan Land Use Map, in order to make such designation consistent with the OPA Plan. . Response to Comment 9-5 � This comment does not specifically address the proposed project,but is duly noted. Response to Comment 9-6 This comment expresses concern over project-related traffic potentially impacting the local circulation network. A TIA Addendum (Appendix A) was prepared for the OPA Compromise Plan to �� address the potential traffic and parking impacts associated with the proposed project as described in the Specific Plan compared with the 712-seat sanctuary scenario analyzed in the City-approved Traffic Impact and Parking Demand Analysis Report dated August 20, 2010. Based on the TIA Addendum for the proposed project, no traffic impacts will be created and adeyuate parking will be provided consistent with the City-approved Traffic Impact and Parking Demand Analysis Report. As part of the proposed project, Salem Lutheran Church and School has agreed to implement a number of traffic and transportation-related modifications to the project as outlined in the Orange Park Association Letter of Support dated/executed June 5, 2014. Response to Comment 9-7 This comment expresses concern that the existing use does not comply with noise standards set forth by the City of Orange. This comment references the existence of an existing issue, not an issue that would be caused or worsened by the proposed project. As addressed in Response to Comment 6-2, � the Draft EIR provides the existing noise levels at adjacent properties near the project site(Section 4.7,Noise, Exhibit 4.7-1 on page 4.7-5)and identifies those sensitive receptors (residences)that exceed the City's noise standards. The Draft EIR addresses the potential to exceed the City's noise standards and determined that with incorporation of Mitigation Measure NOI-1 (Draft EIR Section �� 4.7,Noise) during the demolition phase of the construction activities; temporary exceedance of noise level thresholds established by City would be avoided. Long-term noise impacts associated with operations of the project were found to be less than significant and were addressed in the Initial Study (Appendix A,Notice of Preparation,lnitial Study, Michael Brandman Associates 3-51 H\Clien[(PN-7N)�3771\37710001�RTGFEIItli7710001 Sec03-00 Responses doc Sa/em Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments Response to Comments on the Draft E/R and Comment Letters, of the Draft EIR)prepared for the project prior to the Draft EIR. The Initial Study concluded that the operations phase of the proposed project would not result in noise increases over the existing conditions since the proposed land use would be the same as the existing land use, with similar traffic conditions and onsite activities. Additionally,the Noise Impact Analysis prepared for the proposed project(Appendix G,Noise Impact Analysis, of the Draft EIR) examined long-term, "'" operations-related noise and determined the noise irnpacts would be less than significant in regards to onsite operational noise. The Noise Impact Analysis analyzed potential noise generated by the proposed parking lots,the playground,the sanctuary, and the fellowship reception area, determining that noise produced at any of these locations would not exceed the City of Orange noise standards. � Response to Comment 9-8 This comment expresses that the proposed conversion of the Fowler House into the proposed - preschool facility is inconsistent with the OPA Plan and history of the property. The Fowler House will be removed and replaced with a new parking area. An approximately 7,505 sq ft preschool � building and associated 7,921 sq ft play area will be built adjacent to the western portion of the existing Classroom Building B. Similar to the remainder of the project site, and as more fully �� addressed in Response to Comment 5-5,the OPA Plan designates the property where the Fowler � House is located as Public/Quasi-Public, a designation that allows churches and schools as a matter of right. The proposed project, including the use of the Fowler property as a parking area, is thus � consistent with the OPA Plan. The proposed relocation of the preschool as part of the OPA Compromise Plan will not affect the capacity as evaluated in the Draft EIR and will not impact the � overall enrollment cap as identified in the existing CUP. The issue of rezoning is addressed in detail � in Draft EIR Section 4.6, Land Use and Planning. This Section found that: Eliminating the existing R-1-40(Single-Family Residential)zone district and �� replacing it with the proposed SP/P-I (Specific Plan/Public Institutional) zone district � � would result in consistency with the Salem Lutheran Church and School OPA Compromise Specific Plan. In addition,the proposed SP/P-I zone district would be consistent with the OPA Plan. The City Attorney's Office proposed the zone change as a technical clean-up modification to ensure that the zoning properly reflects and implements the OPA Plan land use designations applicable to the project site and has provided a written memorandum (AppendiY B of the Draft EIR)regarding the � proposed zone change that states the following: 1. Processing a specific plan pursuant to State law as the entitlement vehicle for the �.- project is appropriate; 2. Processing a zone change to SP/P-I is appropriate; and, _ 3. The processing of a specific plan and zone change to SP/P-I is consistent with the entitlement process utilized for Chapman University and St. John's Lutheran Church � 3-52 Michae/Brandman Associates .., H�.\Client(PN-JN)�3771\37710001�RTGFEIli\37710001 Sec03-00 Responses doc Salem Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments on the Draft E/R Responses to Comments .. and school,both of which are public institutional uses as defined by the Orange Municipal Code and are governed by a specific plan. Based on the above, we believe that the proposed entitlement process for the project is consistent with previous and current City practice. As addressed in Response to Comment 5-5,the proposed project, including the rezoning of the project site from R-1-40(Single-Family Residential)to SP/P-I (Specific Plan/Public Institutional), is consistent with the OPA Plan and the City of Orange General Plan. Response to Comment 9-9 This comment expresses concern over the proposed project's consistency with the OPA Plan. As addressed in Response to Comment 5-5,the proposed project is consistent with the OPA Plan and the City of Orange General Plan, and comply with the City of Orange Zoning Ordinance. The trails adjacent to the project site will be preserved and continue to provide connectivity with other trails in OPA and be available to equestrian users. Response to Comment 9-10 This comment expresses concern over existing surface runoff from the project site that results in offsite flooding. Consistent with the "Single Site Access" alternative analyzed in the Draft EIR,there would be no driveway from Santiago Canyon Road, and as a result, stormwater flows will not have a direct outlet onto the roadway as previously proposed. As a result, a private storm drain system is proposed for the project. This storm drain system will pick up the majority of the project site and convey flow toward Santiago Canyon Road where it will be picked up in an existing 36-inch reinforced concrete pipe (RCP) within Santiago Canyon Road. This 36-inch RCP conveys flows to the Handy Creek reinforced concrete box culvert under Santiago Canyon Road. This storm drain system will alleviate flooding that has occurred within the private drive westerly of the project site. � No significant increases in peak flow or runoff volume will occur due to development. Modeled peak runoff for the project remains relatively the same for the l 0-year and 25-year High Confidence Events and decreases approximately ] percent during the 100-year High Confidence Event. Therefore,the project's hydrology and water quality impacts will be similar when compared with those impacts analyzed in the Draft EIR. Response to Comment 9-11 This comment expresses concern over the proposed project's consistency with the OPA Plan, and questions the OPA Plan. As addressed in Response to Comment 5-5, the proposed project is consistent with the OPA Plan and the City of Orange General Plan. Michae/Brandman Associates 3-53 H:\Client(PN-JN)U771\37710001�RTGFEIR\37710001 Sec03-OOResponses.doc Salem Lutheran Church and School OPA Compromise Specific Plan Response to Comments Response to Comments on the Draft EIR Response to Comment 9-12 This comment expresses concern over how well the proposal would meet the standards contained in - the OPA Specific Plan and why a specific plan is needed. Pursuant to California Government Code § 65450 et seq.,the City is authorized to prepare a specific plan for any part of the area covered by its General Plan. There is no minimum acreage required in order to process a specific plan. The project site ("Site") is located within Orange Park Acres, an area of the City governed by the OPA Plan, a �� document that serves as "the land use element of the general plan" for the Orange Park Acres (see 'µ"' City of Orange Resolution No. 3915). Accordingly,the Site's zoning is required to be consistent with �- the OPA Plan and thereby providing consistency between the standards in the OPA Plan and the � Salem Lutheran Church and School OPA Compromise Specific Plan. Response to Comment 9-13 � This comment expresses concern over the benefits of rezoning. The Site's zoning is required to be consistent with the OPA Plan. (California Government Code § 65860 ["city zoning ordinances shall � be consistent with the general plan"].) Nonetheless, despite the fact that the OPA Plan has always designated the Site, including the Fowler property, as "Public/Quasi-public,"a designation that allows � churches and schools without a CUP,the Site was previously zoned as "residential,"a designation that requires a CUP for church use. °" � The proposed project would amend the current zoning so that it is consistent with the OPA Plan by rezoning the Site from residential to Specific Plan/Public and Institutional"("SP-PI"). Because churches, including church schools, are permitted without a CUP in the SP-PI zone, it will no longer "� be necessary for Salem Lutheran Church and School to operate under a CUP once the Site is rezoned. �� Instead, the use of the Site will be governed by a Specific Plan, which will impose various ,,,� requirements and restrictions on the design and operation of the church and school, including by incorporating the operational restrictions contained in Salem Lutheran Church and School's current � CUP. The purpose of such a specific plan is to implement a general plan by providing more specific � requirements consistent with such plan(California Government Code § 65450 ["After the legislative � body has adopted a general plan,the planning agency may . . . prepare specific plans for the ,.� systematic implementation of the general plan. . . ."]). The benefits of implementing the Salem Lutheran Church and School OPA Compromise Specific '"'� Plan are to provide a comprehensive development plan for the relocation and redevelopment of the �:a onsite uses including the relocation of the existing preschool according to the goals and objectives in � the Specific Plan. The Specific Plan includes only existing church-related uses and the preschool and � development on the project site would be restricted to these uses; no commercial development or other development type is proposed. No information is available regarding the effect on land '""` valuation resulting from rezoning. � � 3-54 Michael Brandman Associates „� H.\Client(PN-IN)�3771\37710001UtTC-FEDt\37710001 Sec03-00 Responses.doc k,;=. Salem Lutheran Church and School OPA Compromise Specific P/an Response to Comments on the Draft EIR Responses to Comments � Response to Comment 9-14 This comment requests information regarding how Salem Lutheran Church and School is planning to .. attract new congregants to fill the seats of the proposed Worship Center. The purpose of the proposed project is not to attract new members, but to provide facilities adequate to serve Salem Lutheran Church and School's existing congregation, including existing special events. Thus, while the project � assumes attendance levels of up to 590 attendees,the project is fundamentally a redesign of the existing campus that will better serve Salem Lutheran Church and School's existing attendees by � eliminating the inefficient layout and circulation. As provided in the TIA Addendum (Appendix A), both study intersections are anticipated to continue ` to operate at acceptable LOS B or better compared with City of Orange criteria. As a result, implementation of the project is not expected to cause significant traffic impacts at any of the key study intersections during the Sunday AM peak hour, and therefore, impacts associated with traffic and circulation will be less than significant and no mitigation measures will be required. Response to Comment 9-15 This comment expresses concern over project-related traffic and parking potentially impacting the local circulation network. As provided in the TIA Addendum (Appendix A), both study intersections are anticipated to continue to operate at acceptable LOS B or better compared with the City of Orange criteria. As a result, implementation of the project is not expected to cause significant traffic impacts at any of the key study intersections during the Sunday AM peak hour, and therefore, impacts associated with traffic and circulation will be less than significant and no mitigation measures will be � required. Based on the TIA Addendum for the proposed project, no traffic impacts will be created and adequate parking will be provided consistent with the City-approved Traffic Impact and Parking Demand Analysis Report dated August 20, 2010. As part of the proposed project, Salem Lutheran Church and School has agreed to implement a number of traffic and transportation-related modifications to the project as outlined in the Orange Park Association Letter of Support to the Mayor and Orange City Council, dated/executed June 5, 2014. Response to Comment 9-16 This comment expresses concern over the trail fencing along East Santiago Canyon Road. Consistent with the "Single Site Access"alternative analyzed in the Draft EIR,there would be no driveway from Santiago Canyon Road, and as a result, a break in the trail fencing will no longer be required. Response to Comment 9-17 This comment expresses concern over traffic arriving to the project site from East Santiago Canyon Road and Orange Park Boulevard. Consistent with the "Single Site Access"alternative analyzed in Michael 8randman Associates 3-55 H1Client(PN-IN)\3771\37710001UiTC-FEIR�37710001 Sec03-00 Responses.doc Sa/em Lutheran Church and School OPA Compromise Specific Plan Response to Comments Response to Comments on the Drafi EIR the Draft EIR,there would be no driveway from Santiago Canyon Road. Instead, there will be an additional right-hand turn lane along Orange Park Boulevard, which would improve circulation both internally and on local roads. �� Response to Comment 9-18 „,� This comment expresses concern over traffic and parking impacts related to special planned events. The need for overflow parking is anticipated based upon recent past attendance records of events, ..�, including holiday church services(Easter, Christmas, etc.); school graduations; special school-related events and services (e.g., opening school year church service, Christmas programs, grandparents day); and funerals and weddings. Overflow parking on tlie multipurpose field would be set-up prior to the m � event and is anticipated to fulfill the parking need. � � � Response to Comment 9-19 This comment expresses concern over the use of the grass field for parking. Based on the application � of the City of Orange parking code ratio, as well as the empirical parking ratio consistent with the 2010 Parking Analysis for the 712-seat sanctuary scenario,the approximately 186 surface parking n� spaces plus 105 overflow parking spaces (291 total spaces)will provide adequate onsite parking. It "`°`' should be noted that the l 86 surface parking spaces will satisfy the City parking code requirement of �•- 148 parking spaces and implementation of a parkin,�management plan(PMP)will be required to �, accommodate the empirical parking requirement of'259 parking spaces consistent with the 2010 Parking Analysis for the 712-seat sanctuary scenario. ry � Response to Comment 9-20 �� This comment expresses concern over traffic generated by the existing use and how this traffic +� currently impacts residential access along Frank Lane. This comment references the existence of an �,, existing issue, not an issue that would be caused or worsened by the proposed project. Additionally, � as addressed in Response to Comment 8-2,the proposed project redesign of Frank Lane involves two closely spaced but separate entrances, one for use by the project and one dedicated for residential use �� only. Residential ingress and egress along the soutliern dedicated portion of Frank Lane would be � able to proceed safely and efficiently following development of the project. _ Moreover, as addressed in Response to Comment 6-3, adequate parking would be provided on the � project site to accommodate parking needs on weekdays and Sundays. Furthermare, as addressed in Response to Comment 7-4,the proposed project is not expected to cause significant traffic impacts at � any of the key study intersections based upon the application of the significance criteria referenced above, and thus, impacts are less than significant and no mitigation measures will be necessary under � both Weekday and Sunday AM peak-hour conditions. Rights to use Frank Lane for ingress and egress purposes are governed by a series of recorded �, easements. Specifically,the southernmost 20 feet af the eastern 470 feet of Salem Lutheran Church 3-56 Michael Brandman Associates H.\Client(PN-JN)�3771\37710001�RTGFEIR\37710001 Sec03-00 Responses.doc � ' Sa/em Lutheran Church and Schoo/OPA Compromise Specific P/an Response to Comments on the Draft EIR Responses to Comments and School's property is burdened by roadway easements held by certain of its neighbors, as is the southernmost 10 feet of the more western portion of the property. Conversely, Salem Lutheran Church and School's property is benefited by roadway easements in the northern 10-16 feet of its neighbors' property. The Project will not change the existing easements, but as addressed in Response to Comment 8-2,the proposed project redesign of Frank Lane involves two closely spaced but separate entrances, one for use by the project and one dedicated for residential use only. Residential ingress and egress along the southern dedicated portion of Frank Lane would be able to proceed safely and efficiently following development of the project. Response to Comment 9-21 This comment expresses concern over the existing and project-related traffic. As provided in the TIA � Addendum (Appendix A), both study intersections are anticipated to continue to operate at acceptable „ LOS B or better compared with the City of Orange criteria. As a result, implementation of the project is not expected to cause significant traffic impacts at any of the key study intersections during the Sunday AM peak hour, and therefore, impacts associated with traffic and circulation will be less than significant and no mitigation measures will be required. Response to Comment 9-22 This comment expresses concern over existing surface runoff from the project site that results in offsite flooding particularly along Frank Lane. Consistent with the"Single Site Access"alternative analyzed in the Draft EIR, there would be no driveway from Santiago Canyon Road, and as a result, stormwater flows will not have a direct outlet onto the roadway as previously proposed. As a result, a private storm drain system is proposed far the project. This storm drain system will pick up the majority of the project site and convey flow toward Santiago Canyon Road where it will be picked up in and existing 36-inch RCP within Santiago Canyon Road. This 36-inch RCP conveys flows to the Handy Creek reinforced concrete box culvert under Santiago Canyon Road. This storm drain system will alleviate flooding that has occurred within the private drive westerly of the project site. No significant increases in peak flow or runoff volume will occur due to development. Modeled peak runoff for the project remains relatively the same far the ]0-year and 25-year High Confidence Events and decreases approximately 1 percent during the 100-year High Confidence Event. Therefare,the project's hydrology and water quality impacts will be similar when compared with those impacts analyzed in the Draft EIR. Response to Comment 9-23 This comment states that the Fowler House is currently affected by mold conditions. Section 8, Hazards and Hazardous Materials, of the Initial Study prepared for the Draft EIR(Appendix A, Notice of Preparation, Initial Study, and Comment Letters, of the Draft EIR) addresses the question of whether the proposed project would: Michae/Brandman Associates 3-57 H\Client(PN-IN)�3771\37710001UtTC-FEIIL�37710001 Sec03-00 Responses.doc Sa/em Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments Response to Comments on the Draft EIR Be located on a site which is included on a list of hazardous materials sites complied pursuant to Government Code Section 65962.5 and, as a result, would it create a � significant hazard to the public or the environment? According to the Initial Study,no evidence of hazardous materials contamination has been encountered on or adjacent to the project site. Additionally,the project site is not listed on either federal or State databases presented in the Radius Map Report prepared by Environmental Data ..x., Resources, Inc. (Appendix E, Environmental Data Resources, Inc. [EDR] Map Report, of the Draft EIR). The interior of the Fowler House has not been inspected to verify if mold is present or if the substance is mildew or some other non-hazardous substance. Prior to demolition activities, a licensed "" specialist will inspect the interior of the Fowler House to determine the presence or absence of hazardous substances, including asbestos containing materials(ACM), lead-based paints(LBP), or � other potentially hazardous substances such as mold. In the event that any mold or other potentially hazardous substances are determined to be present, remediation by a licensed specialist would occur prior to demolition activities, as part of standard construction practices and consistent with all �` applicable federal, state, and local provisions related to the handling of potentially hazardous �- substances. This inspection and potential remediation will be placed as a condition of approval on the ,,,,F project. Response to Comment 9-24 .� This comment expresses concern over the size of the proposed Salem Lutheran Church and School. �" As addressed in Response to Comment 5-5,the proposed project and all of its improvements are �u consistent with the OPA Plan and the City of Orange General Plan, and comply with all applicable ,� provisions of the City of Orange Zoning Ordinance in regards to the size (e.g., floor area ratio [FAR]) � of onsite structures. � Response to Comment 9-25 � This comment expresses concern over the size of the proposed project and the project's consistency �. with the surrounding area. As addressed in Response to Comment 5-5,the proposed project and all of ,,,,, its improvements are consistent with the OPA Plan and the City of Orange General Plan, and comply w with all applicable provisions of the City of Orange Zoning Ordinance in regards to the size(e.g., FAR) of onsite structures. � Additionally,the comment questions how the expanded Worship Center space would be utilized. The � fixed-seat capacity of the new sanctuary has been reduced to 590 seats. Overall,the new worship center will be approximately 20,000 to 23,000 square feet and will house the sanctuary, conference/meeting rooms,the sacristy, offices, choir/music rooms, storage, childcare, and other '° ancillary/administrative rooms. � 3-58 Michae/Brandman Associates ,�, H�\Client(PN-JN)�3771\37710001UtTGFEIR\37710001 Sec03-00 Responses.doc Salem Lutheran Church and School OPA Compromise Specific P/an Response to Comments on the Draft EIR Responses to Comments There would be no concurrent use of the sanctuary and the multipurpose building for assembly purposes if the total attendance for the assembly will exceed 590 persons, excluding special events. Therefore,the proposed uses are not inconsistent with the OPA Plan. Response to Comment 9-26 The comment pertains to current conditions and not the proposed project; however,the comment is duly noted. Response to Comment 9-27 This comment expresses concern over existing and project-related noise. As addressed in Response to Comment 6-2,the Draft EIR provides the existing noise levels at adjacent properties near the project site (Exhibit 4.7-1,Noise Monitoring Locations and Nearby Sensitive Receptors, on page 4.7- 5) and identifies those sensitive receptors (residences)that exceed the City's noise standards. The Draft EIR addresses the potential to exceed the City's noise standards and determined that with incorporation of Mitigation Measure NOI-1 (Section 4.7,Noise) during the demolition phase of the construction activities,temporary exceedance of noise level thresholds established by City would be avoided. Long-term noise impacts associated with operations of the project were found to be less than significant and were addressed in the Initial Study (Appendix A,Notice of Preparation,Initial Study, and Comment Letters, of the Draft EIR) prepared for the project prior to the Draft EIR. The Initial Study concluded that the operations phase of the proposed project would not result in noise increases over the existing conditions since the proposed land use would be the same as the existing land use, with similar traffic conditions and onsite activities. Additionally,the Noise Impact Analysis prepared for the proposed project(Appendix G,Noise Impact Analysis, of the Draft EIR) examined long-term, operations-related noise and determined the noise impacts would be less than significant in regards to onsite operational noise. The Noise Impact Analysis analyzed potential noise generated by the proposed parking lots,the playground,the sanctuary, and the fellowship reception area, determining that noise produced at any of these locations would not exceed the City of Orange noise standards. Response to Comment 9-28 The comment does not specifically address the project Draft EIR, but rather expresses a spirit of ` cooperation, which is duly noted. Response to Comment 9-29 This comment refers to a resident-drafted plan included within a separate comment letter(Letter 10), identified herein as the Grayson Traffic Plan. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document for an evaluation of the Grayson Traffic Plan. Michael Brandman Associates 3-59 H-\Clien[(PN-JN)�3771\37710001UtTC-FEIR�i7710001 Sec03-OOResponses.doc Sa/em Lutheran Church and Schoo/OPA Compromise Specific P/an Response to Comments Response to Comments on the Draft E/R Response to Comment 9-30 This comment expresses concern regarding the proposed project in relation to the needs of the � community,the OPA Specific Plan, and difficult traffic conditions. Section 3, Project Description, of the Draft EIR contains a site plan chronology that identifies community involvement in the redesign process. Section 4.8, Transportation and Traffic, of the Draft EIR, Transportation and Traffic evaluated potential traffic impacts associated with implementing the proposed project. Refer to Response to Comment 9-21. Response to Comment 9-25 describes the consistency between the "'� proposed project and the OPA Plan. � � � � � � � � � � �,.: � �� 3-60 Michae/Brandman Associates � H�.\Client(PN-1N)�3771\37710001�RTC-FEIR\37'710001 Sec03-00 Responses.doc �:,�,� LETTER 10 Page 1 of 119 Resident Res onse to p Salem �utheran Church School Draft EIR 1827- 11 Due on or before April 23, 2012 5:30 PM Date: Hand deli�ered 04-23-2012 To: Robert Garcia, Associate Planner City of Urange Community Developrr�ent Department, Planning Division 300 E. Chapman Avenue Orange, CA 92866 From: Tom Grayson, Bobbie Grayson, Liberty Grayson, leremy Grayson, Shawn Grayson Address: 6348 East Frank Lane Orange, CA 92869 Receiving Party: Print name Date Time LETTER10 Page 2 of 119 � Draft �. Enviranmental Mmpact Repart Salem Lutheran Church and �� Schooi Specific Plan City of 0►range, Orange County, California '� State Clearinghouse No. 201�101046 �, ,� Prepared for: Salem Lutheran Church "� 6500 East Santiago Canyon Road ,�, Orange, CA 92869 �E City of Orange Community Development Department • Planning Division � 300 East Chapman Avenue Orange, CA 92866-1591 `�"' Phon�: 714.744.7220 Fax: 714.744.7222 � www.c.iryoforange.org � Contact: Robert Garcia, Associate Planner � ��. � Prepared by: � Michael Brandman Associates � 220 Commerce, Suit� 209 Irvine, CA 92602 Nm" Phon�: 714.508.41 DO �, Contact: Kevin �3hannon, Project Manager �3�- � � January 26, 2012 � � � � LETTER 10 Page 3 of 119 Salem Lutheren Church and Schoo/5peci/Jc P/an Draft EIR Ta6le of Contents Table of Contents Section1: Introduction......................................................................................................1-1 1.1 -Overview, Purpose, and Authority of the Draft EIR..........................................1-1 1.2- Scope of the Draft E I R.....................................................................................1-2 1.3-Technical Documents and Supporting Materials..............................................1-7 1.4 - Lead Agency, Consultant, and Project Applicant.............................................1-8 1.5- Review of the Draft EIR....................................................................................1-8 Section2: Executive Summary.........................................................................................2-1 2.1 - Purpose............................................................................................................2-1 2.2 -Project Summary..............................................................................................2-1 2.3-Significant Unavoidable Impacts......................................................................2-3 2.4-Summary of Project Alternatives......................................................................2-4 2.5- Summary of Environmentai Impacts, Mitigation Measures, and Project DesignFeatures ..............................................................................................2-4 Section 3: Project Description..........................................................................................3-1 3.1 - Project Location ...............................................................................................3-1 3.2-Project Summary, Background and Site Plan Chronology...............................3-1 3.3- Project Objectives..........................................................................................3-10 3.4 - Project Characteristics...................................................................................3-13 3.5-Project Phasing..............................................................................................3-33 3.6- Required Public Agency Approvals and Requested Entitlements..................3-34 Section 4: Environmental Impact Analysis......................................................................4-1 Approach and Method to Environmental Analysis....................................................4-1 EnviranmentalTopics...............................................................................................4-1 Format Used for Impact Analysis.............................................................................4-1 4.1 -Aesthetics......................................................................................................4.1-1 4.2-Air Quality......................................................................................................4.2-1 4.3-Greenhouse Gas Emissions .........................................................................4.3-1 4.4- Hazards and Hazardous Materials................................................................4.4-1 4.5- Hydrology and Water Quality........................................................................a.5-1 4.6- Land Use and Planning.................................................................................4.6-1 4.7- Noise.............................................................................................................4.7-1 4.8-Transportation and 7�affic.............................................................................4.8-1 4.9- Utilities and Service Systems........................................................................4.9-1 Section5: Cumulative Impacts.........................................................................................5-1 5.1 - Introduction and Summary of Cumulative Impacts ..........................................5-1 5.2 - Related Projects...............................................................................................5-3 5.3-Cumulative Impacts.......................................................................................... Section 6: Growth Inducing, Unavoidable Adverse, and Irreversible Impacts ............6-1 6.1 -G�owth-Inducing Impacts.................................................................................6-1 6.2- Unavoidable Adverse Impacts .........................................................................6-1 6.3- Irreversible Impacts..........................................................................................6-2 Mlchael Brendman Aasoclates � �J f!i H:K'liml(PN-1Nn97)IV7111KM711F,IB17•DEIHU771Uftol ScdN1�t12 Saltm lY)("doc LETTER10 Page 4 of 119 Salem LuG►e►an Church and Schoo/SpecHlc Pian Oraft ElR Table of Confonts �..,� Section 7: Alternatfves to the ProJect..............................................................................7-1 7.1 - introduction......................................................................................................7-1 7.2 -Aiternatives Identified for Evaluation and Reasons for Including Selected Aiternatives......................................................................................................7-2 . } 7.3- Conclusion Summaries and Environmentally Superior Aitemative................7-10 7.4 - Project Alternative Comparison .....................................................................7-13 7.5 - Project Objective Feasibility Summary....................... ...................._.....7-23 � 3ection 8: Significant and Unavoidable Im�acts............................................................8-1 . Section 9: Other Long-Term Implications .......................................................................9-1 � 9.1 -Growth-Inducing Impacts.................................................................................9-1 9.2 - Irreversible and Irretrievable Commitment to Resources.................................9-1 9.3 - Cumulative Impacts.........................................................................................9-3 Section 10: Report Preparation Resources...................................................................10-1 � 10.1 - Draft EIR Preparation Personnel .................................................................10-1 �: 10.2-7echnical Subconsultants............................................................................10-1 10.3 - Organizations and Persons Cansulted .10-1 ^� ....................................................... Section11: References ...................................................................................................11-1 r..,, � Appendix A: Notice of Preparation, lnitial Study� and Comment Letters k�,� A.1 - Notice of Preparation and Initial Study A.2- Public Comment Letters �" Appendix B: City of Orange, City Attorney"s Office: Memo-February 8, 2010 . .� Appendix C: City of Orange� Design Revie�uv Committee, Oraft Minutes -May 17, 2006; ,�,,, Neighbor Respon�e Letter- September 22, 2008 C.1 - Design Review Committee Draft Minutes- May 17, 2006 - C.2- Neighbor Response Letter-September 22, 2008 �e Appendix D: Air Quality and Greenhouse Uas Ar�alysis Report Appendix E: Enviranmental Data Resources, Inc. (EDR)Map Report Appendix F: Hydrology and Water Quality �" F.1 - Hydrologic Assessment: Noveml�er 4, 2011 F.2- Preliminary Water Quality Management Plan: November 11, 2011 Appendix G: Noise Impact Analysis '� Appendix H: Traffic Impact and Parking Dr�mand Analysis Appendix L• Salem Lutheran Church and School Specific Plan .� Appendix J: Overflow Parking Plan Mlcltael Bra»dman Assocfates �i�- ---MR _�T � HACII yR(PN-1N/U1711)7TI IMN)Itf�.IRl4-PIilRU7111NNtl 5MNI.U7 tiplem IOC.duc LETTER 10 Page 5 of 119 , Salem lutheran Church and Schoo!Speclfic Plan p�� 7'able o/Contents List of Tables Table 1-1: Technical Studies and Supporting Materials.......................................................1-7 Table 2-1: Impacts and Mitigation Measures Summary.......................................................2-5 Table3-1: Land Use Summary..........................................................................................3-13 Table 3-2: Statisticai Summary..........................................................................................3-14 Table 3-3: Proposed Improvements by Phase...................................................................3-33 Table 4.1-1: Comparison of OPA Plan Aesthetics Policies to Salem Lutheran Church SpecificPlan...............................................................................................4.1-17 7abie 4.2-1:Air Pollutant Standards, Effects, Properties, and Sources............................4.2-4 Table 4.2-2: Best Available Control Measures- SCAQMD Rule 403 ...............................4.2-9 Table 4.2-3: Local Air Quality Monitoring Summary—Anaheim Pampas Lane..............4.2-14 Table 4.2-4: South Coast Air Basin Attainment Status ...................................................4.2-15 Table 4.2-5: SCAQMD Significance Thresholds.............................................................4.2-18 Table 4.2-6; Significance Threshold and Corresponding Draft EIR Impact Number.......4.2-19 Table 4.2-7: Short-Term Localized Construction Ernissions...........................................4.2-23 Table 4.2-8: Traffic Intersection Analysis- 2010.............................................................4.2-24 Table 4.2-9: Short-Term Regional Construction Emissions............................................4.2-26 Table 4.2-10: Regional Operational Emissions...............................................................4.2-28 Table 4.3-1: Greenhouse Gases.......................................................................................4.3-3 Table 4.3-2: Greenhouse Gas Emissions Significance Threshold and Corr�sponding DraftEIR Impact Number...........................................................................4.3-10 Table 4.3-3: Construction Greenhouse Gases................................................................4.3-12 Table 4.3-4: Operational Greenhouse Gases.................................................................4.3-12 Table 4.3-5: Total Annualized Greenhouse Gas Emissions...........................................4.3-13 Tabfe 4.3-6: General Plan Consistency ..........................................................................4.3-14 7able 4.4-1: Hazards and Hazardous Materials Significance Threshold and Corresponding Draft EIR Impact Number ....................................................4.4-7 Table 4.5-1: Salem Lutheran Church and School Existing Condition Runoff Volume Summary and Peak Flow Rate.....................................................................4.5-5 Table 4.5-2: Salem Lutheran Church and School Proposed �ondition Runoff Volume Summary and Condition Peak Flow Rate ....................................................4.5-6 Table 4.5-3: 2-Year Storm Event Conditions (Hydromodification) - Peak Flow Rate(Q)4.5-10 Table 4.5-4: 2-Year Storm Event Conditions (Hydromodification)—Time of Concentration(Tcj......................................................................................4.5-10 Table 4.5-5: 2-Year Storm Event Conditions (Hydromodification)—Volume..................4.5-10 Table 4.5-6: Anticipated and Potential Pollutants Generated by Land Use 7ype...........4.5-12 Table 4.5-7: Combined Risk Level Matrix.......................................................................4.5-20 Table 4.5-8: Site Design BMPs.......................................................................................4.5-21 Mlchae!Brendman Asaoclates � � ` � H:\CIirn11Pi:-1Nj�1�7113T711xM�Hl9R14.DIiI1tU771iMKi1 SMM1�12 tidem 70C dnc LETTER10 Page 6 of 119 Selem lutheren Church and Schoo/Specf�c Plan Dtaft EIR Table o/Confents Table 4.5-9: Non-Structural Source Cantrol BMPs............................... . ..4.5-21 �"�" . ...................... Table 4.5-10: Structural Saurce Control BMPs...............................................................4.5-22 Table4.5-11: Infiltration..................................................................................................4.5-24 „� Table 4.5-12: Preliminary Water Quality 7reatment Summary .......................................4.5-26 Table 4.5-13: Hydrology and Water Quality Significance Threshold and Corresponding Draft EIR Impact Number............................... ........4.5-29 � .................................... Table 4.5-14: Construction-R$lated Pollutants...............................................................4.5-38 Table 4.5-15: Beneficial Uses.........................................................................................4.5-A2 »� Table 4.6-1: Land Use and Planning Significance Threshold and Corresponding Draft EIR Impact Number......................................................................................4.6-6 _ Table 4.6-2: Proposed Project Consistency with Or�nge Park Acres Specific Plan.........4.6-7 � 7able 4.6-3: Project Consistency with the City of O�ange General Plan: Land Use Element......................................................................................................4.6-19 7able 4.8-4: P�oject Consistency with the Ci1y of Orange General Plan: Natu�al '�"` Resources..................................................................................................d.6-25 �u Table 4.6-5: Praject Consistency with the Cit�r of Orange General Plan: Public Safety Element .......4.6-30 ""° ............................................................................................... Table 4.6-6: Project Consistency with the City of Orange General Plan: Circulation and �� MobilityElement.........................................................................................4.6-34 ..� Table 4.6-'7: Project Consistency with the City of Qrange General Plan: Noise Element4.6-39 Table 4.6-8: Project Cnnsistency with the City�of Orange General Plan: Cultural `� Resources and Historic Preservation �lement...........................................4.6-42 � Table 4.$-9: Project Consistency with the City of C7range General Plan: Infrastructure Element ..........4.6-45 � ............................................................................................ Table 4.6-10: Project Consistency with the City of Orange General Plan: Urban ��sign �*- Element......................................................................................................4.6-48 �...e Table 4.6-11: I�roject Consistency with the City of Orange General Plan: Growth ManagementElement................................................................................4.6-52 � Table 4.6-12: Project Consistency with the City of Orange General Plan: Econamic �.:„ DevelopmentElement................................................................................4.6-54 Table 4.6-13: P�oject Consistency with the City of Urange General Plan: Housing "'�` Element...............................