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RES-10358 Certification of Final Environmental Impact Report for Children's Hospital of Orange County Master Plan ProjectRESOLUTION NO. 10358 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ORANGE CERTIFYING THE ADEQUACY OF FINAL ENVIRONMENTAL IMPACT REPORT ENVIRONMENTAL REVIEW NO. 1805-08), STATE CLEARINGHOUSE NO. 2008081118, INCLUDING ADOPTION OF THE FINDINGS OF FACT, STATEMENT OF OVERRIDING CONSIDERATION, AND MITIGATION MONITORING REPORTING PROGRAM FOR THE CHILDREN'S HOSPITAL OF ORANGE COUNTY MASTER PLAN PROJECT. APPLICANT: CHILDREN'S HOSPITAL OF ORANGE COUNTY WHEREAS, the City Council has authority per City of Orange Local CEQA Guidelines to certify Final Environmental Impact Report (EIR) (Environmental Review No. 1805-08), State Clearinghouse Number(SCH#) 200808 1 1 1 8, referred herein as the Final EIR SCH#200808ll 18); and WHEREAS, the applicant has submitted a project in accardance with requirements of the Municipal Code of the City of Orange, known as the Children's Hospital of Orange County (CHOC) Master Plan project which consists of Zone Change No. 1252-08, Major Site Plan Review No. 0504-07, Conditional Use Permit No. 2726-08, Design Review Committee No. 4209-07, Tentative Parcel Map No. 0024-08 (TPM 2008-162), and Development Agreement No. 5390, all of which are collectively referred to herein as the Project; and WHEREAS, an initial study was prepared for the Project and the City determined that an EIR was required to address its potential significant environmental impacts; and WHEREAS, the environmental impacts of the Project have been analyzed through Final EIR (SCH#2008081118), which is comprised of the Draft EIR for the Project, dated December 10, 2008, including technical appendices contained in Volume 1 and 2 dated December 10, 2008, verbatim copies of the comments and recommendations received on the Draft EIR for the Project, the list of persons, organizations and public agencies that commented on the Draft EIR for the Project, the responses of the City to significant environmental points raised in the review and consultation process for the Draft EIR for the Project, and revisions to the Draft EIR for the Project pursuant to the provisions of the California Environmental Quality Act (CEQA), the City's Local CEQA Guidelines, and the State CEQA Guidelines, a full, true and correct copy of which is on file with the City Clerk of the City of Orange; and WHEREAS, the Draft EIR for the Project was circulated for public review and comment for at least 45 days as required by CEQA, with the comment period beginning December 19, 2008 and ending February 2, 2009; and WHEREAS, responses to the comments received on the Draft EIR for the Project incorporated into the Final EIR (SCH# 200808 1 1 1 8) have been prepared to the satisfaction of the City; and WHEREAS, the Planning Commission has reviewed Final EIR(SCH#200808 1 1 1 8); and WHEREAS, the Planning Commission held a duly advertised public hearing on March 2, 2009 for the purpose of considering Final EIR (SCH# 2008081118) and the Project; and WHEREAS, at said public hearing, upon hearing and considering all testimony and arguments, if any, of all persons desiring to be heard, the Planning Commission considered all factors relating to the Project, including potential environmental impacts addressed in the Final EIR(SCH# 2008081118) for the Project; and WHEREAS, the Planning Commission adopted Resolution No. PC 06-09, recommending that the City Council certify and adopt the Final EIR (SCH# 20080811118) for the Project; and WHEREAS, the City Council has reviewed Final EIR (SCH# 2008081118); and WHEREAS, the City Council held a duly advertised public hearing on March 24, 2009 for the purpose of considering Final EIR(SCH# 2008081118) and the Project; and WHEREAS, at said public hearing, upon hearing and considering all testimony and arguments, if any, of all persons desiring to be heard, the City Council considered all factors relating to the Project, including potential environmental impacts addressed in the Final EIR SCH# 2008081118) for the Project. NOW, THEREFORE, BE IT RESOLVED that the City Council certifies and adopts the Final EIR (SCH# 2008081118) for the Project, based on the following findings and declarations: 1. That the Final EIR (SCH# 2008081118) prepared for the Project has been co npleted in compliance with CEQA, the City's Local CEQA Guidelines, and State CEQA Guidelines; and 2. That the City Council has carefully reviewed and considered the information contained in Final EIR(SCH# 2008081118)prior to acting upon the Project; and 3. That the Final EIR (SCH# 2008081118) reflects the independent judgment and analysis of the City of Orange; and 2 4. That based on the information contained in Final EIR (SCH# 2008081 ll8), the City Council finds that there has been an adequate assessment of the potentially significant environmental impacts of the Project and its required discretionary permits; and 5. That the City Council adopt the Findings of Fact and the Statement of Overriding Considerations, attached hereto as Attachment A, and incorporated by this reference, which documents and supports the conclusion that even with the implementation of all feasible mitigation measures recommended in Final EIR SCH# 2008081118), it is infeasible to reduce the Project's impacts on air quality, noise, and traffic and transportation to a level of insignificance, and which further sets forth the overriding benefits of the Project, which outweigh the unavoidable environmental impacts of the Project; and 6. That the City Council of the City of Orange find that the Project's benefits outweigh the adverse impacts; and 7. That the City Council adopt the Mitigation Monitoring Reporting Program MMRP), attached hereto as Attachment B, and incorporated by this reference, as the mitigation monitoring program for the Project; and 8. That based on all of the forgoing, that the City Council certifies and adopts Final EIR(SCH# 200808 1 1 1 8), for the Project. ADOPTED this 24th day of March, 2009 aroly . ave he, Mayor, Ci o range ATTEST: iVIar;E. u y, City Cl , City o nge 3 I, MARY E. MURPHY, City Clerk of the City of Orange, California, do hereby certify that the foregoing Resolution was duly and regularly adopted by the City Council of the City of Orange at a regular meeting thereof held on the 24th day of March, 2009, by the following vote: AYES: COiJNCILMEMBERS: Smith, Murphy, Cavecche, Dumitru NOES: COLTNCILMEMBERS: None ABSENT: COLTNCILMEMBERS: None ABSTAIN (RECUSED): COLJNCILMEMBERS: Bilodeau Mary E y, City Clerk, C Orange 4 RESOLUTION N0. 10358 ATTACHMENT A FINDING OF FACT AND STATEMENT OF OVERRIDING CONSIDERATIONS REGARDING FINAL ENVIRONMENTAL IMPACT REPORT (SCH#2008081118) Findings of Fact/Statement of Overriding Consideration TABLE OF CONTENTS Section Pa e I.INTRODUCTION...................................................................................................1 A. Findings of Fact and Statement of Overriding Considerations....................1 B. Record of Proceedings.................................................................................3 C. Custodian and Location of Records.............................................................4 II. PROJECT SLTIVIMARY...........................................................................................4 A. Project Location...........................................................................................4 B. Project Description.......................................................................................4 C. Discretionary Actions..................................................................................5 D. Use of EIR....................................................................................................6 E. Statement of Objectives...............................................................................6 III. ENVIRONMENTAL REVIEW AND PUBLIC PARTICIPATION......................7 IV. GENERAL FINDINGS...........................................................................................8 V. SUMMARY OF IMPACTS ..................................................................................10 VI. FINDINGS REGARDING IMPACTS..................................................................10 A. Aesthetics.........................:.........................................................................10 B. Air Quality.................................................................................................12 C. Biological Resources .................................................................................23 D. Geology and Soils......................................................................................24 E. Hazards and Hazardous Materials .............................................................27 F. Hydrology and Water Quality..............................:.....................................30 G. Land Use and Planning..............................................................................36 H. Noise..........................................................................................................40 I.Population and Housing.............................................................................47 J.Public Services...........................................................................................48 K. Transportation and Traffic.........................................................................51 L. Utilities and Service Systems.....................................................................61 VII. FINDINGS REGARDING ALTERNATIVES .....................................................69 A. Alternatives Analyzed by Final EIR..........................................................70 VIII. ENVIRONMENTAL ISSUES DETERMINED NOT TO BE POTENTIALI,' AFFECTED BY THE PROJECT..........................................................................75 IX. FINDINGS REGARDING GROWTH INDUCING IMPACTS...........................77 Y TABLE OF CONTENTS (CONT'D) Section Pa e X. FINDINGS REGARDING SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES..................:......................................................78 XI. STATEMENT OF OVERRIDING CONSIDERATIONS....................................79 XII. CONCLUSION......................................................................................................83 ii I. INTRODUCTION A. Findings of Fact and Statement of Overriding Considerations The California Environmental Quality Act (CEQA) (Public Resources Code §§ 2100, et seq.) and the State CEQA Guidelines (Guidelines) (14 Cal. Code Regulations §§ 15000, et seq.) promulgated thereunder, require that the environmental impacts of a project be examined before a project is approved. Specifically, regarding findings, Guidelines Section 15091 provides: a) No public agency shall approve or carry out a project for which an EIR has been certified which identifies one or more significant environmental effects of the project unless the public agency makes one or more written findings for each of those significant effects, accompanied by a brief explanation of the rationale for each finding. The possible findings are: l.Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental affect as identified in the final EIR. 2.Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency. 3.Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR. b) The findings required by subsection (a) shall be supported by substantial evidence in the record. c) The finding in subsection (a)(2) shall not be made if the agency making the finding has concurrent jurisdiction with another agency to deal with identified feasible mitigation measures or alternatives. The finding in subsection a)(3) shall describe the specific reasons for rejecting identified mitigation measures and project alternatives. d) When making the findings required in subsection (a)(1), the agency shall also adopt a program for reporting on or monitoring the changes which it has either required in the project or made a condition of approval Yo avoid or substantially lessen significant environmental effects. These measures must be fully enforceable through permit conditions, agreements, or other measures. 1 e) The public agency shall specify the location and custodian of the documents or other material which constitute the record of the proceedings upon which its decision is based. A statement made pursuant to Section 15093 does not substitute for the findings required by this section. The "changes or alterations" referred to in Section 15091(a)(1) above, that are required in, or incorporated into, the project which mitigate or avoid the significant environmental effects of the project, may include a wide variety of ineasures or actions as set forth in Guidelines Section 15370, including: a) Avoiding the impact altogether by not taking a certain action or parts of an action. b) Minimizing impacts by limiting the degree or magnitude of the action and its implementation. c) Rectifying the impact by repairing, rehabilitating, or restoring the impacted environment. d) Reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action. e) Compensating for the impact by replacing or providing substitute resources or environments. Regarding a Statement of Overriding Considerations, Guidelines Section 15093 provides: a) CEQA requires the decision-making agency to balance, as applicable, the economic, legal, social, technological, or other benefits of a proposed project against its unavoidable environmental risks then determining whether to approve the project. If the specific economic, legal, social, technological, or other benefits of a proposed project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered"acceptable." b) When the lead agency approves a project which will result in the occurrence of significant effects which are identified in the final EIR but are not avoided or substantially lessened, the agency shall state in writing the specific reasons to support its action based on the fmal EIR and/or other information in the record. The statement of overriding considerations shall be supported by substantial evidence in the record. 2 c) If an agency makes a statement of overriding considerations, the statement should be included in the record of the project approval and should be mentioned in the notice of determination. This statement does not substitute for, and shall be in addition to, findings required pursuant to Section 15091. Having received, reviewed, and considered the Final Environmental Impact Report No. 1805-08 for the Children's Hospital of Orange County (CHOC) Master Plan, State Clearinghouse No. 2008081118 (Final EIR), as well as all other information in the record of proceedings on this matter,the following Findings of Fact and Statement of Overriding Considerations (Findings) are hereby adopted by the City of Orange (City) in its capacity as the CEQA Lead Agency. These Findings set forth the environmental basis for current and subsequent discretionary actions to be undertaken by the City and responsible agencies for the implementation of the CHOC Master Plan Project. B. Record of Proceedings For purposes of CEQA and these Findings, the Record of Proceedings for the proposed project consists of the following documents arid other evidence, at a minimum: The Notice of Preparation (NOP) and all other public notices issued by the City in conjunction with the proposed project; The Final EIR for the proposed project; The Draft EIR and Technical Appendices for the proposed project; All written comments submitted by agencies or members of the public during the public review comment period on the Draft EIR; All responses to written comments submitted by agencies or members of the public during the public review comment period on the Draft EIR; All written and verbal public testimony presented during a noticed public hearing for the proposed project at which such testimony was taken; The Mitigation Monitoring Reporting Program(MMRP); The reports and technical memoranda included or referenced in the Response to Comments in the Final EIR; Matters of common knowledge to the City, including but not limited to federal, state and local laws and regulations; Any documents expressly cited in these Findings; and 3 Any other relevant materials required to be in the record of proceedings by Public Resources Code Section 21167.6(e). C. Custodian and Location of Records The documents and other materials which constitute the administrative record for the City's actions related to the Project are located at the City of Orange, 300 East Chapman Avenue, Orange, CA 92866. The City is the custodian of the administrative record for the Project. Copies of these documents, which constitute the record of proceedings, are and at all relevant times have been and will be available upon request at the offices of the City of Orange, Community Development Department, 300 East Chapman Avenue, Orange, CA 92866. This information is provided in compliance with Public Resources Code § 21081.6(a)(2) and Guidelines § 15091(e). II. PROJECT SUMMARY A. Project Location The project site for the proposed project is located in the City of Orange in north-central Orange County. The approximately 12.0-acre project site is generally located to the north of State Route 22 (SR-22), east of Main Street, and south and west of Pepper Street and St. Joseph Hospital. The project site is bisected by La Veta Avenue which runs in an east-west direction. Regional access to the project site is provided via SR-22, the Santa Ana Freeway (Interstate 5 or I-5), and the Orange Freeway (State Route 57 or SR-57). B. Project Description The proposed project provides for the multi-phased upgrade of the CHOC Hospital campus which would allow for the continued use of the existing Hospital and supporting facilities during the implementation of the CHOC Master Plan through the year 2020. The development program for the proposed project would be accomplished in three phases (2012, 2015, and 2020) and result in demolition activities, new construction, and the remodeling of buildings on the project site. All of the external physical changes to the existing conditions on the project site would occur during Phase 1 (by Year 2012) of the proposed project. The demolition activities would remove the Orange Medical Building (1201 La Veta Avenue), the adjacent two-level parking structure, the northern portion of the CHOC pedestrian bridge, and the entry plaza to the hospital. The new construction would result in the development of the CHOC South Tower (which is an expansion of the CHOC North Tower), access improvements, landscaping, and other site improvements. To accommodate the new building, portions of the existing CHOC North Tower would be remodeled. The following provides the overall development phasing of the CHOC South Tower. 4 At the completion of Phase 1, combining the existing and the newly constructed beds, which would include six beds added to the CHOC North Tower in 2009 and the addition of 88 beds in the new CHOC South Tower, the overall number of beds would tota1326. In Phase 2, approximately 54,283 gross square feet of floor area in the CHOC South Tower, which was constructed at shell space in Phase 1, would be finished out. At the completion of Phase 2, combining the existing and newly constructed beds, which would include the removal of 34 beds from the CHOC North Tower and the addition of 60 beds in the new CHOC South Tower, the overall number of beds would total 352. In Phase 3, approximately 38,819 gross square feet of floor area, which is the remainder of the CHOC South Tower constructed as shall space in Phase 1, would be finished out. Combining the existing and the newly constructed beds, which would include the addition of 52 beds in the CHOC South Tower, the overall number of beds would tota1404. During Phase 1 of the proposed project, approximately 40 percent (85,600 square feet) of the CHOC Commerce Tower (505 S. Main Street) would be converted from general office to medical office space. In addition, the proposed project includes the development of a medical office building consisting of approximately 175,000 square feet and associated parking on the southwestern portion of the project site. The general building location, maximum squaxe feet, m imum number of building stories, and parking requirements for this building are the only elements of this portion of the proposed project that have been defined at this time. C. Discretionary Actions Project implementation for the proposed project, based on applications currently pending before the City, includes the following discretionary actions by the City: 1) Certification of the Final EIR. 2) Approval of the Zone Change. 3) Approval of the Tentative and Final Parcel Map and all permits necessary to implement them, including demolition and grading permits. 4) Approval of a development agreement. 5) Approval of the overall final site design through the Major Site Plan Review process. 6) Design review board approval of the landscape concept plan and architecture. 7) Approval of Conditional Use Permit. 8) Approval of encroachment permits in the public right-of-way. 5 In addition, the following county, local agency, state or federal permits or entitlements will be requested under this Final EIR for the CHOC Master Plan Project: 1) Building permits (Office of Statewide Health Planning and Development). 2) Licensing of hospital beds (California State Department of Health Services). 3) Any other permits or approvals that may be necessary to implement the project or approved mitigation measures or conditions of approval. D. Use of EIR The Final EIR serves as the Final EIR for the proposed project. The Final EIR has been prepared by the City to assess the environmental impacts of the proposed project. The EIR was prepared as a Project EIR, as defined in Section 15161 of the CEQA Guidelines, for the project compon.ents that are specific to the portion of the CHOC Master Plan that would result in the development of the CHOC South Tower, the interior remodel of portions of the CHOC North Tower and portions of the CHOC Commerce Tower, and the implementation of the landscape concept plan. For the remainder of the CHOC Master Plan, consisting of the medical office building and parking facilities on the southwestern portion of the project site, the EIR serves as a Program EIR as defined by Section 15168 of the CEQA Guidelines. The program level analysis is based on general building location, m imum square feet, maximum number of building stories, and parking requirements. The evaluation of the medical office building at a program level of analysis allows the EIR to be utilized to determine the extent of any additional environmental documentation that would be prepared with subsequent activities related to this aspect of the proposed project. E. Statement of Objectives As described in Section 3.0 of the Final EIR, CHOC's mission is "To nurture, advance and protect the health and well being of children." CHOC's strategic goals to implement its mission guide the physical planning and development of the proposed project on the project site. In support of these strategic goals, the Project Applicant's objectives for the proposed project consist of the following: 1. Establish a physical design that allows for the development of a hospital that provides "state of the art" facilities and services dedicated exclusively to the care of children. 2. Provide for the development and redevelopment of facilities at the CHOC Hospital campus that address CHOC's mission and strategic goals, including the provision of the following services: 1Vledical and surgical services for an estimated 11,000 children per year from Orange County and the surrounding communities that require hospitalization; 6 State of the art" diagnostic imaging services for children, including Computerized Tomography and Magnetic Resonance Imaging capabilities; Pediatric emergency services for over 60,000 children per year; Medical laboratory services for children; Cutting edge"research in pediatric disease; and Training for pediatric residents and fellows. 3. Provide for the continued utilization of existing facilities while a phased upgrade of the existing CHOC Hospital and supporting facilities occur. 4. Enhance the visual aesthetics of the project frontages along Main Street, La Veta Avenue, Pepper Street, and Providence Street with landscaping, lighting, and signage. 5. Provide a high quality physical environment for patients, visitors, and staff including adequate and safe circulation patterns and parking. III. ENVIRONMENTAL REVIEW AND PUBLIC PARTICIPATION The City prepared an Initial Study for the proposed project and based on that Initial Study, the City determined that the proposed project may have a significant effect on the environment and that an EIR should be prepared to analyze the potential impacts associated with the approval and implementation of the proposed project. In accordance with the Guidelines §15082, the City distributed the Notice of Preparation NOP) and Initial Study for a 30-day public review period. The public review period was initiated on September 2, 2008, held for 30 days as required by CEQA, and closed on October 2, 2008. The NOP and Initial Study, the distribution list, any written comments received, and responses to those comments are contained in Appendix A-1 of the EIR. Two public scoping meetings, one for agencies and the other for the general public, were held on September 18, 2008 by the City staff to discuss the environmental review process for the proposed project, the characteristics of the proposed project, and the environmental issues to be addressed in the Draft EIR based on the conclusion of the NOP and Initial Study distributed by the City. As required by the City's locally adopted CEQA Guidelines, notification of the scoping meetings, including the timeframes of the NOP, were directly mailed on August 28, 2008 to properly owners and tenants within a 300-foot radius of the project boundary. On this same date, notification was also published in the Orange City News, and the project site was posted in various locations. The Notice of Public Scoping Meeting indicated the date, location, and times of the meetings, described the proposed project, and indicated the locations where the NOP and Initial Study were available for public review. The NOP and Initial Study were also 7 posted on the City's web site. The Notice of Public Scoping Meeting, the notice in the newspaper, and the sign-in list from the public scoping meetings are contained in Appendix A-1, of the EIR. The Draft EIR for the proposed project was then prepared and circulated for review and comment by the public, agencies and organizations for a 45-day public review period that began on December 19, 2008 and concluded on February 2, 2009. A Notice of Completion of the Draft EIR was sent to the State Clearinghouse and the Draft EIR was circulated to State agencies for review through the State Clearinghouse, Office of Planning and Research (SCH No. 2008081118). A Notice of Availability and Notice of Completion (NOA/NOC) of the Draft EIR for review was mailed to property owners, tenants, and occupants in the vicinity of the project site. The NOA/NOC was also filed with the County Clerk and posted on the project site. During the public review period, five comment letters on the Draft EIR were received. On February 19, 2009, Responses to Comments on the Draft EIR and revisions to the Draft EIR were published and made available on the City's website. Draft EIR Public Hearings/Meetin The Planning Commission and the City Council each held public hearings on the EIR. The City Council has taken into consideration all of the public comments from these multiple hearings (as well as written comments and the evidence in the administrative record) in making these Findings. IV. GENERAL FINDINGS The City hereby finds as follows: The City is the "Lead Agency" for the proposed project evaluated in the Final EIR; The Draft EIR and Final EIR were prepared in compliance with CEQA and the Guidelines; The City has independently reviewed and analyzed the Draft EIR and the Final EIR, and these documents reflect the independent judgment of the City; A MMRP has been prepared for the proposed project, which the City has adopted or made a condition of approval of the proposed project. That MMRP is incorporated herein by reference and is considered part of the record of proceedings for the proposed proj ect; The MMRP designates responsibility and anticipated timing for the implementation of mitigation. The City will serve as the MMRP Coordinator; In determining whether the proposed project has a significant impact on the environment, and in adopting these Findings pursuant to Section 21081 of CEQA, the City has complied with CEQA Sections 21081.5 and 21082.2; The impacts of the proposed project have been analyzed to the extent feasible at the time of certification of the Final EIR; The City reviewed the comments received on the Draft EIR and Final EIR and the responses thereto and has determined that neither the comments received nor the responses to such comments add significant new information regarding environmental impacts to the Draft EIR or Final EIR. The City has based its actions on full appraisal of all viewpoints, including all comments received up to the date of adoption of these Findings, concerning the environmental impacts identified and analyzed in the Final EIR; The responses to the comments on the Draft EIR, which are contained in the Final EIR, clarify and amplify the analysis in the Draft EIR; Having reviewed the information contained in the Draft EIR and Final EIR and the record of proceedings, as well as the requirements of CEQA and the Guidelines regarding recirculation of Draft EIRs, and having analyzed the changes in the Draft EIR which have occurred since the close of its public review period, the City finds that there is no new significant information in the Final EIR and finds that recirculation is not required.; The use of volume to capacity ("V/C") and intersection capacity utilization ICU") methodologies in the traffic studies for the proposed project was proper, appropriate, and required by the City's General Plan. The Growth Management Element of the City's General Plan specifies that levels of service shall be measured according to the methodology established by the Local Transportation Authority, which is the Orange County Transportation Authority ("OCTA"), OCTA has utilized the V/C and ICU methodologies for conducting traffic impact studies associated with the MPAH. The V/C and ICU methodologies are accepted by transportation professionals to be an accurate method for assessing roadway impacts. The City of Orange has determined to follow this group of experts in mandating the use of the V/C and ICU methodologies for this project, as well as others in the City. The City has made no decisions that constitute an irretrievable commitment of resources toward the proposed project prior to certification of the Final EIR, nor 9 has the City previously committed to a definite course of action with respect to the proposed project; Copies of all the documents incorporated by reference in the Final EIR are and have been available upon request at all times at the offices of the City, custodian of record for such documents or other materials; and Having received, reviewed, and considered all information and documents in the record, the City hereby conditions the proposed project and finds as stated in these Findings. V. SUMMARY OF IMPACTS The Final EIR concludes that impacts of the proposed project with respect to the following resources either will not be significant or will be mitigated to below a level of significance by existing regulations/standard conditions, project design features, and/or mitigation measures that will be made conditions of project approval: aesthetics, air quality, biological resources, geology and. soils, hazards and hazardous materials, hydrology and water quality, land use and planning, noise, population and housing, public resources, transportation and traffic, and utilities and service systems. Certain impacts related to air quality (consistency with Air Quality Management Plan, local PM10 emissions during excavation and grading phase of construction activities, regional NOX and CO emissions from ongoing operations of the proposed project, and incremental contribution of greenhouse gas emission to global climate change), noise construction activities in combination with construction-related traffic and demolition activities), and transportation and traffic (incremental contribution to one study area intersection in General Plan [2030] with Project Conditions and incremental contribution to four study area intersections for the Cumulative Conditions using California Department of Transportation methodology) will remain significant after mitigation. VI. FINDINGS REGARDING IMPACTS A. Aesthetics l. Environmental Impact: Substantiall Degrade the Existing Visual Character or Qualitv of the Site and Its Surroundin s. As discussed in Section 4.1 of the EIR, the proposed project would not substantially degrade the existing visual character of the project site and the surrounding area. No significant impact would occur and no mitigation is required. Finding: The proposed project would have no significant adverse effect regarding changes to the visual character of the project site and the surrounding area and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). 1Q Facts in Support of Finding: The EIR discusses potential impacts regarding Aesthetics in Section 4.1, which is incorporated herein by reference. The EIR determined that although the development of the proposed project would alter the visual quality of the project site, the proposed development and redevelopment on the project site along with the implementation of the landscape concept design would not substantially degrade the existing character of the project site and the surrounding area. The proposed project is consistent with the City's General Plan Land Use and Circulation Element goals and policies. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.1. 2.Environmental Impacts: Create New Sources of Substantial Li ng t and Glare. As discussed in Section 4.1 of the EIR, the proposed project would have a less than significant impact from the creation of additional sources of light and glare and the casting of shade and shadows with the implementation of the mitigation required in EIR No. 1805-08. Finding: Changes or alterations have been required in, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effects regarding the creation of additional sources of light and glare to below a level of significance. Public Resources Code § 21081(a)(1), Guidelines § 15091(a)(1). Facts in Support of Finding: The EIR discusses potential impacts regarding Aesthetics in Section 4.1, which is incorporated herein by reference. The EIR determined that the development of the proposed project would create additional sources of light and glare that would contribute to the nighttime lighting in the project vicinity. The EIR determined that, with the implementation of Mitigation Measure MM 4.1-1 (which requires review and approval of a photometric analysis consistent with the City of Orange Municipal Code Ordinance 17.12.030 prior to issuance of any building permit), this impact would be less than significant. The EIR determined that no significant impact due to shade and shadows cast by the CHOC South Tower and the proposed medical office building would be anticipated. Mitigation Measures: Mitigation Measure MM 4.1-1 is incorporated herein by reference as though fully set forth and shall be a condition of project approval. Reference: EIR Section 4.1. 3.Environmental Impacts: Cumulative Effects. As discussed in Section 4.1 of the EIR, the proposed project would have a less than significant cumulative impact related to aesthetics with the implementation of the mitigation required in EIR No. 1805- 08. 11 Finding: Changes or alterations have been required in, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effects regarding the creation of additional sources of light and glare to below a level of significance. Public Resources Code § 21081(a)(1), Guidelines § 15091(a)(1). Facts in Support of Finding: The EIR discusses potential impacts regarding Aesthetics in Section 4.1, which is incorporated herein by reference. The EIR determined that the development associated with the past, present, and reasonably foreseeable future related projects would contribute to a cumulative effect related to aesthetics as a result in the changes to the physical attributes and light and glare in the general area surrounding the project site. Individually, each of the related projects would be subject to review by the respective jurisdictions and would be required to comply with the respective jurisdictions' requirements regarding architectural design, landscaping, and lighting. Upon completion of the City's review process and the implementation of Mitigation Measure MM 4.1-1 (which requires review and approval of a photometric analysis consistent with the City of Orange Municipal Code Ordinance 17.12.030 prior to issuance of building permits), the potential impacts of the proposed project related to aesthetics would be less than significant or reduced to a less than significant level. The EIR deternuned that upon compliance with the regulatory requirements and the mitigation measure, the proposed project in conjunction with other past, present, and reasonably foreseeable future projects would not result in a significant cumulative impact related to aesthetics. Mitigation Measures: Mitigation Measure MM 4.1-1 is incorporated herein.by reference as though fully set forth and shall be a condition of project approval. Reference: EIR Section 4.1. B. Air Quality 1. Environmental Impact: Conflict With or Obstruct Implementation of the Applicable Air Quality Plan. As discussed in Section 4.2 of the EIR, the proposed project would have a significant adverse impact regarding conflict with the South Coast Air Quality Management District (SCAQMD) Air Quality Management Plan (AQMP) despite the implementation of the mitigation required in EIR No. 1805-08. Finding: Changes or alterations have been required in, or incorporated into, the proposed project which lessens the significant environmental effects regarding air quality emissions during construction activities and ongoing operation of the proposed project. These changes or alterations, however, will not reduce this impact to below a level of significance, and that specific economic, social, technological or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the EIR, as discussed in Section IX of these findings. As described in the Statement of Overriding Considerations, the CiYy 12 has determined that this impact is acceptable because of specific overriding considerations. Public Resources Code § 21081(a)(3), Guidelines § 15091(a)(3). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that the proposed project would result in a conflict with the SCAQMD AQMP as a result of the short-term significant impact to local air quality from PM10 emissions during the excavation and grading phase of the construction activities and a long-term significant impact to regional air quality from NOX and CO emissions. The EIR determined that, with implementation of Mitigation Measures MM 4.2-1, MM 4.2-2, MM 4.2-3, MM 4.2- 4, and MM 4.2-5 (which reduce PM10 emissions during excavation and grading and NOX and CO emissions during ongoing operations), this impact would remain a significant unavoidable adverse impact. Mitigation Measures: Mitigation Measures MM 4.2-1, MM 4.2-2, MM 4.2-3, MM 4.2-4, and MM 4.2-5 are incorporated herein by reference as though fully set forth and shall be a condition of project approval. Reference: EIR Section 4.2; Technical Appendix B. 2.Environmental Impact: Violate any Air Quality Standard or Contribute Substantially to an Existin o r Projected Air Qualitv Violation. As discussed in Section 4.2 of the EIR, the proposed project would have a significant short-term adverse impact to local air quality created by PM10 emissions during excavation and grading activities despite the implementation of the mitigation required in EIR No. 1805-08. Finding: Changes or alterations have been required in, or incorporated into, the proposed project which lessens the significant environmental effects regarding air quality emissions during excavation and grading activities. These changes or alterations, however, will not reduce this impact to below a level of significance, and that specific economic, social, technological or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the EIR, as discussed in Section IX of these findings. As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because of specific overriding considerations. Public Resources Code § 21081(a)(3), Guidelines § 15091(a)(3). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that the excavation and grading phase of the construction activities for the proposed project would result in a short-term significant impact to local air quality due to PM10 emissions. The EIR determined that, with implementation of Mitigation Measure MM 4.2-1 (which reduces PM10 emissions), this impact would remain a significant unavoidable adverse impact. 13 Mitigation Measures: Mitigation Measure MM 4.2-1 is incorporated herein by reference as though fully set forth and shall be a condition of project approval. Reference: EIR Section 4.2; Technical Appendix B. 3.Environmental Impact: Violate an r Qualitv Standard or Contribute Substantially to an Existin o r Projected Air Qualitv Violation. As discussed in Section 4.2 of the EIR, the proposed project would not expose sensitive receptors to significant short-term toxic air contaminants during construction activities. No significant impact would occur and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to the exposure of sensitive receptors to significant short-term toxic air contaminants during construction activities and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR deternuned that given the relatively limited number of heavy-duty construction equipment and the short-term construction schedule, the proposed project would not result in a long-term i.e., 70 years) substantial source of toxic air contaminants emissions and corresponding individual cancer risk. The proposed project would not expose sensitive receptors to significant short-term toxic air contaminants during construction activities. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.2; Technical Appendix B. 4.Environmental Impact: Violate any Air Quality Standard or Contribute Substantiallv to an Existin ogrProjectedAirQualitvViolation. As discussed in Section 4.2 of the EIR, the proposed project would have a short-term less than significant impact to regional air quality during demolition activities and no mitigation is required. Findings: The proposed project would have no significant adverse effect to regional air quality during demolition activities and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that the demolition phase for the proposed project would result in a short-term less than significant impact to regional air quality and no mitigation is required. Mitigation Measures: No mitigation is required. 14 Reference: EIR Section 4.2; Technical Appendix B. 5. Environmental Impact: Violate an_y Air Qualitv Standard or Contribute Substantially to an Existin o Projected Air Qualitv Violation. As discussed in Section 4.2 of the EIR, the proposed project would have a short-term less than significant impact to regional air quality during excavation and grading activities with implementation of the mitigation required in EIR No. 1805-08. Findings: Changes or alterations have been required in, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effect to regional air quality during grading and excavation activities to below a level of significance. Public Resources Code § 21081(a)(1), Guidelines § 15091(a)(1). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that the excavation and grading for the proposed project would have a significant short- term impact to regional air quality due to NOX, PM10, and PM2.5 emissions. The EIR determined, with the implementation of Mitigation Measures MM 4.2-2 and MM 4.2-3 which reduces NOX, PM10, and PM2.5 emissions), this impact would be less than significant. Mitigation Measures: Mitigation Measures MM 4.2-2 and MM 4.2-3 are incorporated herein by reference as though fully set forth and shall be a condition of . project approval. Reference: EIR Section 4.2; Technical Appendix B. 6. Environmental Impact: Violate any Air Quality Standard or Contribute Substantially to an Existin or Projected Air Quality Violation. As discussed in Section 4.2 of the EIR, the proposed project would have a short-term less than significant impact to regional air quality during trenching activities and no mitigation is required. Findings: The proposed project would have no significant adverse effect to regional air quality during trenching activities and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that the trenching phase for the proposed project would result in a short-term less than significant impact to regional air quality and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.2; Technical Appendix B. 15 7.Environmental Impact: Violate anv Air Quality Standard or Contribute Substantiallv to an Existin oQrProjectedAirQualitvViolation. As discussed in Section 4.2 of the EIR, the proposed project would have a short-term less than significant impact to regional air quality during the building construction activities and no mitigation is required. Findings: The proposed project would have no significant adverse effect to regional air quality during building construction activities and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that the building construction activities for the proposed project would result in a short- term less than significant impact to regional air quality and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.2; Technical Appendix B. 8.Environmental Impact: Violate anv Air Ouality Standard or Contribute Substantially to an Existin o r Proiected Air Qualitv Violation. As discussed in Section 4.2 of the EIR, the proposed project would have a short-term less than significant impact to regional air quality during the paving activities and no mitigation is required. Findings: The proposed project would have no significant adverse effect to regional air quality during paving activities and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that the paving activities for the proposed project would result in a short-term less than significant impact to regional air quality and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.2; Technical Appendix B. 9.Environmental Impact: Violate anv Air Qualitv Standard or Contribute Substantiallv to an Existin ogrProjectedAirQualitvViolation. As discussed in Section 4.2 of the EIR, the proposed project would have a significant adverse impact to regional air quality due to ongoing operations despite the implementation of the mitigation required in EIR No. 1805-08. Finding: Changes or alterations have been required in, or incorporated into, the proposed project which lessens the significant environmental effects regarding regional 16 air quality due to the ongoing operation of the proposed project. These changes or alterations, however, will not reduce this impact to below a level of significance, and specific economic, social, technological or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the EIR, as discussed in Section IX of these findings. As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because of specific overriding considerations. Public Resources Code § 21081(a)(3), Guidelines § 15091(a)(3). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that the ongoing operation of the proposed project would result in a long-term significant impact to regional air quality due to NOX and CO emissions. The EIR determined that, with implementation of Mitigation Measures MM 4.2-4 and MM 4.2-5 (which reduce NOX and CO emissions),this impact would remain a significant unavoidable impact. Mitigation Measures: Mitigation Measures MM 4.2-4 and MM 4.2-5 are incorporated herein by reference as though fully set forth and shall be a condition of project approval. Reference: EIR Section 4.2; Technical Appendix B. 10. Environmental Impact: Violate anv Air Qualitv Standard or Contribute Substantiallv to an Existin ogrProjectedAirQualitvViolation. As discussed in Section 4.2 of the EIR, the proposed project would have a long-term less than significant impact to local air quality from vehicle emissions during ongoing operations and no mitigation is required. Findings: The proposed project would have no significant adverse effect to local air quality from vehicle emissions during ongoing operations and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that the vehicle emissions from the ongoing operation of the proposed project would result in a long-term less than significant impact to local air quality and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.2; Technical Appendix B. 11. Environmental Impact: Violate any Air Qualitv Standard or Contribute Substantiallv to an Existin or Projected Air Qualitv Violation. As discussed in Section 4.2 of the EIR, the proposed project would have a less than significant impact related to 17 long-term health risk from diesel emissions during ongoing operations and no mitigation is required. Findings: The proposed project would have no significant adverse effect related to long-term health risk from diesel emissions during ongoing operations and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that no significant long-term health risk is anticipated from project-related diesel emissions with the ongoing operations of the proposed project. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.2; Technical Appendix B. 12. Environmental Impact: Violate any Air Qualitv Standard or Contribute Substantially to an Existin o jected Air Quality Violation. As discussed in Section 4.2 of the EIR, the proposed project would have a less than significant long-term impact to local air quality during ongoing operations and no mitigation is required. Findings: The proposed project would have no significant adverse effect to long- term local air quality during ongoing operations and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that no long-term significant impact to local air quality would occur during the ongoing operation of the proposed project no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.2; Technical Appendix B. 13. Environmental Impacts: Result in a Cumulatively Considerable Net Increase of any Criteria Pollutant for which the Project Region is Categorized as Non- Attainment Under an Applicable Federal or State Ambient Air Qualitv Standard. As discussed in Section 4.2 of the EIR, the proposed project would contribute to a less than significant short-term cumulative impact to regional air quality due to excavation and grading with implementation of the mitigation required in EIR No. 1805-08. Finding: Changes or alterations have been required in, or incorporated into, the proposed project which avoid or substantially lessen the short-term significant cumulative 18 environmental effects regarding regional air quality to below a level of significance. Public Resources Code § 21081(a)(1), Guidelines § 15091(a)(1). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that the excavation and grading for the proposed project would contribute to a significant short-term cumulative impact to regional air quality due to PM10 and PM2.5 emissions. The EIR determined that, with implementation of Mitigation Measures MM 4.2-2 and MM 4.2-3 (which reduce PM10 and PM2.5 emissions), this impact would be less than significant. Mitigation Measures: Mitigation Measures MM 4.2-2 and MM 4.2-3 are incorporated herein by reference as though fully set forth and shall be a condition of project approval. Reference: EIR Section 4.2; Technical Appendix B. 14. Environmental Impacts: Result in a Cumulatively Considerable Net Increase of any Criteria Pollutant for which the Project Region is Cate orized as Non- Attainment Under an A plicable Federal or State Ambient Air Qualitv Standard. As discussed in Section 4.2 of the EIR, the proposed project would contribute to a significant long-term cumulative adverse impact to regional air quality due to ongoing operations despite the implementation of the mitigation required in EIR No. 1805-08. Finding: Changes or alterations have been required in, or incorporated into, the proposed project which lessens the long-term significant cumulative environmental effects regarding regional air quality due to the ongoing operation of the proposed project. These changes or alterations, however, will not reduce this impact to below a level of significance, and specific economic, social, technological or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the EIR, as discussed in Section IX of these findings. As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because of specific overriding considerations. Public Resources Code § 21081(a)(3), Guidelines § 15091(a)(3). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that the ongoing operation of the proposed project would contribute to a long-term significant impact to regional air quality. The EIR determined that, with implementation of Mitigation Measures MM 4.2-4 and MM 4.2-5 (which reduce NOX and CO emissions), this impact would remain a significant unavoidable impact. Mitigation Measures: Mitigation Measures MM 4.2-4 and MM 4.2-5 are incorporated herein by reference as though fully set forth and shall be a condition of project approval. 1 Reference: EIR Section 4.2; Technical Appendix B. 15. Environmental Impact: Expose Sensitive Receptors to Substantial Pollutant Concentrations. As discussed in Section 4.2 of the EIR, the proposed project would not expose sensitive receptors to significant short-term air contaminants during construction activities. No significant impact would occur and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to the exposure of sensitive receptors to significant short-term air contaminants during construction activities and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that the proposed project would not expose sensitive receptors to significant short-term air contaminants during construction activities. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.2; Technical Appendix B. 16. Environmental Impact: Expose Sensitive Receptors to Substantial Pollutant Concentrations. As discussed in Section 4.2 of the EIR, the proposed project would have a less than significant impact related to significant long-term health risks due to project-related diesel emissions during ongoing operations and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to significant long-term health risks due to project-related diesel emissions during ongoing operations and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that no significant long-term health risk is anticipated from project-related diesel emissions with the ongoing operations of the proposed project. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.2; Technical Appendix B. 17. Environmental Impact: Expose Sensitive Receptors to Substantial Pollutant Concentrations. As discussed in Section 4.2 of the EIR, the proposed project 20 would have a less than significant long-term impact to local air quality during ongoing operations and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to local air quality during ongoing operations and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that no long-term significant impact to local air quality would occur during the ongoing operation of the proposed project and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.2; Technical Appendix B. 18. Environmental Impact: Expose Sensitive Receptors to Substantial Pollutant Concentrations. As discussed in Section 4.2 of the EIR, the proposed project would have a less than significant short-term impact from construction-related greenhouse gas (GHG) emissions and no mitigation is required. Finding: The proposed project would have no significant adverse effect from construction-related GHG emissions and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that the greatest annual construction-related GHG emissions from the proposed project would occur in 2012 and would create 1,973.08 metric tons of COZe emissions. This would not exceed the City's proposed threshold of significance of 10,000 metric tons per year of COZe emissions. Therefore, construction activities for the proposed project would have a short-term less than significant impact and no mitigation would be required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.2; Technical Appendix B. 19. Environmental Impact: Expose Sensitive Receptors to Substantial Pollutant Concentrations. As discussed in Section 4.2 of the EIR, the proposed project would have a significant adverse impact as the ongoing operation of the proposed project would create a cumulatively considerable contribution of GHG emissions to global climate change despite the implementation of mitigation required in EIR No. 1805-08. Finding: Changes or alterations have been required in, or incorporated into, the proposed project which lessens the significant environmental effects regarding the 21 contribution of GHG emissions to global climate change. These changes or alterations, however, will not reduce this impact to below a level of significance, and specific economic, social, technological or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the EIR, as discussed in Section IX of these findings. As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because of specific overriding considerations. Public Resources Code § 21081(a)(3), Guidelines § 15091(a)(3). Facts in 5upport of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that the proposed project would generate 20,257.46 metric tons of CO2e per year and would represent 0.0042 percent of California emissions. A cumulative impact related to global climate change impact would occur if the GHG emissions created from the ongoing operations of the proposed project would exceed the City's proposed threshold of significance of 10,000 metric tons per year of CO2e. A 10,257.46 metric ton reduction of CO2e emissions would be required to meet the City's proposed threshold. A reduction of this magnitude would not possible while maintaining the proposed size and functionality of the proposed project. Therefore, the ongoing operation of the proposed project would create a cumulatively considerable contribution of GHG emissions to global climate change and would be a significant impact. The EIR determined that, with implementation of Mitigation Measures MM 4.2-4 and MM 4.2-5 (which reduce NOX and CO emissions), this impact would remain a significant unavoidable impact. Mitigation Measures: Mitigation Measures MM 4.2-4 and MM 4.2-5 are incorporated herein by reference as though fully set forth and shall be a condition of project approval. Reference: EIR Section 4.2; Technical Appendix B. 20. Environmental Impacts: Create Objectionable Odors Affectin Substantial Number of People. As discussed in Section 4.2 of the EIR, the proposed project would have a less than significant impact during construction activities and the ongoing operation of the proposed project and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to odors during construction activities and the ongoing operation of the proposed project and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Air Quality in Section 4.2, which is incorporated herein by reference. The EIR determined that due to the short-term nature and limited amounts of odor producing materials being utilized, a short-term less than significant impact related to odors would occur during construction of the proposed project and no mitigation is required. The EIR determined 22 that to the north of La Veta Avenue, the proposed project would not change the location where the solid waste is stored and due to the placement of the proposed solid waste storage facilities, no substantial odor impact would occur and no mitigation is required. In addition, the EIR determined that, to the south of La Veta Avenue, due to the distance of the nearest sensitive receptors from the proposed medical office building and through compliance with SCAQMD's Rule 402, no significant impact related to odors would occur during ongoing operations of the proposed project and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.2; Technical Appendix B. C. Biological Resources 1. Environmental Impact: Conflict with the Citv of Orange Tree Preservation Ordinance. As discussed in Section 4.3 of the EIR, the proposed project would not conflict with the City of Orange Tree Preservation Ordinance. No significant impact would occur and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to a conflict with the City of Orange Tree Preservation Ordinance and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Biological Resources in Section 4.3.,which is incorporated herein by reference. The EIR determined that with the development of the proposed project there would be a net increase of 14 trees on or adjacent to the project site from the existing condition. Based on the City's practice of requiring a 1:1 replacement ratio and requirements for a tree removal permit, the proposed project would not result in a conflict with the City of Orange Tree Preservation Ordinance. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.3. 2. Environmental Impact: Cumulative Effect. As discussed in Section 4.3 of the EIR, the proposed project would have a less than significant cumulative impact related to the removal of existing trees and the City's Tree Preservation Ordinance and no mitigation is required. Finding: The proposed project would have no significant cumulative effect related to removal of trees and the City's Tree Preservation Ordinance and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). 23 Facts in Support of Finding: The EIR discusses potential impacts regarding Biological Resources in Section 4.3., which is incorporated herein by reference. The EIR determined that the development of past, present, and reasonably foreseeable future related projects would result in the removal of existing trees in the City of Orange and the City of Santa Ana. Individually each of the cumulative projects would be subject to technical evaluation and review by the respective jurisdictions and would be required to comply with the respective jurisdictions' requirements related to the preservation of trees. The development of the proposed project would not result in a conflict with the City's Tree Preservation Ordinance and no significant impact would occur. The EIR determined that the proposed project in conjunction with other past, present, and reasonably foreseeable future projects would not result in a significant cumulative impact related to trees and the City's Tree Preservation Ordinance and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.3. D. Geology and Soils 1.Environmental Impact: Expose People or Structures to Substantial Adverse Effects Including the Risk of Loss Iniurv. or Death, Involvin ng Seismic Ground Shakin. As discussed in Section 4.4 of the EIR, the proposed project would not expose people and structures to substantial adverse effects due to strong seismic ground shaking. No significant impact would occur and no mitigation is required. Finding: The proposed project would have no significant adverse effect from the exposure of people and structures to substantial adverse effects due to strong seismic ground shaking and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Geology and Soils in Section 4.4, which is incorporated herein by reference. The EIR determined that with the construction of the buildings on the project site consistent with the California Building Code (CHOC South Tower and CHOC North Tower), the City's building requirements, and the Uniform Building Code (Seismic Zone 4) (medical office building), the proposed project would not expose people and structures to substantial adverse effects due to strong seismic ground shaking. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.4; Technical Appendix C. 2.Environmental Impact: Expose People or Structures to Substantial Adverse Effects, Includin the Risk of Loss, Injury, or Death, Involving Seismic-Related 24 Ground Failure, Including Liquefaction. As discussed in Section 4.4 of tlie EIR, the proposed project would not expose people or structures to substantial adverse effects from seismic-related ground failure. No impact would occur and no mitigation is required. Finding: The proposed project would have no significant adverse effect from the exposure of people and structures to substantial adverse effects from seismic-related ground failure and no mitigation is required. Public Resources Code § 21081, Guidelines 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Geology and Soils in Section 4.4, which is incorporated herein by reference. The EIR determined that, since the potential for liquefaction is considered low, the potential for lateral spreading to occur on the project site is considered to be low. In addition, the seismically induced settlement would be 0.25 of an inch or less and not considered an adverse effect. The proposed project would not expose people and structures on the project site to substantial adverse effects from seismically related ground failure. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.4; Technical Appendix C. 3.Environmental Impact: Be Located on Geologic Unit or Soil That is Unstable or Would Become Unstable as a Result of the Project, and Potentiallv Result in On- or Off-Site Landslide Lateral Spreading, Subsidence Liquefaction or Collapse. As discussed in Section 4.4 of the EIR, with the proposed project, the soil conditions in the development area for the CHOC South Tower would not result in substantial risks to life and property due to unstable geology or soils. No impact would occur and no mitigation is required. Finding: The proposed project would have no significant adverse effect from soil conditions in the development area for the CHOC south Tower and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Geology and Soils in Section 4.4., which is incorporated herein by reference. Based on the soil conditions on the project site and the anticipated load for the CHOC South Tower, the recommendations provided in Section 6.0 of the Geotechnical Investigation provided in Technical Appendix C of the EIR were incorporated into the grading plans and building design. The EIR determined that the soil conditions in the development area for the CHOC South Tower would not result in substantial risks to life and property due to unstable geology or soils. No impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. 25 Reference: EIR Section 4.4; Technical Appendix C. 4.Environmental Impact: Be located on Expansive Soil, as defined in Table 18-1-B of the Uniform Buildin Cgode (1994 Creating Substantial Risks to Life and Propertv. As discussed in Section 4.4 of the EIR, with the proposed project, the development of the CHOC South Tower would not result in the location of a structure on expansive soils. No impact would occur and no mitigation is required. Finding: The proposed project would have no significant adverse effect from expansive soils in the development area for the CHOC South tower and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Geology and Soils in Section 4.4., which is incorporated herein by reference. The EIR determined that based on subsurface investigations, the silty sand layer, which would be at the depths required for the basement of the CHOC South Tower, has low expansion potential. Therefore, the development of the CHOC South Tower would not result in the location of a structure on expansive soils. No impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.4; Technical Appendix C. 5.Environmental Impact: Cumulative Effect. As discussed in Section 4.4 of the EIR, the proposed project would have a less than significant cumulative impact related to geology and soils and no mitigation is required. Finding: The proposed project would have no significant adverse cumulative effect related to geology and soils and no mitigation is required. Public Resources Code 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Geology and Soils in Section 4.4., which is incorporated herein by reference. The EIR determined that the development of past, present, and reasonably foreseeable future related projects would not contribute to a cumulative effect from geology and soils. Individually, each of the cumulative projects would be individually subject to geotechnical review by the respective jurisdictions and would be required to comply with the respective jurisdictions' requirements, the California Building Code, the Uniform Building Code (Seismic Zone 4), and site-specific geotechnical recommendations in order to adequately address the potential effects related to geology and soils. Upon compliance with the City's grading and building codes and the Uniform Building Code Seismic Zone 4), the potential impacts of the proposed project related to geology and soils would be less than significant. The EIR determined that upon compliance with the regulatory requirements, the proposed project in conjunction with other past, present, and 26 reasonably foreseeable future projects would not result in a significant cumulative impact related to the exposure of people or structure to adverse effects from geology and soils and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.4. E. Hazards and Hazardous Materials 1. Environmental Impacts: Create a Si nificant Hazard to the Public or Environment Throu h Reasonable Foreseeable U set and Accident Conditions Involving the Release of Hazardous Materials into the Environment. As discussed in Section 4.5 of the EIR, during the demolition and remodeling activities, the proposed project would have a less than significant impact from asbestos-containing materials and lead-based paint that would have the potential to result in a hazard to the public from the release of materials into the environment with the implementation of mitigation required in EIR No. 1805-08. Finding: Changes or alterations have been required in, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effects during demolition and remodeling activities from asbestos-containing materials and lead- based paint that would have the potential to result in a hazard to the public from the release of materials into the environment to below a level of significance. Public Resources Code § 21081(a)(1), Guidelines § 15091(a)(1). Facts in Support of Finding: The EIR discusses potential impacts regarding Hazards and Hazardous Materials in Section 4.5, which is incorporated herein by reference. The EIR determined that due to their age, some of the buildings on the project site have the potential to have asbestos-containing materials and lead-based paint. During demolition and remodeling activities for the proposed project, the presence of asbestos-containing materials and lead-based paint would have the potential to result in a hazard to the public from the release of materials into the environment. The EIR determined that, with the implementation of Mitigation Measures MM 4.5-1 and MM 4.5-2, these impacts would be less than significant. The EIR determined that during the construction activities, no significant impact would be anticipated from the disturbance of soil excavation and grading resulting in the release of hazardous materials into the environment from previous land uses on the project site and no mitigation is required. The EIR determined that, with the implementation of the elements of CHOC's Hazardous Materials and Waste Management Plan, no impact would occur from the ongoing operation of the proposed project resulting in the creation of a significant hazard to the public or the environment through reasonable foreseeable upset or accident conditions involving the release of hazardous materials into the environment and no nitigation s required. 27 Mitigation Measures: Mitigation Measures MM 4.5-1 and MM 4.5-2 are incorporated herein by reference as though fully set forth and shall be a condition of project approval. Reference: EIR Section 4.5; Technical Appendix D. 2.Environmental Impact: Emit Hazardous Emissions or Handle Hazardous Materials, Substances, or Waste Within One-Quarter Mile of an Existin Proposed School. As discussed in Section 4.5 of the EIR, the proposed project would have a less than significant impact from the potential release of hazardous emissions within one-quarter mile of an existing school from asbestos-containing materials or lead- based paint during demolition and remodeling activities with implementation of mitigation required in EIR No. 1805-08. Finding: Changes or alterations have been required in, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effects during demolition and remodeling activities from asbestos-containing materials and lead- based paint that would have the potential to result in a hazard to the public from the release of materials into the environment to below a level of significance. Public Resources Code § 21081(a)(1), Guidelines § 15091(a)(1). Facts in Support of Finding: The EIR discusses potential impacts regarding Hazards and Hazardous Materials in Section 4.5, which is incorporated herein by reference. T'he EIR determined that due to their age, some of the buildings on the project site have the potential to have asbestos-containing materials and lead-based paint. During demolition and remodeling activities for the proposed project, the presence of asbestos-containing materials and lead-based paint would have be potential to result in the release of hazardous materials within one-quarter mile of an existing school. The EIR determined that, with the implementation of Mitigation Measures MM 4.5-1 and MM 4.5-2, this impact would be less than significant. Mitigation Measures: Mitigation Measures MM 4.5-1 and MM 4.5-2 are incorporated herein by reference as though fully set forth and shall be a condition of project approval. Reference: EIR Section 4.5; Technical Appendix D. 3. Environmental Impact: Impair Implementation of or Phvsicallv Interfere with an Adopted Emergenc r ponse Plan or Emergency Evacuation Plan. As discussed in Section 4.5, the proposed project would have a less than significant impact from the impairment of the City's ability to implement their Multi-Hazard Functional Plan or utilize the emergency evacuation routes identified in the General Plan Safety Element and no mitigation is required. 2 Finding: The proposed project would have no significant adverse effect related to the impairment of the City's ability to implement their Multi-Hazard Functional Plan or utilize the emergency evacuation routes identified in the General Plan Safety Element and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Hazards and Hazardous Materials in Section 4.5, which is incorporated herein by reference. The EIR determined that there are no emergency evacuation routes adjacent to the project site. During the construction activities for the proposed project, no change in the circulation patterns on the adjacent roadways would occur and the intersections in the project vicinity and the adjacent roadway segment of La Veta Avenue would continue to operate at an adequate level of service. The EIR determined that the construction activities and the ongoing operation of the proposed project would not impair the City's ability to implement their Multi-Hazard Functional Plan or utilize the emergency evacuation routes identified in the General Plan Safety Element. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.5. 