�......................................................................4.6-58 Table 4.6-14: Project Consistency with City Master Plan for 7rails................................4.6-74 � Table 4.7-1: Existing (Ambient)Weekday Noise �evel Measurements............................4.7-7 Tabfe 4.7-2: Existing (Ambient) Sunday Noise Level Measurements...............................4.7-8 Table 4.7-3: Existing Naise Levels at Nearby Sensitive Receptors..................................4.7-9 �^ Table 4.7-4: Existing Weekday Roadway Noise Contours .............................................4.7-10 Table 4.7-5: Existing Sunday Roadway Noise Contours................................................4.7-13 „� Table 4.7-6: City of Orange Maximum Allawable Noise Exposure- Stationary Noise SQurces......................................................................................................4.7-16 Table 4.7-7: Ciry of Orange Municipal Code �:xteriar Noise Standards..........................4.7-17 � Mlchael Brandman Assoctatas � �� ' H'�.1CI�ai1(PN-)N1U 771'.3771IXKq 11:IR19.UlIItU7711NX11 SMM�.�12 tialem lY1C Anc � LETTER 10 Page 7 of 119 Salem tulheren Church and School Specitfc Plan praft EfR Table a/Contents Table 4.7-8: City of Orange Municipal Code Interior Noise Standards...........................4.7-17 Table 4.7-9: Noise Significance Threshold and Corresponding Draft EIR Impact Number.......................................................................................................4.7-21 Table 4.7-1 D: Demolition Noise Impacts at Nearby Sensitive Receptors Prior to Mitigation....................................................................................................4.7-22 Table 4.7-11: Grading Noise Impacts at Nearby Sensitive Receptors............................4.7-23 Table 4.7-12:Building Construction Noise Impacts at Nearby Sensitive Receptors........4.7-24 Table 4.7-13:Weekday Project TraKc Noise Contributions ............................................4.7-25 7able 4.7-14: Sunday Project Traffic Naise Contributions..............................................4.7-26 Table 4.7-15: Project Only Onsite Noise Sources Noise Levels at Nearby Sensitive Receptors...................................................................................................4.7-27 Table 4.7-16� Onsite Sources Maximum Noise Levels at Nearby Sensitive Receptors..4.7-28 Table 4.7-17: Stationary and Transportation Noise Impacts at Nearby Sensitive Receptors........................................................�..........................................4.7-30 Table 4.7-18: Mitigated Demolition Noise Impacts at Nearby Sensitive Receptors........4.7-33 Table 4.7-19: Vibration Source Levels for Construction Equipment ...............................4.7-34 Table 4.7-2Q: Onsite Operational Noise Impacts............................................................4.7-36 Table 4.8-1: Level of Service Descriptions- Signalized Intersections ..............................4.8-4 Table 4.8-2: Level of Service Descriptions—Stop-Cont�olled Intersections.....................4.8-5 Table 4.8-3: Transportation and Traffic Significance Threshold and CQrresponding Draft EIR (mpact Number.............................................................................4.8-6 Table 4.8-4: Existing (2010)AM Peak Hour Levels of Service.........................................4.8-8 Table 4.8-5: Weekday AM Year 2010 Existing + Project Intersection Peak Hour Levels ofService ..................................�.....,..........,...............................................4.8-19 Table 4.8-6: Sunday AM Year 2010 Existing + Project Intersection Peak Hour Levels ofService ...................................................................................................4.8-20 Table 4.8-7: Parking Requirements ................................................................................4.8-22 7able 4.9-1: Orange County Landfills...............................................................................4_9-8 Tabie 4.9-2: Utilities and Service Systems Significance Threshold and Corresponding DraftEIR Impact Number...........................................................................4.9-10 Table 5-1: Cumulative Impact Comparison..........................................................................5-2 Tahle5-2: Related Projects..................................................................................................5-3 Table 7-1: Sunday AM Existing Plus P�oject Intersection Peak Hour Levels of Service....7-12 Table 7-2: Alternative Impact Comparison by Topical Environmental Issue......................7-13 Table 7-3: Impact Summary Camparison of Project Alternatives ......................................7-23 Table 7-4: Project Objective Feasibility Comparison .........................................................7-23 Mlchael8randmen Assoclates � V� �� 11 tClirni IPN•1N�\7 7 1113 7 7 11NRIIIF.IR1'1.DWRU'!)IINNII$ccINl11?S51Cn1 IOC�kK LETTER 10 Page 8 of 119 Sa/em Lutheren Churich and School Speciflc Plen prp�,�//� 7'able o/Contents List of Exhibits " Exhibit 3-1: Regional Location Map.....................................................................................3-3 Exhibit 3-2: local Vicinity Map-Topographic Base...................... .3-5 ��" ...................................... Exhibit 3-3: Lacal Vicinity Map-Aerial Base .......................................................................3-7 Exhibit 3-4: Existing Onsite Uses.......................................................................................3-11 Exhibit 3-5: Conceptual Development Plan .......................................................................3-17 Exhibit 3-6: Landscape Master Plan..................................................................................3-15 _ Exhibit 3-7: Future Conceptual Preschool BuiNding Elevation............................................3-21 .,:,:, Exhibit 3-8: Future Conceptual Worship Center Building Elevation...................................3-23 Exhibit 3-9: Fire Department Requirements.......................................................................3-29 „� Exhibit 3-10: Phasing Plan.......................�.....,...................................................................3-35 Exhibit 4.1-1a: Site Photograph Key Map........................................................................4.1-3 Exhibit 4.1-1 b: Site Photographs 1 and 2 � .........................................................................4.1-5 Exhibit 4.1-1b: Site Photographs 3 and 4 .4.1-7 � ......................................................................... Exhibit 4.1-1 b: Site Photographs 5 and 6 .........................................................................4.1-9 .� Exhibit 4.1-1b: Site Photographs 7 and 8 ........................................................................4.9-11 � Exhibit 4,1-1b: Site Photographs 9 and 10 .....................................................................4.1-13 � Exhibit 4.1-2: Frank Lane Enhancements...,...................................................................4.1-23 Exhibit 4.1-3: Santiago Canyon Road Entry Enhancements ......................... ...4.1-27 �"� .............. Exhibit 4.1-4: Walls, Fences and Monument�tion Details..............................................4.1-29 � Exhibit 4.5-1: Preliminary Water Quality Plan...................................................................4.5-3 � Exhibit 4.5-2: Existing Hydrology....................,..................................................................4.5-7 � Exhibit 4.5-3: Erosion Preventian Plan ............................................................................4.5-33 �.�. Exhibit 4.7-1: Noise Monitoring Locations and Nearby 5ensitive Receptors....................4.7-5 Exhibit 4.7-2: Sunday Noise Contours...........,,.............................. .4.7-11 �^ Exhibit 4.7-3: Onsite Locations of Portable Li�hts and Generators................................4.7-31 � Exhibit 4.8-1: Roadwsy and Intersection Characteristics..................................................4.8-9 � Exhibit 4.8-2: Weekday School Girculation Plan.............................................................4.8-11 :�., Exhibit 4,$-3: Sunday Church Circulation Plart...............................................................4.8-13 Exhibit 4.8-4: Santiago Canyon Road Entry ...............4.8-15 ""' .................................................... Exhibit 4.8-5: Frank Lane................................................................................................4.8-17 Exhibit 4.9-1: Water System Plan .....................................................................................4.9-3 .�, Exhibit 4.9-2: Sewer System Plan.....................................................................................4.9-5 Exhibit 4.9-3: Grading, Earthwork and Storm �rainage Plan..........................................a.9-13 � Exhibit 7-1: Single Access Alternative .................................................................................7-7 � . _....� _.�._.,___ ...__—___ , �,. Mlchsel9raadmen Associates v v �jrj 111(9�m�1�N-1N)U7�IU7)ItNtV11GIR14�P61Rt17711rM�1 ScctA�a�:SaIrmTY)i'Auc � LETTER10 Page 9 of 119 RESPONSE Section 1: Introduction SECTION 1: INTRODUCTION (p 1-1) 1.1 - Purpose, and Authority of the Draft EIR (p 1-1) "...upgrading and improving storm water canveyance..."—Bio-swale in horse trail I 10-1 relocated to south side of Salem. Sewer upgrade not mentioned here. How can SLC expand when SLC cannot use church I �0-2 and multipurpose facility at same time due to sewer problems� No mention of separation between residents and church. That is the primary objective for the neighboring residents. This was supposed to have happened with the`98CUP and 10-3 we are still waiting. Separate the residents and church FIRST. Is the congregation/school growing or are the numbers lower? They do not have enough land to accommodate what they want to do unless they spill out into the neighborhood uniess SLC plans to park on the grass every service where the �0-4 congregation meets tagether. "...more efficient traffic flow..."-traffic flvw SLC has now is not working for residents-have to get Salem traffic off of residential streets and onto SLC property. I 10-5 1.1.1 - Planning Case Numbers (p 1-1) No Comment (NC) 1.1.2 - Purpose and Authority(p 2-1) The CEQq mitigation measures for construction need to be identified and spelled out and reviewed with the residents so that everyone is on the same page. �o-s 1.1.3 -Lead Agency Determination (p 1-2) "...signifitant environmental effecis that would remain after project implementation" his is something the City must pay attention to because the impact between residents and Salem—unless there is a permanent separation between SLC and the residents there will always be significant environmental effects. There are too many different uses of the same 10-7 space-residential and quasi-public. Cannot share the same space with different objectives. Over-spillage of SLC lights,traffic, noise,trash, car fumes,balls and number of people and Salem's safety issues. Alsa abuse Residents receive from Salem patrons and residents. 1.2 -Scope af the Draft EIR (p 1-2� NC Project-Level and Environmental Analysis (p 1-2) NC 1 LETTER 10 � Page 10 of 119 -- RESPONSE Section 1: Introduction � Related Actions (p 1-2) Residents require that SLC put in perrnanent separation and fence before any ather constructfon activities begin. This permanent separation needs to be a white vinyl rail fence � facing the residents with mature cypress trees planted 18"pn center to provide visual � screening, minimum of 6' high,and red painted curb on resident's side of the fence.This �o-s planting area could be part of the bio-swale far 5LC storm runoff. This needs ta be written into the project environmental analysis in th�Scope of the Draft EIR. "" initia) Study (p 1-3) � 1.2.1- Environmental issues Not Found to Be Significant �p 1-3) NC � � Agriculture and Fdrest Resources (p 1-3) NC "� � Biologicai Resources (p 1-3) � NC Cuitural Resources (p 1-4) �.,, NC '��' Geology and Soils (p 1-4? '"� ��, NC � Mineral Resources (p 1-4) M, NC ,� Population and Housing (p 1-5) � .�, "The proposed praject includes relr�cating existing preschool to an existing on-site vacant structure. Therefore the project would not displace existing housing in the project area." `�`' Objection. We believe SI,C misrepr�sented tlheir'98CUP to the City. Salem's current'98 CUP 10-9 � does not include this vacant strudure,the Fowler Property, in their currenY. Therefore, it is y� not an existing onsite structure. The church rnay be adjacent to the property, but SLC cannot �,. say it is"onsite" and they are including a private residence into their proposed plan, in violation of their own'98 CUP. `�` � Public services (p 1-5) � 2 � LETTER 10 Page 11 of 119 RESPONSE Section 1: Introduction SLC is talking about an increased number of students in the school as well as increase attendance in church services. As a result,the police have already been called out by the school because of their own activities and monitored the school traffic for two days, which 10-10 resulted in changes in the school's behavior. Increase of student population was excluded from mention in this evaluation. Please list the"incorporation of requirements from the City" What are the requirements 10-11 from the City? Recreation Is the OPA Horse Trail part of this section? The Plan does impact the OPA Horse Trail. �o-�2 1.2.2-Potentiatly Significant Environmental Issues (p 1-5) NC 1.2.3—�rganization of the Draft EIR (p 1-6) NC Section 2: Executive Summary (p 1-6) I 10-13 Final Draft should not have alternatives in itli!!! Section 3: Project Description (p 1-6) Section 4: Environmental Impact Analysis (p 1-6) Section 5: Cumulative Impacts (p 1-6� Section 6: Growth Inducing, Unavoidable Adverse, and Irre�ersible Impacts (p 1-6) Section 7: Alternatives to the Proposed Project (p 1-6) Section 8: Significant Unavoidable Adverse Impacts (p 1-7} Section 9: Other Long-Term Implications (p 1-7) 3 LETTER 10 � Page 12 of 119 RESPONSE 5ection 1: Introduction ,k,.a � Section 10: Report Preparation Resources �p ].-7) Sectian 11: References (p 1-7) � 1.3 —Technical Dacuments and Supporting Materials (p 1-7) u � Table 1-l: Technical Studies and Supporting Materials (p 1-7) ,,,.. 1.4 —l.ead Agency, Consultant, and Project Applicant (p 1-8) `�` � � Lead Agency(p 1-8) � � Environmentai Consultant �p 1-8) `�'"' � Project Appiicant (p 1-8) � 1.5—Review of the Draft EIR (p 1-$) *� .� � � n rk � � 4 � � LETTER10 Page 13 of 119 RESPONSE Seclion Z: Executive Sumir�ary 5ECTION 2: EXECU�IVE SUMMARY (p 2-1) 2.1 - Purp�se (p 2-1) No Comment (NC) 1.2 -- F'roject Summary (p 2�1) 2.2.1 - Project Location (p 2-1) Not 6.03 acres, but 5.03 according to'98 CUP because the Fowler property is not included in the '98 CUP. Cannot arbitrarily go k►ack to the older CUP as Frank and Carmen said they did. In Salern's Executive Summary presented to OPA Board and REC 10-24-2011 referring to Page 2, item 3 "Mldway through paragraph: "...exiscing buiiding on campus..."refers to rhe house. The Summery indicaies that ic already has been jncluded and opproved for use by Salem." 10-14 eullei poin�reads: "Fronk and Carmen fnformed us xhac since tire house to the wes[of the sf[e in 1973, when OPA Specfffc PJcrn was approved, was origlnaliy part of the church property they are reJniegrating that sixe back co the church. See Anira hisrory handout." This is not in compliance with the Salem '98 CUP so it is illegal. 2.2.2-Project Description (p 2-1) This is a lie! They are proposing new uses becaus�the Fowler Property is not on-site. It is a separate private residence that the use would change for. The Fowler Property is not included in the current'98 CUP. The Fowler Property is also not a "vacant structure". It is in use. Salem is using the Fowler property to park up to 7 cars each week day and up to five cars on Sundays. The house and garage are being used for a storage facility. See pictures below. �,.� � � ,� ��o�",� . rt � � - �Y3:� � °' 10-15 t a ��+ �v ;,� �� _ >,�, � � 'l LETTER10 * Page 14 of 119 RESPONSC Section 2: Executive Sumrnary a ��„�. ��a��,� �� . �«,� � ,,..,....:., s=.,. �� r�.n. �- �- .... . �� 1 ��- ' �� 10-15 , :�� < , e,u- .� �, �rww�rr!!�; CONT �' �,� i .� � __ � ' •. � �� ;o�� :� '.� � Certification of the Environmental Impact Report No. 1927�11 (p 2-Z) `"� :..� NC � ZonE Change No. 1259-11 (p 2-2) y What does this mean? I 10-16� Design Review Committee No 453&11 (p 2-2) "" � NC Specific Plan No SPLAN-OaOz (p 2-2) � What is the motivation for Specific Plan instead of a Continued Use Permit? If Salem cannvt b,�, abide by the current CUP,what makes the City believe that Salem will abide by a Specific 10-17 Plan? "" Other Additional Agenci�s Exp�cfi�d To UsF This CIR �� 2.2.3 — Project Objectives (p 2-3) OBJ-1 (p 2-3) �., Residents' Alternative Plan (RAP) proposes �nuch more suitable use of land, use and �° aesthetics with facilities and concern of residents, It is time for Salem to stop overrunning 10-18 .� the community and start giving back to the community. , � 2 � LETTER 10 Page 15 of 119 RESPONSE Section 2: Executive Summary OBJ-2 (p 2-3) The RAP provides for better appearance,visual character and appeal. OBJ-3 (p 2-3) RAP provides for the greatest possible internal circulation system,with most of the cars on Salem property instead of overflowing adjacent streets as they do now. Plus it insures fundional access and parking needs of the campus. Right now Salem is using residents East Frank Lane easements as well as Frank 5treet as parking and traffic flow. Please see RAP that shows a better parking and circulation system that keeps Salem traffic on Salem's property. OBJ-4 (p 2-3) See RAP plan that provides better parking and not utilizing the campus open space and play fields for parking. Residents are also concerned with the chemicals that are put on the grassy area in order to ne�ate the toxic spillage from vehicles that the children then play in. Public should be kept off the playing�elds with their vehicles. OB1-5 (p 2-3) See RAP with relocated Horse trail which would act as a storm water retention basin along the southern and western borders of Salem's property which is the natural receiving point of drainage water. OBJ-6 (p 2-3) 10-19 See RAP that fulfills these purposes as Salem Specific Plan does not pravide for access to Handy Creek or Santiago Creek. None of the residents want to give Salem easements rights to get the water to Handy Creek or to Santiago Creek. A storm-water system wouid be very costiy. The RAP provides for Salem's water to stay on Salem's property and seep into the ground to water trees and foliage around relocated horse trail. Structural soil as requested by the City in planting areas wouid help dist�ibute the storm water runoff and is much needed because the soils here have high tlay content. OBJ-7 (p 2-3) Salem's Specific Plan does not lncorparate sustainable design where the RAP is a sustainable design as the residents have based their plans around daily on-site observations. We tearned at the meeting with Salem on 04-19-2012 that the architects admitted that they have not been on-site observing the activities of Salem, but got their tnformation from Salem and not their own data. Salem has pro�en over and over again that Salem cannot manage their activities and traffic at this current level. How are they going to manage at a higher level? This is why a better design,such as the RAP keeps with the objective 3 with Salem keeping their awn traffic nn their own property and not impacting the community as Salem is a -- COMMUTER church/school and not a community church/school. Salem is not taking ' responsibly for their own property and abusing the rights of the other residents. 3 LETTER 10 Page 16 of 119 RESPONSE Section 2: Executive Surnmary � 2.3 Significant Unavoidable Impacts (p 2-3) The Data used to rnake these plans does not reflect what actually exists. I �0-20 � 2.4-Summary of Project Alternatives (p 2-4) The RAP would optimize all 7 objec#ives. I 10-21 � 2,4.1 -Alternatives Analyzed in 7his Draft EIR �p 2-4) � Cannot tell which the mast current plan is. F�esidents cannot tell what plan Salem is aperating from. There is such a huge diversity and dollar difference between alternatives,for example, putting in a rail fence ar Botts dots» There is no guarantee in all of these. Salem �0-22 "°� needs to be specific about the alternatives. Mle don't want the City to give approval to do �- whatever Salem wants. � 2.4.2—Environmentally Superior Alternative (p 2-4} x� Please consider the RAP as it is environmentally superior to anything 5alem has proposed.. I 10-23 "� 2.5—Summary of Environmenta) Impacts, Mitigation Measures, and Project Design Features (p � 2-4) '"�" Whoever decided there were no mitigation measures required about water drainage did not come out and view the site. Salem is telling the City it is akay for water drainage to go to a � private residents prop�erty? It sounds like the City is okay wi#h approving Salem to put in more 10-24 � parking, bigger roaf structu�es and the drainage runs off the property and down fio private residences for dispersal. "" Tahle 2-1: Impacts and Mitigation Measure Summary (P 2-5) � Section 4.1-Aesthetics Impact With such a huge building already with the multipu�pose � room and the schonl and naw they want ta rnake a 750 seat auditorium,this is way too large for the area. OPA does not have any kind of structures like this. OPA is quickly losin�the � rural country atmosphere. Saiem lutheran church and school used to be a small community 10-25 �;� church and schaal which fit the neighborhaod. Naw it is not. It is a COMMUTER schaol and church. Students come fram as far away from Huntington Beach and Mlssian Viejo. 7here is '�"' not enough room ta park all the vehicles on their own property and Salem keeps spilling out f��° inta the neighboring streets. � The chain Iink fence aruund Salem is not in a�c�cardance with the OPA. There needs to be I �o-2s �#� better screening,faliage between the schaot facilities and neighbors. The praposed building structures are too tail and too big for the area. I �0-2� "�' 5alem has got to get the vel�icles out of the r�eighborhood and onto their own �roperty which �o-2s ,�. is what the RAP helps provide. a �� LETTER 10 Page 17 of 119 RESPONSE 5ection 2: Executive Summary Sect�on 4.2-Air Quality Impact 600 cars per day, S days a week for the school w(th their motors running does impact the air quality. And Salem wants to increase the amount of ° students will raise the traffic ta approximately 700 cars a day(3,500 cars per week) plus �o-2s Saturday special events and Sunday is too much pollution in a resfdential area. Table 2-1 (cont.): Impacts and Mitigation Measure Summary (p 2-6) Section 4.3-Greenhouse Gas Emissions We disagree with the findings of impact 4.3-1 This number of vehicles in a confined area produces We belie�e that the data that was used needs to be reevaluated be compared to the actual number of vehicles idlfng waiting for up to X hour waiting to pick up kids. New data needs to be taken without notifying Salem as 10-30 Salem consistently alters their school attendance, pick up times, behavior and schedules to make themseives appear less of an impact on the area for all the studies that were taken. Table 2-1 (cont.): Impacts and Mitigation Measure Summary (p 2-7) (p 2-S) Section 4.4Hazards and Hazardous Materials The impact questions do not go far enough to address the realistic situation there at 5alem. 7here are asbestos situations that need to be �0-3� addressed that were not addressed. The Fowler House has been reported as having mold throughout the house and that was not addressed either. The neighbors have gatten unexplainable lung infections, and we believe the Fowl�r House is a cantributing factor. One thing#hat is not considered is vehicle parking on the grass, and the contaminants left behind 10-32 which children playing in the grass afterwards. Section 4.5-Hydroiogy and water quality The RAP is a superior alternative than the proposed plan for the relocated horse trail to the sauth and west property boundaries,and the perma�ent separation of East Frank Lane with tree screening is a huge opportunity for a bio-retention basin for water to seep inta the ground and water the trees. It can be a 10-33 shallow, long retention basin under the horse traii that is a superior alternative to the proposed plan and provides many viable opportunities to receive surface runoff and utilize the water for watering trees and shrubs. Table 2-1 (cont.): Impacts and Mitigation Measure 5ummary (p 2-9) 4.6-Land use and planning The impact of the large size 712 seat sanctuary and the large� school size is a major conflict to the use af land in #hat area as the number of vehicles cannot possible fit on the site. Everything is TOO LARGE for the site. It is an averuse of the space avaflable and the impact will be greater than it is naw. There is spillage over into the 10-34 residence streets, Salem patrons continually walking on private prnperty. Parking on the grass to accommodate larg�numbers is nat the proper use of the land. Salem will be parking on the grass every week. In Salem's Executive Summary presented to OPA Board and REC 10-24-2011 referring to Page 2, item 3 "Mldway througrh paragraph: "...exJsting building on campus..."refers to the house. The Summery indicafes that ft already has been included and approved for use by Salem." 10-35 Bullet poinr reads: �`ra►tk and Carmen informed us that slnce the hause to rhe west of the sit� 5 LETTER10 Page 18 of 119 RESPONSE Section 2: Executive Summary � in 1973, when OPA Specfffc P/an was approved, was arig�nolly part of che church property they are relntegrating that site back to the church. See Anit4 his�ory handout." This is not in 10-35 � CONT compliance with the Salem'98 CUP so i#is illegal. � Section 4.7-Noise Temporary sound wall saunds like it is only far Salem during �" construction. We disagree with the migratiom measures listed as it only deals with the new .._. sanctuary with a windows closed conditio�.li his does not even address the noise from the 10-36 .,.� school kids This environmental impact measures only what the larger sanctuary would do and does not study increase of the schoot. 5anct�aary use is only o� Sunday for a coupie of hours a �° week. School activities are 8 hours a day, 5 dlays a week. � Section 4.8-Trasportation If emergency vehicles cannot get through to a residents easement �� when traffic from the schooljchurch occupies the street,then there is a transportation � congestion problem. The RAP however, changes Salem's propased circulatian plan and pravides a superior circulation pian gives Salem a front door off of Santiago Canyon Road, �0-3� �"' and provides for all of Salem traffic to be an Salem property and nat on adjacent streets and ,�,,, East Frank Lane resident easement. �. The RAP provides for better emergency acce�.s than Salern's proposed plan. „� Table 2-1 (cont.): Impacts and Mifiigation Me��sure Summary(p 2-10) �° The RAP provides for better access for pedestrian and bicycle traffic by providing sidewalks '�"' where none are proposed in Salem's plan.A!�well as covered focused areas for loading and 10-38 � unloading zones that providing a safe enviro�ment in any kind of weather,which are alsa not �: provided in Salern's plan. � Table 2-1 (cont.): Impacts and Mitigation Measure Summary(p 2-11j ;.� Section 4.9 Utilities and Service Systems 1Me have heard that Salem cannot use of the ,� rnultipurpose ronm and sanctuary at the sarne time due to their sewage and water 10-39 conditions. Are their sewer and water systems adequate? Are the pipe sizes adequate? ""�' Table 2-1 (cont.}: Impacts and Mitigation Measure Summary(p 2-12) � .� � � � � � � �� G ,;� ��, LETTER 10 _ Page 19 of 119 RESPONSE Section3: Prqject Description SECTION 3: PROJECT DESCRIPTION (p 3-1) 3.1 - Project Location (p-3-1) 6.03 acres is "proposed" as the Salem`98 CUP is still in effect and we would like to know from the City why Salem is allowed to keep saying that it is included part of the praject site when it 10-40 was not included in the current'98 CUP,when Salem's CUP is their legal right to exist. In Salem's Executive Summary presented to OPA Board and REC 10-24-2011 referring to Page 2, item 3 "Mldway rhrough paragraph: `:..existing buJlding on campus..."refers io the house. The Summery fndicates that it olready hos been included and approved�or use by Solem." Bullet point reads: "Frank and Carmen Jnformed us that sJnce ihe house to rhe wes[of the slte in 1973, when OPA Speci�c Plan was approved, wos orlginally part of ihe church property 10-41 they are reincegrating that slte back to ihe church. See Ar+ita history handout." This is not in compliance with the Salem '98 CUP so it is illegal. Salem's address is on Santiaga Canyon Road and thelr main access should be on 5antfago Canyon Road. The Residents'Alternative Plan(RAP)with relocation of the horse trail to the southern part of the property instead of the northern side of the property would give Salem 10-42 this opportunity to have an entrance on Santiago Canyon Road. Everyone that has seen the RAP so far, is in total agreement, including OPA, REC and East Frank Lane Residents. 3.2 —Project Summary, Background and Site Plan Chronology (p 3-1) 3.2.1 —Project Summary(p 3-1) Salem only talks about increasing the Church activity and does not talk about increasing the 10-43 school activity. This is a�ross failure of this Specific Plan. Last paragraph,it has not been compatible with the surrounding OPA Cammunity since the 1970's. Salem says they are compatible,but the OPA community says and experiences 10-44 sornething else. 3.2.2—Project Background ( p 3-2j Where is the approved document(change of cantinuous'98 CUP)that includes the Fowler Property as the'98 CUP says that Salem will not expand from 5.03 acres? What gives Salem 10-45 the right to arb�trarily include the Fowler Property as their operating CUP when it is definitely NQT included. Exhibit 3-1 Regional Location Map No Comment (NC) Exhibit 3-2 Local Vicinity Map Topographic Base 1 LETTER10 Page 20 of 119 RESPONSE Section3: Project Description � NC Exhibit 3-3 Local Vicinity Map Aerial Base h OBJ-1 (p 3-10) „� 3.2.3 - 5ite Plan Chronology (p 3-9) Paragraph 4,Salem is saying in the presenta#ion in 2006 for the City of Orange that comrnents from neighbors made it sound like the neighbors agreed to Salem's proposed 757 flxed seat . sanctuary. The residents within 30Q feet of the church never approved anything like that. � There is no way Salem is going to pack 200�ehicles on paved surfaces on 5,03 acres, or even on 6.03 even if they turn the Fowler property into a parking lot. THESE NUMBERS ARE 10-46`�" GROSSLY MISLEADING TO THE CITY OF ORANGE. It is like trying to put 50 pounds of potatoes ,� in a 10 pound bag. That is why Salem has spillage all over the community. All of the neighbors we have talked to did not approve this plan. This plan was not reviewed by us and �� we do not know which"neighbors"gave app�oval to this pia�. � The way Salem's statements read,it laoks like Salem has gotten approvals from the '� neighbors,which is not true. At our meeting with Salem an 04-19-2012 with Salem ... representatives, Frank Carmen and Michael,we heard for the first time that Frank, Carmen �-.� and Michael thought they had been meeting with"the neighbors"as they put it,but they were not referring to us. And it was speci#ically voiced again and again that we da not know � who they met with but it was not the residents. The residents within 30Q feet of Salem 10�� .� never did give approva!of the proposed plar� as Salem states in this section. So whatever the City has heard from Frank and Carmen s�ying that the neighbors have approved their plan is "� false. They may have met with one or two neighbors that are on the boards of OPA and REC, � but Salem has never gotten consensus from ALL the neighbors within 300 feet of the church. And from what we have heard from tne neighbors on the boards,that they have been � misquoted. °Y 3.3 - Project Objectives (p 3-10) `� � Project objectives 1-7 below can better be met by the RAP which is superior to the proposed 10-48 specific plan. Piease see the RAP ""` Exhibit 3-4 Existing Onsite Uses � � The Fowler property is not vacant. it is in use as a storage facility and parking. 10-49 y* 3.4—Project Characteristics (p 3-13) ,�, Tahle 3-1: Land Use Summary (p 3-13) " Which one of these represents the use of the Fawier property7 10-50 � � 2 � LETTER 10 Page 21 of 119 RESPONSE Section3: Project Description Table 3-2: Statistical Summary (p 3-14) Total Student enrollment of 726 with 611 allowed an campus at one time per'98 CUP— whoever approved this obviously had not made in-the-field observations of the traffic which occurs every day. Currently Salem has 153 parking spaces, hawever during school hours, XXX parking spaces are not available because they are fenced off to allow the Students to play in 10-51 the qarking lot area. But Salem does not account far that in their numbers for parking spaces. The school hours impact the neighborhaod more than the weekend activities,because this school traffic happens twice a day. The totai number of students now is less than 400,and the impact is 6Q0 cars a day,3600 cars per week! And if the numbers are up to the maximum that wouid mean 800 cars a day,4000 cars per week!! What is going to guarantee the residents o�the community that there is going to be any better control with the City granting Salem a Specific Plan? The language that was in the'98 � CUP guaranteed a lot of changes and impro�ements that never took place. What is going to 10-52 guarantee anything for the residents and the cammunity if the Specific Plan is approved???????? This is why the residents, the OPA and the REC like the RAP more than anything Salem has presented. And the very FIRST thing that needs to be implemented Is a permanent separation between Salem's southern boundary and the residents on East Frank lane, with 10-53 the white rail fence and cypress trees. Second,the horse trail needs to be relacated as a bio- retention basin far Salem's run off water on the southern and western side of Salem. It is time for Salem to prove they are a good neighbor and give back to the neighborhood instead of taking for all these years. Salem's heavy use with 500+vehicles per day has caused 10-54 continuous damage to the residents'easement for the last 30 years without any irnprovement or cqmpensation. 3.4.1 —Zone Change Characteristics (p 3-14) CUP 2213-98 is Salem's right to exist,per City zaning code. However�5alem has vialated the '98 CUP by gaining the Fowler property. And naw Salem wasn't to inciude it in these specific 10-55 plans. Salem should not be allowed ta do this, because gaining the Fowler Property is a violation of thefr'98 GUP. 3.4.2—Architectural 7heme Characteristics (p 3-15) Architectural Theme (p 3-15) NC Worship Center(p 3-15) Praposal for the worship Center is WAY T0� BIG, It is all too big for the community and the area is not big enough to sustain parking and their maximum number of people. �o-5s K-8 5choal {p 3-15) 3 LETTER 10 �` Page 22 of 119 RESPONSE Section3: Project Description � � Preschool (p 3-16) ,� 3.4.3—Landscaping,Trees, Fencing, and Lighting Characteristics (p 3-�.6) Landscaping (p 3-16) "'� There are not enough trees t�shield the schc�ol so that it does not impact the community and �0-57� the Glose neighbors. Their landscaping is nor� specific. """ Fencing and Walls (p 3-16) We do not agree with chain-link fencing. I 10-58 Fencing (p 3-16) � Exhibit 3-S Conceptual Development Plan �- Exhibit 3-6 Landscape Master Plan '"�' � Exhibit 3-7 Future Conceptual Preschool Building Elevation � Use of this residential property is not conducive to a pre-school. It is bette� used as a parking 10-59� lot. It is not a goad mix. � Exhibit 3-S Future Conceptual Worship Center• Building Elevation � The structure is tao tall and too massiwe for the area. I �o-so � Wall (p 3-25) • We da not want massive walls araund the area. It could be done better with planting 10-6� materials and folia�e. � Exterior Lighting (p 3-25) *� ,�,M: Presently the exteriar lighting floods the nei�hborhood and the residents and Salem has done nothing to restrict this spillage since#he'98(:t1P. There have been several broken promises. 10-62'�' What guarantee da the residents have the S�lem is going to fix the(ighting? See picture on ,� next page. W � � .� � � a � LETTER10 Page 23 of 119 RESPONSE Section3: Project Description 10-62 CONT Parking Lot Lighting (p 3-25) They will be adjusted and shielded to avoid light trespass. Salern has been light trespassing onto the residents since the '98 CUP. What assurance to the residents have that this will be corrected? Please see the RAP to resolve Salem's light trespass/encroachment into the neighborhood. See picture below. Temporary Multipurpose Field Lighting (p 3-25) What is the consequence for going over the Iimit? Salem needs to be fined for each infraction for light over spillage and parking on the grass and the fine should be a�xed amount for each incident in a 24-hour period with documentation of the complaint. Thls needs to be incorporated into the Specific Plan dacuments. 7here are no consequences for Salem's violations. Need consequences for infractions and vialations. Good intentions are no longer enough. There has to be some teeth in the Specific Plan. If not approved, there needs to be some teeth in the CUP. And the residents and cr�mmunity would expect the City ta enforce this. 5ecurity Lighting (p 3-26) 5 LETTER10 A � Page 24 of 119 R�SPONSE Section3: Project Description � See above. ��as2 CONT ,��„ 3.4.4-Infrastructure Characteristics (p 3-26) Proposed Vehicular Access and Onsite Circulation (p 3-26) �,, We agree with the new entrance off of Santiaga Canyon Road,as that is Salem's address. I �o-ss Retention of East Frank lane access needs to be reduced to EXIT only, as proposed by `� previous City Traffic engineer,Tom Mahood. Please see our RAP that incorporates Torn 10-64 �°F Mahaod's idea. Proposed OnsiCe vehicular Parking(p 3-27) These numbers are flawed. The 180 paved surface parking spaces shauld not be counted in ^� these numbers for weekday on-ske because the parking spaces between the church and the , . play field are gated off and inaccessible during school hours. This causes traffic spilia�e all 10-65 over the community. �" Proposed Emergency Access (p 3-28) Resident access for Emergency vehicles through Salem traffic and then a "knockdown bollard"? NO THANK YOU!!!!. Been there,done that last year(March 2011) and the emergency crew said it was the worst situation th�y had ever been in,fighting Salem trafFic � and having only a 10' lane to enter residents driveway. It took them 10 minutes to get from 10-66 � the east end of East Frank Lane to the residence just past the lower grade turn around,as Salem traffic would nat move out of the way and give the right-of-way to the emergency °�' vehicle, as they are so packed on the commonly shared street. �� Exhibit 3-9 Fire Department requirements "'"' � The residents need to have their OWN emergency access with a turn-about at the fire hydrant at the west end of East Frank lane, See camment above. 10-67 ,,,� Offsite Equestrian /Pedestrian/ Bicycle Circulation (p 3-31) � � RAP would elirninate the need for crossing signals on East Frank Lane. Left turn exit only for Salem would cut down on number of vehicles using that intersection. RAP would return East 10-68 x Frank Lane back to a private dead-end street., � Water and Wastewater InfraStructure (p 3-31� `� � Have the fire hydrants been calculated far fire flows on the Salem pruperty for the proposed expansion? 10-69 � � Storm Water Conveyance and Water Quality(p 3-31j Site Drainage �p 3-31) ..� 6 � LETTER 10 Page 25 of 119 ftk-SF�UNSE Section3: F'roject I�escription This is a lie! Storm water runoff from Salem property daes NOT directiy discharge into Handy Creek as so stated. Salem runoff is all an private property. This is not per City code. See pictures below. . , � �„,. ,y,�. . � , � , { �r � � , a . �� _.'��Y;;'3&: .. y r� �.;,�. .� � � �`. ,x� 10-70 . ~....A:z:.:s � .. _ ,.� . .T - . . ..._ , ��,..... � _.� �_ � . _ . ,� ,,,• , _ .�� .`' ,;� �_�,.�� . . : .,...<--�-_ �' � r�. :r�„ �..w_ _ �;,,,a., �;a�'^ "' 9 u 3 � w._ C li�r3 � �� • f. � . � �� ..n ...- �v , f�.;,,, � .. , "�.104,.y�.n_ '�r' �yn"�4. "__. 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'« 3�r�"# .��:�+� K+;}�� r , . », -,rt �• . .. , � �. �:� ,�� )4 1' �: -'�� .i, �J �i��; r _ e • LETTER10 Page 27 of 119 RESPONSE S�ction3: Project Description - „� ..�� .�, � �'""r Y 1 -:4. � - � � • r . �`; k - ' .; . �:- - . � � .:. �. �,�.y�� ,. r �� w.,,�,r� � 10-70 CONT �� a *� ,. . ,_ _� : . ,. , ,� ' �'� � � 1,, w� .. .'.��i. '�.:v � .. � � � n. - , .. ,xM:. � �..� ., �d.,. . ,,r,�«i►„� . ... ,;,�a''' „ � ...a.�. � •�,•- 'Y;';�,'��i. �-b �' .• . v�` ��s� �� ... -� . , ...�, .� ;`.=y`.... - .. � . . . . _.:.,.�.,. � -. � �`�.�..+f� � . ��`:t ,Y-.: n�� i.:.:::.. ,+►` `t+mm. .,�.�, ,< a._' .. _ _� �_ � ' r »� +^� � ' ,.+'. '-wu•', . . .. • *�e . ,. ,�y ! . � + }. ` �M� *y�_� < �y. ! :� �i�e. �� ,.,.�,.�"�l�• 4�� . K. ' '7 LETTER10 Page 28 of 119 RE5P�NSE Section3: Project pescripti�n . � � , _ . .:,� , �� * � � t ��- �r=-� �� t . 1 , . � � ,. . ,"� . � � �� ' ��,� .� � � � , ,� R " Yfi . � � E.�. ... , y`.�: � , .. , �,,. .:.�:- �ae .,n- I� � ��0�9� ��:� ,� 10-70 CONT a� � .�, +�, -.� _ w� �� '�,'�` '`� �r �,.M'�, _ � �,�`'' ;` �' ��, � a ':�c��,�°"�'.y,�� '�:." ,r�:. .., r�t�y � wiw �'` l.�w Impact Developrn�nt (p �•-3?_) � �, 10 � LETTER 10 Page 29 of 119 RESPONSE Section3: Project Description We disagree with the hydrologic assessment. Salem claims that water discharge will be through the new entrance on Santiago Canyon Road. How can water run up hill? Also water is still allowed to drain to the west end af East Frank lane. Under city municipal codes water 10-71 is not allowed to be discharged to someone else's private property. the RAP allows Salem's water to be kept on Salem's property. 3.4.5 Services �p 3-33) NC 3.4.6—Offsite Improvements (p 3-33) Property to West is Drown Property. Property to Northwest is the property Salem is talking �0-�2 about in this paragraph. 3.5 Project Phasing (p 3-33) Table 3-3: Proposed improvements by Phase (p 3-33) Phase one should be separation of East Frank lane and relocation of horse trail. Absolutely no Botts dots. 3.5.1 —Grading and Soil Balance (p 3-34) NC 10-73 3.6—Required Public Agency Approvals and Requested Entitlements (p 3-34) NC 3.6.1—Certification of the Environmental Impact Report No. 1827-11 (p 3-34) From the residents' perspective, if there is not the permanent separation of East Frank Lane from Salem with the elements of a split-rail fence and cypress/ficus trees,and emergency turn around at the west end of East Frank Lane,the relocated horse trail with split-rail fence and shrubs,this enviranmental impact report should not be certified. 3.6.2—Zane Chan�e No. 1259-11 (p 3-34j Why should Salem be granted an SP-P1 when they have not abided by their current'98 10-74 CUP???? Exhibit 3-10 Phasing Plan NC 3.6.3—Design Review Committee No, 4538-11 (p 3-37) 11 LETTER 10 '� Page 30 of 119 RESPONSE Section3: Project Description � DRC,we are requesttng the DRC accept the RAP to be incorporated into the Salem Design for �0-�5 '� the 5pecific Plan. � 3.6.4-Specific Plan No, SPI.AN-0002 (p 3-37) ` � DRC,we are requesting the DRC accept the RAP to be incorporated into the 5alem �esign for 10-76 �,� t e Speci ic Plan. � 3.6.5-Other Additional Agencies expected to Use This Draft EIR (p 3-37) NC � � � � � � � �_ � � � � «� � �, :� � � � � 12 � � LETTER 10 Page 31 of 119 RESPOIVSE Sectinn 4: Environmental Impact Analysis RESPONSE Section 4.1-Aesthetics SECTION 4: ENVIRONMENTAL IMPAC7 ANALY515 (p 4-1) Approach and Method to Environmental Analysis (p 4-1) No comment (NC) Environmental Topics (p 4-1) NC Format Used for Impact Analysis (p 4-1) The school's existing environmental conditions were not used for a baseline to determine whether or not the impact would be significant. It was completely omitted. �o-�� 4.1—Aesthetics (p 4.1-1) 4.1.1— Introduction (-4.1-1) Purpose (p 4.1-1 Sources (p 4.1-1) 4.1.2— Environmental Setting (p 4.1-1) Regional (p 4.1-1) Vicinity (p 4.1-ij Site Conditions (p 4.1.�.) Site Conditions (p 4.1-1) Nighttime lighting (p 4.1-2) All this nighttime lighting is light trespassing to the neighbors 10-78 . � 1 LETTER10 ` ` Page 32 of 119 RESPON5E 5ectinn a: �nvironmental Impact Analysis RESPONSE Section 4.1 - Aesthetics � Picture below: Light spiliage from Salem's lights. � � .,� �, � � � 10-79 � � � � � This is a problem and impact to the residents that was not considered that was supposed to ,,,� have been fixed with the'98 CUP. As you can see, it still is not fixed. �:� This was considered not signlficant by the study, but it is an ongoing complaint from the � neighbors. It substanstantially degrades the visual character and quality of the rural atmosphere af the surrounding neighbor. There are no lights along East Frank Lane or Frank `�` Street. This is light trespassing and additional lights frorn bigger buiidings are not welcome. ,:� E� � � ,��: � �, . � � 2 w� � LETTER10 Page 33 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.1 - Aesthetics Daytime Glare (p 4.1-�) Picture below: Salem parent wearing sunglasses and shading her eyes from the sun glare to look at incoming Salem Traffic. �... � , F � � `�� -,�'� . .,'. `' .t. I �r �r. ' ` . 1r� , . . .. ,�" 7N � ? 1 ,.. • � �: ._ � a��. wu . . , . ....�s- 3 ��. '�ic . �� , �Sy�, . ,� „ , . .. __ 10-80 ,�� Sun glare fs a reai problem on East Frank Lane due to the orientation of the schooi and their pick-up zones, and ail the pedestrians,adults and children, are forced to walk on the streets with incoming/outgoing and backing up cars. East Frank Lane is in line with the sun's angle of inclination bHnding all drop-off and pick-up drivers. This was not taken into consideration. The orientation for drop-off and pick-up zones needs to change orientation to north and south. The Residents Alternative Plan takes this into consideratton and appiies it. I 10-81 Topography (4.1-2) Vegetation and Trees (p 4.1-2) 4.1.3— Regulatory Setting (p 4.1-2 Federal (p 4.1-2) State (p 4.1-2) Exhibit 4.1-1a Site Photography Key Map Fxhibit 4.1-1b Site Photographs 1 and 2 Site Phntograph 1 3 LETTER10 � Page 34 of 119 RESPON5E Section 4: Environmental Impact Analysis � RESPONSE Section 4.1 -Aesthetics � Photngraph 1: The hackyard of the onsite vacant structure. `�" � The Fowler Property is not on•site because It is not included in the'98 CUP which is still in effect. This property is in use and is nat"vacant". Salem uses the structure for storage and `�` the driv�:ways for parking on weekdays as well as Sundays, using the resident's only 10' .� easement to enter and exit. For the past years Salem has not paid for any upkeep or � maintenance of the existing resident easement. � Photograph 2: Rear parking lat looking south towards Frank Lane � Exhibit 4.1-1b Site Phatographs 3 and 4 �o-s2 � Photograph 3: This photo shows the existin�onsite vacant structure �° Again,this is not an on-site vacant structure. Why fs the car parked in the front if the � strudure is vacant? The car had to enter using the residenits'private 10'of easement. Salem � is not a resident, or the guest af a restdent and they are abusing the residents' easement. The Fowler property built out 10'into their easement so there is no southern access for that � property. "'� Photograph 4: This photo shows the athletic field, (aoking east toward Orange Park Boulevard � � Exhibit 4.1-1b Site Photographs 5 and 6 � Photograph 5: This photo shows Frank Lane, l.00king north with the church/school on the �ight :�;: and residences on the left. � This photograph does not Iook north, it looks west. I 10-83 „� Photograph 6: This is a photo of the existing entrance to the school/church along �rank Lane. r� Exhibit 4.1-1b Site Photographs 7 and 8 �` Photograph 7: This photo was taken at the driveway/entrance to the church/school property. � � Photograph 8: This photo shows Frank Lane looki�g south, with the church/school facility on the left and residences on the right. """ �s�, Exhibit 4.1-1b Site Photagraphs 9 and 10 � Photograph 9: This photo shows the athletic field, looking in a northwest direction �� Photograph 10: This photo shows the offsite equestrian trai) that runs along the eastern edge � of the project site between the project site and Orange Park Boulevard �� Local (p 4.1-15) ,„� County of Orange (p 4.1-15) _ City of Qrange (p 4.1-15) "�`` �. 4 � � LETTER 10 Page 35 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.1-Aesthetics 4.1.4—Significant Thresholds (4.1-15) 4.1.5— Project Impacts (p 4.1-16) impacts Not Found To Be Significant (p 4.1-16) - We disagree. The overuse of lighting and light spill impacts the neighbors and the surraunding daily. It creates an atmosphere of being in the city when this is supposed to be a 10-84 rural area. And it is alf night long! Potentially Significant Impacts (p 4.1-16) The sun glare can be mitigated by rerouting student drop-off and pick-up to less hazardous locations such as north/south orientation and no entrance onto Salem property on East Frank 10-85 Lane from Orange Park Boulevard. Visual Character(p 4.1-16) Impact 4.1.-1 The project will not substantially degrade the existing visual character or quality of the site and its surroundings. (p 4.1-16j Impact Analysis (p 4.1-16) Short-term Operations (p 4.1-16) Long-term Operations (p 4.7.-17) Table 4.1-1: Comparison of OPA Plan Aesthetics Policies to Salem Lutheran Church Specific Plan (p 4.1-57) Table 4.1-1 (cont.): Comparison of OPA Plan Aesthetics Policies to Salem Lutheran Church - Specific Plan (4.1-18) Table 4.�.-1 (cont.): Comparison of OPA Plan Aesthetics Policies to Salem Lutheran Church Specific Plan (4.1-19y We agree with the OPA policy, and believe Salem could do more to provide that. Please see I 10-86 Residents Alternative Plan. I 10-87 Table 4.1-1 (cont.j: Comparison of OPA Plan Aesthetics Policies to Salem Lutheran Church Specific Plan (4.1-20) Table 4.1-1 (cont.): Comparison of OPA Plan Aesthetics Policies to Salem Lutheran Church Specific Plan (4.1-21) Exhibit 4.1-2 Frank Lane Enhancements Shows a resident ingress/egress as a 16 feet lane an�l needs to be widened to a proper ` emergency vehicle width. See RAP. �o-ss 5 LETTER 10 ""` Page 36 of 119 RESPONSE 5ection 4: Environmental Impact Analysis RESPONSE Section 4.1 -Aesthetics ""'j Levei of 5ignificance Before Mitigation (p 4.1-�26j �. Miti�ation Measures (p 4.1-26) Level of Significance After Mitigation (p 4.1-2Ei) ,,,� New Source of Light ar Glare (p 4.1-26) ""` � Impact 4.1-2 The project will not create a new source of substantial light or glare wich would adversely affect day or nighttime views of the area. (p 4.1-26� "� � Impact Anaiysis (p 4.1-26) � Short-term Operations (p 4.1-26) �, Long-term Operations (p 4.1-26) � � Parking Lot Lighting (p 4.1-26) � Exhibit 4.1-3 Santiago Canyan Rvad Entry Enhancements � Exhibit 4.1-4 Walls, Fences and Manumentation Defiails "� Temporary Multipurpose field lighting (p 4.1-�1) ""� �: 5ecurity Lighting (p 4.1-31) � Level of Significance Before Mitigation {p 4.1-31� � Mitigation Measures (p 4.1-31) "� � Leve) of 5ignificance After Miti�ation (p 4.1-31) � � � � .� � ��. � � 6 � � LETTER 10 Page 37 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.2-Air Quality 4.2 —Air Quality (p 4.2-1) We disagree that the air quality has a less than significant impact. Look at RAP of Salem's existing traffic circulation drawing of RAP#Q00 dated 4-18-12. That shows Salem Traffic as it currently exists.These are idiing vehicles that are either stopped or moving very slowly,so the air quality at the tirne of school drop-off and pick-up is a hot spot in the comrr�unity. This was not taken into cansideration for the Environmental Impact Report. The picture below shows waiting cars on East F�ank Lane. .-�. 10-89 � '+� - �N .. N,,. ,� �.� ,� , � �". 1 LETTER 10 � Page 38 of 11 S R�SPONSE Section A: Environmental Impact Analysis RESPONSE Section 4.2-Air Quality ^*� The picture below shows waiting cars on Santi��go Canyon Road and Orange Park Boulevard, aU idling. „� � � �:� � " � � 10-89 CONT .w ::.� � .....�..vwr �1! � �^ �y. .t� �� .Y'.w� 111F�a.....+ x, i �` [p� � � ;:�� -, p � er..r i � r . � � '"iGiiiY " �..-w,� �• .• "":F � 'i: �ww�� ,.; in.�. „�� M�', . 3 � �� k��#� #�a ,I+ F..r�.e:iA•..., � � ._.� ' �µ . . ._..� bWW 't%,:j:�.Y .p a. .'..x.: ., . . . .�....� . , W4W..:.. . . ... � 4.2.1 —Introduction (p 4.2-1) � Purpose (p 4.2-1) � Sources (p 4.2-1) .,� 4.2.2 — Regulator Setting (p 4.2-1) "'� Federal and State Regulatory Agencies (p 4.2-1) � South Coast Air Quality Management District (��4.2-2) . Rules and Regulations (p 4.2-3) � .-.� South Coast Air Quality Management District Rules (p 4.2-3) � SCAQMD Rule 401 (p4.2-3) � SCAQMD Rule 402 (p 4.2-3) *� � Table 4.2-1: Air Pallutant Standards, Effects, Properties, and Sources (p 4.2-4) � SCAQMD Rule 403 (p 4.2-9) �t SCAQMD Rule 445 (p 4.2-9) .� � 2 � � �" LETTER10 � Page 39 of 119 RESPONSE Section 4: Environmental Impact Analysis � RESPONSE 5ection 4.2-Air Quality � Table 4.1-2 Best Available Control Measures—SCAQMO Rule 403 (p 4.2-9) �,.� � SCAQMD Rule 481 (p 4.2-10) .,�, SCAQMD Rule 1108 ( p 4.2-10) R� SCAQMD Rule 1113 (p 4.2-10) ,.. � SCAQMD Rule 1143 t p 4.2-10) ,.� SCAQMD Rule 1186 ( p 4.2-10) � SCAQMD Rule 1303 ( p 4.2-10) � Statewide Regulation (p 4.2-11) � , ARB Airborne Toxic Control Measu�e to Limit Diesel-Fueled Commercial Motor Vehicle Idiing (p � 4.2-11) ..,� ARB Final Regulation Order, Requirements to Reduce Idling Emissions from New and In-Use � Trucks (p 4.2-11) „� ARB Regulation for In-Use Off-Road Diesel Vehicles (p 4,Z-11) �" ARB Statewide Truck and Bus Rule (p 4.2-11) �,H «� Local Government (p 4.2-11) �„, 4.2.3 — Environmental Setting (p 4.2-12) ``*` Local Climate (p 4.2-12) � � Local Air Quality (p 4.2-14) � Table 4.2-3: Local Air Quality Monitoring Summary- Anaheim Pampas Lane (p 4.2-14) �" Table 4.2-4: South Coast Air Basin Attainment Status (p 4.2-15) � � Local Sources of Air Pollution �p 4.2-16) � Sensitive Receptors (p 4.2-16j `� 4.2.4 Significance Thresholds (p 4.2-16) '� The residents believe that vehicles should not be idling waiting to be picked up, but should be � parked if possible so that they will not be contributing to the bad air quality. They cannot 10-89 ��, shut their cars off on public streets,so the RAP provides for the Salem traffic to wait on CONT ,,,,,, Salem property. 3 � LETTER 10 "'" Page 40 of 119 �- RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.2-Air Quality � CEQA Guidelines (p 4.2-16� t'�� South Coast Air Quality Management ThreshoMds (p 4.2-17) Table 4.2-5: SCAQMD Significance Thresholds (p 4.2-18) .,� 4.2.5—Project Impacts (p 4.2-19) � � The residents disagree. These impacts are significant when the schaal traffic is taken Into 10-89 � consideration 2 times a day, S days a week and not just the church 4 hours on Sunday. CONT �. impacts Not Found To Be Significant (p 4.2-19) � Potentially Significant Impacts (p 4.2-19) „� Table 4.2-6: Significance Threshold and Corresponding Draft EIR Impact Number (p 4.2-19) ��. � Qir Quality Plan (p 4.2-19) � Impact 4.2-1 The project will not conflict with or obstruct Implementation of the applicable air ,� quality plan. (p 4.2-19J �:,, Impact Analysis(p 4.2-19) „� Criterion 1: Project's Contribution to Air Quality Vialatians (p 4.2-20) �° � Criterion 2: Consistency with the AQMP assurnptions (p 4.2-20) � Criterion 3: Control Measures (p 4.2-21j � Level of Significance Before Mitigation (p 4.2-2.1) - Air Quality Standard (p 4.2-21) � �. Impact 4.2-2 The praject will not violate any air quality standard or contribute substantially to �. an existing or projected ai�quality violatian. (p 4.2-21) �. Impact Analysis (p 4.2-21) � Short-term lacal construction impacts (p 4.2-2;�} �y�' Tahle 4.2-7: Short-Term Locaiized Constructio� emissions (p�4.2-23) � Long-term Local Operational Impacts (p 4.2-23) � Carbon Monoxide Hot 5pot Analysis (p 4.2-23) Table 4.2-8: Traffic Intersection Analysis —2010 (p 4.2-24) � �; 4 � � LETTER 10 Page 41 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.2-Air Quality This table refers only to Sunday analysis,which is the least impact to the area. Level of Significance before Mitigation (p 4.2-24) Mitigation Measures (p 4.2-24) Level of Significance After Mitigation (p 4.2-25) Criteria Pollutant (p 4.2-25) We request another look at this with consideration to the impact that the schaal, not just the church, has and the pollutants measured to get a base. Impact 4.2-3 The project will not result in a cumulatively considerable net increase of any criteria pollutant fir which the project region is non-attainment under an applicable federal or 10-89 state ambient air quality standard (including releasing emissions which exceed quantitative CONT thresholds for ozone precursars.) (p 4.2-25) Impact Analysis ((p 4.2-25) Criterion 1: Regional Analysis (p 4.2-26) Short-term Regional Emissions Impact Analysis (4.2-26) Table 4.2-9: Short-Term Regional Construction Emissions (p 4.2-26) Nat so concerned about short-term construction emissions. What the residents are concerned about are the operational emissions that have a long-term impact for the school operation,as this was not measured.The Sunday emissions were the only emissions that were measured. Long-term Regional Operation Emission Impacts (p 4.2-27) Table 4.10: Regional Operationa! Emissions (4.2-28) Criterion Z: Plan Approach (p 4.2-28j CriLerion 3: cumulative Health Impacts (p 4.2-29) Le�el of Significance 8efore Mitigation (p 4.2-29} Mitigation Measures (p 4.2-29) Level of Significance After Mitigativn (p 4.2-29) Sensitive Receptors (p 4.2-29) 5 LETTER 10 1� Page 42 of 119 ' r�r RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.2-Air Quality � Impact 4.2-4 The project wil) not expose sensitive receptors to substantial pollutant � concentrations. (p 4.2-29) ,� Impact Analysis (p 4.2-29) W � Criterion 1: Localized Significance Threshold Impacts (p 4.2-30) �; Criterion 2: CO Hot Spot Threshold Analysis (p 4.2-30) ,,,� Criterion 3: Indoor Air Pollutian (p 4.2-30) � Criterion 4: Toxic Pollutants (p 4.2-31) �' wr Leve) of Significance before Mitigation (p 4.2-32) � Mitigatian Measures(p 4.2-32) "'r Level of Significance After Mitigation (p 4.2-32� � wM � ri r� � � wW � � ■A! r�l � � A � ■1 � � rr� � rr� 6 � � LETTER10 Page 43 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPNSE Sectian 4.3-Greenhouse Gas Emissions 4.3 - Greenhnuse Gas Emissions (p 4.3.1) Picture below: 28 cars can wait in line with their englnes running at the lower grade pick-up at 3:00 PM. This picture was taken at 2:47PM, so they will have to wait 13 minutes. This is not signifitant to the greenhouse gas emisslons? The residents are concerned that the greenhouse gas emissians, most from the waiting vehicles during drop-off and pick-up have a significant impact and were not measures. Church activities take in only a couple of hours on the weekend and they park their vehicles and turn their engines off. The school operation, however, is completely different with 300 cars twice a day idling for an average of 10 to 30 minutes. And this was not measured. � �° `�'� �,� �� * � .� a i ;`�►` ��, „. ��'�"� 10-89 � CONT �� a . � „�� ,� .. ' ' ,.., �� ,e,=- _ �< �,'fi �. ..�.,.�<. 4.3.1 - Introduction ( 4.3-1) Purpose (p 4.3-1) Sources (p 4.3-1) 4.3.2- Environmental Setting (p 4.3-1) Greenhouse Gases (p 4.3-7_) Table 4.3-1: Greenhouse Gasses (p 4.3-3) 4.3.3 � Regulatory 5etting (p 4.3-4) Federal (p 4.3-4) 1 LETTER 10 Page 44 of 11� RESPONSE Section 4: Environmental Impact Analysis RESPNSE Section 4.3-Greenhouse Gas Emissions �^^ State (p 4.3-5) �� .,. Title 24 (p 4.3-5) Catifornia Green Building Standard (p 4.3-6) � Pavley Regulations(p 4.3-6) �" � Executive Order S-3-OS� (p 4.3-6) � Low Carbon Fuel Standard —Executive Order 5-01-07 (p 4.3-6) ,� AB 32—(p 4.3-7) . � Local (p 4.3-7) 4.3.4—Significant Thresholds (p 4.3-8) ;�, SEQA Guidelines (p 4.3-8) '� City of Orange Thresholds �p 4.3-8� � k-. 4.3.5—Projeet Impacts (p 4.3-9) � We believe this analysis is incorrect as it did not take into account the waiting vehicles for the � school activities. � Impacts Nvt Found To Be Significant (p 4.3-9) � Potentially 5ignificant Impacts (p 4.3-9) "� � Table 4.3-2: Greenhouse Gas Emissions Signiflcant thresholds and corresponding Draft EIR Impact Number(p 4.3-10) 10-89 "'" CONT,� Greenhouse Gas Emissions Generation (p 4.3-:10) .� Impact 4.3.-1 Although the project would generate greenhouse gas emissions thee emitions would not have a significant impact on the enwironment. (p 4.3-10j � Impact Analysis p 4.3-10) �� We believe this analysis is incarrect as it did not take into account the waiting vehicles for the �� schaol activities. °°� �� Short-term Operations (4.3-11) Table 4.�-3: Construction Greenhouse Gasrd (p 4.3-12) �Ya � I�' 2 � �� LETTER10 Page 45 of 119 RESPONSE Sectian 4: Environmentai Impact Analysis RESPNSE Section 4.3-Greenhouse Gas Emissions Long-term Operations (p 4.3-12) Table 4.3-4: Operational Greenhouse gases (p 4.3-12) Tofial Annualized (p 4.3-13) Table 4.3-5: Total Annualized Greenhouse Gas Emissions (p 4.3-13) Level of Significance before Mitigation (p 4.3-�.3) Mitigation Measures (p 4.3-13) Level of Significance After Mitigation ( p 4.3-13� Conflict with existing Plans or Policies (p 4.3-14) Impact 4.3-2 The project would not conflict with an applicable policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases. (p 4.3-14) Impact Analysis (p 4.3-14) We believe this analysis is incarrect as it did not take into account the waiting vehicles for the school activities. Table 4.3-6: General Plan Consistency (p 4.3-14) Level of Significance Before Mitigation (p 4.3-17) Mitigation Measures(p 4.3-17) Level of Signifcance After Mitigation (p 4.17) �o-8s CONT Climate Change Adaption (4p 4.3-17) Impact 4.3-3 The project would not be significantly impacted by climate change induced impacts from a reduced waters supply, increased wildfires, or flooding. (p 4.3-17j Impact Analysis (p 4.3-17) We believe this analysis is incorrect as it did not take into account the waiting vehicles for the school activities. Reduction of Water Supply (p 4.3-17) Increased Wildfires (p 4.3-18) Flooding (p 4.3-18) 3 LETTER 10 � Page 46 of 119 RESPONSE Sectian 4: Ernironmentai Impact Analysis ~� RESPNSE Section 4.3-Greenhouse Gas Emissions �* Level of Significance before Mitigation (p 4.3-19) ` � Mitigation Measures (p 4.3-19) Level of Significance After Mitigation (p 4.3-7.9) �,,: �4 � � � � � �� .�: .� �,; �: � � � � � � �. 4 � �� LETTER10 Page 47 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.4 Hazard and Hazardaus Materiais 4.4 Hazard and Haiardous Materials (p 4.4-1� Please see comments in Executive Summary also. I 10-90 4.4.1— Introduction (p 4.4.-1) Purpose (p 4.4-1) Sources (p 4.4-1) 4.4.2 - Environmental setting (p 4.4-1) Vicinity (p 4.4-1) Underground Storage 7ank (p 4.4-1) Leaking Underground Storage Tanks (LUST) (p 4.4-2) Historical Underground Storage 7anks (HIST U57) (p 4.4-2} � Statewide Environmental Evaluation and Planning System (SWE�PS) (p 4.4-2) Review of Potential Hazardous Conditions in Project Vicinity (p4.A-3) CORTESE (p 4.4-2� Site Conditions (p4.4-3) Asbestos (p 4.4-3) Lead �p 4.4-4) Pesticides (p 4.4-4) 4.4.3— Regulatory Setting (p 4.4-4) Federa) (p 4.4-4) Resource Conservation and Recovery Act (p 4.4-4) Comprehensive Environmental Response, Compensation and Liability Act (p 4.4-4) State (p 4.4-5) California Health and Safety Code (p 4.4-5) Transportatian of Hazardous Materials (p 4.4-5) 1 LETTER 10 '""" Page 48 of 119 �: RESP�NSE Section 4: Environm�nta) Impact Analysis RESPONSE Section 4.4 Hazard and Hazardous Materials ""� Local (p 4.4-5) �� County of Orange (p 4.4-5) City of Orange Municipal Code (p 4.4-5) ,,,� Orange Fire Department (p 4,�-6) ��` �rr 4.4-4—Significance Thresholds (p 4.4-6) � a.4.5 — Project Impacts (4.4-7j r�: Impacts Nat Found To Be Significant {p 4.4-7� '""' � These buildings and are suspect for the presence of asbestos and we did not see an asbestos �� survey among the haxardaus materials. They did not list the presence of mold and it is know that there is mold existing in the present vacant structure known as the Fowler House. Many � of the residents have b�en getting lung infec#ions. Just recently Tom experienced for the first 10-91 „� time in his life,had a lung infection--source unknvwn. Other neighbors are experiencing a lot of respiratory prablems also. So, with the known mold that is prevalent in the Fowler � House, it would be wise to have an investigation prior to the City making a determination on .,, this. � Potentially Significant Impacts 9p 4.4-7) �,b Table 4.4-1: Hazards and Hazardous Materials Si�nificance Threshold and Correspanding Draft '�^" EIR impact Number (p 4.47) ._.. Routine Use (p 4.4-8) "" Impact 4.4-1 The project wil) not create a significant hazard ta the public or the environment th�ough the routine transport, use or disposal of hazardous material (p 4.4-8� ""� �:: Impact Analysis (p 4.4-8) � Short-term Operations (p 4.4-9) ,,,,,, Long-term Operations (p 4.4-8) � �:� Level of Significance 6efore Mitigatian (p 4.4-f�) �� Mitigation Measures( p 4.4-8) :.k Leve) of Significance After Mitigation (p 4.4-8) '"" Risk of Wiidfires (p 4.4-8) � � z � � LETTER 10 Page 49 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.4 Hazard and Hazardous Materials Impact 4.4-2 The project will not expose peaple 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. (p 4.4-8) Impact Analysis (P 4.4-8) Short-term Operations (4.4-9) Long-term Operations (4.4-9) Level of Significance 6efore Mitigation (p 4.4-9) ' Mitigation Measures (p 4.4-9) Level of Significance After Mitigation (p 4.4-9) 3 LETTER 10 � Page 50 of 11 f RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.5-Nydrology and Water Quality ^^� 4.5 — Hydrology and Water Quality (p 4.5-5� � I 10-92 Please see cornments in Executive Summary. � Storm water collecting at lower grade turn around. ��. � .,;� � , ,� � ' d � "+�d/' � �:3...: .w. � A` Mp . a ,e.�. ':',�,�""'.. � �� WRr,p � ','� .�pn'r. R.�.. R � � 10-93 �-' � Picture below: Storm water filling culvert under front dri�eway to Fowler house. �.. i II �f)R �,.�y�'-',,� _X,, ,s ' -..�y�j . ��'1'� ��'�.,,�` ,r.-S�` ��a, M�"J��t#� f� "9fj ��i� � !e!R ��k � '� �'t t"� i�i / ��' �d�a �� ~ �' _,�.��° °� ��.'� � ��:. , - W .;a" .. � . , t'� �_ � � ��R��a � � .'�� ` ' "�i' �''�� , �,» ..w..�'''_..- �'� �` � ��a , '":' � �, _ �, '� �` ..�f. `,�}4' �� ` � �o�. I`'8"" �� `. ^�� f '��,r�` �' . t � '��Y"+ � � ��, ,ma � ,� � W � � - � _ � '° �� „z-: , ,. � }�'..• ' ,�� n.* �',iy, s•Y�"�.- np . j�, �/�� R .�Ry�� _ ^iV � � y � y, �<b+y.��'ri �1 R w. v1t y�e, .. . ':�s, 3[ 'NR d c '�,.`. Q„ g, ' ''��.e � ' ' . , .. ... . .n �83��"3"N`�''�"Ra ' �a"L� . " . . ' - .. � . . 1 � .�. LETTER 10 Page 51 of 119 RESPONSE Section 4: Environmental Impact Analysis R�SPONSE Section 4.5-Nydrology and Water Quality Picture below: Water from Salem runoff continuing down ta resident's property at west end of East Frank Lane. Y P = 10-93 � CONT .. ,.� - �� '�;�, M�;i� � �� .+",9`,�,'s.�'�°F . :....�:s'.� � y ' 4.5.1 — Introduction (p 4.5-1) Purpose (p 4.5-1) Sources (p 4.5-1) 4.5.2 —Environmental Setting (P 4.5-1) Regional (p 4.5-].) Vicinity (p 4.5-2� Site Conditions (p 4.5-2) Surface Hydrnlogy (p 4.5-2) Exhibit 4.5-1 Preliminary Water Quality Plan Table 4.5-1: Salem Lutheran Church and School Existing Condition Runoff Volume Summary and Peak Low Rate (p 4.5-5) Table 4.5-2 : : Salem Lufiheran Church and School Praposed Condition Runoff Volume Summary and Peak Low Rate (p 4.5-6) 2 LETTER10 � Page 52 of 119 RESPONSE Section 4: Environmenta) Impact Analysis RESPONSE Section 4.5-Hydrology and Water Quality *� Exhibit 4.5-2 Existing Hydrology Table 4.5-3: Year Storm Event Conditions (Hydromodification)— Peak Flow Rage (Qf {p 4.5-10 Table 4.5-4: Year Storm Event Conditions (Hydromndification)—Time of Concentration (p 4.5- 10) � Table A.S-6: Year Storm Event Conditions lHydromodification)- Volume (p 4.5-10) � Offsite Receivin�Waters (p4.5-11J Water Quality (p 4.5-11) �..� Table 4.5-6: Antidpated and Potential Pollutants Generated by Land Use Type (p 4.5-12) F � Flooding (p 4.5-12) 4.5.3—Regulatar Setting(4.5-�2) ,� Federal (p 4.5-13) � � Federal Clean Water Act (p 4.5-14) � National Pollutant Discharge Elimination System Permits (p 4.5-13� � State (p 4.5-14j � Loca) (p 4.5-16j � .�, City of Orange (4.5-16) � Drainage Area Management Pla� (p 4.5-16) Local Implementatio� Plan (p 4.5-16) � Water Quality Management Plan (4.5-16) � 4.5.4—Proposed Water Quality Conditions (p�4.5-17) � Short-Term Operations (p 4.5-17') �j General Construction Permit (p 4.5-18j � Table 4.5-7: Combined Risk Level Matrix (p 4.5-20 a,�. Post-Construction Activities (p 4.5-20) Table 4.5-8: Site Design BMPs (p 4.5-21) 3 � LETTER 10 Page 53 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.5-Hydrology and Water Quality Table 4.5-9: Non-Structural Source Control BMPS (4.5-21) Table 4.5-10: Structural Sources Cantrol BMPs (p 4.5-22) LID Features— Infiltration BMPs(p 4.5-23) Tabie 4.5-11: Infiltration (p 4.5-24) Drainage Area "A" (p 4.5-24) Drainage Area "B" (p 4.5-25) Drainage Area "C" (p 4.5-25) Drainage Area "D" (p 4.5-25) Drainage Area "E" (p 4.5-25) Drainage Area "F" (p 45-25) Infiltration BMP Calculatinns (p 4.5-25) Table 4.5-12: Preliminary Water Quality Treatment Summary ( p 4.5-26) 4.5.5—Significant Thresholds (p 4.5-27) 4.5.6— Project Impacts (p 4.5-28) Impacts Not Found to be significant (p 4.5-28) Potentially Significant Impacts (p 4.5-29) Table 4.5-13: Hydrology and water Quality Significance Threshold and Corresponding Draft EIR Impact Number (p 4.5-29) Violate Standards or Requirements (p 4.5-3p) Impact 4.5-1: The project will not violate any water quality standards or waste discharge requirements (p 4.5-30) _ Impact Analysis (p 4.5-30) Shnrt-term Operations (p 4.5-30) Long-term Operations (p 4.5-31) Level of Significance Before Mitigation (p 4.5-31) 4 LETTER 10 �n Page 54 of 11� � RE5PONSE Section 4: Environmental impact Analysis RESPONSE Section 4.5-Hydrology and Water Quafity ""` � Mitigation Measures (p 4.5-31) � Level of Significance After Mitigation (p 4.5-37j Erosion or Siltation p 4.5-32) � impact 4.5-2 The project will not substantially aiter 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 a substantial erosion or siltation on-or offsite. (p 4.5-32) Impact Analysi5 (p 4.5-32) �°' Short-term Operations (p 4.5-32) � � long-term Operations (p 4.5-32) Leve) of Significance Before Mitigation (p 4.5-32) � �� Mitigation Measures (p 4.5-32) � Exhibit 4.5-3 Erosion Prevention Plan � Level of Significance After Mitigation (p 4.5-3�i) � Floading (p 4.5-35) � Impact 4.5-3 The project will not substantially alter the existing drainage pattern of the site or � area, including through the alteration af the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on-ar � offsite. ((p 4.5•35) y, Impact Analysis (p 4.5-35) � Short-term Operations (p 4.5-35) � � Long-term Operations (p a.5-3Sj � Level of Significance Before Mifiigation (p 4.5-:35) Mitigation Measures(p 4.5-35) � Level of Significance After Mitigation (p 4.5-35) Runoff Water (p 4.5-36� � See RAP that fulfills these purposes as Salem Specific Plan does nat provide for access to "�° Handy Creek or Santiago Creek. None of the residents want to give 5alern easements rights 10-94 ,�, 5 � � LETTER10 Page 55 of 119 RESPONSE Section a: Environmental Impact Analysis RESPONSE Section 4.5-Hydrology and Water Quality to get the water to Handy Creek or to 5antiaga Creek. A storm-water system would be very costly. The RAP provides for Salem's water to stay on Salem's property and seep into the ground to water trees and foliage around relocated horse trail. 5tructural soil as requested 10-94 by the City in ptanting areas would help distribute the storm water runoff and is much CONT needed because the soils here have high clay content. Whoever decided there were no mitigation measures required about water drainage did not come out and view the site. Salem is telling the City it is okay for water drainage to go to a private residents property? It sounds like the City fs okay with approving Salem to put in 10-95 more parking, bigger roof structures and the drainage runs off the property and down to private residences for dispersal. Impact 4.5-4 The project will not create ar contribute runoff water which would exceed the capacity of existing or planned storm water drainage systems or provide substantial additionat sources of polluted runoff. (p 4.5-36) Impact Analysis (p 4.5-36) Salem's proposal appears to use alternative A to connect their some of their on-site overland flow to an existing drain in Santiago Canyon Road. They are proposing an on-site storm system. The RAP provides for a horse trail/bia-swale retention basin that would take care of all the sheet flow for both the school and the church,and not require the proposed drainage system. 10-96 Plus it would keep ar�d utilize Salem's water on site. Short—term Operations (p 4.5-36) Long-Term Operations (p 4.5-36) Alternative "A" (p 4.5-36) Alternative "B" (p 4.5-36) Alternative "C" (p 4.5-36) -� Level of Significance Before Mitigation (p 4.5-36) Mitigation Measures �p 4.5-37) Level of Significance After Mitigation (p 4.5-37) ��° Water Quality(p 4.5-37) Impact 4.5-5 The praject will not otherwise substantially degrade water quality(p 4.5-37) Impact Analysis (p 4.5-37) 6 LETTER 10 ', Page 56 of 11!�� RESPONSE Section 4: Environmental Impact Analysis �� RESPONSE Section 4.5-Hydrology and Water Quality "°""" Short—term Operatians (p 4.5-37) �� Long-Term Operations (p 4.5-37) �.,w Level of Significance Before Mitigation (p 4.5-37) ,.�, Mitigation Measures(p 4.5-37) � � Level of Significance After Mitigation (p 4.5-37) Stormwater Runoff(p 4.5-37) „� Impact 4.5-6 7he project will not potentially impact stormwater runoff from construction "`"� activities. (p 4.5-37) � Impact Analysis (p 4.5-37) `� � Short—term t3perations (p 4.5-3'7) :� Table 4.5-14; ConstrucCion-Related Pollutants (p 4.5-38) „� Long-Term Operations (p 4.5-40) '� � Level of 5ignificance Before Mitigation (p 4.5-40) � Mitigation Measures (p 4.5-40) � Leve) of Significance After Mitigation (p 4.5-40) "�' Post-construction Stormwater Runoff�p 4.5-4Dj � � Impact 4.5-7 The project will nat potentially impact stormwater runoff from post-construction � activities. (p 4.5-40) � Impact Analysis (p 4.5-4Q) � Short—term Operations (p 4.5-41) �°� � Long-Term Operations (p 4.5-41) .:..;� Level of Significance Before Mitigation (p A.5-41) � Mitigation Measures (p 4.5-41) 3-� Level of Significance After Mitigation (p 4.5-41) � Stormwater Affect on Receiving Waters (p 4.5-41) � 7 � �. LETTER10 Page 57 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.5-Hydrolagy and Water Quality Impact 4.5-8 The project wili not resuit in the potential far discharge of storm water to affect the beneficial uses of the receiving waters.. (p 4.5-41) Impact Analysis (p 4.5-41) Short—term Operations (p 4.5-41) Long-Term Operations (p 4.5-41j Table 4.5-15: Beneficia) Uses (p 4.5-42) Level of Significance Before Mitigatian (p 4.5-42) Mitigation Measures (p 4.5-42) Level of Significance After Mitigation (p 4.5-42) Stormwater Runoff Velocity and Volume (p 4.5-43) See comments under Runoff water impact 4.5-4 on page 4.5-36. 10-97 Impact 4.5•9 The project will not create the potential for significant changes in the flow velocity of volume of stormwater runoff to cause environmental harm. (p 4.5-43� Impact Analysis (p 4.5-43) Short—term Operations (p 4.5-43) Long-Term Operations (p 4.5-43) Level of Significance Before Mitigation (p 4.5-43) Mitigation Measures (p 4.5-43) Level of Significance After Mitigation (p 4.5-43) Increase Erosion (p 4.5-44) Impact 4.5-10 The project will not create significant incr�ases in erosion of the project site or surrounding areas. (p 4.5-44) Impact Analysis (p 4.5-44) Short--term Operations (p 4.5-44� Long-Term Operations (p 4.5-44) Level of Significance Before Mitigation (p 4.5-44} 8 LETTER10 � Page 58 of 119 RESPONSE Section 4: Environmenta) Impact Analysis RESPONSE Section 4.5-Hydrology and Water Quality �" Mitigation Measures (p 4.5-44) � � Level of Significance After Mitigation (p 4.5-44j � � � � � � .� � � �� = � � � �.. � � 9 ,�, �, LETTER 10 Page 59 of 119 RESPONSE 5ection 4: Environmental Impact Analysis RESPONSE Section 4.6- Land Use and Planning 4.6- Land Use and Planning (p 4.6-1) Please see comments in Executive Summary. I �o-9s 4.6.1--Introductian (p 4.6-1) Purpose (p�t.6-1� 4.6.2—Environmental Setting (p 4.6-1) Regional (p 4.6-1} Vicinity (p 4.6-2) Site Conditions(p 4.6-2) 4.6.3—Regulatory Setting (p 4.6-2) Federal (p 4.6-2) State (p 4.6-2) Regional (p 4.6-2) South Coast Air Quality Management District Air Quality Management Plan (p 4.6-2) Southern California Association of Governments Regional Comprehensive Plan (p 4.6-3) Natural Communities Conservation Plan (NCCP) and Habitat Conservation Plan—County of Orange Central and Coastal Sup Region (p 4.6-3) Local (p 4.6-4) Orange Park Acres Specific Plan (p 4.6-4) City General Plan (p 4.6-4j City Master Plan of Recreational Trails (p 4.6-4) City of Orange Zoning Designations (p 4.6-5) - City's Tree Preservation Ordinance (p 4.6-5) 4.6.4—Significant Thresholds (p 4.6-5) 4.6.5— Project Impacts (p 4.6-5) i LETTER 10 � Page 60 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Sectian 4.6- Land Use and Planning � Impacts Not Found To Be Significant (p 4.6-5) Potentially Significant Impacts (p 4.6-5) Table 4.6-1: Land Use and Planning Significance Threshold and Correspondin� Draft EIR impact Number (p 4.6-6) Conflict with Plans, Policies, or Regulations (p 4.6-6) � Impact 4.6-1 The project will nvt canflict 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 ordinancej adopted fot the purpose of avoiding or mitigating an enviranmental effect. (p 4.6-Ej � Impact Analysis (p 4.6-6) City�oning District(p 4.6-6) � .�: Level of Significance Before Mitigation (p Q.6-A) � Mitigation Measures (p 4.6-7) � Level of Significanc�After Mitigation (p 4.6-7) � Orange Park Acres Plan (OPA Plan) (p 4.6-7) ¢ � Table 4.6-2: Proposed Project Consistency with Orange Park Acres Specific Plan (p 4.6-7) �� Level vf Significance Before Mitigation (p 4.6-18j � Mitigation Measures (p 4.6-18) �Y�Y � Level of Significance After Mitigation (p 4.6-18) City Genera) Plan (p 4.6-18) ,�, General Plan— Land Use Element (p 4.5-18) �" � Table 4.6-3: Project Consistency with the City of Orange plan: Land Use Element (p 4.6-19) General Plan—Public Safety Element (p 4.6-30) ,� Table 4.6-5: Praject Consistency with the City of Orange Genera) Plan: Public Safety Element � (p 4.6-30) �., General Plan—Circulation and Mobility Element (p 4.6-34) � 2 ,�, LETTER 10 Page 61 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.6- Land Use and Planning Table 4.6-6: Project Consistency with the City of Orange General Plan: Circulation and Mobility Element (p 4.6-34) General Plan—Noise Element (p 4.6-38) Table 4.6-7: Project Consistency with the City of Orange General Plan: Noise Element (p 4.6-39) General Plan--Cultural Resources and Historical Preservation Element (p 4.6-42) Table 4.6-8: Project Consiste�cy with the City of Orange General Plan: Cultural Resources and Historic Preservation Element (p 4.6-42) General Plan—Infrastructure Preservation Elerr�ent {p 4.6-44) Table 4.6-9: Project Consistency with the City of Orange General Plan: Infrastructure Element (p 4.6-45) Genera) Plan—Urban Design Element (p 4.6-47) Table 4.6-10: Project Consisfiency with the City of Orange General Plan: Urban Design Element (p 4.6-48} General Plan—Growth Management Element (p 4.6-51) Table 4.6-11: Prvject Consistency with the Gity of Orange General Plan: Growth Management Genera) Plan—Economic Development Element (p 4.6-54) Table 4.6-12: Project Consistency with the City of Orange General Plan: Economic Development Element (p 4.6-54) General Plan—Housing Element (p 4.6-57) Table 4.6-13: Project Consistency with the City of Orange General Plan: Housing Element (p 4.6-58) Level of Significance Before Mitigation (p 4.6-74) Mitigation Measures (p 4.6-74) Level of Significance After Mitigation (p 4.6-74) City Master Plan for Trails Table 4.6-14: Project Consistency with the City Master Plan for 7�ails (p 4.6-74) 3 LETTER 10 '� Page 62 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.6- Land Use and Planning '�" Level of Significance Before MiCigation (p 4.6-76) � Mitigation Measures (p 4.6-76) Level of Significance After Mitigation (p 4.6-76) � � � � K=`ai � �N7r �` � � �&'v � �' � � ��. � �9': I� Alirt" 9WMt � 4 „� LETTER 10 Page 63 of 119 RESPONSE Section 4: Environmenta) Impact Analysis RESPONSE Section 4.7—Nnise 4.7— Noise (p 4.7-1) Please see comments in Executive Summary. I 10-99 4.7.1 — Introduction (p 4.7-1) Purpose (p 4.7-1) Sources (p 4.7-1) 4.7.2 — Environmental S�tting (p 4.7-1) Regional (p 4.7-1� Vicinity (p 4.7-1) Site Conditions (p 4.7-1) Noise Description and Standards (p 4.7-2) Noise Descriptors (p 4.7-2) Vibration Descriptors (p 4.7-2) Noise Standards (p 4.7-3) Vibration Standards (p 4.7-4) Transportation-Related Noise (p 4.7-4) R r, b . � . ., � " '� '` 10-100 .i. , . � �� T� � ,� � � _�_ �,�� .i, . �,�` �„ . _. ___ .., � �,.;�- �cP' ��; 1 LETTER 10 -- Page 64 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.7-�Noise ' Two lanes of traffic coming in-vehicular noise , � r� b �p�e� ,�� , , `w � '��x : ?� } ��.� e. �; ,�. �..f � �� .. � �� -. �-- ::: . 10-100 .:r:�w.. �,,�, = CONT "" �,�,�►;�.� Q� .,,,�_� c�. �� - � . ,�� _ . �. � � Field Survey (p 4.7-4) �< Measurement Procedure and Criteria (p 4.7-4) � Exhibit 4.7-1 Noise Manitoring Locations and Nearby 5ensitive Receptors "'� � Table 4.7-1: Existing(Ambi�nt) Weekday Noise Level Measurements (p 4.7�7) � Table 4.7-2; Existing (Ambient) Sunday Noise l,eve) Measurements (p 4.7-8) � SaundPlan Modeled Existing Naise Levels (p 4.7-8) '"� SoundPlan Modeling Results (p G.7-9) „� � Table 4.7-3: Existing Noise Levels at Nearby Sensitive Receptors (p 4.7-9) ,� FNWA Model (p 4.7-10) "� FNWA Model Results (p 4.7-10) � 7able 4.7-4: Existing Weekday Roadway Noise Contours (p 4.7-1Q� _ Exhibit A.7-2 Sunday Noise Contours """ Table 4J-5: Existing Sunday Rnadway Naise Contours (p 4.7-13) � 2 LETTER10 Page 65 of 119 RESPONSE Section 4: Environmental impact Analysis RESPONSE Section 4.7—Noise Construction Related Noise (p 4.7-13) 4.7.3— Regulatory Setting (p 4.7-14) Federal (p 4.7-14) State (p 4.7-15) Local (p 4.7-15) City of Orange— Municipal Code (p 4.7-15) Noise Standards (p 4J-16} Table 4.7-5: City of�range Allowable Noise Exposure—Stationary Noise 5ources (p 4.7-16) City of Orange Municipal Code (p 4.7-16) Section 8.24.050 Exterior Noise Standards (p 4.7-16j Table 4.7-7: City of Orange Municipal Code Exterior Noise Standards (p 4.7-17) 8.24.060 Interior Noise Standards (p 4.7-17) Table 4.7-8: City of Orange Municipal Code Interior Noise Standards (p 4.7-17) City of Orange General Plan Noise Element (p 4.7-18) Goal 1.0: (p 4.7-18) Goal 2.0: (p 4.7-19) 4.7.4—Significant Thresholds (p 4.7-20) 4.7.5— Project Impacts (p 4.7-20) Impacts Not Found To Be Significant (p 4.7-20 Potentially Significant Impacts (p 4.7-21) Table 4.7-9: Noise Significant Threshold and Cc�rresponding Draft EIR Impact Number (p 4.7-21 Noise Levels �p 4.7-19) Impact 4.7-The project will not expose persons to or generation of noise level in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. (p 4.7-21) 3 LETTER10 Page 66 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.7—Noise `� impact Analysis (p 4.7-Z2j � Short—term Operations (p 4.7-22) 1)Demolition (p 4.7-22) � Table 4.7-10: Demolition Noise Impacfs at Ne��rby Sensitive Receptors Prior To Mitigation (p 4.7-22) � 2)Grading(p 4.7-23) � Table 4.7-11: Grading Noise impacts at Nearby Sensitive Receptors (p 4.7-23) 3)Building (P 4.?-z3) � Table 4.7-12: B�ilding Construction Noise Impacts at Nearby Sensitive Receptors (p 4.7-24) � Long-term Operations (p A.7-24) 1)Potential Offsite Vehicular Noise Impacts (p�.7-25) „� Weekday Conditions (p 4.7-25) `� � Table Q�.7-13: Weekday Project Traffic Noise Contributions (p 4.7-25) �; Sunday Conditions (p 4.7-26) „�, Table 4J-14: Sunday Project Traffic Noise Contributions �p 4.7-26) �°" � 2)Potential Operationa)Stationary Noise Impacts{p 4.7-27) � Average Noise Level (L�q) Impacts (p 4.7-27') �, Table 4,7-15: Project fJnly Onsite Noise Sources Noise Levels at Nearby Sensitiue Receptors �" (P 4.7-27) � Ff�� Maximum Noise Level (t�qj Impacts (p 4.7-28) �, Ta61e 4.?-16: Onsite Sources Maximum Noise Levels at Near6y Sensitive Receptors � (p 4.7-28) � 3) Potential Operational Statianary and Transportation Noise Offsite Impacts (p 4.7-29 � Project Impacts (p 4.7-29) • Table 4.7-17: Stationary and T`ransportation Noise Impacts at Nearby Sensitive Receptors "� 4 „�. LETTER10 � Page 67 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.7—Noise (p 4.7-30) Exhibit 4.7-3 Onsite Locations of Portable Lights and Generators Level of Significance Before Mitigation (p 4.7-33) Mitigation Measures (p 4.7-33) Level of Significance After Mitigation (p 4.�-33) Table 4.7-18: Mitigated Demolition Noise Impacts at Nearby sensitive Receptors (p 4.7-33) Groundborne Vibration or Noise (p 4.7-34) Impact 4.7-2 Exposure of persans to or generation of excessive groundborne vibration or groundborne noise levels? (p 4.7-34) Impact Analysis (p 4.7-34) Shart-term Operations (p 4.7-3A) Table 4.7-19: Vibration Source Levels for Construction Equipment (p 4.7-35) Long-term Operations (p 4.7-35) Level of Significance Before Mitigation (p 4.7-35) Mitigation Measures (p 4.7-35) level of Significance After Mitigation (p 4.7-35j Substantial Increase of Ambient Noise (p 4.7-35) Impact 4.73 A substantial temporary or periodic increase in ambient noise levels in the project vicinity is not above levels existing without the project. (p 4.7-35) Impact Analysis (p 4.7-35) Shart-term �perations Level of Significance Before Mitigation (p 4.7-35) Mitigation Measures (p 4.7-35) Level of Significance After Mitigation (p 4.7-35) long—term Operations (p 4.7-36) Potential Operational Onsite Noise Impacts (p 4.7-36► 5 LETTER 10 '"�' Page 68 of 119 RESPONSE Section A: Environmentai Impact Analysis RESPONSE Section 4.7—Noise Table 4J-20: Onsite Operational Noise Impacts (p 4.7-36) Level of Significance Before Mitigation (p 4.7-36) Mitigation Measures(p 4.7-37) - Level of Significance After Mitigakivn (p 4.7-37) � � � � � � � ��. � �< � � � 4�=Rs � �ti': �' � 6 � LETTER 10 Page 69 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.8 - Transportation and Traffic 4.8 - Transportation and TrafFic (p 4.8-�) Please see comrnents in Executive Summary. Picture below shows large truck that mistakenly came down East Frank l.ane. He had to back up in the lower grade turn around with cars parked there waiting to drop off students. It took him six points of maneuvering ta turn around and go back the opposite way. There is no sign at the east end of East Frank Lane that says it is NUT A THRU STREET. � ; � . aa �. 10-101 �� k�. y�� .. .. ..�.. Y ._. . . ' . ��"' . .. _ .. . 1 LETTER 10 "�' Page 70 of 119 RESPONSE Section 4: Environm�ntal Irnpact Analysis RESP�NSE Section 4.8 - Transportation and Traffic '�" Picture below shows two Salem parents parked on Frank Street conducting a conversation. The Salem parents, per Salem Lutheran SchooM Traffic Policy are naf even supposed to be � there. A copy of the Salem Lutheran School 1'raffic policy and vehicle flow chart is induded. , The policy states: "Drivers are not to use, or pc�rk on, Clark Frank or Randal!Streets, unless a resident of rhese streets, or a guest nf a resfdenf of these s�reets." We have seen the School "'�' parent in the vehicle on the right park and wait several times (almost every day) after - dropping off one child and then return to drop off another pre-school child. �he is nat � supposed to use �rank Street across Orange Park Boulevard at all. The Residents Alternative Plan would help get her a parking spat on Salem's property to wait. ` ,Ia � � _ � � 10-101 CONT """ � � � � ` .. � ,�,.� . .. a*�{v x..... � ak.. -...