4. Environmental Impact: Cumulative Effect. As discussed in Section 4.5, the proposed project would have a less than significant cumulative impact related to hazaxds and hazardous materials with the implementation of mitigation required in EIR No. 1805-08. Finding: Changes or alterations have been required in, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effects during demolition and remodeling activities from asbestos-containing materials and lead- based paint that would have the potential to result in a hazard to the public from the release of materials into the environment to below a level of significance. Public Resources Code § 21081(a)(1), Guidelines § 15091(a)(1). Facts in Support of Finding: The EIR discusses potential impacts regarding Hazards and Hazardous Materials in Section 4.5, which is incorporated herein by reference. The EIR determined that the development of past, present, and reasonably foreseeable future related projects would contribute to short-term and long-term cumulative effects related to hazards and hazardous materials. Individually each of the cumulative projects would be subject to technical evaluation and review by the respective jurisdictions regarding exiting potential hazards, the use, storage, and disposal of hazardous materials, and the potential to interfere with emergency response plans ox evacuation routes and would be required to comply with the respective jurisdictions' requirements and site-specific recommendations in order to adequately address potential effects related to existing hazards and potential hazards associated with future 29 development. With the incorporation of Mitigation Measures MM 4.5-1 and MM 4.5-2, the potential impacts of the proposed project would be less than significant or reduced to a less than significant level. In addition, the proposed project would not be anticipated to result in an impact related to the impairment of the City's ability to implement their Multi-Hazard Functional Plan or utilize the emexgency routes identified in the General Plan Safety Element. The EIR determined that with implementation of mitigation, the proposed project in conjunction with other past, present, and reasonably foreseeable future projects would not result in a significant cumulative impact related to hazards. Mitigation Measures: Mitigation Measures MM 4.5-1 and MM 4.5-2 are incorporated herein by reference as though fully set forth and shall be a condition of project approval. Reference: EIR Section 4.5. F. Hydrology and Water Quality 1.Environmental Impact: Violate Anv Water Quality Standards or Waste DischargLe Requirements. As discussed in Section 4.6 of the EIR, the proposed project would have a less than significant impact to water quality during construction activities and the ongoing operation of the proposed project and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to water quality during construction and the ongoing operation of the proposed project and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Hydrology and Water Quality in Section 4.6, which is incorporated herein by reference. The EIR determined that to the north of La Veta Avenue, the proposed project includes Best Management Practices (BMPs) to address water quality during the operation of the proposed project. To the south of La Veta Avenue,the proposed project does not provide for any changes to the surface drainage for the CHOC Commerce Tower and associated parking structure and parking lot, the CHOC nine-level employee paxking structure, and the access roadway. The EIR determined that the medical office building and associated parking proposed on the southwestern portion of the project site are at a conceptual design stage and no details regarding the building design and landscape design are proposed at this time. At the time of detailed planning, design, and development of the medical office building and associated parking occurs, the CHOC Master Plan WQMP would be amended or a new WQMP, in compliance with the current codes, would be submitted for review and approval. Upon compliance with local and state requirements, during construction activities, no significant short-term impact related to water quality would occur. The EIR determined the development of the proposed project would not violate any water quality standards or waste discharge requirements from stormwater runoff from construction or post-construction activities. No significant impact would occur and no mitigation is required. 30 Mitigation Measures: No mitigation is reqnired. Reference: EIR Section 4.6; Technical Appendix F. 2. Environmental Impact: Substantially Alter the Existing Drainage Pattern of the Site or Area Includin¢Throu h the Alteration of the Course of a Stream or River or Substantially Increase the Rate or Amount of Surface Runoff in a Manner Which Would Result in Floodin On- or Off-Site. As discussed in Section 4.6 of the EIR, the proposed project would have a less than significant impact related to the alteration of the existing drainage pattern of the project site and surrounding area and the potential to result in on-site or off-site flooding and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to the alteration of the existing drainage pattern of the project site and surrounding area and the potential to result in on-site or off-site tlooding and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Hydrology and Water Quality in Section 4.6, which is incorporated herein by reference. The EIR determined that the proposed project would result in a slight decrease in the rate and amount of stormwater runoff due to the decrease in the impervious surfaces and the use of the water quality devices on the project site which would discharge the runoff into the ground rather than the existing surface storm drainage system. The EIR determined that the development of the proposed project would not substantially alter the existing drainage pattern of the project site and would not alter the existing drainage pattern in the surrounding area. In addition, the proposed project would not increase the rate or amount of surface runoff discharge from the project site and, therefore, no on-site or off-site flooding would occur. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.6; Technical Appendix E. 3. Environmental Impact: Create or Contribute Runoff Water Which Would Exceed the Capacity of Existin¢ or Planned Storm Water Draina e Svstems or Provide Substantial Additional Sources of Polluted Runoff. As discussed in Section 4.6 of the EIR, the proposed project would have a less than significant impact related to the creation or contribution of surface runoff which would have the potential to exceed the capacity of the existing or planned stormwater drainage system or contribute substantial additional sources of polluted runoff and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to the creation or contribution of surface runoff which would exceed the capacity of the existing or planned stormwater drainage system or contribute substantial additional 31 sources of polluted runoff and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Hydrology and Water Quality in Section 4.6, which is incorporated herein by reference. The EIR determined that the proposed project would result in a decrease in the rate and amount of surface runoff due to the decrease in the impervious surface and the use of water control devices which would discharge the stormwater runoff into the ground rather than the surface storm drainage system. In addition, the structural and non-structural BMPs provided for the potential project would substantially reduce the potential for polluted surface runoff from the project site. The EIR determined that the proposed project would not create or contribute surface runoff which would exceed the capacity of the existing or planned stormwater drainage system or provide substantial additional sources of polluted runoff. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.6; Technical Appendix E. 4.Environmental Impact: Otherwise Substantiall Degrade Water Quality. As discussed in Section 4.6 of the EIR, the proposed project would have a less than significant impact related to otherwise substantially degrading water quality and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to otherwise substantially degrading water quality and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Hydrology and Water Quality in Section 4.6, which is incorporated herein by reference. The EIR determined that the project site is located within an urbanized area that is served by the Orange County Sanitation District (OCSD). The OCSD operates their facilities, including their wastewater treatment plants that would receive effluent from the proposed project, under a National Pollutant Discharge Elimination System(NPDES)pernut issued by the State Water Resources Control Board. Therefore, the treated wastewater from the proposed project would not degrade water quality. The structural and non-structural BMPs provided for the proposed project would substantially reduce the potential for polluted surface runoff from the project site. Construction impacts would be addressed through compliance with the State's General Construction Permits and the City's local codes. The EIR determined that the development of the proposed project would not substantially degrade water quality. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. 32 Reference: EIR Section 4.6; Technical Appendix F. 5.Environmental Impact: Potentiall mpact Stormwater Runoff from Post-Construction Activities. As discussed in Section 4.6 of the EIIt, the proposed project would have a less than significant impact due to stormwater runoff from post- construction activities and no mitigation is required. Finding: The proposed project would have no significant adverse effect due to stormwater runoff from post-construction activities and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Hydrology and Water Quality in Section 4.6, which is incorporated herein by reference. The EIR determined that to the north of La Veta Avenue, the proposed project includes BMPs to address water quality during the operation of the proposed project. To prevent the anticipated potential pollutants from entering the storm drainage system, the proposed project would provide an integrated water quality management system. The EIR determined that the proposed project's water quality management system would reduce water quality impacts from the ongoing operation of the portion of the proposed project to the north of La Veta Avenue to less than significant and no mitigation is required. To the south of La Veta Avenue, the proposed project does not provide for any changes to the surface drainage or treatment of stormwater for the CHOC Commerce Tower and associated parking structure and parking lot, the CHOC nine-level employee parking structure project, and access roadway. The medical office building and associated parking proposed on the southwestern portion of the project site are at a conceptual design stage and no details regarding the building design and landscape design are proposed at this time. At the time of detailed planning, design, and development of the medical office building and associated parking occurs, the CHOC Master Plan WQMP would be amended or a new WQMP, in compliance with the current codes, would be submitted for review and approval. Therefore, no potential impact to stormwater runoff is anticipated to occur from post-construction activities on the portion of the project site to the south of La Veta Avenue and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.6; Technical Appendix F. 6. Environmental Impact: Result in a Potential for Dischar e of Stormwater Pollutants From Areas of Material Stora L Vehicle or Eauinment Fuelin, Vehicle or Equipment Maintenance (Includin Washingl Waste Handlin, Hazardous Materials Handin or Storage Delive Area Loading Docks or Other Outdoor Work Areas. As discussed in Section 4.6 of the EIR, the proposed project would have a less than significant impact related to the discharge of stormwater pollutants from areas of material storage, vehicle or equipment fueling, vehicle or equipment maintenance, waste 33 handling, hazardous materials handling or storage, delivery area, loading docks, or other outdoor work areas and no mitigation is required. Finding: The proposed project would have no significant impact related to the discharge of stormwater pollutants from axeas of material storage, vehicle or equipment fueling, vehicle or equipment maintenance, waste handling, hazaxdous materials handling or storage, delivery area, loading docks, or other outdoor work areas and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Hydrology and Water Quality in Section 4.6, which is incorporated herein by reference. The EIR determined that the construction activities would not have areas of vehicle or equipment fueling, vehicle or equipment maintenance, including washing, hazardous materials storage, or loading docks. Prior to the issuance of grading permits for the proposed project, the applicant would file a Notice of Intent with the RWQCB indicating that the proposed project's construction activities would be in compliance with the conditions" of the Construction Activities General Permit. During construction activities, no significant impact would occur and no mitigation is required. The EIR determined that the proposed project does not have vehicle or equipment fueling areas, maintenance bays, or vehicle or equipment washing areas and these activities would not occur on the project site. The proposed project would provide an integrated water quality management system, structural BMPs, and non-structural BMPs to prevent the anticipated pollutants from entering the storm drainage system. The proposed project's water quality system would reduce water quality impacts from the on-going operation of the proposed project's development to the north of La Veta Avenue to a less than significant level and no mitigation is required. The EIR determined that the proposed project to the south of La Veta Avenue would not discharge storm water pollutants from areas of material storage, vehicle or equipment fueling, vehicle or equipment maintenance (including washing), waste handling, hazardous materials handling or storage, delivery areas, loading docks, or other outdoor work areas. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.6; Technical Appendix F. 7.Environmental Impact: Result in the Potential for Dischar of Stormwater to Affect the Beneficial Uses of the Receiving Waters. As discussed in Section 4.6 of the EIR, the proposed project would have a less than significant impact from the potential for the discharge of stormwater to affect the beneficial uses of the receiving waters and no mitigation is required. Finding: The proposed project would have no significant adverse effect from the potential for the discharge of stormwater to affect the beneficial uses of the receiving 34 waters and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Hydrology and Water Quality in Section 4.6, which is incorporated herein by reference. The EIR determined that the proposed project would result in a decrease in the rate and amount of surface runoff due to the decrease in the impervious surface and the use of water control devices which would discharge the stormwater runoff into the ground rather than the surface storm drainage system. In addition, the structural and non-structural BMPs provided for the potential project would substantially reduce the potential for polluted surface runoff from the project site. Stormwater runoff from the project site would not be anticipated to discharge polluted stormwater into the Santa Ana River and ultimately the Pacific Ocean. The EIR determined that the development of the proposed project would not result in the potential for the discharge of stormwater to affect the beneficial uses of the receiving waters that include water contact and non-water contact recreation, wildlife habitat, and warm water/freshwater habitat. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.6; Technical Appendix F. 8. Environmental Impact: Create the Potential for Significant Chan egsin the Flow Velocity or Volume of Stormwater Runoff to Cause Environmental Harm. As discussed in Section 4.6 of the EIR, the proposed project would have a less than significant impact due to the potential for significant changes in the flow velocity or volume of stormwater runoff and, therefore, cause environmental harm both on-site and off-site and no mitigation is required. Finding: The proposed project would have no significant adverse effects from the potential for significant changes in the flow velocity or volume of stormwater runoff and, therefore, cause environmental harm both o-site and off-site and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Hydrology and Water Quality in Section 4.6, which is ineorporated herein by reference. The EIR deternuned that there would be a reduction in the runoff rate in the proposed condition due to the implementation of the City's and County's BMPs. With the decrease in the volume of stormwater runoff, the stormwater runoff with the proposed project would not have an impact on the City and County storm drain systems. The EIR determined that the development of the proposed project would not create the potential for significant changes in the flow velocity or volume of stormwater runoff and, therefore would not cause environmental harm both on-site and'off-site. No impact would occur and no mitigation is required. 35 Mitigation Measures: No mitigation is required. Reference: EIR Section 4.6; Technical Appendix E. 9.Environmental Impact: Cumulative Effect. As discussed in Section 4.6 of the EIR, the proposed project would have a less than significant cumulative impact related to hydrology and water quality and no mitigation is required. Finding: The proposed project would have no significant cumulative effect related to hydrology and water quality and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Hydrology and Water Quality in Section 4.6, which is incorporated herein by reference. The EIR determined that the development of past, present, and reasonably foreseeable future related projects would contribute to cumulative effects on hydrology and water quality. Individually each of the cumulative projects would be subject to technical evaluation and review by the respective jurisdictions and would be required to comply with the respective jurisdictions' requirements related to hydrology and water quality. The proposed project would have a less than significant project-specific impact and not incrementally contribute to a potential cumulative impact related to hydrology and water quality. The EIR determined that the proposed project in conjunction with other past, present, or reasonably foreseeable future projects would not result in a significant cumulative impact and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.6. G. Land Use and Planning 1.Environmental Impacts: Conflict with Any A plicable Land Use Plan, Policy or Regulation of an Agency with Jurisdiction Over the Project Adopted for the Purpose of Avoiding or Mitigating an Environmental Effect. As discussed in Section 4.7 of the EIR, the proposed project would have a less than significant impact related to the City of Orange General Plan land use designations for the project site, the General Plan Update pending study area recommendations, and the applicable goals and policies of the General Plan Elements and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to the City of Orange General Plan land use designations for the project site, the General Plan iJpdate pending study area recommendations, and the applicable goals and policies of the General Plan Elements and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). 36 Facts in Support of Finding: The EIR discusses potential impacts regarding Land Use and Planning in Section 4.7, which is incorporated herein by reference. The EIR determined that the proposed project is consistent with the Land Use Element Map designations for the project site. No changes to the Land Use Element Map are required. The development of the proposed project would not conflict with the existing General Plan land use designations for the project site and is also consistent with the pending study area recommendations. The EIR determined that the proposed project would not conflict with the applicable goals and policies of the General Plan Elements. No impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.7. 2.Environmental Impacts: Conflict with Any A plicable Land Use Plan, Policy or Regulation of an A.gencv with Jurisdiction Over the Proiect Adopted for the Purpose of Avoiding or Miti an Environmental Effect. As discussed in Section 4.7 of the EIR, with the approval of the Zone Change, the proposed project would have a less than significant impact related to the zoning district designations for the project site and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to the zoning district designations for the project site and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Land Use and Planning in Section 4.7, which is incorporated herein by reference. The EIR determined that with the approval of the Zone Change, the proposed project would not conflict with the zoning district designations for the project site. No impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section.4.7. 3. Environmental Impact: Conflict with Anv A plicable Land Use Plan, Policv or Regulation of an A ency with Jurisdiction Over the Proiect Adopted for the Purpose of Avoidin or Miti ating an Environmental Effect. As discussed in Section 4.7 of the EIR, the proposed project would result in a less than significant impact related to a conflict with the City of Orange Tree Preservation Ordinance and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to a conflict with the City of Orange Tree Preservation Ordinance and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). 37 Facts in Support of Finding: The EIR discusses potential impacts regarding Land Use and Planning in Section 4.7, which is incorporated herein by reference. The EIR determined that with the development of the proposed project, there would be a net increase of 14 trees on or adjacent to the project site from the existing condition. Based upon the City's practice of requiring a 1:1 replacement ratio and requirements for a tree removal permit, the proposed project would not result in a conflict with the City of Orange Tree Preservation Ordinance. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.7. 4. Environmental Impact: Conflict with An pplicable Land Use Plan, Policy, or Regulation of an A ency with Jurisdiction Over the Project Adopted for the Purpose of Avoidin or Miti .gatin L an Environmental Effect. As discussed in Section 4.7 of the EIR, the proposed project would have a less than significant impact related to potential conflict with the Design Standards for the Amendment to the Southwest Project Area and no mitigation is required. Finding: The proposed project would have no significant adverse effect from potential conflict with the Design Standards for the Amendment to the Southwest Project Area and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Land Use and Planning in Section 4.7, which is incorporated herein by reference. The EIR determined that the architecture of the proposed CHOC South Tower would be consistent with the "urban contemporary" theme of the Thematic District. The proposed project would be considered a"large scale development"by the Design Standards since it includes a major development site and buildings over three stories in size that are designed to include or provide a self-contained atmosphere." The proposed project's design addresses the issues defined in the Design Standards for this category of development. The EIR determined that the development of the proposed project is not anticipated to conflict with the Design Standards for the Amendment to the Southwest Project Area. No impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.7. Ss Environmental Impact:_ Conflict with Anv Applicable Land Use Plan, Policv, or Regulation of an A encv with Jurisdiction Over the Project Adopted for the Purpose of Avoiding or Mitigating an Environmental Effect. As discussed in Section 4.7 of the EIR, the proposed project would have a less than significant impact related to 38 potential conflict with the applicable policies of the Southern California Association of Governments (SCAG) Regional Comprehensive Plan and Guide (RCPG) and no mitigation is required. Finding: The proposed project would have no significant adverse effect from potential conflict with the applicable policies of the SCAG RCPG and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Land Use and Planning in Section 4.7, which is incorporated herein by reference. The EIR determined that the proposed project would provide short-term and long-term employment opportunities in an urbanized area with existing infrastructure and access to the local and regional transportation system. The proposed project would be located on a project site that has no natural resources with the exception of trees. Due to its urbanized setting, the development and ongoing operation of the proposed project would result in fewer environmental impacts than if it were developed on vacant or less developed land in the City. The EIR determined that the development of the proposed project would not conflict with the applicable policies of the SCAG RCPG. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.7. 6. Environmental Impact: Conflict with An pplicable Land Use Plan, Policy or Regulation of an Agency with Jurisdiction Over the Proiect Adopted for the Purpose of Avoidin or Mitigatin an Environmental Effect. As discussed in Section 4.7 of the EIR, the proposed project would have a less than significant impact related to conflict with the policies of the Regional transportation Plan (RTP) and no mitigation is required. Finding: The proposed project would have no significant adverse effect from potential conflict with the policies of the RTP and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Land Use and Planning in Section 4.7, which is incorporated herein by reference. The EIR determined that the project site has been previously developed and existing uses are served by regional and local transportation facilities. The proposed project provides for the use of non-vehicular transportation and access to existing transit facilities is available in close proximity to the project site. The development of the proposed project would not conflict with the policies of the RTP. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. 39 Reference: EIR Section 4.7. 