�.., ..:: ..,. ..":.'.. �,. � ,� :..' ,YAIMwwA� "��.c4.us.. . . . . •Y=*wrei'�@SqAMaw.nro+.++w,.xm+bmr[�.r. +.. ..,w:� � . ». .J'.-.� a .�..... . � �;. � ��';� �*1� ,� -` .,* y;� �w w � . 'e�,��,ara„�,k ... �; .v ,�' s1 � �"`� � g $ ��.�� "�� '*"� ;�+��*r � ,� „� �� .a:rF:� ts"�� .�e t''y., a k..r�r�`�= .,�+..aN,. . . . b ��,. . .. , . y., + �`_.i.�^�dE:w.,'';�i�p"'�"x� � :., K � � � � � � � � � � z � LETTER 10 Page 71 of 119 RESPONSE Section 4: Environmental Impact nnalysis RESPONSE Section 4.8 - Transportation and Traffic Picture below shaws back car double parked behind parked cars on south side of building. ��.. � . � ,� �� , '� `�`�� 10-101 . ., �..� , , � ., CONT , f ��,,,,� � �:d� , . . � F� �'�� N�r.. ,,,' �H. ��w., � �� `�� , , . . � �y ;. , �. ,.�, � ,�.� � ��<< � . , �. , -` � '� � 4 i: a,�� ' 3 LETTER 10 `""° Page 72 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.8 - Transportation and Tr�ffic *� Picture below shows students and adul# walk�'ng in street behind parked cars and with incoming and outgoing traffic. ►� � � � ; � E _ � � ,�.� f � 'r��. . {, ;�' � .;a .+' :^�. . , �, � u � . . , , ...,� �T � .�. 1 �i y��bf4 �. �y-, . ,a . ( � z_� �:� �.� � . ��. 1 A� �; � �wis � � � Picture below shows cars parking an the grassy area on Easter Sunday. 10-101 �,, CONT �� . °� i$ '��u ��'�z� " 11�! ��..,� ��.�� w .. �e � `� � �y � � '"4 � y� f � I� Y� f, P � �� /5 � � y ��. ..1wM�i4� � ��, �� t'!�'�` ��,k'$�y �k � tt, } � w�� w � � Zo�: � # ��i �ry �� "+ ... ��.;. � MPkallb�b+.;* �� y � �� . . •• ��50- i i '��4ii ��E ��iX"� ++� '�'� ��,�''�' � ��,� "' ,,�..r^c.. � �.�� '� � " ��.�. t� a � ""` � � �� res ars'ea:. . a; r..:,y ,-s!A�C.�'g�*� s ..:=m .�' .,e�'^+� fi�� . . {.� . ..µ' , i ��5' f .r;.��'2d ��'4�-� '4-'�s � .,... ._ .r..< . �,�cs�f".Y.�a�v� .��. ,_ . .... __�. � 4 .� �� LETTER 10 Page 73 of 119 RESPONSE Section 4: Envirorimental Irnpact Analysis RESPnNSE Section 4.8 - l ransportatian and T�raffic Picture below shows Salem parent double parking behind parked cars. Anather Salem School traffic policy violation. Just as for Salem all these years, there are really no consequences for violating their school traffic policy. �� r�� A �' �f: r.`�4tr�� II ' � .;. �. ''�. y. #�� µ�� r�.,. I ��'� �. .. -. .��w:... . '� }t c, �z. , „ �, >, .�.y�,� , . .. ^'�'"" �'"`. '��S '� s� go�_•K,..�, � x+ �� A_ . 'y'Y � {F;pd;. °a ' . ra . � .. ,� «w..,..,. w � r � �. w.,.g �. + - ... ��- �rt, W ' :�. .. �� "''k.�.y}� . � ��. ,y :, ,,. ._:, , L - � u .... �, � �:: i � � �� a��. 10-101 .��F., , CONT : I�s� • � � ,�. �� t , � _ ;, : . �� . �''a° :�r:k`Ah$35.�.�,y ., . � , ^""°+y��. .�_�.�� ,,. +��► • ,��.� _ . o��a�o� o�:� .�... r . � LETTER 10 9 Page 74 of 119 RESPONSE Section Q: Environmental Impact Analysis RESPONSE Section 4.8 -Trans�ortation and Traffic � Two Salem Children picked-up from preschool have to waik (n the street to get to their double parked car. There are no sidewalks pravided. The long-term parking is taken by �- permanent Staff and te�chers that park in the spots closest to the building and then no parking is available close to the building for parents picking up chiidren from preschaal. 7he RAP provides for this with ample parking close to the building. '� � �. • �,�i 10-101 g CONT""' ,, r . {', e r . . a }.._m: �� \��t�'�, �� F. ...� ` '.".1 �� s a r � �: � . . .. .o-..• S� y�.:....,. .. ..,Wa'�k:�Fy.4�: h� �� ... �....r.., � � ' �Y��\� y/y�j J/�/ P �Bl%� �`MaT:1/�L'�I �L�1:•'� O. x:. y2��: . � . M-x2. +. ;.},tl �..'� �...: . �.:. . ,..: s:..'��..� .. . . ��'°.',9i'`�t.� . .. i. .., r31 d .�v��z�Wta'Ti...i�"�.�'h � 4f8? R�A' �c.,:5 � �N� FWi-0: � 6 � LETTER 10 Page 75 of 119 RESPONS� Sectian 4: Envirorirnental Impact Analysis RESPONSE Section 4,8 Transportation and Traffic Salem student bicycling to schooi on Frank Street has many obstacles: the trash truck, the incoming and outgoing traffic from Salem, northbound and southbound traffic on Orange park Boulevard. � � , �' X •�` � ..t �_�� . � �Ftl _-.. . ,. t � .x.. � .. ' -�. ,. � � � ,�., _ � � `� �" o a �.a� �. � Picture below shows 5alem students walking and bicycling home. These students usually 10-101 leave after the traffic has died down, but still have to deal with Salem Traffic and OPB traffic. CONT There are no sidewalks or crossing markings. 4 � +� � .p.�`�Y� r 1 s�' 1 ... . ... . ..'*r v.y: " '�,�'�+ .. ,�• �T�'� � .r. w � ,�A..B . �;� ';:' , �„' • . ... _. :�n.e , , .._. . y ,�,.. t � , � , � , � � ti , , . �,, � � <x. s .��„ =!� v�}i _ � ,�._.. ._,.._ n ` �: � r��•i + ., �-��«„'� �,�" � �.8.1 Introduction (p �1.8-1) 7 � LETTER10 Page 76 of 119 , RE5P�NSE 5ection 4: Environmental Impact Analysis RESPONSE Section 4.8-7ransportation and Traffic '�` Purpose (p 4.8-1) � Sources (p 4.8-1) �, 4.8.2 — L"nviron�ental Setting (p 4.8-1) � Regional (p 4.8-2) ,� VicinitY (p 4.8-2) Onsite Conditions (p 4.8-3) ^� Frank Lane (p 4.$-3) �. 4.8.3 - Offsite Improvements (p 4.8-43 y 4.8.4— Regulatory Setting (p 4.8-3) � Federal (p 4.8-3) ��' � State (p 4.8-3} � Local (p 4.8-4) �� County of Orange (p 4.8-4) `�' � Congestion Management Program (p 4.8-4) �. Growth Management Plan {p 4.8-4) � City of Orange (p 4.8-4j `�` Table 4,8-1: Level of Service descriptions--Signalized Intersections (p 4.8-4) � � Table 4.8-2—Level of Service Descriptions—Stop Cantrolled Intersections (p 4.8-5) .� 4.8.5— Significance Thresholds (p 4.8-5) .�, 4.$.fi— Proj�ct Impacts (p 4.8-6} Impacts Not To Be Significant (p 4.8-6) � Regional Transportation Plan (p 4.8-6� �� Potentially Significant Impacts (p 4.8-6) Table 4.8-3: Transportation and Traffic Significance 7hreshold and Corresponding Draft EIR � Impact Number (p 4.8-6} 8 � LETTER 10 Page 77 of 119 RESPONSE Sectipn 4: Environmental Impact Analysis RESPONSE Section Q.8-Transportatian and Traffic Conflict with Circulation System Effectiveness (p 4.8-7) Impact 4.8-1 The project will not conflict with an applicable plan, ordinance of policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-matorized travel and relevant components of the circulation system including but not limited to intersections streets. highways and freeways, pedestrian and bicycle paths and mass transit. (p 4.8-7) Traffic and Circulation— Impact Analysis (p 4.8-7} Sunday Church 5ervices and Activities (p 4.8-7) Weekday Elementary Schoo) and Preschoo) (p 4.8-7) Table 4.8-4: Existing (2010) AM Peak Hour Levels of Service (p 4.8-8) Project Traffic Distribution (p 4.8-$) Exhibit 4.8-5 Roadway and Intersection Characteristics Exhibit 4.8-2 Weekday School Circulation Plan Why is there parking shnwn an the grassy area? During schaol hours there is no parking on the grassy area or in the drop off area. Where is the curbside drop off/pick up site lower grades and preschool? It just shows circulatfon pattern. Plan also shows residents and Salem 10-102 can make both right and left turns at the intersection of East Frank Lane and Orange Park Blvd. Exhibit 4.8-3 Sunday Church Circulation Plan Circulation plan shows parking on grassy area. Will this be every Sunday? The legend does not say for just 6 times a year, or specia) events. 10-103 Exhibit 4.8-4 Santiago Canyon Road Entry 4.8-5 Frank Lane Significant Traffic Impact Criteria (p 4.8-19) Table 4.8-5: Weekday AM Year 2Q10 Existing + Project Intersection Peak Hour Levels of Service (p 4.8-19) Table 4.8-6: Sunday AM Year 2D10 Existing + Project Intersection Peak Hour Levels of Service (P 4.8-20) Level Qf Significance Before Mitigation (p 4.8-ZO) Mitigation Measures (p 4.8-20) 9 LETTER 10 °�°^ Page 78 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.8-Transportation and 7raffic "�' Level of Significance After Mitigation (p 4.8-20) � Parking—impact Analysis (p 4.8-20) (p 4.8-21) � Table 4.8-7: Parking Requirements (p 4.8-22) � � Conflict with Congestion Management System (p 4.8-23) Impact 4.8-2 7he projeet will not conflict with an applicable congestion management program, +� including, but nat 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. (p 4.8-2�) � .... Impact Analysis (p 4.8-23) � Level of Significance Before Mitigation (p 4.8-z3) , Mitigatian Measures (p 4.8-23) +� �. Level of Significance After Mitigativn (p 4.8-23) � Transportation or Traffic Hazards Due to Design Features (4.8-z3) Impact 4.8-3 The project will not substantially increase hazards due to a design feature (e.g.,- � sharp curves or dangerous intersectinns) or incompatible uses �e.g., farm equipmenti. (4.8-23) ,� Impact Analysis (p 4.8-23) .� level af Significance Before Mitigation {p 4.8-24) �' � Mitigation Measures (p 4.8-24} � Level of Significance After Mitigation (p 4.8-24) ,� Public Transit, Bicycle, or Pedestrian facilities (4.8-25) �`� � Impact 4.8-5 The project witl not conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety � of sucM facilities supparting alternative transpartation (e.g.-bus turnouts, bicycle racks). � (p 4.$-25) Impact Analysis (p 4.8-25) � Level of Significance Before Mitigation (p 4.8-25) � 10 ,� ��, LETTER 10 Page 79 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.8-Transportation and Traffic Mitigation Measures (p 4.8-25) Level of Significance After Mitigations (p 4.8-25j 11 LETTER 10 �" Page 80 of 119 Salem Lulheran Church and Schaol Existing Parking Spaces � Salem parkin� visual fram Goo�;le maps. �� , :q_.�.w� � � _ v_... . .� , � � �� _. _ __ ________ ____ _ � _ _ ___ _ ___ _ _ _--__ _ , ,o,..� _ . r !� G! M�. �w1� �d 1� ��Y .:.�WW�WtM�M�.. '�W�lsnArPa_■ .Iyp. y�. I�IU. y. � � \11/ 11'i.' '.d.•,•..,j'e�er�.t'>JL"P#h'R{A.�!prya ,Q � Ll � ,� �--zr , x.., �_ . • � �. � � ,_�"� = ir, � '� �� :�' � N - � -... « . , _. ,�, � � . , ��e �. � � � r� � � �, � � � � �� . �� ► ,, . � �� • �, �� , � � �.:. - � � � �, i, ., , . i ��". � � K �� E. � ;;r '`�;� I� '/ ��11��.. ,,...�."�k""�"`� WIfYl: A I ��p `„Y � 10-104 ;- e� � „,,,,_,...._. ,,......_ o.. _ _. __ _ _- _ ,�r.... . ..,,.. . ...� w..�.n.�e.._� a.....r.sd,J .�ww� ,_. Current parkin�spaces: 17 Parking spaces along grassy area of Salem's large parking lot """ 23 Parking spaces in middle area of Salem's large parking lot N,�� 31 Parking spaces along Church and Multi-purpose Building side af Salem's lar�e parking lot 27 Parkin�spaces alan� southern grassy area of Salem (East Frank Lane) "� U6 Parkin�spaces alan� southern metal fence of Salem's large parkin�; lat (l:ast Frank Lane) +� 104 Semi-total parking spaces � Note. Salem does not have any cars park in the large parking lot when schonl is in sessi�n/ in use. � '1'his removes the 17 + 23 + 3] = 71 parking spaces fro�n nc�rmal use. The 71 parking spaces became temporary parkin�; spaces. "'"° � Nate: When Salem has drop-off and pick-up times, the 27 parking s�aces al�ng the sauthern grassy area beeome temporary parkin�; spaces. �""" Out of the 1 U4 sub-tatal parking spaces (isted above, only 06 parking spaccs alang thc southern � metal fenc� are cansidered permanent parking spaces. � The city is requirin� �alem tc� have more rermanent �arking spaces. �° � � � � �w. LETTER10 Page 81 of 119 e��;. ir^1�.,�,.> .:e _ _ . ._ __ ,—.__..... ____ _ _ ___ __.._ . .._ _ _ _ ' _ C� • ''. .�s.a _ , � u .► .....� �.► w .. r.� ..��/W�W�w�.�._ r.urrwNPr...■ . .ry. y,q. ir. {�.` \�ti UI�� tak�^unc�i•.cvc^vaaFca'��p•^a � C7 � ��r�. ,;� a ��,�: � _+ � �� '� -: � ��_- . �"` {yr° e �".� ��TM � �� ,��:„ - � ___f.�-- t�� 4 �� : �► � � � _ .,.��.....�. . ..,,, . ---__.._._,..___ ♦.4�'. �q�i�YM��M�� ,�_Ow��MM�L�e,s-� ��46M Current parking spaces: 12 Angle parkin�;spaces alon�; Salem's south side parkin�, (East Frank Lane) CONT 09 Strait parking spaces along Salem's south side parkin�(East Frank Lane) 07 Parkin6 spaces alan� school side of Salem's smaller parking lot 20 Parkin� spaces alang Fawler rroperty side of Salem's smaller parking lot 04 Parking spaces on Fawler property curved frant driveway (East Frank Lane) 07 Parking spaces on Fowler �raperty back driveway (East Frank Lane) S9 Semi-tata) parking spaces Note: Parking spaces on the Fowler property are not sup}�osed to exist as Salem designates it as a vacant structure. Salem also uses these parking locations as tcmporary and permanent parking spaces. 'I'his removes 04 + p7 = 11 parking spaces from normal use. Uut of the 59 sub-total parking spaces listed above, c�nly 48 parking spaces considered permanent parking spaces. Note: When both of Salem's gates are closed there is only OG + 1? + 09 = 27 permane.nt parking spaces available. Salem dc�es nc�t have a way of preventing any�ne from parking there if they are not affiliatcd with Salem. I S2 "f�lal permanent parking spaces for Salem church S4 'I'otal permanent parking 5pac�s for Salem schc�c�l 152 Total P�rkin� spaces LETTER 10 �"'' Page 82 of 119 t��t k t] S4. Qt�p530Cjq� � �,� �� Salem Lutheran School S,y��" �� • J�°�� "` �'�� ` � 64 I I I:. F r�►nk Ln. A C C R E D 1 T E D �� ()r�ii�gc, t'A �)2H(�r) `�h "."w"":�f�wy� ,� �b1 �b�' � , • l��-.`'�.�-�'�;f s ,A�� Mr. I hili��C;. 1)uc�rr�. 1 rinci�4�) �,?$`j��OGO�'/ Salcm Lutheran �;chaol Traftic Policy '� �.. I'u cnsurc. lhat U•titiic uit ��ilcui C'ampus is s.itc fur c�ur �tucicnls �iuci cc�itsiticratc c>f Salcm`s nci�;hbc�rs, thc fi>1lowing Ir��llir• ,� ��olicy hus hec» ctitablishcd. Bcfure rh�� s�arr uf scl�rjnl, �►nrr�nls ri�i!! rearl vnd si�,�n lliu! Ihe;E� nre iir akrec►r�c•n1 ►niJh !/lis pulic;�'!l/t(J IVIII/l�lflE�hr i�. a� ' � - +� desi�;nated ti�ne ta av�„1,�,trafYic ba�k-�a. Staggered pick-�ip tiche-duie: � l31 . C'llt :1,;�: �MA1.1.C'1RC I.E '"�` �: 3:0�-:i:i0 Ciradcs 7+�K and tiiblin�ti(Whitc) 2:SS-3:IU Grades K-2 & �'�if4'�'�;iblings(t31uc) � :i:I(1-3;2U Cirttcies 5 f�fi and youngcr sibling� (Oran�c) Gracics i+4 (YcUuwj � I)rivcrti will nut �sc��,�� n�+un� <iclherc to�a S MN�1 sR�;ed lintit whcn clriving cm thc cam��u�. � 1)rivers will takc spccial noUcc uf pccJcstriuus und hnrscs, �►n�! givc thcm thc ri�ht of�way. Urivers will yii.ld Ihe right-c�f=way to 1'r,ink Lanc residcnts a1 al) tit»eti, 10-105 "`� I)rivcr5 u�ill turn let't t�n Orrmgc Park �ih�d. upon cxi�ing thc schaol. and procc�cd tow��rds S�ntiago Canyc�n Itot�tl, unlcss � drivcr is a rc5idcnt r�f Or�ngc Park Acres or�� Gompclling rctiyon cxists ta bc in thc Orangc Pnrk/1crc5�+rc;a. �„ I)�ivcr� arc ric�t tc> usc, c�r Eiark cm, C'lark, lirank, nr R�indall ';teccts, i�nlcs5 a rc�idcnt ��f thcsc strccts, or a guc�;1 c,t'a residcnl �,. �n thcsc strccts. f)rivcrs wiU not park alcmg Ihe fenccs c►n Ihc nc►rth ar tiouth sidc of I^'rank l.xnc, during drap-o(r or pit�k-up ti�i�cs. Si�nti wil) � be-��ositiotacd ta slatc this. � Urivcrti �vi11 al no timr doublc-park, cir stc�p lo visit, unlcss fi�,pro�riatcly pf�rkcd. �;,, Drivcrs will i�ot cntcr thc b�ack parking loi, hchind"E3"huildin�. "T'his is (irr stal'I'ptrrkin�;cmly. � Thcrc will bc two entrancc lancs acccssing Ihc ctun��us.�nd two cxil I<►ncs Icaving thr cnit��uti. On� c�l'thc cxit I�incs wil) hc u ,� Icfl tur�7 I�uic,ancl Ihc othcr 1<►ne will bc f'ar a ri�;ht turn. Plt�cc �al��card with yc�ur I.ItiI I1E1111C C)It (IiC 1ttfStiCtI1�;C1'til(Ic viscrr ul��our vr.hicic. lt is in��crativc Ih��t this si�,n iti cict�rly visiblc � t+t rircic ��ick i�r� to hcll� facilittilc timo��h lral�i�: tlu�v. �� A� b�►!h small an�l bib circic �Icasc ��ull Icr Ihc ti�rlhc:;l Ibrward posiliun availablc unci load as yuickly zind s��tcly ais pussil�lc, .� Plrc�tic remcmhcr thi5 is nut ttrc� tiri7c Io speak yc�ur cl}ild's tcac;IlCt 4iill� IIIiU �)Iz�ns ti�r alicr scl7c�n) cvcnt,r• rnusl hc madc prior ict circic pick G�p. u C'Icasc rc��icw thc a�t;u:hccl vchicic tlu�v chsu l. ,�. _. __...._._..�..��.�..__._.�__.. _ _ _ _ I h�ivu rcad Ihis policy �nuJ ��brcc: lu 6►iaidc hy it. � � _ _ _ _ _ __ harcnt tii�nalurc 51ii41rn1 Nainc;'Cir,ulc I)�ilt� � �,� LETTER10 Page 83 of 119 Salem Lutheran Schoal (,41 I !:. Fl�ank I,n. Oran�;c, C'A 92f�69 Mr. 1'hili�C�. I)uerr, Principal � �, . �> ;�r. '. , - v�� `�+ � `� :�;�, . , + a • (,Eilalii�uU , . . . / •° .... , . � 6 . W d � } � , , � — 10-10E M � �� f, , � �.J ✓M . . • � I., • ��l.+'� I G ! ,' . �i �� • "G § . �.'., .. . `; � t . H H.nlctirµ; � ¢ ' r� <r� v � ' �� 1 . . � ' � > I I � � � . Pn•-Sch�rnl Hndd�r�;; � � �� a , � � i _ - �, _ �� LETTER 10 �► Page 84 of 119 �. RESPONSE Section 4: Environmental Impact Analysis RESPONSE 5ection 4.9—Utilities and Service Systems """` � 4.9—Utilities and Service Systems (p 4.9-1) ,,,,, No Comment ""�' � 4.9.1 Introduction (p 4.9-1) Purpose (p 4.9-1) � 5ources (p 4.9-1) �° � 4.9.2—Environmental Setting f p 4.9-1) � Regio�al (p 4.9-1) � Regional Water Supply (p 4.9-1) � Vicinity(p 4.9-1) � Local Water Supply (p 4.9-1� � City of Orange (p 4.9-2) � Irvine Ranch Water District (p 4.9-2) "'� � Site Conditions (p 4.9-2) w Water Supply �p 4.9-2) � Wastewater (p 4.9-2) " � Exhibit 4.9-1 Water System Plan ..,r Exhibit 4.9-2 Sewer System Plan .� Solid Waste (p 4.9-7) **� �, Table 4.9-1: Orange County Landfills (p 4.9-8) .� Natural Gas (p 4.9-8) ,.� Electricity (p 4.9-8) �} Telephone (p 4.9-8) � 4.9.3-- Regulatory Setting (p 4.9-8) Federal (p 4.9-8) � 1 � f.3. LETTER 10 Page 85 of 119 RESPONSE Section 4: Environmental Impact Analysis RESPONSE Section 4.9—Utilities and Service Systems State (p 4.9-8) Local (p 4.9-9) Countywide Integrated Waste Management Plan (CMMP) (p 4.9-9) 4.9.4—Significance Thresholds (p 4.9-9) 4.9.5—Project Impacts (p 4.9-9) Impacts Not Found To Be Significant (p 4.9-9) Potentially Significant Impacts (p 4.9-10) Table 4.9-2: Utilities and service Systems Significance Threshold and Corresponding Draft EIR Impact Number (p 4.9-].0) New Wastewater Treatment or Collection Facilities (p 4.9-10) Impact 4.9-1 The p�aject will not require or result in the construction of new water or wastewater treatment or collection facilities or expansion af existing facilities, the construction or which could cause significant environmental effects. (p 4.9-10) Impact Analysis (p 4.9-10) Short-term Operations (p 4.9-10� Water (p 4.9-10) Wastewater (p 4.9-11) Long-7erm Operations (p 4.9-11) Wastewater(p 4.9-11) Level of 5ignificance Before Mitigation (p 4.9-11) Mitigation Measures (p 4.9-11) Level of Significance After Mitigations (p 4.9-11) Storm Water Drainage Facilities �p 4.9-11} Impact 4.9-7_ The project will not require or result in the canstruction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmenta) effects. (p 4.9-11) 2 LETTER 10 .� Page 86 of 119 RESPONSE Section 4: Environmental Impact Analysis �� RESPONSE Section 4.9—Utilities and Service Systems � Impact Analysis (p 4.9-11) �.� � Short-term Operations (p 4.9-12) �r Long-Term Operations (p 4,9-12) �, Level of Significance Before Mitigation (p 4.9-:12) "`"K � Mitigation Measures (p 4.9-12) ��, Level of Significance After Mitigatians (p 4.9-12) „� Exhibit 4.9-3 Grading, Earthwork and Storm Drainage Plan `�` � Wafier Supplies (p 4.9-15) �� Impact 4.9-3 The project will have sufficient water supplies available to serve the project from „� existing entitlements and resources, or are new o� expanded entitlements needed. (p 4.9-15) ��,: Impact Analysis (p 4.9-15) �,. Short-term Operations (p 4.9-16) '� Long-Term Operations (p 4.9-16) � � Level of 5ignificance Before Mitigation (p 4.9-16} � Mitigatian Measures f p 4.9-16j � Level of Significance After Mitigations (p 4.9-16) '"�` � � � � �: � �, ,�.� � �, 3 �, LETTER 10 Page 87 of 119 RESPONSE Section 5: Cumulative Irnpacts SECTION 5: CUMULATIVE IMPACTS (p 5-1) 5.1 — Introduction and Summary of Cumulative Impacts (p S-1) No Comment(NC) Table 5-1: Cumulative Impact Comparison (p 5-2) Under Environmental Issue column near bottom is Transportation and Circulation row. In the proposed Project impact column Salem's traffic has been labeled as LTS(Less than Significant without mitigation). The Traffic Impact and Parking Demand Analysis in Appendix H mainly talks about Sunday services and the impact of Sunday parking and traffic. The engineers - grossly ignored the impact of the weekday school activities. An analysis was not done on the parking demand and traffic impact of the weekday school activities such as they did for the Sunday services. The whole report is talking about what happens on Sundays only! Out of the 48 pages in Appendix H,only 2 pages (and then only one paragraph on Page 9 under Pa�king Supply and one paragraph on pagel0 under Internal Circulatfon Evaluation) does it mention anything about the school. Obviously the study focuses on Sundays,wt�ich does not impact the community the most. Salem traffic and circulation impact the residents and community most on week days when school is in session, two times a day,5 days a week. In the Study,the week days are only given in percentage averages only taken at the intersection. This informatiun is distorted and ambiguous because there is no data with hard numbers to show what is actually happening with the Salem traffic at the school. 10-107 the amount of vehicles that visit Salem on the weekdays is not addressed. Our observations have indicated there are approximately 300 cars that frequent Salem twice a day during school hours. This is not included in the Environmental impact report. The study has grossly under stated the impact Salem school traffic. 300 cars X 2 times a day X 5 days a week is a tota) of 3000 cars. 7he study addresses 153 parking spaces that are available for Sunday Church. During school hours,of these 153 parking spaces, only 48 parking spaces are available when the gates are closed. Preschool parents dropping off and picking up preschoolers only have 24 of these spaces available south of the grassy area,as permanent staff and teachers are using most of the parking spaces south of the building. That is why preschool parents are double parked, parked in fire lanes, in front of the neighbors' private property,on the residents-only 10' easement, in the turn-around and anywhere else they can find to park. This is the major impact to the cammunity. This is why the Residents'Alternative Plan �RAP) is so important as it addresses the parking and waiting needs of the schaol activities, and keeps Salem traffic on Salem property. This is why the RAP is propasing the Fowler property be turned into a parking lot and adding a 10-108 greater circulation for current Salem parking and traffic flow needs. 1 LETTER 10 �— Page 88 of 119 RESPONSE Section 5: Cumulative Impacts This is why the Graysons at 6348 East Frank Lane have been closely observing Salem`s activities and traffic patterns. From our observations a plan was developed with input and � approval of residents, OPA board and REC board that would greatly mftigate Salem's impact 10-108 V to the neighborhoad. We would very much appreciate that the City of Orange should take this plan into consideration. -� Saiem's analysis of the entire Appendix H is facused on Sunday traffic and activities at the church for 1/7th of the week for 4 haurs only, and virtually ignores the highest impact of 10-109 � Salem traffic and activities at the School which is 5/7 of the week for 8 hours per day. 5.2 - Related Projects (p 5-2) �- Table 5-2: Related Projects (p S-3) � This is fatally flawed because there are no school comparisons. Salem is currently at 400 students, but Salem plans to expand that to 600 students,which is what their maximum is. 10-110 � That expansion is going to impact the neighborhood even mare. ,� 5.3—Cumulative impacts (p 5-3) ; �� Salem is turrentiy at 400 students, but Salern plans to expand that to 600 students, which is �0-111 ,�, what their maximum is. That expansion is going to impact the neighborhood even more. The RAP is,in effect,trying to haue Salem only impact 5alem and not the cammunity. �, 5.3.1—Aesthetics (p S-3} «�� Introduction (p 5-3) '� � RAP goes a (ong way to provide proper borders on the sauth and west side of Salem property and provides a beautiful foiiage and OPA appropriate whlte rail fences. 10-112�, Proposed Project (p 5-4) � � NC � Analysis (p 5-4) � NC �<�. Conclusion (p 5-4) "" It is aur opinian that the level of significance after Salem's plan of mitigation is not adequate. � It does not provide the barriers and privacy that Salem and the residents require, but the 10-113,�.� RAP does. �. Level of Significance Before Mitigation (p 5-4) �� NC � 2 k.�:- LETTER10 Page 89 of 119 RESPONSE Section 5: Cumulative Impacts Mitigation Measures �p 5-4� Level of Significance After Mitigation (p 5-4) 5.3.2 Agriculture and Forestry Resources (p 5-4) Introduction (p 5-4) Proposed Project (p 5-4) Analysis (p 5-4) Conclusion (p 5-5) Level of Significance Befare Mitigation (p 5-5) Mitigation Measures (p S-5) 5.3.3—Air Quality (p 5-5) Introduction (p 5-S) NC P�oposed Project (p 5-5) NC Analysis (p S-5) NC Conclusion (p 5-5) We do not agree with the conclusion as stated in the cumulative impact because there was no analysis of the impact of the automabiles associated with the school. The impact only was 10-114 associated with the Sunday church service. 5ince the church is only 1/7`h of the weekly activities and the school is 5/7ths of the weekly acfiivities the canc{usion is grassly understated. 10-115 What is the air quality like when you get 30Q cars 2 times a day,waiting from 10 to 3U minutes to drop off and pick up students? The reason why school air quality with waiting vehicles cannat be compared#o a major artery(such as Santiago Canyon Road) is because waiting vehicles do not produce air movement to disperse fumes of car emfssions. As stated 10-116 in Appendix �under Air Quality and Greenhouse Gas Analysis report on page 46,4.2-long- 3 LETTER 10 ^�' Page 90 of 119 RESPONSE Section 5: Cumulative Impacts �� Term Regional Qperational Impact 1St paragraph reads"Mobile emissions from motar vehicles are the largest single long-term source af air pollutants from the project. " 10-116 � CONT 5ince that is the most important impact,why were weekday air emissions nat analyzed� Air "` quality during the Sunday Service times does not reflect air qu�lity during school hours. � 10-117 The RAP goes a Iong way to remedy this air quality impact. " Leve) af Significance Before Mitigation (p 5-5) � Mitigation Measures (p 5-5) � 5.3.4— Biological Resources +.� Introduction (p 5-6) � � Proposed Project (p 5-6j Analysis (p S-6) :w� Conclusion (p 5-6) „� Level of Significance Before Mitigatian (p 5-6) +� Mitigation Measures (p 5-6) � ..p+ Level of 5ignificance After Mitigation (p 5-6) � � 5.3.5—Cultural Resources (p 5-6) �. Introduction (p 5-6) �^ �a. Praposed Project (p 5-6) k� Analysis (p 5-6) �� Conclusion (p 5-6) � Level of Significance Before Mitigation (p 5-6) - Mitigation Measures (p 5-6) ""` Level of Significance After MitigaYion (p 5-6) � � 4 � LETTER 10 Page 91 of 119 RESPONSE Section 5: Cumulative Impacts 5.3.6-Geology and Soils (p 5-7) Introduction (p 5-7} Proposed Project (p 5-7) Analysis (p 5-7) Conclusion (p 5-7) Level of 5ignificance Before Mitigation (p 5-7) Mitigation Measures (p S-7� Level of Significance After Mitigation (p 5-7) 5.3.7- Greenhouse Gas Emissions (p 5-7) Introduction (p 5-7) See comments addressed in air quality also. I 10-118 We do not agree with the way the analysis was canducted as the existing conditions have a signiflcant and cumulative impact. No study or analysis of the exiting Greenhouse Gas emissions was taken into account. What ts the impact associated with 300 idling vehicles 2X a day, idling for 10 to 30 minutes average waiting time? This presents pollution air quality 10-119 hot spots for the school, residents and community. This was not included in the study.The study only analyzed increased nurnbers for the church on Sunday. The problem is the school is not at full capacity right now. What is it going to be at fuil capacity with more cars waiting? Please consider the RAP to help mitigate the air quality problems with all the trees along the horse trail. 10-120 Proposed Project �p 5-7} Analysis (p 5-7) Conclusion (p 5-7� Level of 5ignificance Befare Mitigation (p 5-7) Mitigation Measures (p 5-7) Level of Significance After Mitigation (p 5-8) 5 LETTER 10 "'� Page 92 of 119 RESPONSE 5ection 5: Cumulative Impacts � 5.3.8- Hazards and Hazardous Materiais (p S-8) � Introduction (p 5-8) Itemoval of asbestos issues in the buildings to be dernolished was not addressed. Nlold in Fawler House was not addressed. 10-121"'� Proposed Project (p 5-8) � Analysis (p 5-8) Conclusion (p 5-8) � Leve) of 5ignificance Before Mitigation (p 5-8j � � Mitigation Measures (p S-8) �,�� Level of Significance After Mitigation (p 5-8) � � 5.3.9 - Hydrology and Water Quality(p 5-8j """` � Introduction (p 5-$) � The project creates excessive storm water runoff by the additton of mare hardscape with additional parking. 7here is already a current violation af Safem's storm water runoff to 10-122� residenYs p�operty. � � Proposed Project (p 5-8 � Analysis (p 5-8) � The current storm water suriace runoff impacts primarily the Drown property at the west end � of East Frank lane. Actually all of Salem's storm water runoff sheets to East Frank Lane an then dpwn the Drown driveway to a small catch basin at the bottom af the Drown driveway. '� Excessive sto�m water overflows this catch basin and floods the Drown garage. as well as ,�.� sheeting north from the Orown property to the Davidson praperty. The catch basin on the � Orown residence empties into Handy Creek. According to City code Salem is in vialation of directing storm water runaff to a private resident's property. Salem's remedy for thfs storm �o-�23'"' water is to use the existing ansite drainage pattern which creates little impact to Salem as �... Salem is on the higher ground. Their proposed retention basin an the Fawler praperty is not large enau�h to handle all the water withaut an autflow continuing down to the Drown °� residence. Salem's interim solution to their own storm water runoff issues �water paddling at �� the lawer grade turn around) was to dig the ditch deeper and funnel more water to water to � the Drown residence, � 6 � „.< LETTER 10 Page 93 of 119 RESPONSE Section 5: Cumulative Impacts Conclusion (p 5-9) We disagree with the hydrology assessment. Salem claims that water discharge will be through the new entrance on Santiago Canyon Raad. Haw can water run up hill? Also water is stili ailowed to drain to the west end of East Frank Lane. Under city municipal codes water is not allowed to be discharged to someone else`s private property. The RAP allows Salem's wate�to be kept on Salem's property. 10-124 Level of Significance Before Mitigation (p 5-9) 7o Salem there is no impact, but the residents there is a great impact. Mitigation Measures (p S-9) Level of Significance After Mitigation (p 5-9) 5.3.10— Land Use and Planning (p 5-9) Introduction (p 5-9) Salem's land use and planning is incorrect in their proposal as it includes converting a private residential property into a public preschool. An increasing student enrollment from a current 400 to Salem's propose maximum of 600 there is nat enaugh parking on the site for this increase. What is that going to do to the community to add to add to already impacted 10-125 streets when there was no analysis done on the schoal activities? This impacts the residents and their home value depreciates. It tmpacts the�esidents' prlvacy. This is nat short-term. This is long term and is cumulative. The only way that the neighbors see Salem expanding their student population is converting the Fowler house and property into a pa�king lat and converting the traffic flows to stay on 10-126 Salem's own property. This is in the objectives of the plan and it is proposed in the RAP. Proposed Project (p 5-9) Analysis (p 5-9 Conclusion (p 5-9) Level of Significance Before Mitigation (p 5-9) Mitigation Measures (p 5-9) Level of Significance After Mitigation (p 5-9) 7 LETTER10 � Page 94 of 119 RESPONSE Section 5: Cumulative Impacts 5.3.11—Minerai Resources (p 5-9► Introduction (p 5-9) Proposed Project (p 5-9) � Analysis (p S-9) Cnnclusion (p 5-10) �' Level of Significance Before Mitigation �p 5-10) � Mitigation Measures (p 5-10) Leve) of Significance After Mitigation (p 5-10) �„ 5.3.12—Noise (p 5-10) ""� Introductian (p 5-1Qj � � The residents do not agree with the way the naise impact was handled as it only refers to � construction noise and Sunday service noise. It does not address the real noise issues of the children and the vehicles, slammin doors,that is onl 10-127 g y going to grow with additional �** students, since Salem is only operating at 2/3 capacity. These issues were not addressed. �.�, Where are the mitigation measures for the curren# noise? � Building bigger structures on Salem praperty is only going to add to the naise when the �,, children are outside. This has not been addressed. There needs to be a permanent structure in place that keeps the Salem naise on 5alem's property, because now the cvmmunity is 10-128 „� getting noise trespass. This noise trespass is worse#han traveling vehicles and is heard for •� greater distances � ('ropased Project (p 5-10) �.,, Analysis (p 5-10� � �� The greatest noise impact is where you have children at play on a hardscape. The sounds most of the community hears are the kids screaming whether on grassy area, ar hardscape � area. Also, on the school side,when you have external corridors there is a megaphone effect 10-129 tl w that broadcasts noise out to the neighbors and community. � Conclusion (p 5-11) Praper mitigation measures to reduce the cumulative effect of more student noise would be � to make all walk ways and corridors internal, �o the nais� can reverberat�back onto Salem's 10-130 property, and nat pollute the neighbvrhood. � 8 �. LETTER 10 Page 95 of 119 RESPONSE Section 5: Cumulative Impacts Level of Significance Before Mitigation (p 5-11) Mitigation Measures (p 5-11) Leve) of Significance After Mitigation (p 5-11) 5.3.13 Population and Housing(p 5-11j fntroduction (p 5-11) Proposed Project �p 5-11) Analysis (p 5-11) Conclusion (p 5-11} l.evel of Significance Before Mitigation (p 5-11) Mitigation Measures f p 5-11) Level of Significance After Mitigation (p 5-11� 5.3.14—Public 5ervices {p 5-11) Introduction (p 5-11) Proposed Project (p 5-12) Analysis (p 5-12) Conclusion (p 5-12) Level of Significance Before Mitigation (p 5-12) Mitigation Measures (p 5-�.2) Level of Significance After Mitigation (p 5-12) 5.3.15 — Recreation (p 5-12) Introduction (p 5-12) Proposed Praject (p 5-12) Putting an entrance into Salem from Santiago Canyon Road as the proposed plan is a significant cumulative and dangerous impact to the QPA harse community.l'hat is why OPA 10-131 9 LETTER 10 Page 96 of 119 �iESPONSE Sectiar� 5: Curnulative Impacts .�, has rejected Salem's plans. OPA, however, has endorsed the RAP that has the horse t�ail � relocated ta the soufih and west boundaries of Salem property. See RAP 10-131 CONT "'� Analysis (p 5-12) Conclusion (p 5-12) � By following the RAP there would be na impaci after relacating the horse trail. 10-132 � Lev�) of 5ignificance Before Miti�alion (p 5-123) Miti�atit�n M�asures (p 5-13) � Level of Significance After Mitigation (p 5-13) � 5.3.16—7ransportation and Traffic (p 5-13) � Introduc_tion (p 5-13) a Salem parent dropped off lower grade student first and then has to turn left through "�° incoming and outgoing traffic to drop off upper grade student. This is normal Salem weekday �4 traffic. � �� k. � � � � � � � . . . ,, � I , � . , �. �_, 1� � � ' ` ,.� ,��,�w , ` �:� ' �rawNi�q ',�� +�. � " :�#i►`11�, �� ---'� � �. . - " �� '�'"'��, .�� 10-133 _. � �„�•�...Y �,b�Flil .. �. � � ��, . . �� , �� y� b, � �� R��'�' � �. ��b �> � . �'ri �'` �`� �� r � � � ;�',z+- �. wuc I/!A9 . . .. . ... .... .., �,. .„< . . c�r� � � 10 � LETTER 10 Page 97 of 119 RESPONSE Section 5: Cumulative Imp�cts Intersection of Orange Park Bivd. and East Frank Lane. Salem traffic at 3:OOPM pick up. (Salem traffic is early as the picture was take� at 2:54PM and pick up usually lasts for 3A minutes or more. Pick up is nof supposed to start until 3:OOPM, but they are more than half way done. This adds to the confusion for residents and the community as no one ever knows when you will get stuck in the Salem traffic.j (Signs posted on south side of grassy area say NO PARKING from 3:OOPM to 3:30PM. However, if anyone parks there and school lets out early, they are stuck there for thirty minutes or more.) Two lanes in and two lanes out. Cars backed up on Orange Park Blvd. Average of 300 cars twice a day. � •, � � „� � .. �� ,,�;� �' , � � _ _ � � �� ,��' '�"'; ��`'s � � i ��'� �` � �� . r� < dY�.. r�� '��Ab�'��,�q r. � . §.. 4i^ �, 3�,5 � . . . _ . m��....�. . _...-_._,_..- '"" '" 10-133 ..., CONT �,.. •f�... _1� �� ♦ :k`. •� ::, . ti �: I� �� ..¢a �@',5��"„. -�„'"�;,��:: ' ��ii Need we say more? Where is the study of the existing weekday traffic flow? ProposEd Project (p 5-13) Analysis (p 5-13) Conclusion (� 5-13) I_evel af Significance Before Mitigation (p 5-13) Mitigatian Measures (p 5-13) Level of Significance After Mitigatian (p 5-13) 5.3.17 - l)tilities and Service Sysiems (p 5-7 3) Introductian (p 5-13) Proposed Project (p 5-13) 11 LETTER 10 '�'" Page 98 of 119�y RESPONSE Section 5: Cumulative impacts � Analysis {p 5-13) "�" � Conclusion (p 5-13) �,,r� Level of Significance Befare Mitigation (p 5-13) � Mitigation Measures (p 5-13) k. Level of Significance After Mitigation (p 5-13) *� � � 1.�# � � � �.b;. � �. � � �: � � � � � � � � � � 12 �, �,,; LETTER10 Page 99 of 119 RESPONSE Sectian 6: Growth Inducing, Unavoidable, Adverse, and Irreversible Impacts SECTION 6: GROWTH INDUCING, UNAVOIDABLE AOVERSE, ANO IRREVERSIBLE IMPACTS (p 6-1� 6.1 —Growth Inducing Impacts (p 6-1) Excuse me!!The Fowler property has not been par# af the Salem site for over 40 years. It is 10-134 not included in the'98 CUP!!! 6.2 —Unavoidable Adverse Impacts (p b-1) How is Salem going to mitigate the noise during the weekday school hours? I 10-135 When Salem is talking about Sundays only,there is less of an impact. The Conceptual plans are incomplete as they do not address the major problem area, which is the weekday school 10-136 traffic and circulatian. 6.3—Irreversible Impacts (p 6-2) Bio-swale in the relocated horse trail helps to prdvide a better sustainable and reusable water system. It creates an ongoing renewability, helps to beautify, and provides for an 10-137 aesthetically pleasing green envira�ment to reuse Salem's run off water. It does many wonderful things to significantly help the Salem proJect site. See Residents Alternative Plan. Another residential concern is the impact af the negativity between Salem and the residents on the children. It is irreuersible and leaves the children with a distain and negative attitude toward the residents and the community. The children feel it and take on the negative reactions of the parents and transmit them to other children. This is the reason why a number of Salem ex-patrons have quit the church and school. The parents tolerate the situation until their children graduate. Then, instead of keeping church patrons with all the 10-138 animosity, Salem is losing church patrons. Salem does not have a good reputation in the Lutheran community in this area. All of 5alem's plans do not do anything to correct this situation. The RAP will help the situation because it will permanently separate East Frank Lane residents and Salem church/school while solving a lot of other numerous problems that plague Salem. This is an issue that cannot be solved by constructing a bigger sanctuary. It really doesn't help when Salem parents flip off the residents and yell negative things when their children are in the car with them. The child�er� are also starting to flip off the residents. This shows how bad the irreversible damage is to the children wha attend Salem. Instead of taking offense to this,the residents are looking at it as the new"Salem good-neighbor"hand gesture. Salem does not inform the City about this, and probably never will. 10-139 When the police officers were monitoring the situation on Tuesday 3-13-2012, and Wednesday 3-14-2412, some of the community came to the police officers and were thanking the officers for being present, because 5alem traffic had never been this good. Salem was orderly, courteous and abiding by their own traffic policy, driving slower, respecting the rules of the road, one lane in and one lane aut. With the police officers presence,this drew a lot of � the community residents aut of their homes to wonder what was going an. The neighbors on 1 LETTER10 � Page 100 of 119 RESPONSE Section 6: Growth Inducing, Unavoidable, Adverse, and Irreversible Impacts � the other side of Orange Park Bivd.felt the difference in Salem traffic and asked the police officers if they could come e�ery day. �.» Below: Salem Traffic Tuesday 03-13-2p12 3:OOPM. Very orderly, very slow. One lane in and ane lane out. Not normal Salem Traffic. .� ;, � . �. . „ , ,� . ,� � ,� z �� `� � � �'. '�`' ,,�,. �. " �,_ � ilta�,..�m�:�,�, +"� .n:� .�-�. �:�- _., � '-` �. _ w� >-,�:-� ��, � 10-1� � CON _ ,�,,, .�+ Below: Salem traffic Wednesday AM drop off. Very orderly and very slow. Not normal. � .., ��F � � �.� � ..� ,� �� x;_ � � �� .. � .- m, �� .� � a�� b �� ` � � �� ' u �Y:;(Y�u .n.,.. � ....... �, d.+ a� � € ,''4� rJv�, q tny�qx..,.�r �.:'fi � �$ '�^y' � F a� ��€� = .`.°�.s � � �f:y�aFwlg.:. ,.. ,� `�S'� M,_� fJ�,�t,:... u.. r`�^�� x w1 �� .a:" �$"� 4 ty,� >�'�§� �� .�,r.y, ,Y ya F ev� � .�4 � ? � ��, ... . . .'q., ... � 2 � LETTER10 Page 101 of 119 RESPON5E Section 7: Alternatives to the Project SECTION 7: ALTERNATIVES TO TNE PROJECT(p 7-1) 7.1— Introduction (p 7-1j The residents that border East �rank Lane which includes Gray Lane residents whose property is adjacent fo Salem Lutheran Church and School have observered Salern's activities and their short-comings and have been privy ta comment on the Draft EIR. The residents have gotten together and developed through many meetings an alternative plan to Salem Specific Pian Draft EIR. it is the request of the neighboring residents for Salem and the City of Orange to accept for consideration this reasonable and potentially feasible alternative plan. This Residents' Alternative Plan (RAP) presented by the residents better attains all of the project objectives and does not impede construction progress and is conside�ed to be less costly than the proposed projeci. The residents feel that our plan is much more site-suitable and economically viable an better fits the needs of Salem and the OPA community than the Salem proposed plan, or any of Salem's alternatives. After receiving appraval among the neighboring residents,this plan received approval from the OPA board and the t)PA Real Estate Committee, and was presented to Salem on 4-19- 2012. In compliance with the discussion with the City at the 4-18-2012 Design Review Committee meeting. At the City meeting the residents requested that the City defer the appro�a) o the D�aft EIR until the Residents'Aiternative Plan could be presented to Salem. The City Design Review Cammittee required of Salem to pravide the City a copy of the Resident's Alterna#ive Plan for their consideration as a feasibie alternative. At the 4-19-2012 meeting with Salem a colored copy of the Residents'Alternative Pian#3,and three 11" X 17" graphic design renderings done by Jeremy Grayson plus 2 8.5"X 11"of benefits to Salem 10-140 describing the relocation of the horse trail which would provide Salem a front door entrance off of Santiago Canyon Boulevard and ather benefits that this would provide Salem,which are part of the abJecti�es in the Residents'Alternative Plan. Here in this Residents response,we have included ail drawings up-to-date that show a progression af the drawings that reflect the meetings with the residents and OPA input.The residents proposed plan incorporates/elaborates objects in Salem's p�oposal. These drawings are specifically labeled as: DRAWING#000 04-18-12: Salem's Existing Traffic Circulation Drawing#000 shows the current impact two times a day, 5 days a week that Salem school traffic overruns the OPA community, and how residents and emergency vehicles are blocked. DRAWING #001 03-11-12: East Frank Lane Residents Proposed Solution Orawing#001 dated 03-11-12 which specifically shows the Resident-oniy ingress and egress and the turn- around at the west end of East Frank lane with cypress border trees,the relocation of the horse trail combined as a bio-swale along the south and west borders of Salem property.This tree line provides privacy and light shield for both East Frank lane and Gray lane Residents and privacy for Salem. It also shows the Fowler Property converted to a parking lot to give Salem the needed stackin�of cars on Salem property to allow for better and safer pick-up 1 LETTER 10 � Page 102 of 119 � RESPONSE 5ection 7: Alternatives to the Project � and drop-aff of school chitdren and to resolves Salem's traffic congestion off of the � CONT � comrnunity streets. DRAWING#002 03-28-12; East Frank Lar�e Resident's Proposal response to Salem's � Proposal ta City of Orange Drawing#OQ2 dated U3-28-12 which is a more developed catored � drawing with residents input and the tree line foliage spacing around the wes#end changed td accommadate the west end residents request for ficus trees instead of cypress trees to match the trees an that property and provide a li#tle more spacing away fram Salem '"'" activities. The traffic flows have been better develaped. This plan also calis for better safety � for pick-up and drop-off including covered pick-up and drop-off focus points. Please use the � renderings to accompany these drawings. Plan#OQ2 also provides a revised sec#ion of East Frank Lane at the intersection of O�ange Park Boulevard. '�' DRAWING#OQ3 04-17-12: East Frank Lane Resident's Proposal Response to Salem's � Proposal to City of Orange Drawing#003 dated 04-17-12 titled Salem Master Pian is an "' enhanced plan with Delta changes A througF� H based off of residents and OPA camments 10-141 � over plan #002. This was the drawing given to Salem o�M19-2012 to Frank, Carmen and Michael. �� DRAWING#004 04-19-12; East Frank Lane Resident's Proposal Respanse to Salem's Proposal ta City of Orange Drawing#004 dated 04-19-12 tttled Salem Master Plan with Delta "�" changes 1 through N based off of residents and OPA comments. � DRAWING#005 04-19-12: East Frank Lane Resident's Alternative Plan Response to "*" Salem's Proposal to City of Orange Drawing#005 da#ed 04-19-12 titled Section A-A is based ,�, off af residents and OPA commen#s. It is an expanded and enhanced drawin�of Section A-A and demonstrates the value and k�enefits of the Residents Aiternative Plan. This plan �" describes Salem's proposed construction into three phases in accordance with Salem's � phased construction. This plan elabaretes and describes the purpose of the cypress trees, the � horse trail/bia-swale combinatian,the advantages af the tall cypress trees and how Salem prapvsed canstructian with the Residents Alternative Plan can better provide for enhanced � community rela#ions,providing for the needs of all. �. � � RENDERINGS: .,� Renderfng#1: East Frank Lane (looking west)Conceptua) Rendering#1 dated 03-26-2012 shows the intersection of East Frank Lane and Orange Park Boulevard with East Frank Lane '� resident private ingress/egress, raised curb, split-rail fence,tall cypress trees, relacated horse �0-142� trail/bia-swale, white rail fence, Salem left turn exit only, raised curb and sidewalk and � signage. � Rendering#2; East Frank Lane(loaking east� Conceptual Rendering#2 dated �3-26-2012 shows East Frank Lane residents private ingressjegress, raised 6"curb with fire lane red .� 2 � �: LETTER 10 Page 103 of 119 RESPONSE Section 7: Alternatives to the Project paint,white split-rail fence, and tail cypress trees that block resident's view of Salem and provides the OPA rural privacy for residents. Rendering#3: East Frank l,ane Conceptual Rendering#3 dated 03-260-2012,shows a sateilite view of East Frank Lane and Santiago Canyor� Itoad. This shows the relocated horse traii down to the arena and the western and southern border of Salem, the west end of East Frank lane emergency vehicle turn around, conceptual parking lot in Fowler property. Note: the parking area east of Salem facility is what exists currently, it is fenced off to allow the parking lat to transform into a piay area during school hours. Na sidewalk entry on north side of East Frank Lane exists,forcing everyone to watk in the road up and dawn East Frank Lane among moving vehicles. 10-142 With the residents Alternative Pian Salem should not need to park on the grass. CONT 7.2 —Alternatives Identified for Evaluation and Reasons for Including Selected Alternatives (p 7-2) The Residents Alternative Plan takes into consideration the aesthetics, air quality, hydrology� land use, noise,traffic ingress-egress, parking and access. It also provides for the school activlties and trafffc flows not provided for in Salem's proposed plan. It goes a long way in reducing future negative, (ong-term operational impacts to the residents and community. 7.2.1 — No Project Alternative—No Development Alternative (p 7-2) 7.2.2. — Design REview Committee Land Use Plan of May S, 2005 Alternative (p 7-4) Aesthetics (p 7-5) Hydrology (p 7-5) Land Use (p 7-5) Noise (p 7-5) Traffic (p 7-5) 7.2.3—Single Access Alternative (p 7-6) Exhibit 7-1 Single Access Alternative 3 LETTER 10 �^� Page 104 of 119 RESPONSE 5ection 7: Alternatives to the Project � 7.3—Conclusion 5ummaries and Environmentally Superior Alternative (p7-10) � No Project—No Development Alternative Design Review Committee Land Use Alternative of May 5, 2006 �, Single Access Alternative (p 7-10� Environmentally Superior Alternative (p 7-1].) � Table 7-2: Alternative Impact Comparison by-fopical Enviranmental Issue (Alternative) (p 7-13) hW � Table 7-2 (cont.): Alternative Impact Comparison by Topica) Environmenta) Issue (Air Quality) (p 7-14) � Table 7-2 (cont.): Alternative Impact Comparison by Topical Environmental Issue (Greenhouse �,, Gas Emissions) (p 7-15) � Table 7-2 (cont.): Alternative Impact Camparison by Topical Environmentaf Issue �Hazards and Hazardous Materials) (p 7-16) �AIl � Table 7-2 (cont.): Alternative Impact Comparison by Topica) Environmental Issue (Hydrology and Water Quality) �p 7-17) � Table 7-2 (cont.): Alternative Impact Comparison by 7opical Environmental Issue (Land Use and � Planning) (p 7-18) Table 7-2 (cont.): Alternative Impact Comparison by Topical Environmental Issue (Noise) "� fP 7-19) �' Table 7-2 (cont.): Alternative Impact Comparison by Topical Environmental Issue ""` (Transportation and 7raffic) (p 7-20) � Table 7-2 (cont.): Alternative Impact Comparisan by Topical Environmental Issue (Utilities and "' Service Systems) (p 7-21) � Table 7-3: Impact Summary Comparisnn of Project Alternatives {p 7-23) °°� � .� 7.5—Project Objective Feasibility Summary (p 7-23) �� Table 7-4: Project Objeetive Feasibility Comparison (p 7-23) � Table 7-4 (cont.): Project Objective Feasibility Comparison (p 7-24) »� � � 4 «.; �, LETTER 10 Page 105 of 119 RESPONSE Section 8: Significant and Unavoidable Impacts ' SECTION 8: SIGNIFICANT AND UNAVOIDABLE IMPA�75 (p 8-1) Salem's initfal study did not adequately address the following that would have significant unavoidable impacts: School Noise: Sur�eys were taken when school attendance was Iow,as Salem was notified that these surveys were being taken and Salerr� rescheduled their activities to reduce the 10-143 noise during the survey. School Traffic: School Traffic during weekdays was not addressed. Only church traffic on Sunday was addressed. School Traffic is twice a day, five days a week for eight hours a day. 10-144 The impact was not measured. Light Trespassing: Salem promised via their'98 tUP to stop this and it continues since 1998. I 10-145 Storm water runoff: Salem transmits all of their runoff, including over irrigation, south and west to East Frank Lane and down to the private residence of the Drown property for the Drowns to take care of it. Often Salem's runoff floads the Orown and Davidson properties to 10-146 the west. OPA Horse Trafl impact: This was not properly miti�ated in Salem's propased plan and was labeled as less than significant. This is because Salem traffic, church and school, crosses OPA horse trail at East Frank Lane and Santiago Canyon Road. Installing traffic signal lights for the 10-147 horses at East Frank Lane does adequately address the problem. Safety: Children's Safcty araund the school is of utmost importance and was not even addressed. The residents plan provides for covered drop-off and pick-up zones and a vehicle circulation system that addresses the preschool age chfldren's needs,which were not addressed In the Salem Specific plan. Currently there are no sidewalks for pedestrians, and 10-148 preschool children mingle with parked cars and traffic in order to make their way to the registration areas at the school. The Residents Alternative Plan helps to resol�e this problem of Safety which is the greatest liability Salem has. These issues were not addressed. Parking: Parking for school hours was not properly addressed as it is anly mentioned in two short sentences out of AS pages in the Traffic Impact and Parking Demand Analysis in Appendix H. The focus in that section is on the 4 hour Sunday Church senrices and not on the 40 hour(8 hours-a-day, 5 days a week�school activities. Salem says they have 153 current parking spaces and they plan to add 28 more to bring it to 180 tatal. However,they did not address the fact that during sGhool haurs,they fence off all but 48 parking spaces, but half of 10-149 those are filled with permanent staff or teacher parking,sa there are only about Z4 spaces left to park on campus during schaol haurs. This is nat enough to handle the significant lmpact af 600 school children and their parents. This is why the residents Alternative Plan for providing another parking lot on the Fowler property is vitally important for Salem'sparking plan and car cireulation/waiting system. Traffic FIowJCirculation: Impacts of school traffic flow and circulation was not addressed, only a plan showing the praposed traffic ffow was addresses. This does not adequatefy 10-150 1 LETTER 10 '^'" Page 106 of 119 RESPONSE Section 8: Significant and Unavoidable impacts � remove the vehicle impact o�n East Frank Lane or�range Park Boulevard. The Residents 10-150� � Alternative Plan addresses this. CONT,�., Air quality: Waiting vehicles (300 cars with their motors and air conditioners running on an average af 10 to 30 minutes twice a day)for school drap-off and pick-up was never addressed >� 10-151 and is a significant impact to the air quality of the neighborhood. According to Cai 05HA, waiting vehicles produce the worst air quality. � Gashouse Gas Ernissions: Impact of aif the schaol traffic vehicles waiting with their engines �i! an does not have enough movement#o disperse the emission. 7'he impact analysis study only 10-152 showed the emissions along Santiago Canyon Road and Orange Park Boulevard where the °� vehitles are traveting 3Q ta SQ MPH. _ Land Use and Planning: Land use,the impact analysis did not go far enough to address the � residents interface concerns, as the residents want to be completely separated,with not only �,, a split rail fence, but also a sustainable tall tree barrier. This was nat considered deeply 10-153 enough.The residents and community do not want to interface with Salem's traffic, noise, ""� with their light trespass,water runoff, parking issues vr trafFic issues. Residents want a �� permanent separation. .,� Itelated Projects: The Salem Pian is only addr�ssing church activities one day a week, it does 10-154'"`" not address school activities that are 5 days a week. � While Salem's impact analysis does not go far enough to address the critical issues from the residents' point of view,th�R�sidents Alterryative Plan goes a Iong way in addressing all of these issues. By reviewing the Residents Aiternative plan,one can see that the residents are 10-155we not trying to impede Salem's development, but that Salem needs to take care of its neighbors � first. � Since the'98 CUP, Salem has nat valued its neighbors enougM. Salem has abused the �_ neighbors and residents and it refiex in the fact that Salem Lutheran Church and School, but a COMMUTER church and school and come from cities all over the county and have no regard "" far the neighbors or the neighborhaod. Therefore,the Residents Alternative Plan goes a long 10-156y,,,,, way to address the needs of the residents,the community, OPA,the horse trail and the OPA � Real Estate Committee. We respectfully reques#that Salem and the Ci#y consider the Residents Alternative Plan to avaid the�ignificant impact ta the neighborhood. ""� ,� ��: � � � z � � LETTER10 Page 107 of 119 RE5PON5E Section 9: Other Lang-Term Implications SECTION 9: OTHER LONG-TERM IMPLICA710NS (p 9-1) 9.1 -Growth-Inducing Impacts {p 9-1) increased Salem traffic will impose new burdens on the community, as Salem has nat dealt with their current problems with the School traffic as required in their'98 CUP. 10-157 Another impact that would greatly help Salem and the community and would be a win/win for all invoived would be the relocation of the horse trail to the southern and western borders of the 5alem property. This takes care af many issues such as Salem's growth of 10-158 hardscape to accommodate larger facilities and parking. The horse trail/bio-swale take care of thls increased watershed. It also opens up Santiago Canyon Road as a main entrance to the church and school facility, a large sought-after opportunity for Salem. By planting tall cypress trees and ficus hedge between 5alem and the residents provides and 10-159 aestheticaily pleasing border for Salem and residents privacy. Another important issue is parking lot size that more adequately fits the needs of Salem for both church and schooi is to convert the Fowler property into long-term parking, an can be 10-160 used to stack cars during waiting periads for school drap-off and pick-up. An entrance directly off of Santiago Canyon Road is a huge positive impact for Salem and the OPA community.The Residents Alternative Plan would allow delivery trucks and trash pick- up during school hours at the north end of the property. This would stop the long-term impact of school delivery vehicles that park on the East Frank Lane residents' ingress and 10-161 egress. It would also provide for trash trucks nat to have tu operate when children and pedestrians are walking in the street,which would greatly reduce Salerri's liability. 9.2—irreversible and Irretrievable Commitment to Resources (p 9-1} No Comment (NC) 2010 California Green Building Standards Cade (CALGreen) (p 9-2) Relocation of the OPA horse trail/bio-swale with all the trees would greatly add to Salem's 10-162 reuse of their water shed. 9.3—Cumulative Impacts (p 9-3) The Residents Alternative Pian reduces many vf Salem's excessive impacts to a buiit-in manageable, low impact, low cost system, and resolves a plethora of problems into the 10-163 manifold combination of horse trail/bio-swale,cypress and ficus tree divider between 5alem 1 LETTER 10 .� Page 108 of 119 �d RESP�NSE Section 9: Other Long-Term Implications � and the neighbors. It{arovides for a superiar resolution that meets all 7 objectives,and takes `�v care of both phases of implementation of short-term construction operations and long-term 10-163 �„ CONT Salem operatfons. . �. � � � � �. � � �.. �.� �, �ifr. � � � � � � � AtiY�" � �u df 1lIIB? z � �:: LETTER10 Page 109 of 119 RESPONSE Section 10: Report Preparation Resources SECTION 10: REPORT PREPARATION RESOURCES (p 10-1) 10.1— Draft EIR Preparation Personnel (p 10-1) Thanks to all of you for handling all of the paperwork. 10.2—Technical Subconsultants (p 10-1) No Comment (NC) 10.3 —Organizations and Persons Consulted (P 10-1) NC 1 LETTER 10 ,�, Page 110 of 119 �� RESPONSE Section 11: References � SECTION 11: REfERENCES (p 11-1} �" � 10.1— Draft EIR Preparation Personnel (p 11-1) No Carnment ..., R� � �, � «� �� x�rt � kfii. � � WNi. � YWN1, � $Y�y � � � � 1 � ip5:: � �� LETTER 10 Page 111 of 119 �" � o 0 0 o a o m odA�B�#21dd 3JNV2lO oo�m� �raim�oo. mmo 'i ; �,1o�cacaoo�a�:a�� Q m '! 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THIS PAGE INTENTIONALLY LEFT BLANK ' Sa/em Lutheran Church and School OPA Compromise Specific Plan Response to Comments on the Draft E/R Responses to Comments Letter 10 - Tom Grayson, et al. Thirty-five comments within Letter 10 specifically state "No Comment" (or "NC) and are not addressed in the following response to comments for Letter 10. Response to Comments 10-1 through 10-5 below represent an overview of individual comments �� provided in this letter. Response to Comment 10-1 This comment refers to a resident-drafted plan included within this comment letter(Letter l 0), identified herein as the Grayson Traffic Plan. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document for an evaluation of the Grayson Traffic Plan. Response to Comment 10-2 This comment expresses concern over the existing use's wastewater conveyance infrastructure. As addressed in Draft EIR Section 4.9, Utilities and Service Systems, an existing onsite 21-inch wastewater line provides wastewater conveyance from the project site. The Orange County Sanitation District(OCSD)owns a 21-inch diameter vitrified clay pipe (VCP)main in Frank Lane, which turns north and passes through the project site within a public easement in the site's primary parking lot. The OCSD main is reduced to a 16-inch diameter at an angle point in East Santiago Canyon Road, at which point the OCSD main turns easterly and continues in East Santiago Canyon Road. The OCSD 21-inch diameter main, which passes through the project site, currently serves the school and the church, and is expected to continue as the point of service far the proposed project. In addition, refer to Section 3, Project Description, of the Draft EIR. Under the proposed conditions,the entire project site would continue to receive wastewater service from the OCSD. The development of the proposed project would not result in a significant impact related to the wastewater conveyance facilities that serve the project site because there is excess � capacity in the conveyance facilities. Thus,the project does not have the potential to require or result in the construction of new water or wastewater treatment facilities or expansion of eXisting facilities. In addition, refer to Section 3,Project Description, of the Draft EIR. Response to Comment 10-3 This comment expresses concern over the separation between project and residential traffic along Frank Lane. As addressed in Response to Comment 8-3,the proposed project redesign of Frank Lane involves two closely spaced but separate entrances, one for use by the project and one dedicated for residential use only. As illustrated in Section 4.8, Transportation and Traffic, Exhibit 4.8-2, Weekday School Circulation Plan, on page 4.8-11 ofthe Draft EIR, and Exhibit 4.8-3, Sunday Church Circulation Plan, on page 4.8-13 of the Draft EIR, residential ingress and egress along the southern Michae/Brandman Associates 3-181 H�\Client(PN-JN)�3771\37710001�RTGFEIIt�37710001 Sec03-OOResponsesdoc Sa/em Lutheran Church and Schoo/OPA Compromise Specific P/an Responses to Comments Response to Comments on the Drafi E/R �, dedicated portion of Frank Lane would be able to proceed safely and efficiently following ,,,,,, development of the project. In addition,refer to Section 3, Project Description, of the Draft EIR. � Response to Comment 10-4 This comment expresses concern over the size of the proposed project compared with the size of the "�" project site. As addressed in Response to Comment 5-5, the proposed project and all of its '~� improvements are consistent with the OPA Plan and the City of Orange General Plan or will be with � the approval of the Salem Lutheran Church and School OPA Compromise Specific Plan, and comply � with all applicable provisions of the City of Orange Zoning Ordinance in regards to the size(e.g., FAR)of onsite structures. As addressed in Comment 6-3, a discussion of field parking is provided. � �: Response to Comment 10-5 � This comment expresses concern over project-related traffic potentially impacting the local � circulation network. A TIA Addendum (Appendix A)was prepared for the OPA Compromise Plan to �, address the potential traffic and parking impacts associated with the proposed project as described in the Specific Plan compared with the 712-seat sanctuary scenario analyzed in the City-approved � Traffic Impact and Parking Demand Analysis Report dated August 20, 2010. Based on the TIA '""� Addendum for the proposed project, no traffic impacts will be created and adequate parking will be � provided consistent with the City-approved Traffic Impact and Parking Demand Analysis Report. As � part of the proposed project, Salem Lutheran Church and School has agreed to implement a number of traffic and transportation-related modifications to the project as outlined in the Orange Park � Association Letter of Support dated/executed June 5, 2014. � Response to Comment 10-6 � � This comment recommends identifying and "spelling out"mitigation measures for the construction ,�, phase of the project. Mitigation measures for the project's construction activities are provided in the �, Draft EIR within their appropriate corresponding topical sections, and are summarized in Table 2-1, Impacts and Mitigation Measures Summary, in Section 2, Executive Summary, of the Draft EIR. �' Mitigation measures are also listed within each of the topical environmental issues in the Draft EIR, �► where applicable. With implementation of the recommended mitigation measures, impacts associated .� with both construction and operations of the project were determined to be less than significant. �, Response to Comment 10-7 �_ The comment includes a partial quotation from Draft EIR Section 1, Introduction, subsection l.13. `"� This section of the Draft EIR discusses the role of the Lead Agency (i.e., City of Orange)under "�� CEQA and their statutory responsibilities far processing environmental documentation. The text �.. merely references the procedure related to impacts that cannot feasibly be mitigated below the level of significance; the text does not conclude there will be any environmental impacts unable to be �, mitigated. The discussion and analysis of environmental impacts occurs in Draft EIR Sections 4, 3-182 Michae/Brandman Associates � H�.\Client(PN-JN)\3771\37710001VtTGFEQt\37710001 Sec03-00 Responses.doc Salem Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments on the Draft EIR Responses to Comments Environmental Impact Analysis; 5, Cumulative Impacts, and 6, Growth Inducing, Unavoidable Adverse, and Irreversible Impacts. Draft EIR Section 3, Project Description, subsection 3.2.1 provides project summary, including a reference that all of the existing uses within the project site boundary conform to the Public/Quasi-Public designation as specified in the OPA Plan. Draft EIR Section 3, Project Description, subsection 3.3 provides the list of objectives for the proposed project. Refer to Draft EIR Section 4, Environmental Impact Analysis, for a discussion of individual topical environmental issues. Response to Comment 10-8 This comment is duly noted. Response to Comment 10-9 This comment expresses concern over the planned use of the Fowler House as a component of the proposed project and identification of it as an onsite structure. The Fowler House will be removed and replaced with a new parking area. An approximately 7,505 sq ft preschool building and associated 7,921 sq ft play area will be built adjacent to the western portion of the existing Classroom Building B. Similar to the remainder of the project site, the proposed project, including the use of the Fowler property as a parking area, is consistent with the OPA Plan and the City of Orange General Plan. The OPA Plan designates the property where the Fowler House is located as Public/Quasi- Public, which is consistent with the proposed project. The proposed relocation of the preschool as part of the OPA Compromise Plan will not affect the capacity as evaluated in the Draft EIR and will not impact the overall enrollment cap as identified in the existing CUP. A CUP was previously required for the existing use because the project site was zoned residential by the City despite being designated as Public/Quasi-Public under the OPA Plan, a designation that allows churches and schools as a matter of right. In order to be consistent with the project site's OPA Plan designation,the Applicant proposed a specific plan and requested that the site be rezoned to Specific Plan/Public Institutional. According to the City's Zoning Ordinance, churches and church schools are permitted without a CUP in the Specific Plan/Public Institutional zoning district. In addition, referencing the Fowler House as an onsite structure indicates the structure is on property owned by the Church and is included in the proposed project area. This does not infer that the structure is part of the existing CUP area. In addition,the existing CUP does not prevent the Church from purchasing additional land, such as was done when the Fowler House was purchased, and proceeding through an entitlement process to incorporate the land into its operations. Response to comment 10-10 The comment expresses concern over the potential for increased student enrollment at the school facility. As addressed under the K-8 School subsection in Section 3, Project Description subsection 3.4.2, Architectural Theme Characteristics, of the Draft EIR(page 3-15 of the Draft EIR), per the Michae/Brandman Associates 3-183 H�\Clien[(PN-IN)U771\37710001ViTGFEIIt�37710001 Sec03-00 Responses.doc Sa/em Lutheran Church and School OPA Compromise Specific P/an Responses to Comments Response to Comments on the Draft EIR � CUP 2213-98, Resolution 8974, approved by the City of Orange on July 14, 1998,the m�imum student enrollment is 726 students and the maximum number of students allowed on campus at one time is 6]1. This limitation on the number of students both enrolled and allowed on campus at any � given time would still apply to the proposed project even though there would be no longer be a CUP. The restrictive covenant previously recorded against the existing use and property would remain in *�' effect. Table 4.3 of the Specific Plan identify the same limits on maximum student enrollment and �_ maximum number of students on campus at one time as the current CUP. The proposed project � would not increase the existing school's capacity, as there would be no new school facilities,just the replacement of existing facilities(i.e.,the new preschool would replace the existing preschool). � Overall, the proposed project would have no effect on student enrollment levels. '"�* »�: The purpose of the proposed project is to provide facilities adequate to serve Salem Lutheran Church and School's existing congregation, including existing special events. Thus, the project considered � impacts related to attendance levels of up to 590 attendees, and this project is fundamentally a �� redesign of the existing campus that will better serve Salem Lutheran Church and School's existing - attendees by eliminating the inefficient layout and circulation. ,�e Response to Comment 10-11 � This comment reyuests clarification regarding the following statement found under the Draft EIR � Section l, Introduction Section 1.2.1 Public Services, Environmental Issues Not Found To Be ""� Significant(page 1-5): �,,, � With incorparation of requirements from the City and the Uniform Building Code, the impacts from the proposed project related to fire and police protection services �' would be less than significant. � �. The specific "requirements"would be determined by the City of Orange prior to final approval of the �. proposed project by the City's Planning Commission and City Council and would be included as conditions of approval. The City's Building Division, and Police and Fire Departments would review � the proposed project during the plan check process to ensure compliance with the necessary � requirements. ;� Response to Comment 10-12 "'�` �: As noted in Section 1, Introduction, of the Draft EIR,the proposed project does not include recreational facilities or result in an increase of recreational facilities. As noted in Response to '� Comment 9-9,the trails adjacent to the project site will be preserved, will continue to provide � connectivity with other trails in OPA, and be available to equestrian users. Tn addition, consistent ..� with the "Single Site Access"alternative analyzed in the Draft EIR,there would be no driveway from Santiago Canyon Road, and as a result, a break in the trail fencing will no longer be required. �. 3-184 Michae/Brandman Associates ,� H�.\Client(PN-JN)�3771\37710001�RTC-FEIIt\37710001 Sec03-00 Responses.doc Salem Lutheran Church and School OPA Compromise Specific P/an Response to Comments on the Draft E/R Responses to Comments Response to Comment 10-13 This comment expresses concern over the inclusion of an alternative discussion in the Draft EIR. As � addressed in Section 7, Alternatives to the Project: The [CEQA] Guidelines require the Draft EIR 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. A Draft EIR is not required to consider every conceivable alternative to a proposed project. Rather, a Draft EIR must consider a reasonable range of alternatives that are potentially feasible; a Draft EIR is not required to consider infeasible alternatives. Alternatives must be considered even if they would impede,to some degree,the attainment of project objectives or be more costly. The determination of feasibility of project alternatives may include, but not be limited to, factors such as site suitability, economic viability, infrastructure,plan consistency, regulatory and jurisdictional limitations, and control of an alternative site, if applicable. Therefore,the Draft EIR contains three alternatives in compliance with the requirements of the State CEQA Guidelines. Response to Comment 10-14 The comment refers to a document that is not part of the Specific Plan and Draft EIR. These comments are duly noted. In addition,the comment is concerned with including the Fowler House in the proposed project site boundaries. Referencing the Fowler House as an onsite structure indicates the structure is on property owned by the Church and is included in the proposed project area. This does not infer that the structure is part of the existing CUP area. In addition,the existing CUP does nor prevent the Church from purchasing additional land, such as was done when the Fowler House was purchased, and proceeding through an entitlement process to incorporate the land into its operations. Therefore,the area of the proposed Specific Plan is 6.03 acres. Refer to Response to Comment 9-8 and Response to Comment ]0-16. Response to Comment 10-15 The Fowler House will be removed and replaced with a new parking area. An approximately 7,505 sq ft preschool building and associated 7,921 sq ft play area will be built adjacent to the western portion of the existing Classroom Building B. Similar to the remainder of the project site,the � proposed project, including the use of the Fowler property as a parking area, is consistent with the OPA Plan and the City of Orange General Plan. The proposed relocation of the preschool as part of the OPA Compromise Plan will not affect the capacity as evaluated in the Draft EIR and will not impact the overall enrollment cap as identified in the existing CUP. Michae/Brandman Associates 3-185 H-.\Client(PN-JN)\3771\37710001�RTGFEIR�37710001 Sec03-00 Responses.doc ,� Sa/em Lutheran Church and Schoo/OPA Compromise Specific Plan Responses to Comments Response to Comments on the Draft E/R � The existing onsite uses include a school, preschool,and worship center/church. The proposed ,, project involves the same uses and does not propose any new uses, although new construction is proposed for a new church and the applicant proposes to relocate the preschool. The Fowler House is � referred to as "the vacant structure"because it is not used as a residence or for any church/school � activities. The OPA Plan designates the property where the Fowler House is located as Public/Quasi- �� Public, which is consistent with the proposed project. A CUP was previously required for the .,,�� existing use because the project site was zoned residential by the City despite being designated as «� Public/Quasi-Public under the OPA Plan, a designation that allows churches and schools as a matter of right. In order to be consistent with the project site's OPA Plan designation, the Applicant � proposed a specific plan and requested that the site be rezoned to Specific Plan/Public Institutional. ""' Per the City's Zoning Ordinance, churches and church schools are permitted without a CUP in the � Specific Plan/Public Institutional zoning district. � Response to Comment 10-16 � � This comment requests clarification regarding Zone Change No. 1259-11, which refers to the designation assigned by the City of Orange to the Applicant's request for a zone change. The issue of '� rezoning is addressed in detail in Draft EIR Section 4.6, Land Use and Planning. This Section found � that: � Eliminating the existing R-1-40(Single-Family Residential)zone district and '"� replacing it with the proposed SP/P-I (Specific Plan/Public Institutional) zone district � would result in consistency with the Salem Specific Plan. In addition, the proposed � SP/P-I zone district would be consistent with the OPA Plan. The City Attorney's � Office proposed the zone change as a technical clean-up modification to ensure that the zoning properly reflects and implements the OPA Plan land use designations �"` applicable to the project site and has provided a written memorandum (Appendix B =�' of the Draft EIR)regarding the proposed zone change that states the following: ,,,� 1. Processing a specific plan pursuant to State law as the entitlement vehicle for the �� project is appropriate; � 2. Processing a zone change to SP/P-I is appropriate; and, � 3. The processing of a specific plan and zone change to SP/P-I is consistent with the '"�` entitlement process utilized for Chapman University and St. John's Lutheran Church �y.. and school, both of which are public institutional uses as defined by the Orange � Municipal Code and are governed by a specific plan. Based on the above, we believe �:... that the proposed entitlement process for the project is consistent with previous and current C�ty practice. � .�, � 3-186 Michae/8randman Associates �,,: H�\Client(PN-JN)U7'71\37710001�RTGFEIR\37710001 Sec03-00 Responses.doc Sa/em Lutheran Church and School OPA Compromise Specific Plan Response to Commenis on the Draft EIR Responses to Comments The City's Planning Commission and City Council will use the Final EIR prepared for the project to aid their decision regarding rezoning of the residential zone district. Response to Comment 10-17 This comment questions the need for a specific plan instead of a CUP. Please note that the proposed project is consistent with the OPA Plan and has been operating at a similar capacity in accordance with CUP 2213-98. The specific plan will serve as the entitlement vehicle for the proposed project. The specific plan process allows the City of Orange to establish specific design guidelines for the proposed project. Because the specific plan will be subordinate to the OPA Plan,the specific plan is required to be entirely consistent with the OPA Plan. Thus,the specific plan will serve to implement the standards contained in the OPA Plan. The entitlement process being used for the proposed project(i.e.,the processing of a specific plan and zone change) is consistent with the process used for other similar projects within the City. A CUP was previously required for the existing use because the project site was zoned residential by the City despite being designated as Public/Quasi-Public under the OPA Plan, a designation that allows churches and schools as a matter of right. In order to be consistent with the project site's OPA Plan designation,the Applicant proposed a specific plan and requested that the site be rezoned to Specific Plan/Public Institutional. According to the City's Zoning Ordinance, churches and church schools are permitted without a CUP in the Specific Plan/Public Institutional zoning district. Response to Comment 10-18 This comment does not pertain to the proposed project; however, the comment is duly noted. Response to Comment 10-19 This comment does not pertain to the proposed project; however, the comment is duly noted. Response to Comment 10-20 This comment expresses concern regarding the accuracy of the data used in the Draft EIR. Technical studies prepared by qualified professionals in support of the analysis in the Draft EIR include an Air Quality/Greenhouse Gas Analysis, an Environmental Data Report identifying hazardous materials, a Hydrologic Assessment and Preliminary Water Quality Management Plan, a Noise Impact Assessment, and a Traffic and Parking Demand Study. Response to Comment 10-21 This comment does not pertain to the proposed project; however,the comment is duly noted. Michael Brandman Associates 3-187 H�.\Client(PN-1N)�3771\37710001�RTC-FEIIt\37710001 Sec03-OOResponses.doc Sa/em Lutheran Church and Schoo/OPA Compromise Specific P/an " Responses to Comments Response to Comments on the Draft EIR � Response to Comment 10-22 This comment expresses concern over the project compared with the project alternatives analyzed in � the Draft EIR(i.e.,No Project Alternative; Design Review Committee Land Use Plan of May 5, 2006 ��. Alternative; and Single Access Alternative). The proposed project is discussed in Section 3, Project �. Description, of the Draft EIR, and Section 2, OPA Compromise Plan Analysis,of this Response to �.m.; Comments document. The project's potential environmental effects are discussed throughout in Draft EIR Section 4, Environmental Impact Analysis, as well as in Section 2 of this document. The project "'� alternatives and their potential impacts are outlined in Draft EIR Section 7, Alternatives to the � Project. Both the proposed project and the project alternatives have been described and analyzed in � detail throughout the Draft EIR. Should the City approve the project, either the project or one of the �,,, project alternatives would be approved,but not all of them. � The comment also directly address the topic of lane separation along Frank Lane. Residential traffic ,,�,, would be separated from project traffic with"TYPE AY"pavement markers. The final decisions � regarding the final site plan and project specifics, including the use of pavement markers along Frank Lane, would require the approval of the City of Orange priar to the commencement of construction '�`"` activities. � Response to Comment 10-23 `�" � This comment does not pertain to the proposed project; however,the comment is duly noted. � Response to Comment 10-24 � This comment expresses concern over existing surface runoff from the project site that results in "� offsite flooding. Consistent with the"Single Site Access"alternative analyzed in the Draft EIR,there �� would be no driveway from Santiago Canyon Road, and thus, stormwater flows will not have a direct ,,,�, outlet onto the roadway as previously proposed. As a result, a private storm drain system is proposed for the project. This starm drain system will pick up the majority of the project site and convey flow � toward Santiago Canyon Road where it will be picked up in and existing 36-inch RCP within �� Santiago Canyon Road. This 36-inch RCP conveys flows to the Handy Creek reinforced concrete � box culvert under Santiago Canyon Road. This storm drain system will alleviate flooding that has � occurred within the private drive westerly of the project site. � No significant increases in peak flow or runoff volume will occur due to development. Modeled peak "`�� runoff for the project remains relatively the same for the 10-year and 25-year High Confidence Events „�, and decreases approximately 1 percent during the 100-year High Confidence Event. Therefore,the ,�, project's hydrology and water quality impacts will be similar when compared with those impacts analyzed in the Draft EIR ""'"' 3-188 Michae/Brandman Associates �, H1Client(PN-JN)�3771\37710001V2TC-FEIlL\37710001 Sec03-OOResponses.doc a, Salem Lutheran Church and School OPA Compromise Specific Plan Response to Comments on the Draft E/R Responses to Comments Response to Comment 10-25 This comment expresses concern over the size of the proposed project. As addressed in Response to Comment 5-5,the proposed project and all of its improvements are consistent with the OPA Plan and the City of Orange General Plan, and comply with all applicable provisions of the City of Orange Zoning Ordinance in regards to the size(e.g., FAR) of onsite structures. Response to Comment 10-26 As addressed in Draft EIR Section 3, Project Description subsection 3.4.3, Landscaping, Trees, Fencing, and Lighting Characteristics,the existing chain link fencing was proposed for retention on a portion of the project site. However, consistent with the comment from the City's DRC, the existing chain link fencing will be removed and replaced with maximum 6-foot-high syuare tubular steel fencing. Where ball control is required,the tubular fencing will be backed by prefinished rectangular welded wire fabric colored to match the tubular steel fencing. The use of such fencing will be placed as a condition of approval on the project. Response to Comment 10-27 This comment expresses concern over the size and height of the building. Section 7.3 of the Specific Plan contains the development standards and regulations related to size and height. In addition, Section 3, Project Description, of the Draft EIR provides a site plan chronology regarding the process to arrive at the current proposed facility size and location on the project site. Further,the maximum building height of the new worship center has been reduced from 39 feet to 36 feet, and no more than 25 percent of the roof plane will be permitted to exceed 32 feet in height. Response to Comment 10-28 As addressed in Response to Comment 10-5,this comment expresses concern over project-related traffic potentially impacting the local circulation network. A TIA Addendum (Appendix A)was prepared far the OPA Compromise Plan to address the potential traffic and parking impacts associated with the proposed project as described in the Specific Plan compared with the 7l2-seat sanctuary scenario analyzed in the City-approved Traffic Impact and Parking Demand Analysis Report dated August 20, 20l 0. Based on the TIA Addendum for the proposed project, no traffic impacts will be created and adequate parking will be provided consistent with the City-approved Traffic Impact and Parking Demand Analysis Report. Response to Comment 10-29 This comment expresses concern over the impact conclusion of the air quality analysis contained in Draft EIR Section 4.2, Air Quality. In part, this comment references the existence of an existing issue, not an issue that would be caused or worsened by the proposed project. The purpose of CEQA and the preparation of an EIR is not to address current alleged environmental problems, but to analyze Michael Brandman Associates 3-189 H:\Client(PN-JN)\3771\37710001UtTC-FEIIt�37710001 Sec03-00 Responses doc Sa/em Lutheran Church and Schoo/OPA Compromise Specific Plan Responses to Comments Response to Comments on the Draft E/R �, whether a proposed project would result in any new impacts. Regardless, as addressed in the TIA Addendum (Appendix A),the project will result in up to 413 AM peak-hour trips for a typical Sunday church service, representing a 30-percent net trip reduction in the number of AM peak-hour trips � analyzed in the Draft EIR. In general,the project's operational emissions are at least in part related to "�� project-generated traffic and the exhaust emissions from those vehicles. Thus, because of the � reduction in peak-hour trips, it can be assumed that vehicle exhaust emissions, as well as any �M contaminants contained in those emissions such as VOC,NOX, and ROG, will also be reduced. � Therefore,the project's air quality and greenhouse gas impacts will be reduced when compared with those impacts analyzed in the Draft EIR, which were already determined to be less than significant. � � Response to Comment 10-30 .;� As addressed in Response to Comment 10-29, the Draft EIR Appendix D, Air Quality and ,,,,r Greenhouse Gas Analysis Report, long-term air quality analysis took into account the Traffic Impact �, Analysis(Draft EIR Appendix H, Traffic Impact and Parking Demand Analysis) prepared for the project to provide estimates of the incremental changes in traffic associated with the expansion of the � church component of the proposed project. '"" � Response to Comment 10-31 � This comment states that the Fowler House is currently affected by mold conditions, as addressed in � Response to Comment 9-23. The comment also expresses concern over the potential for ACM occurring within the existing buildings on the project site. Draft EIR Section 4.4, Hazards and � Hazardous Materials, describes asbestos and its potential environmental and health impacts based in "�" part on when a building was constructed. The interior of the Fowler House has not been inspected to """`° verify if mold is present or if the substance is mildew or some other non-hazardous substance. Prior �. to demolition activities, a licensed specialist will inspect the interiar of the Fowler House to � determine the presence or absence of hazardous substances, including ACM, LBP, or other potentially hazardous substances such as mold. In the event that any mold or other potentially """" hazardous substances are determined to be present, remediation by a licensed specialist would occur '""� prior to demolition activities, as part of standard construction practices and consistent with all ,�„ applicable federal, state, and local provisions related to the handling of potendally hazardous .