7.Environmental Impact: Cumulative Effect. As discussed in Section 4.7 of the EIR, the proposed project would have a less than significant cumulative impact related to land use and planning and no mitigation is required. Finding: The proposed project would have no significant adverse cumulative effect related to land use and planning and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regaxding Land Use and Planning in Section 4.7, which is incorporated herein by reference. The EIR determined that individually, the past, present, and reasonably foreseeable future related projects would be expected to occur in accordance with the adopted plans and policies of the City of Orange and the City of Santa Ana. The proposed project would not result in a significant impact related to land use and planning. The EIR determined that the proposed project in conjunction with past, present, or reasonably foreseeable future projects would result in a less than significant impact related to land use and planning and no mitigation is required. Mitfgation Measures: No mitigation is required. Reference: EIR Section 4.7. H. Noise 1.Environmental Impact: Exposure of Persons to or Generation of Noise Levels in Excess of Standards Established in the General Plan or Noise Ordinance, or Applicable Standards of Other A e ncies. As discussed in Section 4.8 of the EIR, the proposed project would result in a less than significant impact due to noise levels from off-site construction traffic using the haul routes and no mitigation is required. Finding: The proposed project would have no significant adverse effect due to noise levels from off-site construction traffic using the haul routes and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Findings: The EIR discusses potential impacts regarding Noise in Section 4.8, which is incorporated herein by reference. The EIR determined that during the construction activities for the proposed project, the noise levels due to off-site construction traffic from the use of the haul routes would not exceed the City's noise standards. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.8; Technical Appendix G. 40 2. Environmental Impact: Exposure of Persons to or Generation of Noise Levels in Excess of Standards Established in the General Plan or Noise Ordinance, or Apnlicable Standards of Other A e ncies. A discussed in Section 4.8 of the EIR, the proposed project would have a less significant adverse impact due to noise levels at nearby sensitive receptors as a result of the on-site construction activities in combination with the off-site construction-related traffic despite the implementation of the mitigation required in EIR No. 1805-08. Finding: Changes or alterations have been required in or incorporated into, the proposed project which lessens the significant environmental effect regarding the increase in noise levels at nearby sensitive receptors as a result of on-site construction activities in combination with off-site construction-related traffic. These changes or alterations, however, will not reduce this impact to below a level of significance, and that specific economic, social, technological or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the EIR, as discussed in Section IX of these findings. As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because of specific overriding considerations. Public Resources Code § 21081(a)(3), Guidelines § 15091(a)(3). Facts in Support of Findings: The EIR discusses potential impacts regarding Noise in Section 4.8, which is incorporated herein by reference. The EIR determined that during the construction activities for the proposed project, the noise levels at nearby sensitive receptors as a result of the on-site construction activities in combination with the off-site construction-related traffic would exceed the City's noise standards and would be considered a significant impact. The EIR determined that, with implementation of Mitigation Measure MM 4.8-1, this impact would remain a significant unavoidable adverse impact. Mitigation Measures: Mitigation Measure MM 4.8-1 is incorporated herein by reference as though fully set forth and shall be conditions of project approval. Reference: EIR Section 4.8. 3. Environmental Impact: Exposure of Persons to or Generation of Noise Levels in Excess of Standards Established in the General Plan or Noise Ordinance, or Applicable Standards of Other A e ncies. As discussed in Section 4.8 of the EIR, the proposed project would have a less than significant impact from noise levels due to the project-related traffic along the study area roadway segments for the Cumulative 2012 with Project Phase 1 Conditions, the Cumulative 2015 with Project Phases 1 and 2 Conditions, the Cumulative 2020 with Project Buildout (Phases 1, 2, and 3) Conditions, and the Cumulative 2030 with Project Conditions and no mitigation is required. 41 Finding: The proposed project would have no significant adverse effect from noise levels due to the project-related traffic along the study area roadway segments for the Cumulative 2012 with Project Phase 1 Conditions, the Cumulative 2015 with Project Phase 1 and 2 Conditions,the Cumulative 2020 with Project Buildout (Phases 1, 2, and 3) Conditions, and the Cumulative 2030 with Project Conditions and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Findings: The EIR discusses potential impacts regarding I oise in Section 4.8, which is incorporated herein by reference. The EIR determined that for the Cumulative 2012 with Project Phase 1 Conditions, the Cumulative 2015 with Project Phases 1 and 2 Conditions, the Cumulative 2020 with Project Buildout (Phases 1, 2, and 3) Conditions, and the Cumulative 2030 with Project Conditions, no long-term significant off-site noise impact from project-related traffic would occur along the study area roadways segments and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.8; Technical Appendix G. 4.Environmental Impact: Exposure of Persons to or Generation of Noise Levels in Excess of Standards Established in the General Plan or Noise Ordinance, or Avplicable Standards of Other A egncies. As discussed in Section 4.8 of the EIR, the proposed project would have a less than significant impact at the nearby sensitive receptors from the on-site stationary noise sources during ongoing operations and no mitigation is required. Finding: The proposed project would have no significant adverse effect at the nearby sensitive receptors from the on-site stationary noise sources during ongoing operations and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Findings: The EIR discusses potential impacts regarding Noise in Section 4.8, which is incorporated herein by reference. The EIR determined that the ongoing operation of the proposed project would not result in a significant impact from on-site stationary noise sources at any of the nearby sensitive receptors and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.8; Technical Appendix G. 5.Environmental Impact: Exposure of Persons to or Generation of Noise Y.evels in Excess of Standards Established in the General Plan or Noise Ordinance, or Annlicable Standards of Other A e. As discussed in Section 4.8 of the EIR, the proposed project would have a less than significant impact from noise levels in the 42 interior of the building on the project site from the combined traffic-related noise and on- site stationary noise sources during ongoing operations and no mitigation is required. Finding: The proposed project would have no significant adverse effect from noise levels in the interior of the building on the project site from the combined traffic- related noise and on-site stationary noise sources during ongoing operations and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Findings: The EIR discusses potential impacts regarding Noise in Section 4.8,which is incorporated herein by reference. The EIR determined that the ongoing operation of the proposed project would not result in a long-term significant impact from the combined traffic-related noise and on-site stationary noise sources in the interior of the buildings on the project site. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.8; Technical Appendix G. 6. Environmental Impact: Exposure of Persons to or Generation of Excessive Groundborne Vibration or Groundborne Noise Levels. As discussed in Section 4.8 of this EIR, the proposed project would have a short-term significant adverse impact to the existing on-site CHOC North Tower during the demolition activities due to on-site groundborne vibration and groundborne noise levels despite the implementation required in EIR No. 1805-08. Finding: Specific economic, social, technological, or other consideration, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the EIR, as discussed in Section IX of these findings. As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because of specific overriding considerations. Public Resources Code § 21081(a)(3), Guidelines § 15091(a)(3). Facts in Support of Finding: The EIR discusses potential impacts regarding Noise in Section 4.8, which is incorporated herein by reference. The EIR determined that the closest land use potentially impacted from the vibration during the construction activities would be the existing CHOC North Tower located on the project site adjacent to the structure to be demolished. It is anticipated that the vibration levels caused by a jackhammer operating at the edge of the CHOC North Tower would exceed the threshold of significance. The demolition phase for the proposed project would result in the exposure of people on-site to groundborne vibration and groundborne noise levels and a short-term significant impact would occur. The EIR determined that there is no feasible mitigation and this impact would remain a significant unavoidable adverse impact. Mitigation Measures: No mitigation is feasible. 43 Reference: EIR Section 4.8; Technical Appendix G. 7.Environmental Impact: Exposure of Persons to or Generation of Excessive Groundborne Vibration or Groundborne Noise Levels. As discussed in Section 4.8 of this EIR, the proposed project would have a short-term significant adverse impact to off-site sensitive receptors during the demolition activities due to groundborne vibration and groundborne noise levels and no mitigation is required. Finding: The proposed project would have no short-term significant adverse effect to off-site sensitive receptors during the demolition activities due to groundborne vibration and groundborne noise levels and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Noise in Section 4.8, which is incorporated herein by reference. The EIR determined that the closest off-site sensitive receptor that could potentially be impacted from the vibration during the construction activities would be St. Joseph Hospital, located approximately 80 feet east of the demolition area. At this distance, a jackhammer would produce a vibration level which would be below the threshold of significance. The EIR determined that the demolition phase for the proposed project would not result in the exposure of persons at off-site land uses, including St. Joseph Hospital, to excessive groundborne vibration or groundborne noise. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.8; Technical Appendix G. 8. Environmental Impact: Exposure of Persons to or Generation of Excessive Groundborne Vibration or Crroundborne Noise Levels. As discussed in Section 4.8 of the EIR, the proposed project would have a long-term less than significant impact as a result of groundborne vibration or groundborne noise levels from trucks traveling on Pepper Street and La Veta Avenue and no mitigation is required. Finding: The proposed project would have no long-term significant adverse effects as a result of groundborne vibration or groundborne noise levels from trucks traveling on Pepper Street and La Veta Avenue and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Noise in Section 4.8, which is incorporated herein by reference. The EIR determined that there are no activities that would occur on the project site that would cause vibration. However, the buildings on the project site may be impacted by vibration caused by trucks traveling along South Pepper Street, West Providence Avenue, South Main Street, and West La Veta Avenue. The buildings that have the most potential to be affected by 44 vibration are the CHOC North Tower which is approximately 15 feet from the nearest lane on South Pepper Street and the CHOC South Tower which is approximately 25 feet from the nearest travel lane on La Veta Avenue. The EIR determined that the vibration level would be below the threshold of significance. Therefore, the ongoing operation of the proposed project would not result in the exposure of persons on the project site to excessive groundborne vibration or groundborne noise levels. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.8; Technical Appendix G. 9. Environmental Impact: A Substantial Permanent Increase in Ambient Noise Levels in the Project Vicinity Above Levels Existing Without the Pronosed Project. As discussed in Section 4.8 of the EIR, the proposed project would have a less than significant impact due to a substantial permanent.increase in the ambient noise levels in the project vicinity above the noise levels without the proposed project and no mitigation is required. Finding: The proposed project would have no significant adverse effect due to a substantial permanent increase in the ambient noise levels in the project vicinity above the noise levels without the proposed project and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Noise in Section 4.8, which is incorporated herein by reference. The EIR determined that the ongoing operation of the proposed project would not result in a significant off-site noise impact from the project-related traffic along the study area roadway segments. In addition, the ongoing operation of the proposed project would not result in a long-term significant impact from on-site stationary noise sources at any nearby sensitive receptors. Further, the ongoing operation of the proposed project would not result in a long-term significant impact from the combined traffic-related noise and on-site stationary noise sources at any of the nearby sensitive receptors or in the interior of the buildings on the project site. The EIR determined that the ongoing operation of the proposed project would not result in a substantial permanent increase in the ambient noise levels in the project vicinity above the noise levels existing without the proposed project. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.8; Technical Appendix G. 10. Environmental Impact: A Substantial Tempora or Periodic Increase in Ambient Noise Levels in the Pr ect Vicinitv Above Levels Existin Without the Proposed Project. As discussed in Section 4.8 of the EIR, the proposed project would 45 have a short-term less than significant impact due to the use of the haul routes on the roadways in the project vicinity during construction activities and no mitigation is required. Finding: The proposed project would have no significant adverse effect due to the use of the haul routes on the roadways in the project vicinity during construction activities and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Findings: The EIR discusses potential impacts regarding Noise in Section 4.8., which is incorporated herein by reference. The EIR determined that during the construction activities for the proposed project, the noise levels from the use of the haul routes would not exceed the City's noise standaxds and no significant impact would occur. The EIR determined that the use of the haul routes on the roadways in the project vicinity during the construction activities for the proposed project would not result in a substantial temporary or periodic increase in ambient noise levels in the project vicinity above the noise levels existing without the proposed project. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.8; Technical Appendix G. 11. Environmental Impact: A Substantial Temporary or Periodic Increase in Ambient Noise Levels in the Project Vicinity Above Levels Existing Without the Proposed Project. As discussed in Section 4.8 of the EIR, the proposed project would have a significant adverse impact due to noise levels at nearby sensitive receptors as a result of the on-site construction activities in combination with the off-site construction- related traffic despite the implementation of mitigation required in EIR No. 1805-08. Finding: Changes or alterations have been required in, or incorporated into, the proposed project which lessen the significant environmental effect regarding the increase in noise levels at nearby sensitive receptors as a result of on-site construction activities in combination with off-site construction-related traffic. These changes or alterations, however, will not reduce this impact to below a level of significance, and that specific economic, social, technological or other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the EIR, as discussed in Section IX of these findings. As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because of specific overriding considerations. Public Resources Code § 21081(a)(3), Guidelines § 15091(a)(3). Facts in Support of Findings: The EIR discusses potential impacts regarding Noise in Section 4.8, which is incorporated herein by reference. The EIR determined that during the construction activities for the proposed project, the noise levels at nearby 46 sensitive receptors as a result of the on-site construction activities in combination with the off-site construction-related traffic would exceed the City's noise standards and would be considered a significant impact. Therefore, the on-site construction activities in combination with the off-site construction-related traffic for the proposed project would result in a substantial or periodic increase in ambient noise levels in the project vicinity above the noise levels existing without the proposed project. The EIR determined that, with implementation of Mitigation Measure MM 4.8-1, this impact would remain a significant unavoidable adverse impact. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.8; Technical Appendix G. I. Population and Housing 1. Environmental Impact: Induce Substantial Population Growth in the Project Area. As discussed in Section 4.9 of the EIR, the proposed project would have a less than significant impact related to inducement of substantial population growth in the City or the surrounding area and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to inducement of substantial population growth in the City or the surrounding area and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Population and Housing in Section 4.9, which is incorporated herein by reference. The EIR determined that the construction activities for the proposed project would not result in employment that would induce substantial population growth in the City or the surrounding area. Based on the City's projected population of 151,910 in the year 2020, the 1,454 "worst-case residents" as a result of the proposed project would only represent 0.96 percent of the City's population. This would not be considered a significant increase in population in the City. Therefore, the ongoing operation of the proposed project would not directly induce substantial population growth in the City and no significant impact would occur and no mitigation is required. The EIR determined that the proposed project would not indirectly induce population growth in the area through the extension of existing roadways or infrastruciure. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.9. 2.Environmental Impact: Cumulative Impact. As discussed in Section 4.9 of the EIR, the proposed project would have a less than significant cumulative impact related to population and no mitigation is required. 47 Finding: The proposed project would have no significant cumulative effect related to population and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Population and Housing in Section 4.9, which is incorporated herein by reference. The EIR deternuned that the development of past, present, and reasonably foreseeable future related projects would contribute to a cumulative effect on population in the City of Orange and the City of Santa Ana. Individually, each of these cumulative projects would be subject to environmental review and evaluation by the respective jurisdictions and would be required to comply with the respective jurisdictions' requirements related to population growth. The proposed project would not induce substantial population growth in the City, either directly or indirectly. The EIR determined that the proposed project in conjunction with other past, present, and reasonably foreseeable future projects would not result in a significant cumulative impact related to population and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.9. J. Public Services 1.Environmental Impacts: Result in Substantial Adverse Phvsical Impacts Associated With the Provision of or Need for New or Phvsicallv Altered Governmental Facilities, the Construction of Which Could Cause Significant Environmental Impacts, in Order to Maintain Acceptable Service Ratios, Response Times or Other Performance Objective Related to Fire Protection. As discussed in Section 4.10 of the EIR, the proposed project would have a less than significant impact related to the need for new or expanded fire protection facilities and the provision of fire protection facilities and would not result in substantial adverse physical impacts associated with the need for new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts in order to maintain acceptable service ratios, response times, or other performance objectives and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to the need for new or expanded fire protection facilities and the provision of fire protection facilities and would not result in substantial adverse physical impacts associated with the need for new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts in order to maintain acceptable service ratios, response times, or other performance objectives and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Public Services in Section 4.10, which is incorporated herein by reference. The EIR 48 determined that during the construction of the proposed project, the addition of construction workers and the on-site activities, including the use of construction equipment, the construction activities, and the short-term storage of materials, have the potential to increase the number of responses to the project site by the Fire Department. This would also have the potential to temporarily affect access and, therefore, response times by the Fire Department to the project site. This would not result in the need for new or expanded fire protection facilities and no impact would occur. The ongoing operation of the proposed project would have the potential to result in an increase in call volume for emergency services to the project site and vicinity and, therefore, have the potential to result in the need for additional equipment and staffing in order to maintain the response times and level of service currently provided by the Fire Department. Compliance with Orange Municipal Code Chapter 15.38 would reduce the proportional effects of the proposed project related to the provision of adequate fire protection services. The ongoing operation of the proposed project would result in a long-term less than significant impact related to the provision of fire protection services. Fire protection services would continue to be provided from existing fire stations in the City. The EIR determined that the proposed project would not result in substantial adverse physical impacts associated with the need for new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts in order to maintain acceptable service ratios, response times, or other performance objectives. No impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.10. 2. Environmental Impacts: Result in Substantial Adverse Physical Impacts Associated With the Provision of or Need for New or Phvsicallv Altered Governmental Facilities the Construction of Which Could Cause Si¢nificant Environmental Impacts, m Order to Maintain Acceptable Service Ratios Response Times or Other Performance Objective Related to Police Protection. As discussed in Section 4.10 of the EIR, the proposed project would have a less than significant impact related to the need for new or expanded police protection facilities and the provision of police protection services and would not result in substantial adverse physical impacts associated with the need for new or physically altered police protection facilities, the construction of which could cause significant environmental impacts in order to maintain acceptable service ratios, response times, or other performance objectives and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to the need for new or expanded police protection facilities and the provision of police protection services and would not result in substantial adverse physical impacts associated with the need for new or physically altered police protection facilities, khe construction of which could cause significant environmental impacts in order to maintairn 49 acceptable service ratios, response times, or other performance objectives and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Public Services in Section 4.10, which is incorporated herein by reference. The EIR determined that during the construction of the proposed project, the addition of construction workers and the on-site activities have the potential to increase the number of responses to the project site and on the surrounding roadways by the Police Department. This would also have the potential to temporarily affect access and, therefore, response times by the Police Department to the project site and vicinity. This would not result in the need for new or expanded police protection facilities and no impact would occur. The ongoing operation of the proposed project would have the potential to result in an increase in call volume for police protection services to the project site and on the roadways in the project viciniiy and, therefore, have the potential to result in the need for additional equipment and staffing in order to maintain the response times and level of service provided by the Police Department. Compliance with Orange Municipal Code Chapter 3.13 would reduce the proportional effects of the proposed project related to the provision of adequate police protection services. The ongoing operation of the proposed project would result in a long-term less than significant impact related to the provision of police protection services. Police protection services would continue to be provided from the existing Police Headquarters in the City. The EIR determined that the proposed project would not result in substantial adverse physical impacts associated with the need for new or physically altered police protection facilities, the construction of which could cause significant environmental impacts in order to maintain acceptable service ratios, response times, or other performance objectives. No impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.10. 3.Environmental Impacts: Cumulative Effects. As discussed in Section 4.10 of the EIR, the proposed project would have a less than significant cumulative impact related to fire protection and police protection services. Finding: The proposed project would have no significant cumulative adverse effect related to fire protection and police protection services. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference. The EIR deternuned that the development of past, present, and reasonably foreseeabYe future related projects would contribute to a cumulative effect on fire protection and police protection services. Individually, each of the cumulative projects would be 50 individually subject to technical evaluation and review by the respective jurisdictions and would be required to comply with the respective jurisdictions' requirements related to public services. The proposed project's potential impacts related to fire protection and police protection services would be less than significant and no mitigation is required. The EIR determined that the proposed project in conjunction with other past, present, or reasonably foreseeable future projects would result in a less than significant cumulative impact related to fire protection and police protection services and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIIZ Section 4.10. K. Transportation and Traffic 1. Environmental Impact: Cause an Increase in Traffic which is Substantial in Relation to the Existin Traffic Load and Capacity of the Street Svstem. As discussed in Section 4.11 of the EIR, during the demolition phase of the construction activities for the proposed project, the construction trips traveling to and from the project site would have a less than significant impact to the study area intersections or West La Veta Avenue between South Main Street and South Pepper Street and no mitigation is required. Finding: The proposed project would have no significant adverse effect from construction trips during the demolition phase to the study area intersections or West La Veta Avenue between South Main Street and South Pepper Street and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference. The EIR determined that during the demolition phase of the construction activities for the proposed project, the construction trips traveling to and from the project site would have a less than significant impact to the study area intersections or West La Veta Avenue between South Main Street and South Pepper Street and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.1 l; Technical Appendix H. 2. Environmental Impact: Cause an Increase in Traffic which is Substantial in Relation to the Existin Traffic Load and Capacitv of the Street Svstem. As discussed in Section 4.11 of the EIR, during the excavation and grading phase of Yhe construction activities for the proposed project, the construction trips traveling to anc from the project site would have a less than significant impact to the study area 51 intersections or West La Veta Avenue between South Main Street and South Pepper Street and no mitigation is required. Finding: The proposed project would have no significant adverse effect from construction trips during the excavation and grading phase to the study area intersections or West La Veta Avenue between South Main Street and South Pepper Street and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference. The EIR determined that during the excavation and grading phase of the construction activities for the proposed project, the construction trips traveling to and from the project site would have a less than significant impact to the study area intersections or West La Veta Avenue between South Main Street and South Pepper Street and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.11; Technical Appendix H. 3.Environmental Impact: Cause an Increase in Traffic which is Substantial in Relation to the Existin Traffic Load and Capacitv of the Street Svstem. As discussed in Section 4.11 of the EIR, during the building construction phase of the construction activities for the proposed project, the construction trips traveling to and from the proj ect site would have a less than significant impact to the study area intersection of West La Veta Avenue between South Main Street and South Pepper Street and no mitigation is required. Finding: The proposed project would have no signif cant adverse effect from construction trips during the building construction phase to the study area intersections or West La Veta Avenue between South Main Street and South Pepper Street and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference. The EIR determined that during the building construction phase of the construction activities for the proposed project, the construction trips traveling to and from the project site would have a less than significant impact to the study area intersection of West La Veta Avenue between South Main Street and South Pepper Street and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.11; Technical Appendix H. 52 4.Environmental Impact: Cause an Increase in Traffic which is Substantial in Relation to the Existin Traffic Load and Capacitv of the Street Svstem. As discussed in Section 4.11 of the EIR, the proposed project would result in a less than significant impact to the study area intersections for the Cumulative (2012) plus Project Phase 1 Conditions and no mitigation is required. Finding: The proposed project would have no significant adverse effect to the study area intersections for the Cumulative (2012) plus Project Phase 1 Conditions and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference. The EIR determined that the study area intersections would continue to operate at an acceptable LOS (LOS D or better) with the addition of traffic from Phase 1 of the proposed project. The EIR determined that no significant impact would occur to the study area intersections for the Cumulative (2012) plus Project Phase 1 Conditions and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.11; Technical Appendix H. 5. Environmental Impact: Cause an Increase in Traffic which is Substantial in Relation to the Existin Traffic Load and Capacitv of the Street Svstem. As discussed in Section 4.11 of the EIR, the proposed project would result in a less than significant impact to the study area intersections for the Cumulative (2012) plus Project Phases 1 and 2 Conditions and no mitigation is required. Finding: The proposed project would have no significant adverse effect to the study area intersections for the Cumulative (2012)plus Project Phases 1 and 2 Conditions and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference. The EIR determined that the study area intersections would continue to operate at an acceptable LOS (LOS D or better) with the addition of traffic from Phases 1 and 2 of the proposed project. The EIR determined that no significant impact would occur to the study area intersections for the Cumulative (2012) plus Project Phases 1 and 2 Conditions and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.11; Technical Appendix H. 53 6.Environmental Impact: Cause an Increase in Traffic which is Substantial in Relation to the Existin Traffic Load and Capacitv of the Street Svstem. As discussed in Section 4.11 of the EIR, the proposed project would result in a less than significant impact to the study area intersections for the Cumulative (2020) plus Project Buildout (Phases 1, 2, and 3) Conditions and no mitigation is required. Finding: The proposed project would have no significant adverse effect to the study area intersections for the Cumulative (2020)plus Project Buildout(Phases 1, 2, and 3) Conditions and no mitigation is required. Public Resources Code § 21081, Guidelines 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference. The EIR determined that the study area intersections would continue to operate at an acceptable LOS (LOS D or better) with the addition of traffic from buildout of the proposed project (Phases 1, 2, and 3). The EIR determined that no significant transportation impact would occur for the Cumulative (2020) plus Project Buildout Phases 1, 2, and 3) Conditions and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.11; Technical Appendix H. 7.Environmental Impact: Cause an Increase in Traffic which is Substantial in Relation to the Existing Traffic Load and Capacitv of the Street Svstem. As discussed in Section 4.11 of the EIR, the proposed project would have a significant adverse impact at the intersection of South Main Street/West La Veta Avenue for the General Plan(2030)with Project Condition. Finding: Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the EIR, as discussed in Section IX of these findings. As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because of specific overriding considerations. Public Resources Code § 21081(a)(3), Guidelines § 15091(a)(3). Facts in 5upport of Finding: The EIR discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference. The EIR determined that if an intersection is operating at LOS E or F (greater than 0.90 v/c) and a project increases the volume-to-capacity (v/c) ratio equal to or greater than 0.010 volume-to-capacity (v/c), then the project causes a significant impact. The change in ICU at the intersection of South Main StreetJWest La Veta Avenue would be 0.01 v/c at LOS E during the P.M. peak hour. The proposed project would contribute to a significant impact at this intersection in the General Plan (2030) with Project Conditions. Since this intersection would be constructed to its ultimate configuration in the General 54 Plan (2030) Conditions and no additional improvements would be feasible due to right- of-way constraints, there is no feasible mitigation. This impact would be a significant unavoidable cumulative adverse impact. Mitigation Measures: No mitigation is feasible. Reference: EIR Section 4.11; Technical Appendix H. 8. Environmental Impact: Cause an Increase in Traffic which is Substantial in Relation to the Existin Traffic Load and Capacitv of the Street Svstem. As discussed in Section 4.11 of the EIR, the proposed project would have a significant adverse impact at four study area intersections (North Main Street/Edgewood Lane (I-5 northbound off- ramp/HOV on-ramp), North Main Street/West Santa Clara Avenue (I-5 northbound on- ramp), North Main Street/West Buffalo Avenue (I-5 southbound on-ramp), and SR-22 eastbound ramps/West Town and Country Road). Finding: Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the alternatives identified in the EIR, as discussed in Section IX of these findings. As described in the Statement of Overriding Considerations, the City has determined that this impact is acceptable because of specific overriding considerations. Public Resources Code § 21081(a)(3), Guidelines § 15091(a)(3). Facts in Support of Finding: The EIR discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference. The EIR determined that the following four study area intersections are forecast to operate at an unsatisfactory LOS (LOS D or worse) during the A.M. and P.vt. peak hour without the proposed project: North Main Street/Edgewood Lane during the Cumulative 2012, 2015, and 2020) Conditions and the General Plan (2030) Conditions; North Main Street/West Santa Clara Avenue during the Cumulative (2012, 2015, and 2020) Conditions and the General Plan (2030) Conditions; North Main StreetBuffalo Avenue during the Cumulative (2020) Conditions and the General Plan (2030) Conditions; and SR-22 eastbound ramps/West Town and Country Road during the Cumulative (2020) Conditions. The proposed project would contribute trips to these four study area intersections that are projected to operate at an unacceptable LOS (LOS D or worse) for the Cumulative Conditions utilizing the Caltrans methodology. The EIR determined that the proposed project would result in an incremental contribution to a significant cumulative impact at these four intersections. This would be a significant unavoidable adverse cumulative impact. Mitigation Measures: No mitigation is feasible. Reference: EIR Section 4.11; Technical Appendix H. 55 9.Environmental Impact: Cause an Increase in Traffic which is Substantial in Relation to the Existin Traffic Load and Capacitv of the Street Svstem. As discussed in Section 4.11 of the EIR, the proposed project would result in a less than significant impact to the circulation system as a result of the vehicle queuing for the driveways on South Pepper Street and no mitigation is required. Finding: The proposed project would have no significant adverse effect to the circulation system as a result of the vehicle queuing for the driveways on South Pepper Street and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference. The EIR determined that based on the results of the queuing analysis, the location and configuration of the driveways along the west side of South Pepper Street would not cause a significant impact to the circulation system as a result of the vehicles generated by the proposed project queuing and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.11; Technical Appendix H. 10. Environmental Impact: Cause an Increase in Traffic which is Substantial in Relation to the Existin Traffic Load and Capacity of the Street Svstem. As discussed in Section 4.11 of the EIR, the proposed project would result in a less than significant impact related to the vehicle queuing in the southbound left-turn pocket at the intersection of South Main Street/CHOC Court with the implementation of the mitigation required in EIR No. 1805-08. Finding: Changes or alterations have been required in, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effects related to the vehicle queuing in the southbound left-turn pocket at the intersection of South Main Street/CHOC Court to below a level of significance. Public Resources Code 21081(a)(1), Guidelines § 15091(a)(1). Facts in Support of Finding: The EIR discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference. The EIR determined that based on the results of the queuing analysis, the maximum vehicle queuing length for the southbound left-turn lane at the intersection of South Main Street/CHOC Court would be 343 feet in the a.m. peak hour and 139 feet in the p.m. peak hour. Therefore, the maximum vehicle queue at the intersection would extend beyond the existing length of the southbound left-turn pocket that is 100 feet with a 40-foot transition. This would be considered a significant impact. The EIR determined that, with the implementation of Mitigation Measure MM 4.11-1 (extend southbound left-turra lane),this impact would be less than significant. 56 Mitigation Measures: Mitigation Measure MM 4.11-1 is incorporated herein by reference as though fully set forth and shall be a condition of project approval. Reference: EIR Section 4.11; Technical Appendix H. 11. Environmental Impact: Exceed Either Individuallv or Cumulativelv, a Level of Service Standard Established by the Countv Con estion Mana ement Agencv for Desi nated Roads or Hi ng ways. As discussed in Section 4.11 of the EIR, the proposed project would result in a less than significant impact related to the exceedance of a level of service standard for Congestion Management Program (CMP) intersections or roadways and no mitigation is required. Finding: The proposed project would have no significant adverse effect from exceedance of a level of service standard for Congestion Management Program (CMP) intersections or roadways and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference. The EIR determined that within the project study area, the study area intersections analyzed axe not identified as Congestion Management Program (CMP) intersections or roadways. The closest CMP facility is Katella Avenue, located north of the project site outside of the study area. The EIR determined that the proposed project would not result in traffic that would exceed, either individually or cumulatively, a level of service established by the Congestion Management Program for CMP intersections or roadways. No impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.11; Technical Appendix H. 12. Environmental Impact: Substantiall Increase Hazards Due to a DesiQn Feature or Incompatible Uses. As discussed in Section 4.11 of the EIR, the proposed project would result in a less than significant impact related to an increase in hazards due to a design feature or incompatible uses on or adjacent to the project site and no mitigation is required. Finding: The proposed project would have no significant adverse effect from an increase in hazards due to a design feature or incompatible uses on or adjacent to the project site and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a), Facts in Support of Finding: The EIR discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference. The EIR determined that the proposed project would not significantly increase hazards 57 due to a design feature or incompatible uses provided on or adjacent to the project site. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.11; Technical Appendix H. 13. Environmental Impacts: Substantially Increase Hazards Due to a Desi n Feature or Incompatible Uses. As discussed in Section 4.11 of the EIR, the proposed project would result in a less than significant impact to the circulation system as a result of the vehicle queuing for the driveways on South Pepper Street and no mitigation is required. Finding: The proposed project would have no significant adverse effect to the circulation system as a result of the vehicle queuing for the driveways on South Pepper Street and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in 5upport of Finding: The EIR discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference. The EIR determined that based on the results of the queuing analysis, the location and configuration of the driveways along the west side of South Pepper Street would not' cause a significant impact to the circulation system as a result of the vehicles generated by the proposed project queuing and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.11; Technical Appendix H. 14. Environmental Impact: Substantially Increase Hazards Due to a Desi n Feature or Incompatible Uses. As discussed in Section 4.11 of the EIR, the proposed project would result in a less than significant impact related to the vehicle queuing in the southbound left-turn pocket at the intersection of South Main Street/CHOC Court with the implementation of the mitigation required in EIR No. 1805-08. Finding: Changes or alterations have been required in, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effects related to the vehicle queuing in the southbound left-turn pocket at the intersection of South Main StreebCHOC Court to below a level of significance. Public Resources Code 21081(a)(1), Guidelines § 15091(a)(1). Facts in 5upport of Finding: The EIR discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference, The EIR determined that based on the results of the queuing analysis, the maximum vehicle queuing length for the southbound left-turn lane at the intersection of South Main 58 Street/CHOC Court would be 343 feet in the a.m. peak hour and 139 feet in the p.m. peak hour. Therefore, the maximum vehicle queue at the intersection would extend beyond the existing length of the southbound left-turn pocket that is 100 feet with a 40-foot transition. This would be considered a significant impact. The EIR determined that, with the implementation of Mitigation Measure MM 4.11-1 (extend southbound left-turn lane),this impact would be less than significant. Mitigation Measures: Mitigation Measure MM 4.11-1 is incorporated herein by reference as though fully set forth and shall be a condition of project approval. Reference: EIR Section 4.11; Technical Appendix H. 15. Environmental Impact: Result in Inadequate Emer Lncv Access. As discussed in Section 4.11 of the EIR, the proposed project would result in a less than significant impact related to emergency access due to lane closures and the addition of construction-related vehicles on the adjacent roadways with the implementation of the mitigation required in EIR No. 1805-08. Finding: Changes or alterations have been required in, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effects regarding emergency access due to lane closures and the addition of construction-related vehicles on the adjacent roadways. Public Resources Code § 21081(a)(1), Guidelines § 15091(a)(1). Facts in Support of Finding: The EIR discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference. The EIR determined that the construction activities on the portion of the project site to the north of La Veta Avenue have the potential to result in inadequate emergency access due to the lane closures and the addition of construction-related vehicles traveling on the adjacent roadways. This would be considered a significant impact. The EIR determined that with the implementation of Mitigation Measure MM 4.11-2 (requiring a construction phase emergency access plan),this impact would be less than significant. Mitigation Measures: Mitigation Measure MM 4.11-2 is incorporated herein by reference as though fully set forth and shall be a condition of project approval. Reference: EIR Section 4.11; Technical Appendix H. 16. Environmental Impact: Result in Inadequate Emer encv Access. As discussed in Section 4.11 of the EIR, the proposed project would have a less than significant impact related to emergency access on-site or off-site in the immediate vicinity and no mitigation is required. 59 Finding: The proposed project would have no significant adverse effect related to emergency access on-site or off-site in the immediate vicinity and no mitigation is required. Public Resources Code §21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR. discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference. The EIR determined that the proposed project includes a new emergency room entrance and emergency dock along South Pepper Street just north of the Proposed CHOC Driveway. The new emergency and drop-off area provides adequate drive aisle widths and distances for vehicles along South Pepper Street. South Pepper Street would not be altered due to the proposed project and there would be adequate emergency access to the proposed emergency dock. In addition, the proposed project would not alter the emergency access and emergency room driveways at St. Joseph Hospital (directly across South Pepper Street). The operation of the proposed project would not result in inadequate emergency access on-site or off-site in the immediate vicinity. The EIR determined that no significant impact would occur during the ongoing operation of the proposed project and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.11; Technical Appendix H. 17. Environmental Impact: Result in Inadequate Parkin Capacitv. As discussed in Section 4.11 of the EIR, the proposed project would have a less than significant impact related to parking capacity during construction and ongoing operations and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to parking capacity during construction and ongoing operations and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference. The EIR deternuned that based upon the residual supply at each project milestone, the impact to parking capacity of the project both during construction and at completion is found to be less than significant and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.11; Technical Appendix H. 18. Environmental Impact: Conflict with Adopted Policies, Plans, or Pro rams Supportin Alternative Transportation. As discussed in Section 4.11 of the EIR, the proposed project would have a less than significant impact related to alternative 60 transportation, including pedestrian facilities,bicycle facilities, and transit service, and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to alternative transportation, including pedestrian facilities, bicycle facilities, and transit service, and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Transportation and Traffic in Section 4.11, which is incorporated herein by reference. The EIR determined that although there would be a slight increase in pedestrian traffic that would utilize the sidewalks adjacent to the project site, the proposed project would not conflict with the use of these facilities. Therefore, no significant impact to pedestrian circulation on-site and in the vicinity of the project site would be anticipated with development of the proposed project and no mitigation is required. The proposed project would not alter the existing or planned bicycle circulation within the immediate project vicinity of the project site. In addition, the proposed project would not affect the existing bicycle racks or bicycle storage facilities on the project site. No impact would be anticipated and no mitigation is required. The Orange County Transportation Authority OCTA) operates five bus routes in the project vicinity. The proposed project would not change or alter the existing transit service to the immediate vicinity of the project site. Therefore, the proposed project would not result in a significant impact to the transit service and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.11; Technical Appendix H. L. Utilities and Service Systems 1. Environmental Impact: Exceed Wastewater Treatment Reauirements of the Applicable Re ional Water Qualitv Control Board. As discussed in Section 4.12 of the EIR, the proposed project would not cause the Orange County Sanitation District's wastewater treatment facilities to exceed the wastewater treatment requirements of the Santa Ana Regional Water Quality Control Board. No impact would occur and no mitigation is required. Finding: Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Utilities and Service Systems in Section 4.12, which is incorporated herein by reference. The EIR determined that the proposed project would have no significant adverse effect as the project-generated wastewater would not cause the Orange County Sanitation District's wastewater treatment facilities to exceed the wastewater treatment requirements 61 of the Santa Ana Regional Water Quality Control Board. No impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.12. 