� substances. This inspection and potential remediation will be placed as a condition of approval on the project. � � Response to Comment 10-32 � The comment expresses concern over potential contaminants left behind from vehicles parking on the � multipurpose field/overflow parking lot. As addressed in Draft EIR Section 4.4, Hazards and � Hazardous Materials: � � 3-190 Michae/Brandman Associates � HiClient(PN-JN)�3771\37710001�RTGFEIIt\37710001 Sec03-00 Responses.doc � Salem Lutheran Church and School OPA Compromise Specific Plan Response to Comments on the Draft EIR Responses to Comments The use of multipurpose field will be used for overflow parking of motor vehicles on an intermittent basis would pose an insignificant risk to recreational users of the field. The minor amounts of fluids from vehicles infiltrate into the grass surface and would not be a hazard for users the following day. In addition,the frequent mowing and removal of clippings would reduce any long-term build-up of pollutants on the surface. In the event of a major leak or spill, special clean up measures would be required.2 Response to Comment 10-33 This comment does not pertain to the proposed project; however,the comment is duly noted. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document. Response to Comment 10-34 This comment expresses concern over the size of the proposed project and parking. As addressed in Response to Comment 5-5,the proposed project and all of its improvements are consistent with the OPA Plan and the City of Orange General Plan, and comply with all applicable provisions of the City of Orange Zoning Ordinance in regards to the size (e.g., FAR)of onsite structures. Additionally, potential parking impacts were addressed in both Response to Comment 6-3 and Response to Comment 8-4. As determined in the Draft EIR and previously addressed in the aforementioned responses, project-generated parking would be less than significant. Response to Comment 10-35 This comment does not address the proposed project; however,the comment is duly noted. Response to Comment 10-36 This comment expresses concern over project-related operations noise. As addressed in Response to Comment 6-2, long-term noise impacts associated with operations of the project were found to be less than significant and were addressed in the Initial Study (Draft EIR Appendix A,Notice of Preparation, Initial Study, and Comment Letters) prepared for the project prior to the Draft EIR. The Initial Study concluded that the operations phase of the proposed project would not result in noise increases over the existing conditions since the proposed land use would be the same as the existing land use, with similar traffic conditions and onsite activities. Additionally,the Noise Impact Analysis prepared for the proposed project(Draft EIR Appendix G,Noise Impact Analysis)examined long- term, operations-related noise and determined the noise impacts would be less than significant regarding onsite operational noise. The Noise Impact Analysis analyzed potential noise generated by the proposed parking lots,the playground,the sanctuary, and the fellowship reception area, z Fuscoe Engineering,December 20,2012. Michae/Brandman Associates 3-191 H-\Client(PN-JN)�3771\37710001�RTGFEIIL�37710001 Sec03-OOResponses-doc ,�r Sa/em Lutheran Church and Schoo/OPA Compromise Speciic P/an � Responses to Comments Response to Comments on the Draft E/R � determining that noise produced at any of these locations would not exceed the City of Orange noise � standards. This analysis was completed consistent with Section 8.24.070 of the Orange Municipal Code and the Noise Element of the City's General Plan. � Response to Comment 10-37 � This comment does not pertain to the proposed project; however,the comment is duly noted. Refer to �`` Section 4, The Grayson Traffic Plan, of this Response to Comments document ,,,� Response to Comment 10-38 � This comment does not pertain to the proposed project; however,the comment is duly noted. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document � � Response to Comment 10-39 �, This comment expresses concern over the existing use's wastewater conveyance infrastructure. �; Section 4.9, Utilities and Service Systems of the Draft EIR discussed wastewater conveyance ,,,� infrastructure. As addressed in Response to Comment 10-2, an existing onsite 21-inch wastewater line provides wastewater conveyance from the project site. The OCSD owns a 21-inch diameter VCP � main in Frank Lane,which turns north and passes through the project site within a public easement in '�` the site's primary parking lot. The OCSD main is reduced to a 16-inch diameter at an angle point in ,,,� East Santiago Canyon Road,at which point the OCSD main turns easterly and continues in East „�,; Santiago Canyon Road. The OCSD 21-inch diameter main, which passes through the project site, w� currently serves the school and the church, and is expected to continue as the point of service for the proposed project. "�° � Under the proposed conditions,the entire project site would continue to receive wastewater service from the OCSD. The development of the proposed project would not result in a significant impact �� related to the wastewater conveyance facilities that serve the project site because there is excess `�"' capacity in the conveyance facilities. Thus,the project does not have the potential to reyuire or result � in the construction of new water ar wastewater treatment facilities or expansion of existing facilities. ,,,�,, Response to Comment 10-40 ""` � The proposed project site is not required to have the same boundaries as the existing CUP. Salem Lutheran Church and School is allowed to propose a Specific Plan for land under its control or owned � by Salem Lutheran Church and School. � � Response to Comment 10-41 � This comment does not pertain to the proposed project; however,the comment is duly noted. ,, � 3-192 Michae/Brandman Associates � H\Client(PN-JN)U771\37710001U2TC-FEIIt\37710001 Sec03-00 Responses.doc � Sa/em Lutheran Church and Schoo/OPA Compromise Specifc Plan Response to Comments on the Draft EIR Responses to Comments Response to Comment 10-42 This comment refers to a resident-drafted plan included within this comment letter(Letter 10), identified herein as the Grayson Traffic Plan. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document for an evaluation of the Grayson Traffic Plan. Response to Comment 10-43 As addressed in Response to Comment ]0-10, under the current CUP,the maximum student enrollment is 726 students and the maximum number of students allowed on campus at one time is 611. This limitation on the number of students both enrolled and allowed on campus at any given time would still apply to the proposed project even though there would be no longer be a CUP. The restrictive covenant previously recorded against the existing use and property would remain in effect. The Specific Plan contains the same limits on maximum student enrollment and maximum number of students on campus at one time as the current CUP. The proposed project would not increase the existing school's capacity, as there would be no new school facilities,just the replacement of existing facilities (i.e., the new preschool would replace the existing preschool). Overall,the proposed project would have no effect on student enrollment levels. Response to Comment 10-44 This comment expresses concern over the proposed project's consistency with the OPA Plan. As addressed in Response to Comment 5-5,the proposed project is consistent with the OPA Plan and the City of Orange General Plan. Response to Comment 10-45 The proposed project site is not required to have the same boundaries as the existing CUP. Salem Lutheran Church and School is allowed to propose a Specific Plan for land under its control or owned by Salem Lutheran Church and School. Response to Comment 10-46 This comment makes reference to Draft EIR Section 3, Project Description subsection 3.2.3, Site Plan Chronology. The purpose of including this section in the Draft EIR was to outline previous public outreach efforts that have occurred over the past several years. CEQA encourages public participation and transparency during the planning process;this section was included to illustrate this point, and show to the reader that efforts have been made to involve the public during the planning of the proposed project. Your comments are duly noted. Michael Brandman Associates 3-193 H1Client(PN-JN)�i771\377IOOOl�RTGFEIR�37710001 Sec03A0Responses.doc Sa/em Lutheran Church and Schoo/OPA Compromise Specific Plan Responses to Comments Response to Comments on the Draft E/R Response to Comment 10-47 As addressed in Response to Comment 10-46,the purpose of including Draft EIR Section 3, Project Description subsection 3.2.3, Site Plan Chronology, was to outline previous public outreach efforts that have occurred over the past several years. Your comments are duly noted. Response to Comment 10-48 This comment does not pertain to the proposed project; however,the comment is duly noted. Response to Comment 10-49 The Fowler House is being referred to as a vacant structure because it is not being used as a residence or for church/school activities. „m:. Response to Comment 10-50 This comment requests clarification regarding Draft EIR Section 3, Project Description Table 3-1, Land Use Summary, and where the Fowler property is addressed in the table. The Fowler House will be removed and replaced with a new parking area. An approximately 7,505 sy ft preschool building „� and associated 7,921 sq ft play area will be built adjacent to the western portion of the existing $,� Classroom Building B. As such,the Fowler House will not be part of operation of the proposed project and the Fowler property will be part of the overall project site. The proposed relocation of the � preschool as part of the OPA Compromise Plan will not affect the capacity as evaluated in the Draft EIR and will not impact the overall enrollment cap as identified in the existing CUP. �� Response to Comment 10-51 i � This comment expresses concern over the effect planned student enrollment would have on the proposed parking plan. As addressed in Response to Comment 10-10, and as addressed under the K-8 School subsection in Draft EIR Section 3, Project Description subsection 3.4.2,Architectural � Theme Characteristics (page 3-15), per the CUP 2213-98, Resolution 8974, approved by the City of "'"` Orange on July 14, 1998,the maximum student enrollment is 726 students and the maximum number �„p of students allowed on campus at one time is 611. This limitation on the number of students both �k,. enrolled and allowed on campus at any given time would still apply to the proposed project even though there would be no longer be a CUP. The restrictive covenant previously recorded against the � existing use and property would remain in effect upon approval of the proposed project. The Specific '""� Plan contains the same limits on maximum student enrollment and m�imum number of students on ,�, campus at one time as the current CUP. The proposed project would not increase the existing �. school's capacity, as there would be no new school facilities,just the replacement of existing facilities (i.e.,the new preschool would replace the existing preschool). Overall,the proposed project would � have no effect on student enrollment levels. • � 3-194 Michae/Brandman Associates �� H�\Client(PN-J1��3771\37710001�RTC-FEilt\37710001 Sec03-OOResponses-doc Salem Lutheran Church and School OPA Compromise Specific Plan Response to Commenis on the Draft E/R Responses to Comments A TIA Addendum(Appendix A)was prepared for the OPA Compromise Plan to address the potential traffic and parking impacts associated with the proposed project as described in the Specific Plan compared with the 712-seat sanctuary scenario analyzed in the City-approved Traffic Impact and Parking Demand Analysis Report dated August 20, 2010. Based on the TIA Addendum for the proposed project,no traffic impacts will be created and adequate parking will be provided consistent - with the City-approved Traffic Impact and Parking Demand Analysis Report. Per City of Orange Zoning Ordinance 1734.60, Off-Street Parking and Loading, Required Number of Parking Spaces(Table 17.34.060.A),the following parking requirements under"Educational"are provided(there are no standards addressing pre-school or kindergarten): • Day Care,Nursery School: 2 spaces per employee. • Elementary and Junior High School: 1.8 spaces per classroom. Assuming the proposed project's Preschool and Pre-K component has 8-1 1 staff inembers, 16 to 22 parking spaces would be required in accordance with the above parking ordinance. Assuming the project's Kindergarten component has up to 20 total classrooms(note that this is an approximate total, as the exact number of classrooms is currently not finalized, although the total is unlikely to exceed 20 rooms), 36 spaces would be necessary in accordance with the above parking ordinance. This would result in a combined total of approximately 52 to 56 spaces required. During school hours, approximately 108 of the project's 186 surface parking spaces will be available for teacher parking. (Roughly 78 surface spaces are located in the central parking area, which is used � for play courts during the school day.) Nonetheless,the 108 available parking spaces would satisfy the daily parking needs of the proposed project's preschool. Response to Comment 10-52 Section 8 of the Specific Plan (Appendix I, Salem Lutheran Church and School OPA Compromise Specific Plan, of the Draft EIR)discusses the administrative procedures the City will use to implement and administer the specific plan, which includes phasing, lot line adjustments, and site plan review. Response to Comment 10-53 This comment refers to a resident-drafted plan included within this comment letter(Letter 10), identified herein as the Grayson Traffic Plan. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document for an evaluation of the Grayson Traffic Plan. Response to Comment 10-54 The comment addresses an existing condition and does not specifically address the proposed project; however,the comment is duly noted. Michael Brandman Associates 3-195 H�.\Client(PN-JN)�3771\37710001�RTGFE[R�37710001 Sec03-00 Responses doc Sa/em Lutheran Church and School OPA Compromise Specific P/an Responses to Comments Response to Comments on the Draft E/R � Response to Comment 10-55 The purchase of the Fowler House did not violate the existing CUP. As addressed in Response to � Comment 10-9,the proposed project, including the development of the Fowler property as a parking area following the removal of the Fowler House, is consistent with the OPA Plan and the City of � Orange General Plan. The proposed relocation of the preschool as part of the OPA Compromise Plan will not affect the capacity as evaluated in the Draft EIR and will not impact the overall enrollment � cap as identified in the existing CUP. � � Response to Comment 10-56 � This comment expresses concern over the size of the proposed project and parking. As addressed in �,, Response to Comment 5-5,the proposed project and all of its improvements are consistent with the OPA Plan and the City of Orange General Plan, and comply with all applicable provisions of the City � of Orange Zoning Ordinance in regards to the size (e.g., FAR)of onsite structures. � .�r Additionally,potential parking impacts were addressed in both Response to Comment 6-3 and � Response to Comment 8-4. As determined in the Draft EIR and previously addressed in the aforementioned responses, project-generated parking would be less than significant. '�1` w� Response to Comment 10-57 � This comment states that the proposed project does not contain enough trees and the landscape plan is not specific. A detailed landscape plan is provided as Section 3, Project Description Exhibit 3-6, � Landscape Master Plan, on page 3-19 of the Draft EIR. As stated under the Landscaping subsection in Section 3, Project Description subsection 3.4.3, Landscaping, Trees, Fencing, and Lighting � Characteristics, of the Draft EIR(page 3-16 of the Draft EIR): �, � The intent of the landscape design on site is to unify the exterior spaces of the property,to complement the architectural style of the existing/proposed buildings '�"'" and to connect the project contextually to the surrounding OPA community. A plant �"� materials palette has been developed with consideration to the rural characteristics of �„ this part of the City of Orange and OPA and includes both low maintenance plant ,� materials and the efficient use of water, as is specified in the City of Orange � document, `Guidelines for Water Efficient Landscapes.' Exhibit 3 6 (of the Draft EIR)provides the landscape master plan. Refer to the landscape guidelines section `"� of the Specific Plan in Appendix I (of the Draft EIR)for a detailed description of the ,,,E proposed plant palette and tree species proposed for removal and retention. � � Additionally, an updated Landscape Master Plan will be implemented onsite, which will increase the number and size of trees and planting on the project site. The final Landscape Plan would be `'�` � � 3-196 Michae/Brandman Associates �,�„ H\Client(PN-JN)�3771\37710001�RTC-FEIR\37710001 Sec03-00 Responses.doc �u Salem Lutheran Church and School OPA Compromise Specific Plan Response to Comments on the Draft EIR Responses to Comments submitted for review by the City of Orange at the time of the final Site Plan review and is part of the site plan review process. Response to Comment 10-58 This comment expresses concern over the use of chain link style fencing along a portion of the periphery of the project site. However, per comment from the City's DRC,the existing chain link fencing will be removed and replaced with maximum 6-foot-high square tubular steel fencing. Where ball control is required, the tubular fencing will be backed by prefinished rectangular welded wire fabric colored to match the tubular steel fencing. The use of such fencing will be placed as a condition of approval on the project.. Response to Comment 10-59 The comment is duly noted. Response to Comment 10-60 This comment expresses concern over the size of the proposed project. As addressed in Response to Comment 5-5,the proposed project and all of its improvements are consistent with the OPA Plan and the City of Orange General Plan, and comply with all applicable provisions of the City of Orange Zoning Ordinance in regards to the size (e.g., FAR) of onsite structures. Response to Comment 10-61 This comment expresses concern over the proposed reconstruction of an existing masonry wall along the western boundary of the project site. In the time that has lapsed since this particular comment was � � submitted,this existing masonry wall has been rebuilt by the adjacent property owner. Thus,the reconstruction of this wall is no longer part of the proposed project. Response to Comment 10-62 This comment expresses concern over lighting impacts. In part,this comment also states the existence of an existing issue, not an issue that would be caused or worsened by the proposed project. Light and glare impacts are addressed in Draft EIR Section 4.1, Aesthetics. The Draft EIR determined that light resulting from the operations of the proposed project, including parking lot, temporary overflow parking lot, and security lighting, would comply with all City of Orange requirements. Parking lot lighting,temporary multipurpose field lighting, and lighting would be shielded and adjusted to avoid light overspill (light trespass). No single definition of light overspill or light trespass has been established. However, light overspill examples are when spill light from a streetlight ar floodlight enters a window and illuminates an indoor area, light falling over property lines illuminating adjacent grounds or buildings in an objectionable manner, or unwanted light, which causes annoyance, discomfort, distraction, or a reduction in visibility. All light direction shall be downward, rather than upward or sideways,to eliminate light pollution to the extent possible. The Michael8randman Associates 3-197 H.\Client(PN-.IN)U771\37710001UtTGFEIIt�37710001 Sec03-OOResponses.doc Salem Lutheran Church and Schoo/OPA Compromise Specific P/an Responses to Comments Response to Comments on the DraR E/R ��N= areas illuminated would be minimized but would comply with the City of Orange minimum , photometric requirements. �fi The comment also expresses the opinion that there is a need for `some teeth in the Specific Plan.' tl°^� Any violation of the development standards contained in the Specific Plan would constitute a � violation of the City's Zoning Code. Pursuant to § 17.02.030 of the City's Code, "any use of property �G,� contrary to the provisions of this title . . . is unlawful and a public nuisance,"which the City may take action to abate. Accordingly,the City has sufficient authority to enforce the Specific Plan. 1°° �,� Response to Comment 10-63 � This comment expresses the commenter's approval of the previously proposed driveway off East �. Santiago Canyon Road. However, consistent with the "Single Site Access" alternative analyzed in � the Draft EIR,there would be no driveway from Santiago Canyon Road. Instead,there will be an � additional right-hand turn lane along Orange Park Boulevard, which would improve circulation both internally and on local roads. � � Response to Comment 10-64 A. This comment refers to a resident-drafted plan included within this comment letter(Letter 10), „� identified herein as the Grayson Traffic Plan. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document for an evaluation of the Grayson Traffic Plan. � Response to Comment 10-65 � This comment expresses concern over the proposed parking plan. A TIA Addendum (Appendix A) � was prepared far the OPA Compromise Plan to address the potential traffic and parking impacts �, associated with the proposed project as described in the Specific Plan compared with the 712-seat � sanctuary scenario analyzed in the City-approved Traffic Impact and Parking Demand Analysis Report dated August 20, 2010. Based on the TIA Addendum for the proposed project, no traffic `""" impacts will be created and adequate parking will be provided consistent with the City-approved "� Traffic Impact and Parking Demand Analysis Report. � Response to Comment 10-66 °� � This comment expresses concern over emergency access along Frank Lane. While § 503.2.1, Dimensions, of the City's Municipal Code states, "Fire apparatus roads shall have a[n] unobstructed � width of not less than 20 feet(6,096 mm), and shall have an unobstructed vertical clearance of not �*r' less than 13 feet 6 inches (4,115 mm)",the section continues to provide three exceptions, one of ,�. which states, "Divided fire access roads shall be in accordance with Section 503.2.].2". Section � 503.2.1.2, Divide Fire Access Roads, states, "Divided fire access roads shall be subject to review and approval by the fire code official. Each lane shall be a minimum width of 14 feet." Both the northern � (project) and southern (residential) portions of the divided Frank Lane would be at minimum l4 feet """"" � 3-198 Michael Brandman Associates �, H�\Client(PN-IN)U771\37710001UiTC-FEIR\37710001 Sec03-OOResponses.doc � Sa/em Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments on the Draft E/R Responses to Comments wide. Additionally, a"hammerhead"turnaround will be constructed at the western terminus of Frank Lane, in accordance with City of Orange Fire Department Standards,to aid in the movement of large vehicles such as fire trucks. As addressed in the Section,the City of Orange Fire Chief or their representative would provide a final review of all site plans, including circulation plans, prior to the issuance of building permits, ensuring that any circulation improvements conducted as part of the project would comply with the standards established by the City's Fire Code. Therefore,the project would comply with this element of the City's Fire Code. Response to Comment 10-67 See Response to Comment 5-4. Response to Comment 10-68 This comment does not pertain to the proposed project; however,the comment is duly noted. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document. Response to Comment 10-69 This comment expresses concern over fire flow requirements. As addressed in Draft EIR Section 4.9, Utilities and Service Systems,the proposed project will comply with all applicable codes and requirements related to fire flow, and thus, less than significant impacts required to fire flow water supply would result from project implementation. The City of Orange Fire Chief or their representative would provide a final review of all site plans prior to the issuance of building permits, ensuring that the proposed project's fire flow and water pressure would comply with the standards established by the City's Fire Code. Therefore,the project would comply with this element of the City's Fire Code. Response to Comment 10-70 Draft EIR Section 3, Project Description, acknowledges that stormwater flows as sheet flow along Frank Lane before reaching Handy Creek. Consistent with the"Single Site Access"alternative analyzed in the Draft EIR,there would be no driveway from Santiago Canyon Road, and as a result, stormwater flows will not have a direct outlet onto the roadway as previously proposed. As a result, a private storm drain system is proposed for the project. This storm drain system will pick up the majority of the project site and convey flow toward Santiago Canyon Road where it will be picked up in and existing 36-inch RCP within Santiago Canyon Road. This 36-inch RCP conveys flows to the Handy Creek reinforced concrete box culvert under Santiago Canyon Road. This storm drain system will alleviate flooding that has occurred within the private drive westerly of the project site. No significant increases in peak flow or runoff volume will occur due to development. Modeled peak runoff for the project remains relatively the same for the 10-year and 25-year High Confidence Events and decreases approximately l percent during the ]00-year High Confidence Event. Therefore,the Michael8randman Associates 3-199 H-\Client(PN-1N)�3771\37710001�RTGFEIIL�37710001 Sec03-00 Responses.doc Sa/em Lutheran Church and Schoo/OPA Compromise Specific Plan Responses to Comments Response to Comments on the Draft E/R � project's hydrology and water quality impacts will be similar when compared with those impacts analyzed in the Draft EIR. � Response to Comment 10-71 � Consistent with the "Single Site Access"alternative analyzed in the Draft EIR,there would be no ""� driveway from Santiago Canyon Road, and as a result, stormwater flows will not have a direct outlet '�' onto the roadway as previously proposed. As a result, a private storm drain system is proposed for ,,,� the project. This storm drain system will pick up the majarity of the project site and convey flow ,�. toward Santiago Canyon Road where it will be picked up in and existing 36-inch RCP within Santiago Canyon Road. This 36-inch RCP conveys flows to the Handy Creek reinforced concrete � box culvert under Santiago Canyon Road. This storm drain system will alleviate flooding that has '°� occurred within the private drive westerly of the project site. � No significant increases in peak flow or runoff volume will occur due to development. Modeled peak � runoff for the project remains relatively the same for the 10-year and 25-year High Confidence Events "' and decreases approximately 1 percent during the 100-year High Confidence Event. Therefore, the � project's hydrology and water quality impacts will be similar when compared with those impacts � analyzed in the Draft EIR. �e Response to Comment 10-72 � This comment states that although Draft EIR Section 3, Project Description subsection 3.4.6, Offsite "�" Improvements, makes reference to a property "west" of the project site, this property is actually �, "northwest"of the site. Consistent with the"Single Site Access"alternative analyzed in the Draft ,�,,; EIR,there would be no driveway from Santiago Canyon Road, and as a result, land will no longer be � required form the adjacent property owner northwest of the project site to accommodate a deceleration lane. �'" � Response to Comment 10-73 � This comment expresses the commenter's opinion regarding the proposed project's use of pavement �,,,,, markers to divide Frank Lane. Residential traffic would be separated from project traffic with "TYPE � AY"pavement markers. The final decisions regarding the final site plan and project specifics, including the use of pavement markers along Frank Lane, would require the approval of the City of "� Orange prior to the commencement of construction activities. '� Response to Comment 10-74 � � The comment references an existing condition and does not specifically address the proposed project, � but is duly noted. � � �: 3-200 Michae/Brandman Associates � H�.\Client(PN-JN)�3771\37710001V2TGFEIlt\37710001 Sec03-00 Responses_doc � Salem Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments on the Oraft EIR Responses to Comments Response to Comment 10-75 This comment does not pertain to the proposed project; however,the comment is duly noted. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document. Response to Comment 10-76 This comment does not pertain to the proposed project; however,the comment is duly noted. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document. Response to Comment 10-77 This comment states that an incorrect baseline was used to analyze potential project impacts. Each of environmental topic sections (e.g.,Aesthetics, Air Quality, Biological Resources, etc.) included an Environmental Setting section that described the existing conditions. These existing conditions were used as the environmental baseline, which is the acceptable and appropriate practice according to CEQA and CEQA Guidelines. These existing conditions were representative of the conditions found on and adjacent to the project site on the date that the Notice of Preparation(NOP [Appendix A, Notice of Preparation, lnitial Study, and Comment Letters, of the Draft EIR)for the proposed project was distributed (October 13, 2011). Response to Comment 10-78 In part,this comment states the existence of an existing issue, not an issue that would be caused or worsened by the proposed project. Light and glare impacts are addressed in Draft EIR Section 4.1, Aesthetics. The Draft EIR determined that light resulting from the operations of the proposed project, including parking lot,temporary overflow parking lot, and security lighting, would comply with all City of Orange requirements. Response to Comment 10-79 This comment expresses concern over existing light spillage from the Site, and thus, largely concerns an alleged existing issue, not an impact that would be caused or worsened by the proposed project. Light and glare impacts are addressed in Draft EIR Section 4.1, Aesthetics. The Draft EIR determined that light resulting from the operations of the proposed project, including parking lot, temporary overflow parking lot, and security lighting, would comply with all City of Orange requirements. Refer to Response to Comment 10-62. Response to Comment 10-80 This comment expresses concern over existing issues related to glare, and thus, largely concerns an alleged existing issue, not an impact that would be caused or worsened by the proposed project. Light and glare impacts are addressed in Draft EIR Section 4.1, Aesthetics. The Draft EIR determined that light resulting from the operations of the proposed project, including parking lot,temporary overflow Michael Brandman Associates 3-201 H.\Cliem(PN-JN)�3771\37710001ViTC-FEIIt\37710001 Sec03-OOResponsesdoc Salem Lutheran Church and School OPA Compromise Specific P/an Responses to Comments Response to Comments on the Draft E/R parking lot,and security lighting, would comply with all City of Orange requirements. Refer to Response to Comment 10-62. � Response to Comment 10-81 �� This comment does not pertain to the proposed project; however,the comment is duly noted. Refer to �' Section 4, The Grayson Traffic Plan, of this Response to Comments document. � � Response to Comment 10-82 � As addressed in Response to Comment 10-9,the proposed project, including development of the � Fowler property as a parking area following the removal of the Fowler House, is consistent with the � OPA Plan and the City of Orange General Plan. The proposed relocation of the preschool as part of the OPA Compromise Plan will not affect the capacity as evaluated in the Draft EIR and will not '"'� impact the overall enrollment cap as identified in the existing CUP. �_ � In addition, referencing the Fowler House as an onsite structure indicates the structure is on property owned by the Church and is included in the proposed project area. This does not infer that the "' structure is part of the existing CUP area. In addition,the existing CUP does nor prevent the Church � from purchasing additional land, such as was done when the Fowler House was purchased, and �;, proceeding through an entitlement process to incorporate the land into its operations. The Fowler House is being referred to as a vacant structure because it is not being used as a residence or for � church/school activities. Past maintenance is not part of the proposed project or Draft EIR; the � comment is duly noted. � � Response to Comment 10-83 � This comment states that although Draft EIR Section 4.1 Aesthetics Exhibit 4.1-1 b, Site Photographs � 5 and 6, makes reference to Photograph 5's orientation as looking"north,"the photograph is actually looking"west." The caption under Exhibit 4.1-Ib, Site Photograph 5 is revised as follows: '""'` �. Photograph 5: This photo shows Frank Lane, looking�e�kwest, with the church/ � school on the right and residences on the left. � � Response to Comment 10-84 � � This comment expresses concern over existing light spillage, and thus, largely concerns an alleged existing issue, not an impact that would be caused or worsened by the proposed project. Lighting � impacts are addressed in Draft EIR Section 4.1, Aesthetics. The Draft EIR determined that light � resulting from the operations of the proposed project, including parking lot,temporary overflow � parking lot, and security lighting, would comply with all City of Orange requirements. Per Sections � 6.5 and 7.4 of the Specific Plan, light shields would be provided on all exteriar light fixtures. � � 3-202 Michael8randman Associates � H�.\Client(PN-JN)13771\37710001�RTC-FEIR\37710001 Sec03-00 Responses.doc � � Salem Lutheran Church and Schoo/OPA Compromise Specific P/an Response to Comments on ihe Draft E/R Responses to Comments Response to Comment 10-85 This comment is concerned with sun glare affecting student drop-off and pick-up locations. Glare from the sun varies throughout the year and time of day. Section 3, Project Description, of the Draft EIR describes the school drop-off and pick-up and states that traffic control personnel will direct traffic. In addition, Exhibit 4.8-2 in Section 4.8, Transportation and Traffic, of the Draft EIR graphically depicts the drop-off and pick-up location,which is oriented in a northwest/southeast direction. Student drop-off and pick-up is not proposed along Frank Lane. Reorienting the student drop-off and pick-up location to a north/south axis would result in the need to redesign the site because this orientation would require proposed parking spaces to be removed. Response to Comment 10-86 This comment acknowledges the Orange Park Association policy. This comment is duly noted. Response to Comment 10-87 This comment does not pertain to the proposed project; however, the comment is duly noted. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document. Response to Comment 10-88 The comment references the need to widen the resident lane to a proper emergency vehicle width. As addressed in Response to Comment No. 10-66, a discussion on emergency vehicle access is provided. Response to Comment 10-89 This comment expresses concern over the impact conclusion of the air quality analysis contained in Draft EIR Section 4.2, Air Quality. In part,this comment references the existence of an existing issue, not an issue that would be caused or worsened by the proposed project. The purpose of CEQA and the preparation of a Draft EIR is to analyze whether a proposed project would result in any new significant environmental impacts,not to address existing issues. Regardless, as addressed in the TIA Addendum (Appendix A),the project will result in up to 413 AM peak-hour trips for a typical Sunday church service, representing a 30-percent net trip reduction in the number of AM peak-hour trips analyzed in the Draft EIR. In general,the project's operational emissions are at least in part related to project-generated traffic and the exhaust emissions from those vehicles. Thus, because of the reduction in peak-hour trips, it can be assumed that vehicle exhaust emissions, as well as any contaminants contained in those emissions such as VOC,NOX, and ROG, will also be reduced. Therefore,the project's air quality and greenhouse gas impacts will be reduced when compared with those impacts analyzed in the Draft EIR, which were already determined to be less than significant. Michael Brandman Associates 3-203 H�\Client(PN-JN)�3771\37710001�RTC-FEIIt�37710001 Sec03-OOResponses.doc Sa/em Lutheran Church and Schoo/OPA Compromise Specific P/an Responses to Comments Response to Comments on the Drafi EIR � Response to Comment 10-90 � As addressed in Response to Comment 10-31, according to the Initial Study, no evidence of w�r hazardous materials contamination has been encountered on or adjacent to the project site. �, Additionally,the project site is not listed on either federal or State databases presented in the Radius � Map Report prepared by Environmental Data Resources, Inc. (Draft EIR Appendix E, Environmental Data Resources, Inc. [EDR] Map Report). As addressed in Response to Comment 9-23 and Response � to Comment l 0-31, a discussion of potentially hazardous materials is provided. � �. Response to Comment 10-91 � As addressed in Response to Comment 10-31, according to the Initial Study, no evidence of � hazardous materials contamination has been encountered on or adjacent to the project site. Additionally,the project site is not listed on either federal or State databases presented in the Radius � Map Report prepared by Environmental Data Resources, Inc. (Draft EIR Appendix E, Environmental "�" Data Resources, Inc. [EDR] Map Report). The comment also expresses concern over the potential for ,,,� asbestos containing materials occurring within the existing buildings on the project site. Draft EIR ,� Section 4.4,Hazards and Hazardous Materials, describes asbestos and its potential environmental and health impacts based in part on when a building was constructed. The interior of the Fowler House � has not been inspected to verify if mold is present or if the substance is mildew or some other non- �`" hazardous substance. Prior to demolition activities, a licensed specialist will inspect the interior of ,� the Fowler House to determine the presence or absence of hazardous substances, including ACM, „�; LBP, or other potentially hazardous substances such as mold. In the event that any mold or other � potentially hazardous substances are determined to be present, remediation by a licensed specialist would occur prior to demolition activities, as part of standard construction practices and consistent � with all applicable federal, state, and local provisions related to the handling of potentially hazardous .w substances. This inspection and potential remediation will be placed as a condition of approval on the ,� project. � Response to Comment 10-92 � Consistent with the "Single Site Access"alternative analyzed in the Draft EIR,there would be no '� driveway from Santiago Canyon Road, and as a result, stormwater flows will not have a direct outlet �' onto the roadway as previously proposed. As a result, a private storm drain system is proposed for ,,,,, the project. This storm drain system will pick up the majority of the project site and convey flow � toward Santiago Canyon Road where it will be picked up in and existing 36-inch RCP within Santiago Canyon Road. This 36-inch RCP conveys flows to the Handy Creek reinforced concrete � box culvert under Santiago Canyon Road. This storm drain system will alleviate flooding that has "� occurred within the private drive westerly of the project site. w� � No significant increases in peak flow or runoffvolume will occur due to development. Modeled peak runoff for the project remains relatively the same for the 10-year and 25-year High Confidence Events "°' � 3-204 Michae/Brandman Associates � H�.\Client(PN-JN)�3771\37710001�RTC-FEIR\37710001 Sec03-00 Responsesdoc Yis Salem Lutheran Church and School OPA Compromise Specific Plan Response to Comments on the Draft EIR Responses to Commenfs and decreases approximately 1 percent during the 100-year High Confidence Event. Therefore,the project's hydrology and water quality impacts will be similar when compared with those impacts analyzed in the Draft EIR. Response to Comment 10-93 This comment consists of captioned photos that purport to depict existing drainage conditions. Accordingly,this comment relates largely to an alleged existing issue, rather than an impact that would be caused by the proposed project. Regardless, consistent with the"Single Site Access" alternative analyzed in the Draft EIR,there would be no driveway from Santiago Canyon Road, and as a result, stormwater flows will not have a direct outlet onto the roadway as previously proposed. As a result, a private storm drain system is proposed for the project. This storm drain system will pick up the majority of the project site and convey flow toward Santiago Canyon Road where it will be picked up in and existing 36-inch RCP within Santiago Canyon Road. This 36-inch RCP conveys flows to the Handy Creek reinforced concrete box culvert under Santiago Canyon Road. This storm drain system will alleviate flooding that has occurred within the private drive westerly of the project site. No significant increases in peak flow or runoff volume will occur due to development. Modeled peak runoff for the project remains relatively the same for the 10-year and 25-year High Confidence Events and decreases approximately 1 percent during the 100-year High Confidence Event. Therefare,the project's hydrology and water quality impacts will be similar when compared with those impacts analyzed in the Draft EIR. Response to Comment 10-94 This comment does not pertain to the proposed project; however,the comment is duly noted. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments. Response to Comment 10-95 Consistent with the "Single Site Access" alternative analyzed in the Draft EIR,there would be no driveway from Santiago Canyon Road, and as a result, stormwater flows will not have a direct outlet onto the roadway as previously proposed. As a result, a private storm drain system is proposed for the project. This storm drain system will pick up the majority of the project site and convey flow toward Santiago Canyon Road where it will be picked up in and existing 36-inch RCP within Santiago Canyon Road. This 36-inch RCP conveys flows to the Handy Creek reinforced concrete box culvert under Santiago Canyon Road. This storm drain system will alleviate flooding that has occurred within the private drive westerly of the project site. No significant increases in peak flow or runoff volume will occur due to development. Modeled peak runoff for the project remains relatively the same for the 10-year and 25-year High Confidence Events and decreases approximately 1 percent during the 100-year High Confidence Event. Therefore, the Michael Brandman Associates 3-205 H.AClien[(PN-JN)�i771A37710001UtTGFEIR�37710001 Sec03-00 Responses.doc Salem Lutheran Church and Schoo/OPA Compromise Specific P/an Responses to Comments Response to Comments on the Draft E/R project's hydrology and water quality impacts will be similar when compared with those impacts analyzed in the Draft EIR. � Response to Comment 10-96 This comment does not pertain to the proposed project; however,the comment is duly noted. Refer to '""' Section 4, The Grayson Traffic Plan, of this Response to Comments document. � Response to Comment 10-97 � �,, Consistent with the"Single Site Access"alternative analyzed in the Draft EIR, there would be no � driveway from Santiago Canyon Road, and as a result, stormwater flows will not have a direct outlet onto the roadway as previously proposed. As a result, a private storm drain system is proposed for � the project. This storm drain system will pick up the majority of the project site and convey flow '"`" toward Santiago Canyon Road where it will be picked up in and existing 36-inch RCP within �- Santiago Canyon Road. This 36-inch RCP conveys flows to the Handy Creek reinforced concrete � box culvert under Santiago Canyon Road. This storm drain system will alleviate flooding that has occurred within the private drive westerly of the project site. � No significant increases in peak flow or runoff volume will occur due to development. Modeled peak �„ runoff for the project remains relatively the same for the 10-year and 25-year High Confidence Events and decreases approximately 1 percent during the 100-year High Confidence Event. Therefore,the � project's hydrology and water quality impacts will be similar when compared with those impacts '� analyzed in the Draft EIR. � Response to Comment 10-98 � � As addressed in to Response to Comment 10-9 the proposed project, including the development of the Fowler property as a preschool facility, is consistent with the OPA Plan and the City of Orange � General Plan. +� �: Response to Comment 10-99 � This comment expresses concern over project-related operations noise. As previously addressed in �, Response to Comment 6-2, long-term noise impacts associated with operations of the project were found to be less than significant and were addressed in the Initial Study (Draft EIR Appendix A, � �:, Notice of Preparation, Initial Study, and Comment Letters)prepared for the project prior to the Draft EIR. The Initial Study concluded that the operations phase of the proposed project would not result *� in noise increases over the existing conditions since the proposed land use would be the same as the �: existing land use, with similar traffic conditions and onsite activities. Additionally,the Noise Impact � Analysis prepared for the proposed project(Draft EIR Appendix G,Noise Impact Analysis) examined long-tenn, operations-related noise and determined the noise impacts would be less than significant in � regards to onsite operational noise. The Noise Impact Analysis analyzed potential noise generated by '""' 3-206 Michae/Brandman Associates � H�.\Client(PN-JN)�3771\37710001�RTGFEIIL\37710001 Sec03-00 Responses.doc �: Salem Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments on the Draft E/R Responses to Comments the proposed parking lots,the playground,the sanctuary, and the fellowship reception area, determining that noise produced at any of these locations would not exceed the City of Orange noise standards. This analysis was completed consistent with § 8.24.070 of the Orange Municipal Code and the Noise Element of the City's General Plan. Response to Comment 10-100 This comment consists of two photographs depicting existing vehicular traffic along Frank Lane. The comment is not accompanied by a text comment, but presumably expresses concern over noise generated by onsite traffic generated by the proposed project. In part,this comment references the existence of an existing issue, not an issue that would be caused or worsened by the proposed project. Additionally,the Draft EIR analyaed potential noise impacts from project-related activities on parking lots and onsite roads. Draft EIR Section 4.7,Noise Table 4.7-16 provided the maximum noise levels from onsite sources at the nearest sensitive receptors. Draft EIR Table 4J-16 provided a worst-case scenario, as attenuation from walls, buildings, and landscaping was not incorporated into calculations. Even without taking into account attenuation from walls, buildings, and landscaping, maximum noise levels from onsite sources, which would include vehicular traffic on parking lots and onsite roads, would not exceed the City's daytime maximum noise standard of 75 dBA Lmax at the nearest sensitive receptors. Michael Brandman Associates 3-207 H\Client(PN-.!N)�3771\37710001UtTC-FEIRll7710001 Sec03-00 Responses doc Sa/em Lutheran Church and Schoo/OPA Compromise Specifc P/an Responses to Comments Response to Comments on the Drafi E/R Response to Comment 10-101 This comment contains a series of photographs and descriptions of alleged existing traffic issues. � This comment references the existence of an existing issue, not an issue that would be caused or ,�„� worsened by the proposed project. A TIA Addendum (Appendix A)was prepared for the OPA Compromise Plan to address the potential traffic and parking impacts associated with the proposed � project as described in the Specific Plan compared with the 712-seat sanctuary scenario analyzed in � the City-approved Traffic Impact and Parking Demand Analysis Report dated August 20, 2010. �"°' Based on the TIA Addendum for the proposed project, no traffic impacts will be created and adequate �k parking will be provided consistent with the City-approved Traffic Impact and Parking Demand � Analysis Report. � Response to Comment 10-102 ,� This comment expresses concern over the proposed secondary use of the proposed multipurpose field '�"" as a temporary overflow parking lot during highly-attended events. The need for overflow parking is ■+. anticipated based upon recent past attendance recards of events, including holiday church services �,, (Easter, Christmas, etc.), school graduations, special school-related events and services (e.g., opening school year church service, Christmas programs, grandparents day), and funerals and weddings. � Overflow parking on the multipurpose field would be set-up prior to the event and is anticipated to �' fulfill the parking need. ,�, ,��: Draft EIR Section 4.8, Transportation and Traffic Exhibit 4.8-2 identifies location"A"for school drop-off and pick-up and location "B" for pre-school drop-off and pick-up. Exhibit 4.8-2 only '"� provided a description of location"A" in the key. Exhibit 4.8-2 is revised as follows to provide the �' description of location "B" in the key. No curbside drop-off and pick-up is provided for the � preschool because parents must sign children in and out and therefore must park their cars. �; � �. � ,� � � � +w� e� � � �: 3-208 Michae/Brandman Associates � H:\Client(PN-.TN)13771\37710001�RTC-FEDt\37710001 Sec03-00 Responses.doc il�. � ZK 1 � � LL W a I � N� Y w C �� a� � O �¢ � y �,, a L (p �� LLa� X U a¢ � n W � au4 �. aW �&�� U �Z o�� $o � O a u �I � v> xg�a I � z �'�w� w L �w ca_o �/� �dNo K Z V/ W��Z�i`Z a � �0��8 N21Vd 3`JNV21 ac—.......,......w...,, �'' � Y�<� .41 Q� Z ��`p<K U � $ — d — — — — � 2 � F�4b�aLL o � s 3 -- �' � U �a�� r � � � �� j � �Y R'Z\�� q � �1�� ` � � V�i VO�`V O g �I TI �• J �w O W V O V J = � I I� � �+ U a U�a�O N � -- W *. 2&S�&`�` S W � � -f ! 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I II $ I I � � — � a �.. 3NVl dNf1091f10� � � � � N � � `m �i S213HilVW N I Z m g LN3W3AYd 03SIVi1 � n � (S1N30LS3tl)�� N T � AtlM3�INd fO 10 x 31VAlild�� " � 0 � � 113Q1f1OHS � � m tO � °� o e J � � � � HiaoN� o J �� o � �� in �� w� � � �� w�- � �. � �, � � w� THIS PAGE INTENTIONALLY LEFT BLANK � � �. � � � � � � � � � � � � � � � � Sa/em Lutheran Church and School OPA Compromise Specific Plan Response to Comments on the Drafi E/R Responses to Comments Response to Comment 10-103 Refer to Response to Comment l 0-102 where a discussion of parking is provided. Additionally, refer to Draft EIR Section 4.8, Transportation and Traffic, Table 4.8-7, Parking Requirements, for an illustration of typical attendance and parking scenarios. Response to Comment 10-104 This comment does not directly address the proposed project; however,the comment is duly noted. Response to Comment 10-105 This comment contains a copy of document titled "Salem Lutheran Church and School Traffic Policy." No further comment is provided. Response to Comment 10-106 This comment contains a copy of document titled"Salem Lutheran School"and a figure illustrating a circulation pattern. No further comment is provided. Response to Comment 10-107 This comment refers to a resident-drafted plan included within this comment letter(Letter 10), identified herein as the Grayson Traffic Plan. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document for an evaluation of the Grayson Traffic Plan. Additionally, this comment expresses concern that projected weekday traffic was not addressed in the Draft EIR. The reason that the Traffic Impact Analysis (Draft EIR Appendix H, Traffic Impact and Parking Demand Analysis) focused on Sunday AM peak-hour conditions instead of weekday traffic associated with the educational component was that maximum student enrollment would not change with the proposed project. As addressed in Response to Comment 10-]0, per the CUP 2213-98, Resolution 8974, approved by the City of Orange on July 14, 1998,the maximum student enrollment is 726 students and the maximum number of students allowed on campus at one time is 611. This limitation on the number of students both enrolled and allowed on campus at any given time would still apply to the proposed project even though there would be no longer be a CUP. The restrictive covenant previously recorded against the existing use and property would remain in effect. The Specific Plan contains the same limits on maximum student enrollment and maximum number of students on campus at one time as the current CUP. The proposed project would not increase the existing school's capacity, as there would be no new school facilities,just the replacement of existing facilities (i.e.,the new preschoo] would replace the existing preschool). Overall, the proposed project would have no effect on student enrollment levels. Thus, since the proposed project would not increase the school component's maximum student enrollment,the project would not increase weekday traffic associated with the school. Michael Brandman Associates 3-2�� H1Client(PN-JN)13771\37710001�RTGFEQL�37710001 Sec03-00 Responses.doc � Salem Lutheran Church and Schoo/OPA Compromise Specifc Plan �"" Responses to Comments Response to Comments on the Draft E/R �e Response to Comment 10-108 ,� This comment refers to a resident-drafted plan included within this comment letter(Letter 10), +� identified herein as the Grayson Traffic Plan. Refer to Section 4, The Grayson Traffic Plan, of this � Response to Comments document for an evaluation of the Grayson Traffic Plan. � Response to Comment 10-109 � This comment states that traffic analysis performed for the proposed project only include Sunday � traffic in its modeling. However, as addressed by Draft EIR Impact 4.8-1 in Section 4.8, �' Transportation and Traffic, based upon the application of the significance criteria described in Draft ,� EIR Table 4.8-5,the proposed project is not anticipated to cause significant traffic impacts at any of � the key study intersections during the weekday and Sunday AM peak hour,when traffic is assumed to be most intense. � � Under the current CUP,the maximum student enrollment is 726 students and the maximum number �, of students allowed on campus at one time is 611. This limitation on the number of students both �: enrolled and allowed on campus at any given time would still apply to the proposed project even though there would be no longer be a CUP. The restrictive covenant previously recorded against the "" existing use and property would remain in effect. The Specific Plan contains the same limits on � maximum student enrollment and maximum number of students on campus at one time as the current � CUP. The proposed project would not increase the existing school's capacity, as there would be no � new school facilities,just the replacement of existing facilities(i.e., the new preschool would replace the existing preschool). Overall,the proposed project would have no effect on student enrollment '"� levels. � The maximum allowable student enrollment number would not change as a result of the proposed � project, and as a result, an increase in enrollment numbers does not require consideration for traffic � analysis. Implementation of the proposed project would not change the overall capacity of the school � component of the project, and thus, only the proposed increased capacity of the church/worship center .�. element of the project requires consideration for traffic analysis. � Response to Comment 10-110 � This comment states that the traffic analysis took into account only the existing student enrollment �` numbers and not the proposed enrollment numbers and excluded schools in the analysis in Draft EIR "� Section 5, Cumulative Impacts. As addressed under the K-8 School subsection in Draft EIR Section ,■,� 3,Project Description subsection 3.4.2, Architectural Theme Characteristics (page 3-1 5), per the CUP „� 2213-98, Resolution 8974, approved by the City of Orange on July 14, l 998,the maximum student enrollment is 726 students and the maximum number of students allowed on campus at one time is � 6]1. This limitation on the number of students both enrolled and allowed on campus at any given � time would still apply to the proposed project even though there would be no longer be a CUP. The � 3-212 Michael Brandman Associates „�;, H:\Client(PNdN)�3771\37710001�RTGFEIlt\37710001 Sec03-00 Responses-doc �;: Salem Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments on the Draft EIR Responses to Comments restrictive covenant previously recorded against the existing use and property would remain in effect. Table 4.3 of the Specific Plan contains the same limits on maximum student enrollment and maximum number of students on campus at one time as the current CUP. The proposed project would not increase the existing school's capacity, as there would be no new school facilities,just the replacement of existing facilities (i.e.,the new preschool would replace the existing preschool). Overall,the proposed project would have no effect on student enrollment levels. The maximum allowable student enrollment number would not change as a result of the proposed project, and as a result, an increase in enrollment numbers does not require consideration for traffic analysis. As addressed in the Traffic Impact Analysis prepared for the proposed project(Draft EIR Appendix H, Traffic Impact and Parking Demand Analysis), implementation of the proposed project would not change the overall capacity of the school component of the project, and thus, only the proposed increased capacity of the church/worship center element of the project requires consideration for traffic analysis. The list of related projects was derived from the City's list of pending land use applications and from the Notice of Preparation for the proposed Rio Santiago project. Response to Comment 10-111 Refer to Response to Comment 10-110 for a discussion for student enrollment. Part of this comment refers to a resident-drafted plan included within this comment letter(Letter 10), identified herein as the Grayson Traffic Plan. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document for an evaluation of the Grayson Traffic Plan. Also, refer to Response to Comment 10-110 Response to Comment 10-112 This comment does not directly address the proposed project; however,the comment is duly noted. Response to Comment 10-113 This comment expresses concern over the adequacy of"barriers"that would be installed between the proposed project and the adjacent residential uses. As addressed in Response to Comment 5-5,the proposed project, including the periphery landscaping, fencing, walls, and setbacks, are consistent with the OPA Plan and the City of Orange General Plan, and would comply with all applicable provisions of the City of Orange Zoning Ordinance in regards to any such "barriers." Response to Comment 10-114 As addressed by Draft EIR Impact 4.8-1 in Section 4.8, Transportation and Traffic, based upon the application of the significance criteria described in Draft EIR Table 4.8 5,the proposed project is not anticipated to cause significant traffic impacts at any of the key study intersections during both the Michael8randman Associates 3-213 H�.AClient(PN-JI��3771A37710001UtTC-FPIIt�37710001 Sec03-00 Responses.doc � Sa/em Lutheran Church and Schoo/OPA Compromise Specific P/an `�'" Responses to Comments Response to Comments on the Draft EIR � weekday and Sunday AM peak hour, when traffic is assumed to be most intense. The maximum „�, allowable student enrollment number would not change as a result of the proposed project, and as a � result, an increase in enrollment numbers does not require consideration for traffic analysis. Implementation of the proposed project would not change the overall capacity of the school � component of the project, and thus, only the proposed increased capacity of the church/worship center � element of the project requires consideration for traffic analysis. � Response to Comment 10-115 '" � Again,the proposed project is not anticipated to cause significant traffic impacts at any of the key study intersections during both the weekday and Sunday AM peak hour, when traffic is assumed to be � most intense. The ma�cimum allowable student enrollment number would not change as a result of "`� the proposed project, and as a result, an increase in enrollment numbers does not require ,,,� consideration for traffic analysis. Implementation of the proposed project would not change the � overall capacity of the school component of the project, and thus, only the proposed increased � capacity of the church/worship center element of the project requires consideration for traffic analysis. '� � Response to Comment 10-116 � When analyzing air quality emission and potential impacts associated with the project, daily regional � operational emissions generated from both onsite and offsite sources were derived from the � URBEMIS2007 land use emission model for the Sunday morning peak attendance(95`h percentile) and are shown in Draft EIR Appendix D, Table 12 in the Air Quality and Greenhouse Gas Analysis '""� Report, for the summer and winter seasons along with the SCAQMD daily regional emission '� significance thresholds assuming a buildout year of 2012. The URBEMIS2007 land use emission ,� model takes into account vehicle queuing, or idling, as part of the air quality analysis. As shown in � Draft EIR Appendix D, Air Quality and Greenhouse Gas Analysis Report,the proposed project's emissions do not exceed any SCAQMD regional emission thresholds in either the summer or winter � season, and therefore, are considered less than significant. "� aa�a The Air Quality study prepared for the proposed project evaluated the potential for carbon monoxide (CO) "hot spots." A hot spot is a localized concentration of CO that is above the state or national 1- � hour or 8-hour CO ambient air standards. Localized high levels of CO are associated with traffic � congestion and idling or slow-moving vehicles. To provide a worst-case scenario, CO concentrations � are estimated at project-impacted intersections, where the concentrations would be the greatest. The � study concluded that project implementation would not result in a CO hot spot. r� As addressed in the TIA Addendum (Appendix A),the project will result in up to 413 AM peak-hour ,� trips for a typical Sunday church service, representing a 30-percent net trip reduction in the number of �,� AM peak-hour trips analyzed in the Draft EIR. In general,the project's operational emissions are at least in part related to project-generated traffic and the exhaust emissions from those vehicles. Thus, � 3-214 Michael8randman Associates �,,,, H\Client(PN-IN)�i771\37710001�RTGFEIR\37710001 Sec03-OOResponses.doc � Salem Lutheran Church and School OPA Compromise Specific Plan Response to Comments on the Draft EIR Responses to Comments because of the reduction in peak-hour trips, it can be assumed that vehicle exhaust emissions, as well as any contaminants contained in those emissions such as VOC,NOX,and ROG,will also be reduced. Therefore,the project's air quality and greenhouse gas impacts will be reduced when compared with those impacts analyzed in the Draft EIR, which were already determined to be less than significant. Response to Comment 10-117 When analyzing air quality emission and potential impacts associated with the project, daily regional operational emissions generated from both onsite and offsite sources were derived from the URBEMIS2007 land use emission model for the Sunday morning peak attendance(95`h percentile) and are shown in Draft EIR Appendix D, Table 12 in the Air Quality and Greenhouse Gas Analysis Report, for the summer and winter seasons along with the SCAQMD daily regional emission significance thresholds assuming a buildout year of 2012. The URBEMIS2007 land use emission model takes into account vehicle queuing, or idling, as part of the air quality analysis. As shown in Draft EIR Appendix D, Air Quality and Greenhouse Gas Analysis Report,the proposed project's emissions do not exceed any SCAQMD regional emission thresholds in either the summer or winter season, and therefore, are considered less than significant. As addressed in the TIA Addendum (Appendix A), the project will result in up to 413 AM peak-hour trips for a typical Sunday church service, representing a 30-percent net trip reduction in the number of AM peak-hour trips analyzed in the Draft EIR. In general,the project's operational emissions are at least in part related to project-generated traffic and the exhaust emissions from those vehicles. Thus, because of the reduction in peak-hour trips, it can be assumed that vehicle exhaust emissions, as well as any contaminants contained in those emissions such as VOC,NOX, and ROG, will also be reduced. Therefore,the project's air quality and greenhouse gas impacts will be reduced when compared with those impacts analyzed in the Draft EIR, which were already determined to be less than significant. Response to Comment 10-118 When analyzing air quality emission and potential impacts associated with the project, daily regional operational emissions generated from both onsite and offsite sources were derived from the URBEMIS2007 land use emission model for the Sunday morning peak attendance(95`h percentile) and are shown in Draft EIR Appendix D, Table 12 in the Air Quality and Greenhouse Gas Analysis Report, for the summer and winter seasons along with the SCAQMD daily regional emission significance thresholds assuming a buildout year of 2012. The URBEMIS2007 land use emission model takes into account vehicle queuing, or idling, as part of the air quality analysis. As shown in Draft EIR Appendix D, Air Quality and Greenhouse Gas Analysis Report, the proposed project's emissions do not exceed any SCAQMD regional emission thresholds in either the summer or winter season, and therefore, are considered less than significant. As addressed in the TIA Addendum(Appendix A),the project will result in up to 413 AM peak-hour trips for a typical Sunday church service, representing a 30-percent net trip reduction in the number of Michael Brandman Associates 3-215 H.\Client(PN-JN)13771\37710001�RTC-FEIIt�37710001 Sec03-00 Responses.doc � Sa/em Lutheran Church and Schoo/OPA Compromise Specific P/an �" Responses to Comments Response to Comments on the Drafi EIR � AM peak-hour trips analyzed in the Draft EIR In general,the project's operational emissions are at „�: least in part related to project-generated traffic and the exhaust emissions from those vehicles. Thus, � because of the reduction in peak-hour trips, it can be assumed that vehicle exhaust emissions, as well �, as any contaminants contained in those emissions such as VOC,NOX, and ROG, will also be reduced. Therefore, the project's air quality and greenhouse gas impacts will be reduced when compared with � those impacts analyzed in the Draft EIR, which were already determined to be less than significant. � Response to Comment 10-119 "'� � This comment asks why the Draft EIR did not address existing GHG emissions and air quality issues. The purpose of CEQA and the preparation of a Draft EIR is to analyze whether a proposed project �" would result in any new significant environmental impacts, not to address existing issues. When '�" analyzing air quality emission and potential impacts associated with the project, daily regional .,� operational emissions generated from both onsite avd offsite sources were derived from the � URBEMIS2007 land use emission model far the Sunday morning peak attendance (95`h percentile) and are shown in Draft EIR Appendix D, Table 12 in the Air Quality and Greenhouse Gas Analysis � Report, for the summer and winter seasons along with the SCAQMD daily regional emission � significance thresholds assuming a buildout year of 2012. The URBEMIS2007 land use emission � model takes into account vehicle queuing, or idling, as part of the air quality analysis. As shown in � Draft EIR Appendix D, Air Quality and Greenhouse Gas Analysis Report,the project's emissions do � not exceed any SCAQMD regional emission thresholds in either the summer or winter season, and therefore, are considered less than significant. Because the proposed project would not increase the '"� school component's maximum student enrollment,the project would not increase weekday traffic � associated with the school, and thus, would not increase weekday traffic-related emissions. �, The maximum student enrollment under Salem Lutheran Church and School's current CUP is 726 '"'� students and the maximum number of students allowed on campus at one time is 611. This limitation "�" on the number of students both enrolled and allowed on campus at any given time would still apply to ,�„ the proposed project even though there would be no longer be a CUP. The restrictive covenant �: previously recorded against the existing use and property would remain in effect. The Specific Plan contains the same limits on maximum student enrollment and maximum number of students on '� campus at one time as the current CUP. The proposed project would not increase the existing '"�` school's capacity, as there would be no new school facilities,just the replacement of existing facilities ,� (i.e.,the new preschool would replace the existing preschool). Overall,the proposed project would ,� have no effect on student enrollment levels. Thus, since the proposed project would not increase the school component's maximum student enrollment, the project would not increase weekday traffic � associated with the school, and thus, would not increase weekday traffic-related greenhouse gas "�' emissions. �,,, � The Air Quality study prepared for the proposed project evaluated the potential for carbon monoxide (CO)"hot spots." A hot spot is a localized concentration of CO that is above the state or national 1- "�' 3-216 Michae/Brandman Associates � H:\Client(PN-7N)U771\37710001UtTGFEIIi\37710001 Sec03-00 Responses.doc � Sa/em Lutheran Church and Schoo/OPA Compromise Specific P/an Response to Comments on the Draft E/R Responses to Comments hour or 8-hour CO ambient air standards. Localized high levels of CO are associated with traffic congestion and idling or slow-moving vehicles. To provide a worst-case scenario, CO concentrations are estimated at project-impacted intersections, where the concentrations would be the greatest. The study concluded that project implementation would not result in a CO hot spot. As addressed in the TIA Addendum(Appendix A),the project will result in up to 413 AM peak-hour trips for a typical Sunday church service, representing a 30-percent net trip reduction in the number of AM peak-hour trips analyzed in the Draft EIR In general,the project's operational emissions are at least in part related to project-generated traffic and the e�aust emissions from those vehicles. Thus, because of the reduction in peak-hour trips, it can be assumed that vehicle exhaust emissions, as well as any contaminants contained in those emissions such as VOC,NOX, and ROG, will also be reduced. Therefore,the project's air quality and greenhouse gas impacts will be reduced when compared with those impacts analyzed in the Draft EIR, which were already determined to be less than significant. Response to Comment 10-120 This comment does not directly address the proposed project; however,the comment is duly noted. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments. Response to Comment 10-121 The comment expresses concern regarding the presence of mold and asbestos. As addressed in Response to Comment 10-31, according to the Initial Study,no evidence of hazardous materials contamination has been encountered on or adjacent to the project site. Additionally,the project site is not listed on either federal or State databases presented in the Radius Map Report prepared by Environmental Data Resources, Inc. (Draft EIR Appendix E, Environmental Data Resources, Inc. (EDR)Map Report). The interior of the Fowler House has not been inspected to verify if mold is present or if the substance is mildew or some other non-hazardous substance. Prior to demolition activities, a licensed specialist will inspect the interior of the Fowler House to determine the presence or absence of hazardous substances, including ACM, LBP, or other potentially hazardous substances such as mold. In the event that any mold or other potentially hazardous substances are determined to be present, remediation by a licensed specialist would occur prior to demolition activities, as part of standard construction practices and consistent with all applicable federal, state, and local provisions related to the handling of potentially hazardous substances. This inspection and potential remediation will be placed as a condition of approval on the project. Response to Comment 10-122 This comment expresses concern over existing surface runoff from the project site that results in offsite flooding particularly alone Frank Lane. Consistent with the "Single Site Access"alternative analyzed in the Draft EIR,there would be no driveway from Santiago Canyon Road, and thus, stormwater flows will not have a direct outlet onto the roadway as previously proposed. As a result, a Michael8randman Associates 3-217 H.\Client(PN-IN)U771\37710001�RTGFEIRU7710001 Sec03-00 Responses.doc Salem Lutheran Church and School OPA Compromise Specific P/an Responses to Comments Response to Comments on the Drafl EIR � private storm drain system is proposed for the project. This storm drain system will pick up the �; majority of the project site and convey flow toward Santiago Canyon Road where it will be picked up �w in and existing 36-inch RCP within Santiago Canyon Road. This 36-inch RCP conveys flows to the Handy Creek reinforced concrete box culvert under Santiago Canyon Road. This storm drain system � will alleviate flooding that has occurred within the private drive westerly of the project site. *� � No significant increases in peak flow or runoff volume will occur due to development. Modeled peak runoff for the project remains relatively the same for the 10-year and 25-year High Confidence Events � and decreases approximately 1 percent during the 100-year High Confidence Event. Therefore, the ""° project's hydrology and water quality impacts will be similar when compared with those impacts „� analyzed in the Draft EIR. � Response to Comment 10-123 � �. This comment expresses concern over existing surface runoff from the project site that results in offsite flooding particularly alone Frank Lane. Consistent with the "Single Site Access" alternative "" analyzed in the Draft EIR,there would be no driveway from Santiago Canyon Road, and as a result, � stormwater flows will not have a direct outlet onto the roadway as previously proposed. As a result, a � private storm drain system is proposed for the project. This storm drain system will pick up the � majority of the project site and convey flow toward Santiago Canyon Road where it will be picked up in and existing 36-inch RCP within Santiago Canyon Road. This 36-inch RCP conveys flows to the '"'"� Handy Creek reinforced concrete box culvert under Santiago Canyon Road. This storm drain system � will alleviate flooding that has occurred within the private drive westerly of the project site. �,, No significant increases in peak flow or runoff volume will occur due to development. Modeled peak � runoff for the project remains relatively the same for the 10-year and 25-year High Confidence Events � and decreases approximately 1 percent during the 100-year High Confidence Event. Therefore,the ,� project's hydrology and water quality impacts will be similar when compared with those impacts analyzed in the Draft EIR. � � Response to Comment 10-124 � This comment expresses concern over existing surface runoff from the project site that results in "�" offsite flooding particularly alone Frank Lane. Consistent with the "Single Site Access"alternative � analyzed in the Draft EIR,there would be no driveway from Santiago Canyon Road, and as a result, � stormwater flows will not have a direct outlet onto the roadway as previously proposed. As a result, a private storm drain system is proposed for the project. This storm drain system will pick up the '� majority of the project site and convey flow toward Santiago Canyon Road where it will be picked up °"� in and existing 36-inch RCP within Santiago Canyon Road. This 36-inch RCP conveys flows to the .� Handy Creek reinforced concrete box culvert under Santiago Canyon Road. This storm drain system �..„ will alleviate flooding that has occurred within the private drive westerly of the project site. � 3-2�8 Michae/Brandman Associates � H�\Gient(PN-JN)�3771\37710001�R7'GFEIR\37710001 Sec03-00 Responses.doc �: Salem Lutheran Church and School OPA Compromise Specific Plan Response to Comments on the Draft E/R Responses to Comments No significant increases in peak flow or runoff volume will occur due to development. Modeled peak runoff for the project remains relatively the same for the 10-year and 25-year High Confidence Events and decreases approximately 1 percent during the 100-year High Confidence Event. Therefore,the project's hydrology and water quality impacts will be similar when compared with those impacts analyzed in the Draft EIR. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document for an evaluation of the Grayson Traffic Plan. Response to Comment 10-125 As addressed in Response to Comment 10-9,the proposed project, including the development of the Fowler property as a parking area following the removal of the Fowler House, are consistent with the OPA Plan and the City of Orange General Plan. The OPA Plan designates the property where the Fowler House is located as Public/Quasi-Public, which is consistent with the proposed project. The proposed relocation of the preschool as part of the OPA Compromise Plan will not affect the capacity as evaluated in the Draft EIR and will not impact the overall enrollment cap as identified in the existing CUP. As addressed in Response to Comment 10-10, under the current CUP,the maximum student enrollment is 726 students and the maximum number of students allowed on campus at one time is 6l 1. This limitation on the number of students both enrolled and allowed on campus at any given time would still apply to the proposed project even though there would be no longer be a CUP. The restrictive covenant previously recorded against the existing use and property would remain in effect. The Specific Plan contains the same limits on maximum student enrollment and maximum number of students on campus at one time as the current CUP. The proposed project would not increase the existing school's capacity, as there would be no new school facilities,just the replacement of existing facilities (i.e.,the new preschool would replace the existing preschool). Overall,the proposed project would have no effect on student enrollment levels. Response to Comment 10-126 This comment refers to the Grayson Traffic Plan's proposal to convert the Fowler property into a parking lot. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document for an evaluation of the Grayson Traffic Plan. Response to Comment 10-127 As addressed in Response to Comment 6-2, long-term noise impacts associated with operations of the project were found to be less than significant and were addressed in the Initial Study (Draft EIR Appendix A,Notice of Preparation, Initial Study, and Comment Letters)prepared for the project prior to the Draft EIR. The Initial Study concluded that the operations phase of the proposed project would not result in noise increases over the existing conditions since the proposed land use would be the Michael Brandman Associates 3-219 H\Client(PN-JN)\3771\37710001�RTGFEIIt�37710001 Sec03-00 Responses.doc ..� Sa/em Lutheran Church and School OPA Compromise Specific P/an v'"` Responses to Comments Response to Comments on the Draft E/R � same as the existing land use, with similar traffic conditions and onsite activities. Additionally,the �, Noise Impact Analysis prepared for the proposed project(Draft EIR Appendix G,Noise Impact � Analysis)examined long-term, operations-related noise and determined the noise impacts would be less than significant in regards to onsite operational noise. The Noise Impact Analysis analyzed � potential noise generated by the proposed parking lots,the playground,the sanctuary, and the � fellowship reception area, determining that noise produced at any of these locations would not exceed � the City of Orange noise standards. This analysis was completed consistent with § 8.24.070 of the � Orange Municipal Code and the Noise Element of the City's General Plan. � Response to Comment 10-128 „� As addressed in Response to Comment 6-2, long-term noise impacts associated with operations of the '�" project were found to be less than significant and were addressed in the Initial Study (Draft EIR ,�„� Appendix A,Notice of Preparation, Initial Study, and Comment Letters)prepared for the project prior �,, to the Draft EIR. The Initial Study concluded that the operations phase of the proposed project would not result in noise increases over the existing conditions since the proposed land use would be the � same as the existing land use, with similar traffic conditions and onsite activities. Additionally,the °�� Noise Impact Analysis prepared for the proposed project(Draft EIR Appendix G,Noise Impact � Analysis)examined long-term, operations-related noise and determined the noise impacts would be �, less than significant in regards to onsite operational noise. The Noise Impact Analysis analyzed � potential noise generated by the proposed parking lots,the playground,the sanctuary, and the fellowship reception area, determining that noise produced at any of these locations would not exceed � the City of Orange noise standards. � � Response to Comment 10-129 � As addressed in Response to Comment 6-2, long-term noise impacts associated with operations of the �: project were found to be less than significant and were addressed in the Initial Study (Draft EIR Appendix A,Notice of Preparation, Initial Study, and Comment Letters) prepared for the project prior ""� to the Draft EIR. The Initial Study concluded that the operations phase of the proposed project would `'� not result in noise increases over the existing conditions since the proposed land use would be the ,,,� same as the existing land use, with similar traffic conditions and onsite activities. Additionally,the � Noise Impact Analysis prepared for the proposed project(Draft EIR Appendix G,Noise Impact Analysis)examined long-term, operations-related noise and determined the noise impacts would be �" less than significant in regards to onsite operational noise. The Noise Impact Analysis analyzed � potential noise generated by the proposed parking lots, the playground,the sanctuary, and the ,�„ fellowship reception area, determining that noise produced at any of these locations would not exceed ,�; the City of Orange noise standards. This analysis was completed consistent with § 8.24.070 of the Orange Municipal Code and the Noise Element of the City's General Plan. � �,, � 3-220 Michae/Brandman Associates � H\Client(PN-JN)13771\37710001�RTC-FEIlt\37710001 Sec03-00 Responses-doc � Salem Lutheran Church and Schoo/OPA Compromise Specifc Plan Response to Comments on the Draft EIR Responses to Comments Response to Comment 10-130 This comment does not directly address the proposed project; however,the comment is duly noted. Response to Comment 10-131 This comment does not directly address the proposed project; however,the comment is duly noted. Response to Comment 10-132 This comment does not directly address the proposed project; however,the comment is duly noted. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document. Response to Comment 10-133 This comment consists of a captioned photo purporting to show existing traffic conditions, and thus, relates in large part to an alleged existing issue, rather than an impact that would result from the proposed project. A TIA Addendum (Appendix A)was prepared for the OPA Compromise Plan to address the potential traffic and parking impacts associated with the proposed project as described in the Specific Plan compared with the 712-seat sanctuary scenario analyzed in the City-approved Traffic Impact and Parking Demand Analysis Report dated August 20, 2010. Based on the TIA Addendum for the proposed project, no traffic impacts will be created and adequate parking will be provided consistent with the City-approved Traffic Impact and Parking Demand Analysis Report. Under the current CUP,the maximum student enrollment is 726 students and the maximum number of students allowed on campus at one time is 611. This limitation on the number of students both enrolled and allowed on campus at any given time would still apply to the proposed project even though there would be no longer be a CUP. The restrictive covenant previously recorded against the existing use and property would remain in effect. The Specific Plan contains the same limits on maximum student enrollment and maximum number of students on campus at one time as the current CUP. The proposed project would not increase the existing school's capacity, as there would be no new schoo] facilities,just the replacement of existing facilities (i.e., the new preschool would replace the existing preschool). Overall, the proposed project would have no effect on student enrollment levels. The maa�imum allowable student enrollment number would not change as a result of the proposed project, and as a result, an increase in enrollment numbers does not reyuire consideration for traffic analysis. Implementation of the proposed project would not change the overall capacity of the school component of the project, and thus, only the proposed increased capacity of the church/worship center element of the project requires consideration for traffic analysis. Michae/Brandman Associates 3-221 H.