2.Environmental Impacts: Require or Result in the Construction of New Water or Wastewater Treatment or Collection Facilities or Expansion of Existin Facilities, the Construction of Which Could Cause Si nificant Environmental Effects. As discussed in Section 4.12 of the EIR, the proposed project would not result in a significant impact related to the adequacy of the water distribution facilities and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to the adequacy of the water distribution facilities and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Utilities and Service Systems in Section 4.12, which is incorporated herein by reference. The EIR determined that the existing water service system to the project site would be adequate to meet the proposed project's domestic water demand. To meet the current City and industry sizing and material standards, the water mains in Main Street, La Veta Avenue, and Pepper Street need to be upgraded to 12-inch ductile iron pipe. The Water Division staff has required as a condition of approval that a 6-inch water main on the north side of La Veta Avenue, an 8-inch water main on the south side of La Veta Avenue, and a 10-inch water main on west side of Pepper Street, all consisting of cast iron pipe, be replaced by mains that are 12-inch ductile iron pipe. The proposed project will, as component of Phase 1 construction, include the construction of these water mains in La Veta Avenue and Pepper Street. The proposed project would not result in a significant impact related to the adequacy of the water distribution facilities and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.12. 3.Environmental Impacts: Require or Result in the Construction of New Water or Wastewater Treatment or Collection Facilities or Expansion of Existing Facilities,the Construction of Which Could Cause Si nificant Environmental Effects. As discussed in Section 4.12 of the EIR, the proposed project would have a less than significant impact related to adequate fire flow to the project site with the implementation of mitigation required in EIR No. 1805-08. 62 Finding: Changes or alterations have been required in, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effects related to adequate fire flow to the project site to below a level of significance. Public Resources Code § 21081(a)(1), Guidelines § 15091(a)(1). Facts in Support of Finding: The EIR discusses potential impacts regarding Utilities and Service Systems in Section 4.12., which is incorporated herein by reference. The EIR determined that the proposed project would provide fire sprinkler systems within the new buildings and, therefore, the water lines to the project site are anticipated to have a minimum required fire flow level of 4,000 gallons per minute at 20 pounds per square inch for a 2-hour fire incident subject to verification with the corresponding authorities. The Utility Systems Analysis concluded that the water lines that serve the project site would have adequate volume to meet the estimated domestic consumption requirements. However, until verified by the appropriate fire authorities based on their review of improvement plans, the proposed project would have the potential to result in a significant impact related to the provision of adequate fire flow to the project site. The EIR determined that, with the implementation of Mitigation Measure MM 4.12-1 requiring a water improvement plan),this impact would be less than significant. Mitigation Measures: Mitigarion Measure 4.12-1 is incorporated herein by reference as thoroughly set forth and shall be a condition of project approval. Reference: EIR Section 4.12; Technical Appendix J. 4. Environmental Impacts: Rec uire or Result in the Construction of New Water or Wastewater Treatment or Collection Facilities or Expansion of Existing Facilities the Construction of Which Could Cause Sisnificant Environmental Effects. As discussed in Section 4.12 of the EIR, the proposed project would have a less than significant impact due to construction of new water facilities or the expansion of existing water conveyance facilities and the construction of those would not cause significant environmental effects and no mitigation is required. Finding: The proposed project would have no significant adverse effect due to construction of new water facilities or the expansion of existing water conveyance facilities and the construction of those would not cause significant environmental effects and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Utilities and Service Systems in Section 4.12, which is incorporated herein by reference. The EIR determined that the replacement of water mains in La Veta Avenue and Pepper Street would occur consistent with the City's requirements including the implementation of BMPs that would include erosion control measures. The EIR determined that the proposed project would not result in a significant impact due to the construction of newwaterfacilitiesortheexpansionofexistingwaterconveyancefacilitiesandthe 63 construction of these would not cause significant environmental effects and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.12. 5. Environmental Impact: Require or Result in the Construction of New Water or Wastewater Treatment or Collection Facilities or Expansion of ExistinQ Facilities the Construction of Which Could Cause Si nificant Environmental Effects. As discussed in Section 4.12 of the EIR, the proposed project would not result in the construction of new sewer facilities or the expansion of existing facilities in the vicinity of the project site, the construction of which could cause significant environmental effects. No significant impact would occur and no mitigation is required. Finding: The proposed project would have no significant adverse effect as the project-generated wastewater would not result in the construction of new sewer facilities or the expansion of existing facilities in the vicinity of the project site, the construction of which could cause significant environmental effects. No significant impact would occur and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Utilities and Service Systems in Section 4.12, which is incorporated herein by reference. The EIR determined that the existing sewer system to the project site had sufficient capacity and would be adequate to convey the wastewater generated by the proposed project. Therefore, the development of the proposed project would not result in the construction of new sewer facilities or the expansion of existing facilities in the vicinity of the project site, the construction of which could cause significant environmental effects. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.12; Technical Appendix J. 6. Environmental Impact: Require or Result in the Construction of New Water or Wastewater Treatment or Collection Facilities or Expansion of Existin Facilities, the Construction of Which Could Cause Si nificant Environmental Effects. As discussed in Section 4.12 of the EIR, the proposed project would not result in the construction of wastewater treatment facilities or the expansion of existing facilities, the construction of which could cause significant environmental effects. No significant impact would occur and no mitigation is required. Finding: The proposed project would have no significant adverse effect as the project-generated wastewater would not result in the construction of wastewater treatment facilities or the expansion of existing facilities, the construction of which could 64 cause significant environmental effects. No significant impact would occur and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Utilities and Service Systems in Section 4.12, which is incorporated herein by reference. The EIR determined that the proposed project would generate an increase in wastewater which represents 0.118 percent of the remaining existing capacity at Reclamation Plant No. 1 and 0.670 percent of the existing capacity at Reclamation Plant No. 2. The EIR determined that the development of the proposed project would not result in the construction of wastewater treatment facilities or the expansion of existing facilities, the construction of which could cause significant environmental effects. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.12. 7. Environmental Impact: Require or Result in the Construction of New Storm Draina e Facilities or Expansion of ExistingLFacilities the Construction of Which Could Cause Si nificant Environmental Effects. As discussed in Section 4.12 of the EIR, the proposed project would not require or result in the construction of new storm drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects. No significant impact would occur and no mitigation is required. Finding: The proposed project would have no significant adverse effect as the stormwater runoff from the project site would not require or result in the construction of new storm drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects. No significant impact would occur and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Utilities and Service Systems in Section 4.12, which is incorporated herein by reference. The EIR determined that the proposed project would result in a decrease in the rate and amount of stormwater runoff due to the decrease in the pervious surfaces and the use of the water quality devices on the project site which would discharge the runoff into the ground rather than the existing surface storm drainage system. Since the rate and amount of the stormwater runoff from the project site would be reduced, no new off-site storm drainage facilities or the expansion of an exiting facility would be required as a result of the proposed project. The EIR determined that the development of the proposed project would not require or result in the construction of new storm drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. 65 Reference: EIR Section 4.12. 8.Environmental Impact: Have 5ufficient Water Supplies Available to Serve the Project From Existing Entitlements and Resources, or Are New or Expanded Entitlements Needed. As discussed in Section 4.12 of the EIR, the proposed project would have a less than significant impact related to water supply since the City would have sufficient water supplies available to serve the proposed project from their existing entitlements and resources and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to water supply since the City would have sufficient water supplies available to serve the proposed project from their existing entitlements and resources and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Utilities and Service Systems in Section 4.12, which is incorporated herein by reference. The EIR determined that the proposed project would result in an increase in water consumption that represents a nominal increase of 0.36 percent in the City's daily water usage based on 31 million gallons per day in the 2005/2006 fiscal year. The EIR determined that the City would have sufficient water supplies available to serve the proposed project from their existing entitlements and resources. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.12; Technical Appendix I. 9.Environmental Impact: Result in a Determination bv the Wastewater Treatment Provider Which Serves or Mav Serve the Project that it has Adequate Capacitv to Serve the Project's Projected Demand in Addition to the Provider's Existin Commitments. As discussed in Section 4.12 of the EIR, the proposed project would have a less than significant impact related to whether the Orange County Sanitation District's wastewater treatment plants have adequate capacity to serve the proposed project's projected demand in addition to their existing commitments and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to whether the Orange County Sanitation District's wastewater treatment plants have adequate capacity to serve the proposed project's projected demand in addition to their existing commitments and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Utilities and Service Systems in Section 4.12, which is incorporated herein by reference. The EIR determined that the proposed project would generate an increase in wastewater generation that represents 0.118 percent of the remaining existing capacity at 6 Reclamation Plant No. 1 and 0.670 percent of the existing capacity at Reclamation Plant No. 2. Therefore, the OCSD's wastewater treatment plants have adequate capacity to serve the proposed project's projected demand in addition to their existing commitments. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.12. 10. Environmental Impact: Be Served bv a Landfill with Insufficient Permitted Capacitv to Accommodate the ProjecYs Solid Waste Disnosal Needs. As discussed in Section 4.12 of the EIR, the proposed project would have a less than significant impact related to the disposal of construction-related solid waste and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to the disposal of construction-related solid waste and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Utilities and Service Systems in Section 4.12, which is incorporated herein by reference. The EIR determined that the construction activities for the proposed project would result in a temporary increase in the generation of construction waste materials. Consistent with City requirements, prior to the issuance of the demolition, grading, and building permits, the Project Applicant will be required to submit a construction waste management plan that demonstrates that construction-generated waste is reduced by 50 percent consistent with the California lntegrated Waste Management Act. The plan will be reviewed and approved by the City Public Works Department. The EIR determined that no significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.12. 11. Environmental Impact: Be Served by a Landfill with Insufficient Permitted Capacity to Accommodate the Project's Solid Waste Disposal Needs. As discussed in Section 4.12 of the EIR, the proposed project would have a less than significant impact related to the ability to be served by a landfill with sufficient permitted capacity to accommodate the solid waste generated by the ongoing use of the proposed project and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to the ability to be served by a landfill with sufficient permitted capacity to accommodate the solid waste generated by the ongoing use of the proposed project and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). 67 Facts in Support of Finding: The EIR discusses potential impacts regarding Utilities and Service Systems in Section 4.12, which is incorporated herein by reference. The EIR determined that the development of the proposed project would result in an incremental increase in the long-term generation of solid waste on the project site. The proposed project would generate approximately 1.48 tons per day and use approximately less than 0.00007 percent of the permitted daily landfill tonnage in Orange County. Consistent with the State requirements (The Integrated Waste Management Act) and City policies, the waste hauler under license to the City would provide for the processing of solid waste at material recovery facilities for the recovery of recyclable materials from the proposed project. This would further reduce the solid waste generated by the proposed project that would need to be disposed of at a landfill. The EIR determined that the proposed project would be served by a landfill with sufficient permitted capacity to accommodate the solid waste generated by the ongoing use of the proposed project. No significant impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.12. 12. Environmental Impact: Com lv with Federal, State, and Local Statues and Re ulations Related to Solid Wastes. As discussed in EIR Section 4.12 of the EIR, the proposed project would have a less than signi icant impact related to compliance with applicable federal, state, and local statues and regulations regarding solid wastes and no mitigation is required. Finding: The proposed project would have no significant adverse effect related to compliance with applicable federal, state, and local statues and regulations regarding solid wastes and no mitigation is required. Public Resources Code § 21081, Guidelines § 15091(a). Facts in Support of Finding: The EIR discusses potential impacts regarding Utilities and Service Systems in Section 4.12, which is incorporated herein by reference. The EIR determined that solid waste collection in the City is coordinated by the City of Orange Public Works Department and provided by Waste Management of Orange County, a commercial solid waste hauler under license from the City. The State mandates that, through source reduction, recycling, and composting, a 25 percent reduction in solid waste was to occur by the Year 1995 and 50 percent by the Year 2000. These mandates are addressed by the City through their license agreement with the waste hauler. The development of the proposed project would comply with applicable federal, state, and local statutes and regulation related to solid wastes. No impact would occur and no mitigation is required. Mitigation Measures: No mitigation is required. Reference: EIR Section 4.12. 68 13. Environmental Impact: Cumulative Effect. As discussed in EIR Section 4.12 of the EIR, the proposed project would have a less than significant cumulative impact related to utilities and seroice systems with the implementation of mitigation required in EIR No. 1805-08. Findings: Changes or alterations have been required in, or incorporated into, the proposed project which avoid or substantially lessen the significant environmental effectsregardingtheadequacyofthefireflowfortheprojectsitetobelowalevelof significance. Public Resources Code § 21081(a)(1), Guidelines § 15091(a)(1). Facts in Support of Finding: The EIR discusses potential impacts regarding Utilities and Service Systems in Section 4.12, which is incorporated herein by reference. The EIR determined that the development of past, present, and reasonably foreseeable future related projects would contribute to cumulative effects on utilities and service systems. Individually each of the cumulative projects would be subject to technical evaluation and review by the respective jurisdictions and would be required to comply with the respective jurisdictions' requirements related to utilities and service systems. With the implementation of Mitigation Measure 4.12-1, the potential impact of the proposed project related to the adequacy of the fire flow for the project site would be reduced to a less than significant level. With the incorporation of the mitigation measure, the proposed project's impacts would not incrementally contribute to potentially significant impacts to utilities and service systems. The EIR determined that, with the implementation of Mitigation Measures 4.12-1, the proposed project in conjunction with other past, present, and reasonably foreseeable future projects would not result in a significant cumulative impact related to utilities and service systems would occur. Mitigation Measures: Mitigation Measure 4.12-1 is incorporated herein by reference as thoroughly set forth and shall be a condition of project approval. Reference: EIR Section 4.12. VII. FINDINGS REGARDING ALTERNATIVES Because the proposed project will cause unavoidable significant environmental effects related to air quality (consistency with Air Quality Management Plan, local PM 10 emissions during excavation and grading phase of construction activities, regional NOX and CO emissions from ongoing operations of the proposed project, and incremental contribution of greenhouse gas emission to global climate change), noise (construction activities in combination with construction-related traffic and demolition activities), and transportation and traffic (incremental contribution to one study area intersection in General Plan [2030] with Project Conditions and incremental contribution to four study area intersections for the Cumulative Conditions using California Department of Transportation methodology), the City must consider the feasibility of any environmentally superior alternatives to the proposed project, evaluating whether these 69 alternatives could avoid or substantially lessen the unavoidable significant environmental effects while achieving most of the objectives of the proposed project. The EIR evaluated three alternatives to the proposed project and evaluated the feasibility of each of the alternatives in light of the project objectives and other considerations. As described in Section 3.0 of the EIR, the specific objectives of the proposed project consist of: 1. Establish a physical design that allows for the development of a hospital that provides "state of the art" facilities and services dedicated exclusively to the care of children. 2. Provide for the development and redevelopment of facilities at the CHOC Hospital campus that address CHOC's mission and strategic goals, including the provision of the following services: Medical and surgical services for an estimated 11,000 children per year from Orange County and the surrounding communities that require hospitalization; State of the art" diagnostic imaging services for children, including Computerized Tomography and Magnetic Resonance Imaging capabilities; Pediatric emergency services for over 60,000 children per year; Medical laboratory services for children; Cutting edge"research in pediatric disease; and Training for pediatric residents and fellows. 3. Provide for the continued utilization of existing facilities while a phased upgrade of the existing CHOC Hospital and suppor ing facilities occur. 4. Enhance the visual aesthetics of the project frontages along Main Street, La Veta Avenue, Pepper Street, and Providence Street with landscaping, lighting, and signage. 5. Provide a high quality physical environment for patients, visitors, and staff including adequate and safe circulation patterns and parking. The alternatives presented in the EIR constitute a reasonable range of alternatives necessary to permit a reasoned choice among the options available to the City and/or the project proponent. Based on the administrative record for the project, the City makes the following findings concerning the alternatives to the proposed project. A. Alternatfve Analyzed by EIR As discussed in Section 6.0 of the EIR, the following alternatives were evaluated for the proposed project: (1) Alternative 1 - No Project/No Development; (2) Alternative 2 - No 70 Project/Development Under Existing General Plan and Zoning Designations; and (3) Alternative 3 - Lower Intensity Alternative. Each of the alternatives to the proposed project are discussed below. Alternative 3 - Lower Intensity Alternative is the alternative that is the"environmentally superior alternative"under CEQA. 1. Alternative 1 -No Project/No Development Description: As discussed in Section 6.2 of the EIR, Alternative 1 - No Project/No Development assumes that the proposed project resulting in the expansion of CHOC Hospital with the construction of the CHOC South Tower and the interior remodeling of a portion of the existing CHOC North Tower, and the remodeling of 40 percent of the CHOC Commerce Tower from general office to medical office space would not occur. In addition, the construction of the medical office building would not occur. The Orange Medical Building (1201 La Veta Avenue), the two-level parking structure, and the entry plaza to the hospital would not be removed from the project site. The approximately 12.0-acre project site would remain in its current condition. Finding: The City finds that specific economic, legal, social, technological, or other considerations, including considerations for the provision of health care for children in need and employment opportunities for highly trained workers, makes Alternative 1 - No Project/No Development infeasible (Public Resources Code § 21081(a)(3), Guidelines § 15091(a)(3)). Facts in Support of Finding: As discussed in Section 6.2 of the EIR,Alternative 1 - No Project/No Development assumes that development and redevelopment of the project site would not occur and the project site would remain in its current condition. Alternative 1 would not achieve the majority of the project objectives. Alternative 1 would not establish a physical design that allows for the development of a hospital that provides "state of the art" facilities and services dedicated exclusively to the care of children, as no new hospital facilities or medical office space would be constructed. Alternative 1 would not provide for the development and redevelopment of facilities at the CHOC Hospital campus that address CHOC's mission and strategic goals, as no new facilities would be constructed to allow CHOC Hospital to accomplish its mission and strategic goals. Alternative 1 would provide for the continued utilization of existing facilities. However, Alternative 1 would not provide for the phased upgrade of the existing CHOC Hospital and supporting facilities. Alternative 1 would not enhance the visual aesthetics of the project frontages along Main Street, La Veta Avenue, Pepper Street, and Providence Street with landscaping, lighting, and signage. No improvements to these street frontages would occur. As discussed in Section 6.2 of the EIR, Alternative 1 - No Project/No Development would be environmentally superior to the proposed project due to avoidance of the majority of the physical environmental impacts as a result of no construction activities and no ongoing use of the proposed development. 71 2. Alternative 2 - No Project/Development Under Existing General Plan and Zoning District Designations Description: As discussed in Section 6.3 of the EIR, Alternative 2 - No Projecd Development Under Existing General Plan and Zoning District Designations assumes development of the project site consistent with the existing General Plan and Zoning designations. The General Plan land use designations for the project site are Public Facilities on the north side of La Veta Avenue and Commercia12.5-3.0 FAR on the south side of La Veta Avenue. The existing zoning district designations for the project site consist of PI (Public Institution), C3 (Commercial), and OP (Office Professional) on the portion of the project site north of La Veta Avenue, and C2 (General Business) on the portion of the project site south of La Veta Avenue. Based on these designations, Alternative 2 assumes that to the north of La Veta Avenue, the CHOC North Tower, the Orange Medical Building (1201 La Veta), and the five-level parking structure would remain in their existing condition and the remainder of the project site would be redeveloped consistent with the existing zoning district designations. Although the existing C3 (Commercial) zoning district designation is inconsistent with the Public Facilities General Plan land use designation, Alternative 2 would assume the demolition of the CHOC West Building and the CHOC Research Building and reconstruction for commercial use consistent with the existing C3 Commercial) zoning district designation on that portion of the project site. Consistent with the C3 (Commercial) zoning, anticipated uses on this portion of the project site would be administrative and professional offices, medical offices, multi-family housing with mixed use development, retail and service uses including pharmacy, copy center, dry cleaners, hair salon, and restaurants and food services. As applicable, some of these uses would be permitted by conditional use permit. In addition, Alternative 2 assumes that to the south of La Veta Avenue, the CHOC Commerce Center (505 S. Main Street) with associated parking structure and surface lot and the CHOC nine-level employee parking structure would remain in its existing condition and the remainder of the project site would be redeveloped consistent with the existing zoning district designations. This would result in the demolition of the CHOC Educational Building and the surface parking lot in the southwestern corner of the project site. New development on the southwestern portion of the project site would consist of general commercial development. Commercial uses would be those permitted under the existing C2 (General Commercial) zoning district designation. Finding: The City finds that specific economic, legal, social, technological, or other considerations, including considerations for the provision of health care for children in need and employment opportunities for highly trained workers, makes Alternative 2 - No Project/ Development Under Existing General Plan and Zoning District Designations infeasible (Public Resources Code § 21081(a)(3), Guidelines § 15091(a)(3)). 72 Facts in Support of Findings: As discussed in Section 6.3 of the EIR, Alternative 2 - No Project/ Development Under Existing General Plan and Zoning District Designations assumes development of the project site consistent with the existing General Plan and Zoning designations. Alternative 2 would not achieve all of the project objectives. Alternative 2 would not establish a physical design that allows for the development of a hospital that provides "state of the art" facilities and services dedicated exclusively to the care of children, as no new hospital facilities that would provide beds would be constructed. Alternative 2 would not provide for the development and redevelopment of facilities at the CHOC Hospital campus that address CHOC's mission and strategic goals, as no new hospital facilities that would provide beds would be constructed. Alternative 2 would provide for the continued utilization of existing facilities. However, Alternative 2 would not provide for the phased upgrade of the existing CHOC Hospital or the upgrade of the supporting facilities, including medical office space, to the extent that the proposed project would. Alternative 2 would not enhance the visual aesthetics of the project frontages along portions of Main Street, portions of La Veta Avenue, Pepper Street, and Providence Street with landscaping, lighting, and signage.No improvements to these street frontages would occur. In general, the implementation of Alternative 2 - No Project/Development under Existing General Plan and Zoning District Designations Alternative would have similar or increased significant impacts related to the construction and ongoing operation of the proposed project. Overall, Alternative 2 would have increased significant impacts in comparison to the significant impacts as a result of the proposed project. The implementation of Alternative 2 - No Project/Development Under the Existing General Plan and Zoning Designations would eliminate the impacts of the proposed project related to the demolition of the Orange Medical Building (1201 La Veta) and the two-level parking structure. It would also eliminate the project impacts from the construction and operation of the additional hospital beds and the medical office building south of La Veta Avenue. Alternative 2 would increase the severity of impacts overall related to construction and operation due to the intensification of the land uses on the project site. In addition to the increased areas to be developed, Alternative 2 would introduce retail commercial uses to the project site. As discussed in Section 6.3 of the EIR, Alternative 2 - No ProjecdDevelopment Under the Existing General Plan and Zoning Designations would not be environmentally superior to the proposed project due to the increased impacts related to air quality, noise, transportation and traffic, and utilities and sewer systems. 3. Alternative 3 -Lower Intensity Alternative Description: As discussed in Section 6.4 of the EIR, Alternative 3 - Lower Intensity Alternative assumes development of the project site with a reduction in the number of hospital beds (resulting in a total of 326 beds at buildout). This reduced 73 number of hospital beds would be equivalent to the number of beds provided with Phase 1 of the proposed project). With this alternative, the CHOC West and CHOC Research buildings would remain as is. This alternative would not include the new medical office building (175,000 square feet), thereby reserving the southwestern portion of the project site as a potential location for other further CHOC Master Plan uses. In addition, Alternative 3 would not include the conversion of 40 percent of the CHOC Commerce Center from general office to medical office space. Alternative 3 would retain the 91,000 squaxe foot Orange Medical Building at 1201 La Veta Avenue, the two-level parking structure, and the entry plaza. Finding: The City finds that specific economic, legal, social, technological, or other considerations, including considerations for the provision of health care for children and employment opportunities for highly trained workers, makes Alternative 3 - Lower Intensity Alternative infeasible (Public Resources Code § 21081(a)(3), Guidelines § 15091(a)(3)). Facts in Support of Findings: As discussed in Section 6.4 of the EIR, Alternative 3 - Lower Intensity Alternative assumes development of the project site with a reduction in the number of hospital beds (resulting in a total of 326 beds at buildout). Alternative 3 would not achieve all of the project objectives. Alternative 3 would not fully establish a physical design that allows for the development of a hospital that provides "state of the art" facilities and services dedicated exclusively to the care of children. The additional hospital building would be limited to addressing the addition of the 88 beds and not the additional support services to be provided with the proposed project. Alternative 3 would not provide for the development and redevelopment of facilities at the CHOC Hospital campus that address CHOC's mission and strategic goals. Alternative 3 would provide for the continued utilization of existing facilities. However, Alternative 3 would not provide for the phased upgrade of the existing CHOC Hospital and supporting facilities. Alternative 3 would not enhance the visual aesthetics of the project frontages along Main Street, La Veta Avenue, Pepper Street, and Providence Street with landscaping, lighting, and signage. No improvements to these street frontages would occur. In general, the implementation of Alternative 3 - Lower Intensity Alternative would reduce the significant impacts related to the construction and ongoing operation of the proposed project. Overall, this alternative would have decreased impacts in comparison to the significant impacts as a result of the proposed project. The implementation of Alternative 3 would not increase the severity of impacts and would not have impacts that are not impacts of the proposed project. As discussed in Section 6.4 of the EIR, Alternative 3 - Lower Intensity Alternative would be environmentally superior to the proposed project as Alternative 3 would decrease the proposed project's significant impacts to air, noise, public services, and transportation and traffic. 74 VIII. ENVIRONMENTAL ISSUES DETERNIINED NOT TO BE POTENTIALLY AFFECTED BY THE PROJECT All environmental resource areas identified as having a potential impact as a result of the proposed project in the Initial Study in Appendix A-1, NOP Process, of the EIR were analyzed in detail in the EIR. Based on the Initial Study and responses to the NOP, the City determined that the potential impacts to environmental resources categorized as agricultural resources, cultural resources, mineral resources, and recreation were less than significant without mitigation and, therefore, would not warrant further consideration in the EIR. Further the City determined that the following specific environmental effects of the proposed project were found to be less than significant without mitigation and, therefore, would not warrant further consideration in the EIR: 1. Aesthetics Scenic Vistas Scenic Resources within a State Scenic Highway 2. Biological Resources Candidate, Sensitive, or Special Status Species Riparian Habitat or Other Sensitive Natural Community Wetlands Wildlife Movement and Use of Native Wildlife Nursery Sites Conflict with Adopted Habitat Conservation Plan, Natural Community Conservation Plan, or Other Habitat Conservation Plan 3. Geology and Soils Hazards from Fault Rupture Hazards from Landslides Substantial Erosion or Loss of Topsoil Soils Related Use of Septic Tanks or Alternative Wastewater Disposal Systems 4. Hazards and Hazardous Materials Hazard to Public or Environment through Routine Transport, Use, or Disposal of Hazardous Materials 75 Hazardous Materials Sites Pursuant to Government Code Section 65962.5 Safety Hazard from Public or Public Use Airport Safety Hazaxd from Private Airstrip Hazard from Wildland Fires 5. Hydrology and Water Quality Groundwater Supplies or Groundwater Recharge Alter Stream or River Resulting in Substantial Erosion or Siltation On- and Off- site Housing within 100-year Flood Hazard Area Structures within 100-year Flood Hazard Area that would Impede or Redirect Flood Flows Hazaxds from Failure of a Levee or Dam Inundation by Seiche, Tsunami, or Mudflow Stormwater Runoff from Construction Activities Increases in Erosion On-Site and in Surrounding Areas 6. Land Use/Planning Physically Divide an Established Community Conflict with Habitat Conservation Plan or Natural Community Conservation Plan 7. Noise Excessive Noise Levels from Public or Public Use Airport Excessive Noise Levels from Private Airstrip 8. Population and Housing Displacement of Existing Housing Displacement of People Requiring Replacement Housing Elsewhere 76 9. Public Services Schools Parks Libraries 10. Transportation and Traffic Change in Air Traffic Patterns No substantial evidence has been presented to or identified by the City which would modify or otherwise alter the City's less than significant determination for these environmental issues. IX. FINDING REGARDING GROWTH INDUCING IMPACT5 Guideline Section 15126.2(d)requires that an EIR: Discuss the ways in which the proposed project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. Direct Growth Inducing Impacts: As discussed in Section 5.3 of the EIR, the proposed project would not directly induce substantial population growth in the City or the surrounding area. On a short-term basis, construction jobs would be generated by the proposed project. The construction activities for the CHOC South Tower,which involves the most substantial construction activities as a result of the proposed project, would occur by the year 2012. The first phase of construction, which is demolition, would generate a maximum of 25 construction jobs on the project site. The second phase of construction, excavation and grading, would generate a maximum of 50 construction jobs on the project site. The third phase of construction, building construction, would generate a maximum of 450 construction jobs on the project site. These jobs would terminate after construction activities for the proposed project have completed. In addition, based on experience with previous construction activities, CHOC anticipates that construction employees would be drawn from the region and that construction employees would not relocate to the City due to the short-term nature of the employment opportunities. Therefore, the construction activities for the proposed project would result in employment that would not directly induce substantial population growth in the City or the surrounding area. On a long-term basis, the proposed project would result in new employment opportunities in the City. These employment opportunities would occur as a result of the addition of 202 beds and additional medical services to CHOC Hospital and the addition 77 of 175,000 square feet of inedical office space in the medical office building proposed for the southwestern portion of the project site. CHOC anticipates that the majority of the employees within the proposed medical office building would be associates of CHOC Hospital and, therefore, accounted for in the projected increase in employees generated by CHOC Hospital. The conversion of 85,600 square feet of general office space to medical office space in the CHOC Commerce Tower would also generate employment. The proposed project would result in the removal of the Orange Medical Building consisting of 91,000 square feet) and, therefore, eliminate employment opportunities at this building. Currently, CHOC Hospital employs 2,371 personnel. CHOC Hospital projects that, at buildout of the proposed project in the year 2020, there would be a total 3,825 employees. This represents an increase of 1,454 employees (or 61.3 percent) from the existing condition. Since the location of an employee's residence is a personal decision and would be based on unknown factors that cannot be predicted, a worst-case approach was used to analyze if the proposed project would result in a substantial increase of the population in the City. This approach assumes that each employee would become a resident of the City and, therefore, result in the addition of 1,454 people to the population of the City by the year 2020. Based on the City's projected population of 151,910 in the year 2020, the 1,454 "worst-case residents" as a result of the proposed project would only represent 0.96 percent of the City's population. This would not be considered a significant increase in population in the City. Therefore, the ongoing operation of the proposed project would not directly induce substantial population growth in the City. Indirect Growth Inducing Impacts: As discussed in Section 5.3 of the EIR, the proposed project would not indirectly induce population growth in the area through the extension of existing roadwAys or infrastructure. The project site is located in an urbanized area that has existing roadways and infrastructure. The proposed project would not result in the construction of any public roadways and the utility improvements that would occur as a result of the proposed project would serve the existing and proposed buildings on the project site as well as upgrade some of the utilities at the request of the City. Therefore, the proposed project would not indirectly induce substantial population growth in the City or the surrounding area. X. FINDING REGARDING SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES Guideline Section 15126.2(c) indicates that: Uses of nonrenewable resources during the initial and continued phases of the project may be irreversible since a large commitment of such resources makes removal or nonuse thereafter unlikely. The Guidelines also indicate that: 78 Irretrievable commitments of resources should be evaluated to assure that such current consumption is justified. As discussed in Section 5.2 of the EIR, implementation of the proposed project would require the long-term commitment of natural resources that result in an irretrievable commitment of nonrenewable resources such as energy supplies and other construction-related resources. These energy resource demands would be used for construction, heating and cooling of the proposed hospital building and medical office building and the remodeled hospital space and office space, heating of water for use in these buildings, transportation of people and goods to and from the project site, and lighting and other associated energy needs. As fossil fuels currently are the principal source of energy, the implementation of the proposed project would directly reduce existing supplies of fuels, including lubricating oil, natural gas, and gasoline. In addition to the fossil fuels consumed during short-term construction activities, the on-going operation of the proposed project would consume electricity, natural gas, and vehicular-related fuels and lubricants. This represents a long-term commitment to consumption of an essentially nonrenewable resource. The implementation of the proposed project would require the commitment or destruction of other nonrenewable andlor slowly renewable resources. These resources include, but are not limited to: lumber and other forest products; sand and gravel; asphalt; petrochemical-based construction materials; steel; copper; lead and other metals; and water. An increased commitment of utilities and service systems, such as solid waste disposal and wastewater treatment, would also occur. XI. STATEMENT OF OVERRIDING CONSIDERATIONS Pursuant to Public Resources Code § 21081(b) and the Guidelines § 15093, the City has balanced the benefits of the proposed project against unavoidable adverse impacts to air quality, noise, and transportation and traffic associated with the proposed project and has adopted all feasible mitigation measures with respect to impacts to air quality, noise, and transportation and traffic. The City also has examined alternatives to the proposed project, none of which both meet the project objectives and is environmentally preferable to the proposed project. The City, after balancing the specific economic, legal, social, technological, and other benefits of the proposed project, has determined that the unavoidable adverse environmental impacts identified above may be considered "acceptable" due to the following specific considerations which outweigh the unavoidable adverse environmental impacts of the proposed project. Each of the separate benefits of the proposed project, as stated herein, is determined to be, unto it and independent of the other project benefits, a 79 basis for overriding all unavoidable adverse environmental impacts identified in these Findings. 1.CHOC Serves Children in Need The CHOC mission is straightforward: to nurture, advance and protect the health and well-being of children. CHOC is dedicated to working cooperatively, assisting and enriching existing services as well as developing programs to benefit the families of Orange County. In fiscal year 2006, over 200,000 children came through CHOC's doors for inpatient, outpatient, and emergency room visits regardless of their family's ability to pay. CHOC offers the following premier pediatric services: Neonatal Intensive Care Unit Pediatric Intensive Care Unit Cardiovascular Intensive Care Unit Oncology Unit Neuroscience Unit Medical Surgical Unit Surgical Short Stay Unit These specific factors support the decision to approve the proposed project despite the significant unavoidable adverse impacts to air quality, noise and transportation and traffic associated with the proposed project. Reference: Children's Hospital of Orange County Communiry Benefit Plan. 2.CHOC Provides Quality and Safe Care and Promise of Research CHOC offers patients the option to participate in clinical trials as part of their continuum of care, especially when conventional treatment methods have failed or when they are suffering from diseases or disorders for which no treatment protocols have yet been established. These specific factors support the decision to approve the proposed project despite the significant unavoidable adverse impacts to air quality, noise and transportation and traffic associated with the proposed project. Reference: Children's Hospital of Orange County Community Benefit Plan. 80 3.CHOC Reaches Out to the Community As the major pediatric safety-net hospital in Orange County, CHOC has a steadfast commitment to treat every child seeking medical treatment, regardless of ability to pay. Last year, CHOC provided more than $142.9 million through 111 benefit services to children in the community, most of them underinsured or uninsured. CHOC's commitment goes beyond providing charity care, it is about connecting patients with suitable insurance programs that can meet their needs long term. Through assisting patients and their families with enrollment in programs like CalOptima (managed MediCal program in Orange County) and Healthy Families, CHOC can help them to establish a successful healthcare home. A significant part of the mission at CHOC is to serve those who do not always have access to healthcare services due to either financial and/or transportation barriers. During fiscal year 2006, CHOC improved patient access to care by bringing clinics and programs services right where patients need them the most. The CHOC Clinic at Orange, located on the CHOC Hospital campus, promotes wellness and preventive care in high-risk/disadvantaged populations, with referral to the most appropriate level of care. The clinic supports well-child and routine medical care, and provides services for the prevention, treatment and management of chronic diseases: In fiscal year 2006, the CHOC Clinic at Orange had 34,223 visits. The CHOC Clinic also serves as a teaching center for the CHOC Residency Program, and interns in their first year donate a significant number of volunteer hours at this clinic site. The CHOC Clinic outpatient facilities, at the main CHOC Campus in the City, are also home to over 24 subspecialty clinics which provide highly sp cialized care for children with a range of conditions and chronic illness. The specialtie offered include: Infectious Disease, Spasticity, Spina Bifida. Gastroenterology, Epi epsy, Oncology, Orthopaedics, RSV clinic, Adolescent Medicine, Hand, Endocrinology, Developmental Behavior, Sports Medicine, Primary Immune Deficiency, Allergy, Fracture, Metabolic, Hematology, Muscle Disease, Pulmonology, Cardiology, Physiatry, Residents, and Flu Vaccine Clinic. CHOC provides healthcare, education, and information to patients and their families through educational resources that include: KidsHealth Magazine, Parent Advice Line, and Pediatric Advisor. Additionally, CHOC provides family-centered care. CHOC patients and their families have access to several innovative programs and services that are designated to complement clinical care. Some f these programs include: CHOC Care Pages, School Reintegration, Social Services, support groups, and child life specialists. These specific factors support the decision to approve the proposed project despite the significant unavoidable adverse impacts to air quality, noise, and transportation and traffic associated with the proposed project. 81 Reference: Children's Hospital of Orange County Community Benefit Plan. 4.Additional Benefits in the Development Agreement The proposed project includes a development agreement between the City and the Project Applicant. In approving the development agreement the City council will have specifically found that the project provides substantial public benefits to the City, which benefits are detailed in the development agreement and incorporated herein. These benefits form a basis for overriding the project's unavoidable environmental impacts that are identified in the Final EIR and support the decision to approve the proposed project despite the significant unavoidable adverse impacts to air quality, noise, and transportation and traffic associated with the proposed project. Reference: Development Agreement. XII. CONCLUSION For the foregoing reasons, the City of Orange concludes that the CHOC Master Plan Project will result in numerous public benefits beyond those required to mitigate project impacts, each of which individually is sufficient to outweigh the unavoidable environmental impacts of the proposed project. 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