\Client(PN-IN)�3771\37710001UtTC-FEIIt137710001 Sec03-OOResponses.doc � Salem Lutheran Church and School OPA Compromise Specific Plan Responses to Comments Response to Comments on the Draft EIR w� Response to Comment 10-134 � As addressed in Response to Comment 10-9,the proposed project, including the development of the � Fowler property as a parking area following the removal of the Fowler House, are consistent with the �,, OPA Plan and the City of Orange General Plan. The proposed relocation of the preschool as part of .� the OPA Compromise Plan will not affect the capacity as evaluated in the Draft EIR and will not � impact the overall enrollment cap as identified in the existing CUP. � Response to Comment 10-135 „� As addressed in Response to Comment 6-2, long-term noise impacts associated with operations of the ,,,,f project were found to be less than significant and were addressed in the Initial Study (Draft EIR „� Appendix A,Notice of Preparation, Initial Study, and Comment Letters)prepared for the project prior � to the Draft EIR. The Initial Study concluded that the operations phase of the proposed project would not result in noise increases over the existing conditions since the proposed land use would be the �` same as the existing land use, with similar traffic conditions and onsite activities. Additionally,the � Noise Impact Analysis prepared for the proposed project(Draft EIR Appendix G,Noise Impact �._ Analysis)examined long-term, operations-related noise and determined the noise impacts would be � less than significant in regards to onsite operational noise. The Noise Impact Analysis analyzed potential noise generated by the proposed parking lots,the playground, the sanctuary, and the � fellowship reception area, determining that noise produced at any of these locations would not exceed ,.� the City of Orange noise standards. � Response to Comment 10-136 '�"' � This comment expresses concern over project-related weekday traffic potentially impacting the local circulation network. A TIA Addendum (Appendix A)was prepared for the OPA Compromise Plan to """� address the potential traffic and parking impacts associated with the proposed project as described in '�" the Specific Plan compared with the 712-seat sanctuary scenario analyzed in the City-approved ,,,� Traffic Impact and Parking Demand Analysis Report dated August 20, 2010. Based on the TIA � Addendum for the proposed project, no traffic impacts will be created and adequate parking will be provided consistent with the City-approved Traffic Impact and Parking Demand Analysis Report. '� � Under the current CUP,the maximum student enrollment is 726 students and the maximum number � of students allowed on campus at one time is 611. This limitation on the number of students both � enrolled and allowed on campus at any given time would still apply to the proposed project even though there would be no longer be a CUP. The restrictive covenant previously recorded against the "'� existing use and property would remain in effect. The Specific Plan contains the same limits on � maximum student enrollment and maximum number of students on campus at one time as the current �, CUP. The proposed project would not increase the existing school's capacity, as there would be no �. new school facilities,just the replacement of existing facilities (i.e.,the new preschool would replace � � 3_yyy Michael Brandman Associates ,� H.\Client(PN-JN)�3771\37710001UtTC-FEIIt\37710001 Sec03-00 Responses doc � Sa/em Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments on the Draft E/R Responses to Comments the existing preschool). Overall,the proposed project would have no effect on student enrollment levels. The maximum allowable student enrollment number would not change as a result of the proposed project, and as a result, an increase in enrollment numbers does not require consideration for traffic analysis. Implementation of the proposed project would not change the overall capacity of the school component of the project, and thus, only the proposed increased capacity of the church/worship center element of the project requires consideration for traffic analysis. Response to Comment 10-137 This comment does not directly address the proposed project; however,the comment is duly noted Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document. Response to Comment 10-138 This comment does not directly address the proposed project; however,the comment is duly noted Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document. Response to Comment 10-139 This comment does not specifically address the proposed project, but is duly noted. Response to Comment 10-140 This comment does not directly address the proposed project; however,the comment is duly noted Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document for an evaluation of the Grayson Traffic Plan. Response to Comment 10-141 This comment does not directly address the proposed project; however,the comment is duly noted Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments. Response to Comment 10-142 This comment does not directly address the proposed project; however,the comment is duly noted Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments. Response to Comment 10-143 This comment states that noise surveys taken at the existing use during school hours underestimated existing noise levels because "surveys were taken when school attendance was low, as Salem Lutheran Church and School was notified that the surveys were being taken." The commenter, however, provided no evidence to this allegation. It is standard practice to notify an existing Michael Brandman Associates 3-223 H:\Client(PN-1N)\3771\37710001U2TC-FEIIt�37710001 Sec03-OOResponses.doc � Salem Lutheran Church and School OPA Compromise Specific P/an �° Responses to Comments Response to Comments on fhe Draft E/R � operation(i.e., Salem Lutheran Church and School)as to when monitoring would take place, in order ,� to avoid any question as to the reason for noise monitoring professional(s)to be on and adjacent to � the site, especially in the presence of school-aged children. Noise monitoring was conducted on a � typical operating weekday far the existing school, and as a result, noise monitoring results represent existing weekday conditions. '� � Response to Comment 10-144 � The maximum allowable student enrollment number would not change as a result of the proposed � project, and as a result, an increase in enrollment numbers does not require consideration for traffic analysis. Implementation of the proposed project would not change the overall capacity of the school `� component of the project, and thus, only the proposed increased capacity of the church/worship center '"�' element of the project requires consideration for traffic analysis. ,,,� �: Response to Comment 10-145 � As addressed in Response to Comment 10-62, light and glare impacts are addressed in Draft EIR �� Section 4.1, Aesthetics. The Draft EIR determined that light resulting from the operations of the proposed project, including parking lot,temporary overflow parking lot, and security lighting, would "�`° comply with all City of Orange requirements. Parking lot lighting,temporary multipurpose field +� lighting, and lighting would be shielded and adjusted to avoid light overspill (light trespass). All light � direction shall be downward, rather than upward or sideways,to eliminate light pollution to the extent � possible. The areas illuminated would be minimized but would comply with the City of Orange minimum photometric reyuirements. "'"� � Response to Comment 10-146 � This comment does not directly address the proposed project; however,the comment is duly noted �„, Response to Comment 10-147 '" � This comment states impacts to the eyuestrian trail at the proposed East Santiago Canyon Road entrance were not properly addressed. Consistent with the"Single Site Access"alternative analyzed '� in the Draft EIR,there would be no driveway from Santiago Canyon Road, and as a result,this "�' comment as it related to the East Santiago Canyon Road driveway no longer applies. ,,,� � Response to Comment 10-148 � This comment is concerned with the safety of children. Draft EIR Section 3,Project Description, .►� describes the school drop-off and pick-up and states that traffic control personnel will direct traffic to provide far the safety of schoolchildren. Preschool are directly escorted by their parents from the '"" vehicle because parents must sign children in and out and therefore must park their cars. In addition, � the proposed site plan provides for a dedicated drop-off and pick-up location that is graphically � depicted on Exhibit 4.8-2 in Draft EIR Section 4.8, Transportation and Traffic. ��. 3-224 Michael Brandman Associates ,,� H1Client(PN-.IN)�3771\37710001�RTC-FEIIi\37710001 Sec03-00 Responses.doc � wti� Salem Lutheran Church and Schoo/OPA Compromise Specific Plan Response to Comments on the Draft E/R Responses fo Comments .. Part of this comment refers to a resident-drafted plan included within this comment letter(Letter 10), identified herein as the Grayson Traffic Plan. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document for an evaluation of the Grayson Traffic Plan. Response to Comment 10-149 As addressed in Response to Comment 6-3 and Response to Comment 8-4,the Draft EIR determined that project-generated parking would be less than significant. Response to Comment 10-150 A TIA Addendum (Appendix A)was prepared for the OPA Compromise Plan to address the potential traffic and parking impacts associated with the proposed project as described in the Specific Plan compared with the 712-seat sanctuary scenario analyzed in the City-approved Traffic Impact and Parking Demand Analysis Report dated August 20, 2010. Based on the TIA Addendum for the proposed project, no traffic impacts will be created and adequate parking will be provided consistent with the City-approved Traffic Impact and Parking Demand Analysis Report. Under the current CUP,the maximum student enrollment is 726 students and the maximum number of students allowed on campus at one time is 611. This limitation on the number of students both enrolled and allowed on campus at any given time would still apply to the proposed project even though there would be no longer be a CUP. The restrictive covenant previously recorded against the existing use and property would remain in effect. The Specific Plan contains the same limits on maximum student enrollment and maximum number of students on campus at one time as the current CUP. The proposed project would not increase the existing school's capacity, as there would be no new school facilities,just the replacement of existing facilities (i.e., the new preschool would replace the existing preschool). Overall,the proposed project would have no effect on student enrollment levels. The maximum allowable student enrollment number would not change as a result of the proposed project, and as a result, an increase in enrollment numbers does not require consideration for traffic analysis. Implementation of the proposed project would not change the overall capacity of the school component of the project, and thus, only the proposed increased capacity of the church/worship center element of the project requires consideration for traffic analysis. Response to Comment 10-151 When analyzing air quality emission and potential impacts associated with the project, daily regional operational emissions generated from both onsite and offsite sources were derived from the URBEMIS2007 land use emission model for the Sunday morning peak attendance(95`h percentile) and are shown in Draft EIR Appendix D, Table 12 in the Air Quality and Greenhouse Gas Analysis Report, for the summer and winter seasons along with the SCAQMD daily regional emission significance thresholds assuming a buildout year of 2012. The URBEMIS2007 land use emission Michae/Brandman Associates 3-225 H.\Client(PN-JN)\3771\37710001�RTC-FEIIt�37710001 Sec03-00 Responses.doc Salem Lutheran Church and School OPA Compromise Specific Plan Responses to Comments Response to Comments on the Draft E/R � model takes into account vehicle queuing, or idling, as part of the air quality analysis. As shown in Draft EIR Appendix D, Air Quality and Greenhouse Gas Analysis Report,the proposed project's � emissions do not exceed any SCAQMD regional emission thresholds in either the summer or winter season, and therefore, are considered less than significant. � As addressed in the TIA Addendum(Appendix A),the project will result in up to 413 AM peak-hour �», trips for a typical Sunday church service,representing a 30-percent net trip reduction in the number of AM peak-hour trips analyzed in the Draft EIR In general,the project's operational emissions are at � least in part related to project-generated traffic and the exhaust emissions from those vehicles. Thus, �'" because of the reduction in peak-hour trips, it can be assumed that vehicle exhaust emissions, as well „� as any contaminants contained in those emissions such as VOC,NOx, and ROG,will also be reduced. Therefore,the project's air quality and greenhouse gas impacts will be reduced when compared with � those impacts analyzed in the Draft EIR, which were already determined to be less than significant. Response to Comment 10-152 � When analyzing air quality emission and potential impacts associated with the project, daily regional �� operational emissions generated from both onsite and offsite sources were derived from the ,�, URBEMIS2007 land use emission model for the Sunday morning peak attendance (95`h percentile) � and are shown in Draft EIR Appendix D, Table 12 in the Air Quality and Greenhouse Gas Analysis Report, for the summer and winter seasons along with the SCAQMD daily regional emission """' significance thresholds assuming a buildout year of 2012. The URBEMIS2007 land use emission � model takes into account vehicle queuing, ar idling, as part of the air quality analysis. As shown in � Draft EIR Appendix D, Air Quality and Greenhouse Gas Analysis Report,the proposed project's � emissions do not exceed any SCAQMD regional emission thresholds in either the summer or winter season, and therefore, are considered less than significant. '� � As addressed in the TIA Addendum(Appendix A),the project will result in up to 4l 3 AM peak-hour � trips for a typical Sunday church service, representing a 30-percent net trip reduction in the number of �. AM peak-hour trips analyzed in the Draft EIR. In general,the project's operational emissions are at least in part related to project-generated traffic and the e�aust emissions from those vehicles. Thus, +� because of the reduction in peak-hour trips, it can be assumed that vehicle exhaust emissions, as well � as any contaminants contained in those emissions such as VOC,NOx, and ROG, will also be reduced. � Therefore,the project's air quality and greenhouse gas impacts will be reduced when compared with � those impacts analyzed in the Draft EIR, which were already determined to be less than significant.. � Response to Comment 10-153 � This comment recommends a permanent physical element to separate the proposed project from the .�r surrounding residential land uses. As addressed in Response to Comment 5-5,the proposed project, ,�; including the periphery landscaping, fencing,walls, and setbacks, are consistent with the OPA Plan � � 3-226 Michael8randman Associates ,�, H:\Client(PN-JN)�3771\37710001�RTC-FEIli\37710001 Sec03-00 Responses doc � wu� Salem Lutheran Church and Schoo/OPA Compromise Specific P/an Response to Comments on the Draft EIR Responses to Comments and the City of Orange General Plan, and would comply with all applicable provisions of the City of Orange Zoning Ordinance in regards to such elements. Response to Comment 10-154 As addressed in Response to Comment 10-110, under the current CUP,the maximum student enrollment is 726 students and the maximum number of students allowed on campus at one time is 611. This limitation on the number of students both enrolled and allowed on campus at any given time would still apply to the proposed project even though there would be no longer be a CUP. The restrictive covenant previously recorded against the existing use and property would remain in effect. The Specific Plan contains the same limits on maximum student enrollment and maximum number of students on campus at one time as the current CUP. The proposed project would not increase the existing school's capacity, as there would be no new school facilities,just the replacement of existing facilities (i.e., the new preschool would replace the existing preschool). Overall,the proposed project would have no effect on student enrollment levels. The maYimum allowable student enrollment number would not change as a result of the proposed project, and as a result, an increase in enrollment numbers does not require consideration for traffic analysis. As addressed in the Traffic Impact Analysis prepared for the proposed project(Draft E(R AppendiX H, Traffic Impact and Parking Demand Analysis), implementation of the proposed project would not change the overall capacity of the school component of the project, and thus, only the proposed increased capacity of the church/worship center element of the project requires consideration for traffic analysis. Response to Comment 10-155 Section 3, Project Description, of the Draft EIR provides a site plan chronology regarding the process to arrive at the current proposed facility size and location on the project site, which incorporated the point of view of adjacent residents. Part of this comment does not directly address the proposed project; however,the comment is duly noted. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document for an evaluation of the Grayson Traffic Plan. Response to Comment 10-156 This comment does not directly address the proposed project; however,the comment is duly noted. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments. Response to Comment 10-157 A TIA Addendum (Appendix A)was prepared for the OPA Compromise Plan to address the potential traffic and parking impacts associated with the proposed project as described in the Specific Plan compared with the 712-seat sanctuary scenario analyzed in the City-approved Traffic Impact and Parking Demand Analysis Report dated August 20, 2010. Based on the TIA Addendum for the Michael Brandman Associates 3-227 H:ACliem(PN-JN)�3771A37710001�R'IGFEIILU7710001 Sec03-OOResponses.doc � Salem Lutheran Church and Schoo/OPA Compromise Specific Plan Responses to Comments Response to Comments on the Draft EIR .� proposed project, no traffic impacts will be created and adequate parking will be provided consistent . . with the City-approved Traffic Impact and Parking Demand Analysis Report. �: Under the current CUP,the maximum student enrollment is 726 students and the maximum number of students allowed on campus at one time is 611. This limitation on the number of students both � enrolled and allowed on campus at any given time would still apply to the proposed project even though there would be no longer be a CUP. The restrictive covenant previously recorded against the existing use and properly would remain in effect. The Specific Plan contains the same limits on "� maximum student enrollment and maximum number of students on campus at one time as the current ` CUP. The proposed project would not increase the existing school's capacity, as there would be no ,� new school facilities,just the replacement of existing facilities (i.e.,the new preschool would replace ,�� the existing preschool). Overall,the proposed project would have no effect on student enrollment � levels. Y�.. The maximum allowable student enrollment number would not change as a result of the proposed � project, and as a result, an increase in enrollment numbers does not require consideration for traffic �:< analysis. Implementation of the proposed project would not change the overall capacity of the school component of the project, and thus, only the proposed increased capacity of the church/worship center '"'� element of the project requires consideration for traffic analysis. '�� r Response to Comment 10-158 � The commenter's statement regarding relocation of the existing OPA Horse Trail does not �.. specifically address the proposed project, but is duly noted. � Response to Comment 10-159 „� The commenter's statement regarding the use of specific trees and vegetarion between Salem �"' Lutheran Church and School and the neighboring residential uses does not specifically address the �, proposed project, but is duly noted. � Response to Comment 10-160 � � This comment does not directly address the proposed project; however,the comment is duly noted. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments. � � Response to Comment 10-161 ,,.� This comment recommends an entrance directly off East Santiago Canyon Road. However, � consistent with the"Single Site Access"alternative analyzed in the Draft EIR,there would be no driveway from Santiago Canyon Road. Instead,there will be an additional right-hand turn lane along � Orange Park Boulevard, which would improve circulation both internally and on local roads. � � � 3-228 Michael8randman Associates �, H1Client(PN-JN)�377]\37710001�RTGFEIR\37710001 Sec03-OOResponses.doc tai�fi Salem Lutheran Church and Schoo/OPA Compromise Specific P/an Response to Comments on the Draft EIR Responses to Comments Response to Comment 10-162 This comment does not directly address the proposed project; however,the comment is duly noted. Response to Comment 10-163 This comment does not directly address the proposed project; however, the comment is duly noted. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document. Response to Comment 10-164 This comment does not directly address the proposed project; however,the comment is duly noted. Refer to Section 4, The Grayson Traffic Plan, of this Response to Comments document. Michael Brandman Associates 3-229 H�.\Client(PN-JN)\3771\37710001�RTGFEIRU7710001 Sec03-OOResponsesdoc � �.,E � � � THIS PAGE INTENTIONALLY LEFT BLANK `x � � � �� s � �� . � � � �,., Salem Lutheran Church and School OPA Compromise Specific Plan Response to Comments on the Draft EIR The Grayson Tra�c Plan SECTION 4: THE GRAYSON TRAFFIC PLAN Letter ]0 provided comments on the Draft EIR and included a traffic plan herein called the Grayson Traffic Plan. The Grayson Traffic Plan focuses mainly on the circulation elements of the project and does not include a written narrative regarding the plan features. The City has made an effort to address and respond to the Grayson Traffic Plan to the extent possible as part of the response to comments set forth in this Response to Comments on The Draft EIR document. The primary impacts that the Grayson Traffic Plan purports to address, i.e., Transportation and Traffic, Hydrology and Water Quality, and Aesthetics, are discussed below and compared with the proposed project. In addition, Draft EIR Section 3, Project Description subsection 3.4, Other Impacts, evaluates(to the extent possible given the level of detail set forth in the submission)whether the Grayson Traffic Plan would meet the objectives of the proposed project. As discussed below,the Grayson Traffic Plan does not meet many of the objectives of the proposed project, and would ultimately result in similar, and likely greater,transportation and traffic impacts than the proposed project. Furthermore, it would likely not avoid any significant environmental impacts, since the proposed project will not have any significant environmental impacts, and since the impacts of the Grayson Traffic Plan,to the extent they can be evaluated based on the information provided, appear to be similar or greater to those of the proposed project. Therefore,the Grayson Traffic Plan is not a feasible replacement for the proposed project. However, as previously addressed, several concepts from the Grayson Traffic Plan were incorporated into the project's development options, including the elimination of the Fowler House in lieu of parking; the relocation of the preschool closer to the existing buildings; student drop-off and pick-up on the east side and west side of the existing buildings; separate resident and church/school travel lanes; a vehicular turn- around at the west end of Frank Lane; and maintaining the central parking lot and play court configuration comparable to existing conditions. In addition to the foregoing and as part of the communiry outreach,the applicant met with the OPA Real Estate Committee on May 7, 2012 and presented the findings set forth below. 4.1 - Transportation and Traffic The Grayson Traffic Plan included an alternative traffic circulation and parking plan. An annotated version of that plan that numbers the various elements of that plan is attached hereto as Exhibit 4-1. The numbered comments below refer to the numbered elements shown on Exhibit 4-1, and discuss traffic issues that would be created by the Grayson Traffic Plan. 4.1.1 - Site Access Issues 1. The Grayson Traffic Plan would prohibit ingress to the project site from Frank Lane, and provide only one lane for egress from the site. This would require all inbound school and Michael Brandman Associates 4-1 H\Client(PN-JN)�3771\37710001�RTGFEQt\37710001 Sec04-00 GraysonTraffic.doc Sa/em Lutheran Church and Schoo/OPA Compromise Specific P/an The Grayson Tra�c P/an Response to Comments on the Draft E/R church traffic from the south (northbound on Orange Park Boulevard) and east(westbound on East Santiago Canyon Road)to travel west of the site and execute a legal U-turn movement ,Y„ in order to access the site via an eastbound right turn movement. This would divert additional traffic through the Orange Park Boulevard-East Santiago Canyon Road intersection and create unnecessary U-turn movements that can be unsafe depending on where they are � executed (Nicky Way is the first intersection that will provide an opportunity for a U-turn _ movement). The nearest controlled U-turn movement is at the Cannon Street and East � Santiago Canyon Road signalized intersection, which is over a half-mile from the site. Thus, requiring inbound traffic to follow this circuitous route would increase the vehicle miles � traveled(VMT)generated by the project. Furthermore, executing a westbound U-turn � movement in a timely manner during the AM peak period may be difficult due to the - significant eastbound traffic volume on East Santiago Canyon Road during the AM peak ,�, period. Exhibit 4-2 and Exhibit 4-3 depict how traffic would be diverted by the Grayson Traffic Plan, including the volume of such traffia �� 2. Limiting the Frank Lane egress to one outbound lane(50 percent of proposed plan for school days)will significantly increase the queue for the outbound movement compared to the r�f. proposed plan, which consists of two outbound lanes for school days. As a result,vehicles "" destined for west of the site, may choose to first turn east on East Santiago Canyon Road, and � then make a U-turn along East Santiago Canyon Road east of Orange Park Boulevard, which � as noted above, can be unsafe depending on where they are executed. ��:�. 3. Limiting the Frank Lane driveway to egess only would mean that there would be only one ..� entrance to the project site. This would conflict with general site planning principles, which recommend redundancy of access for non-residential developments. � 4. The Grayson Traffic Plan proposes establishing a horse trail between two roadways. This � would create a potential hazard, since it would require a significant number of potentially � conflicting movements between vehicles and horses compared to the current harse trail � configuration. „�, 5. While it is difficult to determine the exact dimensions of some of elements shown on the .� Grayson Traffic Plan, it appears that the Frank Lane school/church access is estimated to be �,, as short as 12 feet wide, which would not satisfy City and Fire Department access and circulation requirements for roadway/drive aisle widths. Similarly,the East Santiago Canyon � �_: Road access does not appear to comply with such requirements. 6. The design of the East Santiago Canyon Road access has several fundamental flaws, which � create potentially unsafe conditions, including the lack of an eastbound deceleration lane(an �� element that was required by the City), a difficult weaving condition for the inbound vs. "'"� outbound movement at the property line, and a merge condition for the exiting movement at �n the property line. � 4'2 Michae/Brandman Associates � H\Client(PN-.RJ)U771\37710001U2TC-FEIR�37710001 Sec04-00 GraysonTraffic.doc � � C Z� ' � � aa � � 00 , W '� � s o o �. a N� �� _ �A18 �21Vd �JNa2f0 + L � °< � L'd� C# C� _ � OO O i�� X f`0 a� .-. __ r. ...__ — �i �P �� wF' � ' I t )�� '':�3: 3�i .. ..ii:-�'.-..�- ,_ Y.�r' ..a«s;:..� � ,�,,.t '�' f 3 �� " O p a --_ .. �I.. Z ---�..__ '� � `��i ��i `�' >, oZ � � o � .� � },� _�( ; � �; � � �� ^f ��1; � �'Z � � J � W r. _t, .o Z= � � _� � j , _ ' � � c� � � �v�i � � � '4 ` I pl��' i� F� � � �� _ � _ �. � ; � � �� . Q �o Q . 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[ ;; ':'';:::::;:;:''; ;::::: Z O �''''; '; '''''''; '''°;';�;`� � `�`:;:;::::::::`::::::::::::::'� O Q � ��'✓ LL � z ° � � U � N��( W�( � U .� U O �I m � `I � ` O (n L � d Y F- � C 41 � ~ � `� U W c Q W � � c�0 } � a W � > c � Y d � � m fn� � � II II � `� � � o � �, — C PNN�N � 'x�` J � a a � '-' o HlaoN � o U �� J �� O � � O 7 �� U h � �� M � � �.. � � � � � .�r � � THIS PAGE INTENTIONALLY LEFT BLANK '� � � � � � � � � � � �� Sa/em Lutheran Church and Schoo/OPA Compromise Specific P/an Response to Comments on the Draft EIR The Grayson Tra�c P/an 7. Based on the recommendation by the Orange Park Association,the proposed Santiago Canyon Road driveway has been eliminated,thus making the Grayson Traffic Plan inconsistent with both the request of the Orange Park Association and the design of the currently proposed project. 4.1.2 - Internal Circulation Issues 8. The internal circulation pattern approaching the school pick-up and drop-off area reyuires a weaving movement between the inbound traffic traveling to the drop-off/pick-up area and outbound traffic traveling to the Frank Lane exit, which would likely cause significant congestion and unsafe conditions, particularly since vehicles would be stacking up in the drop-off/pick-up lane. 9. The internal circulation pattern departing the school pick-up and drop-off area similarly requires a weaving movement between the inbound traffic directed to the preschool drop- off/pick-up area and outbound traffic traveling to the Frank Lane exit from the school drop- off/pick-up area, which would likely cause significant congestion and potentially unsafe conditions. 10. The Grayson Traffic Plan appears to include two drop-off/pick-up lanes at the preschool drop-off/pick-up area. This would create an unsafe situation, since it would require children to walk between stopped vehicles and from the parking area to the west. 11. The overall internal circulation design of the plan requires significant circulatory travel within the site and around the perimeter of the buildings for all traffic utilizing the East Santiago Canyon Road exit, which could cause driver confusion, frustration, and therefore potentially unsafe conditions and inefficient use of parking. Specifically, vehicles approaching the site from the east would be required to drive past the site, execute a U-turn movement somewhere to the west,turn right into the site, experience at least two weaving movements and circulate entirely around the buildings to exit on East Santiago Canyon Road (or continue one and one-half times around to exit on Frank Lane). In addition,the elimination of the playfield for parking concentrates parking in a smaller area and decreases the total number of spaces available for parking. 4.1.3 - Orange Park Boulevard at East Santiago Canyon Road Issues 12. Limiting the Frank Lane driveway to egress only diverts and therefore adds approximately 83 AM peak hour vehicles to the northbound left turn (NBL) movement at the Orange Park Boulevard and East Santiago Canyon Road intersection for a total volume of approximately 300 NBL turns,thus creating potentially significant yueuing in the NBL pocket. As a result of the issues discussed above,the Grayson Traffic Plan would result in greater impacts to Traffic and Transportation related to traffic queuing than the proposed project, which, as discussed in the Draft EIR, will not result in any significant traffic impacts. Michael Brandman Associates 4-9 H:AClient(PN-JN)13�71A37710001�RTGFEIR\37710001 Sec04-OOGrayson'CratTiadoc � Salem Lutheran Church and Schoo/OPA Compromise Specifc Plan The Grayson Tra�c P/an Response to Comments on the Draft EIR � 4.2 - Hydrology and Water Quality While the Grayson Traffic Plan does not include a complete hydrology plan, it proposes a horse trail "�` that would double as a bioswale, and suggests such bioswale could replace the storm water - conveyance and water quality system included in the proposed project. Although biotreatment best �, management practices(BMPs)can be effective under certain circumstances, combining Biotreatment BMPs and a horse trail is inadvisable, and such a system would not provide sufficient water quality treatment. � As explained in the Fact Sheet for the 2011 Model Water Quality Management Plan (WQMP) � Technical Guidance Document(TGD), bioretention with underdrains are landscaped shallow depressions that capture and filter stormwater runoff. The facilities function as a soil and plant-based � filtration device that removes pollutants through a variety of physical, biological, and chemical """ treatment processes. As stormwater passes down through the planting soil, pollutants are filtered, 4y adsorbed,biodegraded, and sequestered by the soil and plants. The design of biotreatment BMPs � requires a sump condition allowing for ponding on average of 3 to 6 inches, 2 to 3 inches of mulch, vegetation height between 4 and 6 inches, and a percolation rate of 2.5 inches/hour to 5.0 inches/hour. � Biotreatment BMPs require non-compacted soils and extensive vegetative cover ranging from 80 to '�""" 100 percent to perform properly. ��s The introduction of harses within a bioretention system would significantly reduce the effectiveness � of such a system, because it would result in localized compaction of the upper soil layers,thereby "� limiting percolation of runoff through the soil layers (<2.5 inches/hour) and constant trampling of the � vegetative cover that would result in plant die of£ A more traditional decomposed granite horse trail ,�, with enhanced soil media below would not function adequately for water quality purposes due to a w� lack of vegetative cover and low infiltration rates associated with the decomposed granite component of the trail. `�` � In addition, harse uses within a bioretention system would require maintenance-intensive daily pick � up of horse waste from the system. Horse waste left for more than a couple of days would begin to decompose thereby creating significant bacteria hot spots within the biotreatment system. Therefore, � the proposed system would not only be an ineffecrive water yuality solution, it could actually create �"� additional water yuality impacts due to bacteria. � Accordingly, a combined bioswale/horse trail is not an effective water quality BMP. To the extent � the Grayson Traffic Plan proposes to replace the storm water conveyance and water quality system � included in the proposed project with its proposed horse trail/bioswale,the Grayson Traffic Plan ��• would result in greater impacts to water quality than the proposed plan, which, as discussed in the � Draft EIR, will not result in any significant impacts related to hydrology or water quality. � 4-10 Michae/Brandman Associates � H-\Clien[(PN-IN)�3771\3"7710001UiTGFEIR\37710001 Su04-00 GraysonTraffic-doc � Sa/em Lutheran Church and School OPA Compromise Specific Plan Response to Comments on the Draft E/R The Grayson Traffic Plan 4.3 -Aesthetics The Grayson Traffic Plan includes several elements that are purported to improve project aesthetics, an attempt has been made to analyze the aesthetics of such plan. The Grayson Traffic Plan purports to eliminate the glare experienced by pedestrians, adults, and children that accessing Frank Lane because of the alignment of this roadway in relation to the Sun's orientation under the proposed project by restricting Frank Lane access to resident-only access and a horse trail. However,the Grayson Traffic Plan provides a sidewalk that parallels Frank Lane that would continue to expose pedestrians to glare. In addition, unless physical barriers were established prohibiting access of Frank Lane by pedestrians,this route would likely continue to be used along with the horse traiL In addition,the Grayson Traffic Plan provides fewer trees than the proposed plan, which would result in greater glare. Accordingly,the Grayson Traffic Plan would not ��- significantly reduce any impacts related to glare, which are already insignificant under the proposed project. The Grayson Traffic Plan proposes planting 30-foot cypress trees along the proposed horse trail/bioswale to shield the project site from its neighbors. In order to evaluate the extent to which . such trees would be effective in reducing aesthetic impacts, line of site exhibits were prepared to determine what portion, if any, of the apex of the roof of the proposed sanctuary is visible from selected neighboring properties under existing circumstances. Four properties adjacent to the south side of Frank Lane were selected for evaluation and are identified as the Ronk properiy, Rosenow property, Cunningham property, and the Grayson property (Exhibit 4-4). Field surveys of the Ronk, Rosenow, and Cunningham properties were conducted on May 29, 2012 and July 12,2012 for the Grayson property to measure the heights of existing hedges and trees, and to determine two viewing locations on each of the four properties. For the Grayson property,the height of existing Salem Lutheran Church and School Building B was measured due to the close proximity of the building to this residence. Specifically, as depicted on the exhibits,two viewing locations were selected in the rear yard of the Ronk property (Exhibit 4-5 and Exhibit 4-6),the Rosenow property (Exhibit 4-7 and Exhibit 4-8), and the Cunningham property (Exhibit 4-9 and Exhibit 4-10). For each of these properties, one viewing location was selected near the north property line with the second viewing location randomly selected on or near pools or patios to simulate locations that residents would typically occupy. The Grayson property directly faces the Salem Lutheran Church and School property; therefore,the viewing locations of the observer were selected near the front entry of the residence and near the north property line (Exhibit 4-11 and Exhibit 4-12). The front entry point of view represents the most likely view corridor and was selected in the interest of authenticity. The surveys combined with aerial photographs and conceptual architectural plans were used in development of the site line exhibit. The method was used to make the model as authentic as reasonably possible. As the observer's point of view moves about within the properties, incremental Michae/Brandman Associates 411 H�\Client(PN-JN)�3771\37710001�RTGFEIR\37710001 Sec04-00 GraysonTraffic.doc � Sa/em Lutheran Church and School OPA Compromise Specifc P/an ' ' The Grayson Tra�c P/an Response to Comments on the Draft E/R � changes to the site lines will occur. Table 4-1 provides the results of the sight line analysis. It is .,. important to note that the preparation of the site line analysis was based on the project previously � proposed in the Draft EIR. Under the OPA Compromise Plan,however,the maximum building heights that will be permitted on the project site will be reduced from 39 feet to 36 feet. Therefore, the following site line analysis, as well as the supporting exhibits, represents a"worst-case" scenario '�"` because the onsite buildings will be even less visible from the adjacent properties than what was previously analyzed in the site line analysis. ��„ Table 4-1: Sight Line Summary _ �, ' Portion of Roof Apex " Property Viewing Location Roof Apex Visible �sible(ft.) Ronk Section A-A No na � Ronk Section B-B Yes 4 feet Rosenow Section GC No na _ � Rosenow Section D-D No na Cunningham Section E-E No na Cunningham Section F-F No na �' Grayson Section G-G Yes 0.5 feet �� Grayson Section H-H Yes 0.5 feet +� Note: �� na=not applicable Source:Fuscoe Engineering,July 2012. � � As demonstrated in the table above,the roof apex of the proposed sanctuary is not visible from either the Rosenow or Cunningham properties. From the Ronk property, only the top 4 feet of the roof apex ""`� is visible from viewing location B-B (Exhibit 4-6). From the Grayson property,the roof apex would �`"" be negligibly visible, estimated at approximately one-half foot, from both viewing locations (Exhibit .� 4-11 and Exhibit 4-12). Thus,the line of site study indicates that very little of the new construction ,�, will be visible from neighboring residents because of existing vegetation and buildings, and confirms � the Draft EIR's conclusion that the project will not have any significant adverse impacts related to aesthetics. Consequently,the additional trees included in the Grayson Traffic Plan are not necessary `�"� to mitigate any such aesthetic impact. *� � � � 412 Michael Brandman Associates „�, H�\Client(PN-JN)\3771\37710001�RTC-FEIR�37710001 Sec04-00 GraysonTraffic-doc '[F' a z� � � So � a � �� L N oQ XY aa w �"' O� � V� Q Z � U) O� . � o°� - - __ _ _ � V> ��-�� , �� w ° , � � _y�-- -- -- � J Z W � � � aH 2 l i �� O „ I P - z =H g � �" ' � c Vz y ' i =; e� � 7 Z� � � �� k i 8 I �' —, =O � � , € _ �O . 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These revisions are minor modifications and clarifications to the document, and do not change the significance of any of the environmental issue conclusions within the Draft EIR. The revisions are listed by page number. All additions to the text are underlined (underlined)and all deletions from the text are stricken(�). 5.1 - Changes in Response to Specific Comments Page 4.1-9 The caption under Site Photograph 5 on Section 4.1, Aesthetics Exhibit 4.1-1 b, is revised as follows: Photograph 5: This photo shows Frank Lane, looking�west,with the church/school on the right and residences on the left. Page 4.8-11 � Draft EIR Section 4.8, Transportation and Traffic Exhibit 4.8-2 identifies location"A" for school drop-off and pick-up and location"B"for pre-school drop-off and pick-up. Exhibit 4.8-2 only provided a description of location "A" in the key. Exhibit 4.8-2 is revised as follows to provide the description of location "B" in the key. Page 4.6-17 The paragraph following Table 4.6-2 is revised as follows: The OPA Specific Plan contains�35 policies, of which�}317 apply to the proposed project and the remaining�818 policies do not apply to the proposed project. The Salem Lutheran Church and School project the OPA Compromise Plan, is consistent with all applicable policies of the OPA Specific Plan Table 4.6-2. The redesign of the school and church facilities would be in conformance with the site's land use designation in the OPA Specific Plan. Refer to the City Attorney memo in Appendix B stating that "the existing church and school uses are consistent with both the OPA Plan and [City] General Plan designations." Michael8randman Associates 5"� H�.AClient(PN-JN)�3771A37710001UtTC-FEIlt�37710001 Sec05-OORTCErrata.doc �.,,o nRe � � 11lA5 ws � THIS PAGE INTENTIONALLY LEFT BLANK �-�• � � �.. � � .� �� s. 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